PRIVACY POLICY

Privacy Policy

We hereby establish and declare our privacy policy under the Personal Information Protection Act of Japan and the Financial Instruments and Exchange Act of Japan in relation to appropriate protection and use of customers' personal information as follows: We will review and continue to improve this privacy policy when necessary for appropriate handling of customers' personal information.

1. Handling Policy of Personal Information

We will comply with all applicable laws, regulations and guidelines by the Minister concerned, including the Personal Information Protection Act of Japan, and this Privacy Policy.
We will collect minimum customers' personal information necessary for business operations in a lawful and fair manner .
We will quickly and appropriately respond to customers' inquiries and complaints.

2. Purpose of Use

We will collect and use customers' personal information within the limits of implementing the following purposes, with the exceptions of the cases of customers' prior agreement or requirements by laws and regulations:

1.
To implement contracts of obtaining, managing and dealing with real estate and the like (including trust beneficiary rights, hereinafter "Real Estate and the like" includes "trust beneficiary rights) with associated provision of information and services;
2.
To implement contracts of sale and purchase, intermediation, lease, management and other dealings of Real Estate and the like with associated provision of information and services;
3.
To implement contracts of sale and purchase, intermediation, management and other dealings of claimable assets with associated provision information and services;
4.
To implement contracts of advisory work on Real Estate and the like and claimable assets and the like with associated provision of information and services;
5.
To implement contracts of due diligence (assessment of real estate, claimable assets and the like) with associated provision of information and services;
6.
To liaise with governmental offices and other institutions;
7.
To keep shareholders book of our company and its subsidiaries, our company's parent company and its subsidiaries pursuant to the Company Act (hereinafter called "Our Group");
8.
To keep Our Group's customers book;
9.
To exercise anti-crime measures or risk management of violation of laws and regulations by Our Group's directors, officers and other employees and other preventive measures;
10.
To manage Our Group's directors, officers and other employees;
11.
To recruit Our Group's directors, officers and other employees;
12.
To communicate by writing, postal mail, telephone, facsimile, e-mail and the like for implementing all the above purposes;

3. Securement of Accurate Personal Data

We will do our best to keep our personal data accurate and up-to-date as far as it is necessary for implementation of purpose of use.

4. Procedures of Security Management of Personal Data

We will do necessary and appropriate security management to prevent leakage of personal data provided by our customers together with proper oversight of our directors, officers and other employees.

5. Provision of Personal Data to Third Parties

We will not provide customers' and the families' personal data acquired by us, such as real estate information, name, address and the like to third parties, unless such provision is required by applicable laws and regulations or such provision is agreed by the customers. In the latter case, such provision will be done by writing, telephone, facsimile, e-mail and the like.

(Scope of third parties) *The following is for purposes of showing examples and not limitation.)

1.
Counterparts or potential counterparts of contracts or business dealings;
2.
Other financial-products traders of the second category, or realty business traders;
3.
Advertising providers or other entities of internet and other advertisements;
4.
Designated marketing system of real-estate (marketing and price-assessment operations through the system by registration of real estate, conclusion of agreements and data-search within the system)
5.
Judicial scriveners, real-estate surveyors engaged in registration or the like;
6.
Financial institutions, financial-products traders and other money-loaners in relation to finance loan;
7.
Management agents, receiving financial institutions, officers of management association in relation to real-estate management and the like;
8.
Attorneys at law (attorneys dealing with foreign laws), certified public accountants, certified tax accountants, real-estate valuers and certified social insurance and labor consultants who provide professional advices and services;
9.
Credit-information surveyors, real-estate information surveyors and the like;
10.
State or local governmental institutions or their assignees;
11.
Business partners of Our Group, etc.

6. Co-use of Personal Data

Our Group will use our acquired personal data in the following way in solicitation of Our Group employees, etc.

1.
Items of Personal Data to be Co-Used
The customers' and the families' name, address and other personal data;
2.
Scope of Co-Users
Our Group
3.
Purpose of Use
Reference for recruiting Our Group's directors, officers and other employees
4.
Name of Entity Responsible for Management of Personal Data
REGALO CAPITAL Co., Ltd.

7. Contract for Handling of Personal Data

We may contract out handling of minimum personal data provided by customers as far as required for implementing the purpose of use after conclusion of agreement required by the Guidelines Regarding Protection of Personal Information Obtained from Customers in the Financial Sector (Notification No. 67 of the Financial Service Agency, 2004, hereinafter called the "Financial Service Agency Guidelines") and the like. We will oversee the contractor and subcontractor satisfactorily and appropriately.

8. Disclosure, Correction, etc. of Personal Data

We will respond without delay to the requests from the customer, of disclosure, correction and cease of use of personal data owned by Our Group as the following procedure:

1.
Procedure of Disclosure Request and the Like of Personal Data
We will appropriately and promptly respond to the requests from the customers and the deputies regarding disclosure, correction, addition, deletion and cease of use or provision to third parties of personal data (hereinafter called "Disclosure Request, etc.") with exclusion of unnecessary disclosures pursuant to applicable laws and regulations, upon confirmation that such request is made by the customer himself/herself or the proxy authorized by the customer.
2.
Disclosure Items, etc. of Personal Data to Be Requested
Name, address, telephone number, birth date, work place (name of entity or occupation, telephone number), record of transaction and the like
3.
Contact Point of Disclosure Request, etc.
Please request at 10. Complaint Contact Point below (Internal Management Office).
4.
Required Document
・Application form of Disclosure Request, etc. of personal information to us
・Document for Identification Verification of the Customer (Copy of driver's license, Passport or the like)
・Valid power of attorney (in case of deputy; please allow us to hold our response until verified by us)
5.
Responding Method
We will respond in writing to the address registered by the customer or the deputy. Please, be advised in advance that we may directly respond to the customer even in case of the deputy's request.
6.
Purpose of Use of Personal Information given at the time of Disclosure Request, etc.
Personal information given at the time of Disclosure Request, etc. will be used for investigation for the request, identification of the customer and the deputy and response to the said Disclosure Request, etc.
7.
Management agents, receiving financial institutions, officers of management association in relation to real-estate management and the like;
8.
Attorneys at law (attorneys dealing with foreign laws), certified public accountants, certified tax accountants, real-estate valuers and certified social insurance and labor consultants who provide professional advices and services;
9.
Credit-information surveyors, real-estate information surveyors and the like;
10.
State or local governmental institutions or their assignees;
11.
Business partners of Our Group, etc.

9. Handling of the Sensitive Information

In accordance with the Financial Agency Guidelines, etc. we do not acquire, use or disclose to third parties the sensitive information, except as set forth in the Guidelines and no other way found for business operations. Sensitive information means the information concerning race, religious beliefs, family origins, the locality where one's family register is kept, medical health treatment, criminal background and other special secret information. Further, even in the above inevitable case, we do not use or provide to third parties the sensitive information for any purpose other than those necessary for appropriate business operations, etc. provided under the Cabinet Office Regulations, etc. concerning financial-products traders and the like.

10. Complaint Contact Point

We will promptly and sincerely respond to customer complaints concerning handling of personal information such as security management, etc. Please contact our Complaint Contact Point below for complaints, etc.

Complaint Contact Point
Internal Control Division
Tokyo Office

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