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Basic Policy on Proper Handling of Personal Information

MINAMI AOYAMA REAL ESTATE Co., Ltd. (hereinafter referred to as "the company") has formulated a personal information protection management system to promote the protection and proper handling of personal information as an organization provided by customers and of employees, and the following Personal Information Protection Policy ("this Policy") is enacted and published.

1. Compliance with relevant laws, regulations, and guidelines

Regarding the handling of personal information, the company shall refer to the "Act on the Protection of Personal Information" ("Act on the Protection of Personal Information") and the Guidelines of the Personal Information Protection Commission.

2.Definition

The terms used in this policy are based on the definition of the Act on the Protection of Personal Information.

3. Acquisition of personal information

When we obtain personal information, we will clarify the purpose of the collection to our customers and will do so in a legal and fair manner to the extent necessary to achieve that objective.

4.Purpose of use

We will use the provided personal information for the following purposes.

1. (1) Provision of information on property for the search of the other party of the transaction (including information on property for advertising on the internet and flyers).
2. (2) Property information registration in the designated distribution organization (the organization designated by the Ministry of Land, Infrastructure and Transport under the Housing Land Building Trading Law)for the exploration of trading partners and the provision of the closed agreement information after concluding the agreement to designated distribution organizations (Only the information on the sale, information such as property description, date of the agreement, price of the property that was closed are included and the name is not included). The designated distribution organization will use property information and contract information for their business purposes as specified in the Real estate brokerage act, such as providing electronic data and paper media to the designated distribution organization's member brokerage companies and public organizations.
3. (3) Execution of agreements with customers regarding real estate sales, leasing, brokerage and agency of sale and lease, lease management, construction work and the provision of information and services.
4. (4) In cases involving real estate management work, fulfill the management consignment contract work concluded by the management union of the condominium.
5. (5) Price appraisal relating to the sale and lease of the real estate. Note that the information used for price appraisal may be provided to intermediaries as "basis of opinions" stipulated in Article 34-2, paragraph 2 of the Real Estate Brokerage Act.
6. (6) Stored as books and materials in accordance with Article 49 of the Real Estate Brokerage Act.
7. (7) Responding to inquiries and requests for documents related to property information and other matters related to our services.
8. (8) Information on our company and business partners that we think will be useful to our customers, shipping of products, related after-sales services, and information on operations such as maintenance in management. In addition, if we receive a request from the customer, we will stop providing information.
9. (9) Analysis of the Company's customer trends or research analysis of product development etc.
10. (10) Improvement of services provided by the company.
11. (11) Implementation of contracts with customers in relation to the following businesses of the company, as well as solicitation and advertising by means of DM, e-mail and other methods.
    
    1. [1] Storage room operation, leasing, management and brokerage.
    2. [2] Restaurant business
    3. [3] Sales and import/export of various foodstuffs, drinking water, alcoholic beverages, general daily necessities, fixtures, furniture, fittings, interior goods, art works and antiques.
    4. [4] Secondhand dealer business under the Secondhand Articles Business Act.
    5. [5] Private lodging, private lodging management and private lodging brokerage businesses based on the Private Lodging Business Act.
    6. [6] Management, brokerage and consultation of lodging facilities.
    The above businesses of the company may be increased or discontinued.
12. (12) Performance of other obligations and exercise of rights associated with and related to the Company's business.
13. (13) The personal information of employees of the Company is managed in terms of labor management, payroll management, social insurance management and health management ("Consent for the Treatment of Personal Data").

5.Provision to third parties

We will provide the personal information to a third party in the following cases.

1. (1) With the consent of the person
2. (2) When all or part of the handling of personal information is outsourced to the extent necessary to achieve the purposes set forth in 4 above
3. (3) When based on the provisions of laws and regulations
4. (4) When it is necessary for the protection of a person's life, body, or property and if it was difficult to obtain your consent
5. (5) When it is especially necessary to improve public health or promote the sound development of children and it is difficult to obtain your consent
6. (6) When it is necessary for a national institution or local public organization or a person who has been entrusted with it to cooperate in the performance of the affairs prescribed by laws and regulations and if obtaining the consent of the individual may interfere with the performance of the relevant work
7. (7) in the case of succession due to a merger, company split, business transfer or other reason

6. Outsourcing of personal information

We may consign the handling of personal information to third parties. In this case, the company will provide necessary and appropriate supervision to its subcontractors in accordance with the Personal Information Protection Management System.

7. Matters relating to safety control measures

The company shall establish "Regulations for the Treatment of Personal Data" for the purpose of appropriate management, such as preventing the leakage, loss or damage of personal information, and we will implement organizational, human, physical and technical safety management measures in accordance with this procedure.

[Institutional security control measures]

1. (1) In addition to appointing a person responsible for the handling of personal information, we clarify the employees who handles and the coverage scope of it, as well as in the event of the occurrence of an incident such as a leakage of personal information, or if we become aware of any signs of such an incident, we will promptly take the necessary measures in accordance with the reporting and communication system established within the company. Necessary measures shall be taken in accordance with the case, such as fact-finding investigations and investigation of the cause of the incident.
2. (2) Regular self-inspections are carried out on the status of the handling of personal information, as well as audits by other departments and external parties.

[Personal safety control measures]

1. (1) Employees receive regular training at least once a year on rules and points to bear in mind when handling personal information, as well as examples of accidents that have occurred at other companies.
2. (2) We stipulate in our employment regulations and other company rules that employees are obliged to keep personal information confidential during their employment and after they leave the company.

[Physical security control measures]

1. (1) Restrictions are in place to control employee access to areas where personal information is handled, to limit the equipment and other items that employees may bring in, and to prevent unauthorised persons from viewing personal data.
2. (2) Steps are taken to prevent theft or loss of equipment, electronic media and documents that handle personal information, and password locks are applied when such equipment, electronic media, etc. are carried, including when moving within the business premises, to ensure that personal information is not easily revealed.
3. (3) Personal information is subject to dissolution or shredding to ensure that it cannot be recovered.

[Technical security control measures]

1. (1) Implement access controls to limit the scope of persons in charge and the personal information they handle.
2. (2) Measures are in place to protect the information systems that handle personal information from illegal access from outside and from malware.

[Comprehending the external environment]

1. In cases where personal information needs to be handled in a foreign country, we investigate the system for the protection of personal information in the destination country and implement safety management measures, such as concluding appropriate contracts with the business or other entity in the destination country.

8. Disclosure of personal information

When a request is made by you or your agent to disclose personal data held in relation to such personal information, the company will respond without delay, except in the following cases:
- when there is a risk of harm to the life, body, property or other right interests of you or a third party
- when there is a risk of significant disruption to the proper performance of the company's operations
- when it violates laws and regulations

9. The name of the authorised personal data protection organisation and the address to which complaints should be submitted for resolution

Our company is a certified personal data protection organisation, which has been accredited by Japan Foundation for Private Information Conservation Organization(JAPiCO), and the contact details for resolving complaints and consultations regarding the handling of personal data are as follows.

Japan Foundation for Private Information Conservation Organization (JAPiCO)
Contact for resolution of complaints
Consultation and complaint desk
Address: Grace Building Sengakuji-mae, 2-15-8 Takanawa, Minato-ku, Tokyo 108-0074
TEL: 03-6311-7161 FAX: 03-4415-2032

10. Contact for inquiries regarding personal information of the company

If you have any comments, requests or inquiries regarding this policy or requests for disclosure, correction, suspension or deletion of personal information, please contact us at:

FARO Minamiaoyama, 3F, 6-7-7 Minamiaoyama, Minato Ward, Tokyo, 107-0062 MINAMI AOYAMA REALESTATE Co., Ltd. / General Affairs Department / Personal Information Protection desk
E-mail：privacy@ma-r.co.jp

11. Continuous improvement of this basic policy

The Company shall review the status of its operations in relation to the handling of personal information as appropriate and strive for continuous improvement, and this Basic Policy may be changed as necessary. If there is a change, we will notify you of any changes by posting them on our website. However, any changes that require your consent to be legally agreed shall be obtained from you in a manner prescribed by the company.

Date of enactment　1st September 2020
Effective date　1st June 2023

MINAMI AOYAMA REAL ESTATE Co., Ltd.
President　Ryo Tabata