Policy on the Protection of Personal Information

Reqree Inc. (hereinafter referred to as the “Company”), in accordance with a management philosophy calling for the pursuit of the ideal state of being, operates in line with the vision of increasing lives of affluence and happiness by recreating the value of real estate with a focus on the planning and production of high-end office buildings and high-end residences. In order to handle the personal information of many clients and employees in the course of its business operations, the Company reaffirms that the protection and management of personal information is a fundamental responsibility to be fulfilled as part of our business activities and declares that all of our employees shall comply with the following items.

1. Purpose for which personal information is to be used (general)

The Company shall obtain and use your personal information to the extent required to fulfill the following purposes:

• To provide the Service and other information related to the Service
• To verify the identity of the user
• To send email magazines that could be useful to users of the Service
• To produce and use statistical information on the Service to the extent that no specific individual can be identified
• To deliver targeted advertising based on the user’s actions, sex, access history, and other attributes
• To exercise rights and fulfill obligations based on contracts, laws, and other governing provisions
• To provide after-sales service and respond to inquiries
• To prevent the use of the Service in a manner that violates the Terms and Conditions of Use

2. Purpose for which personal information is to be used (other)

In addition to the preceding paragraph, the Company shall obtain and use your personal information to the extent required to fulfill the following purposes. The personal information of the person in charge of a business connection shall be used to respond to inquiries and communications, carry out operations, reissue an ID or password, and provide information on new products and services. Client survey information in the form of feedback after a service has been used shall be used to improve the usability of the Company’s website. (Unless permission has been expressly obtained, we will not post any company names, the names of persons in charge, or other pieces of information that can be used to identify individuals.)

3. Managing personal information

Personal information shall be strictly managed and measures that are necessary and appropriate to prevent and remedy the leakage or loss of or damage caused to personal information and otherwise ensure the safe management of personal information shall be implemented. In the event that an incident involving the leakage or loss of or damage caused to personal information occurs, we shall take immediate action, investigate the cause thereof, and remedy the issue. In addition, we shall continuously make improvements to the management system for the protection of personal information as it relates to administrative structures and mechanisms for the protection of personal information. Personal information entrusted to us in the context of outsourced operations shall be handled in accordance with the applicable outsourcing agreement after the outsourced operations are completed.

4. Providing personal information to a third party

Personal information that has been obtained shall not be provided to a third party without the consent of the person to whom the personal information belongs except where any of the following applies:

• Where provision is needed for the protection of the life, body, or property of an individual and where the consent of the person to whom the personal information belongs cannot be obtained without difficulty
• Where provision is especially needed to improve public health or promote the sound growth of children and where the consent of the person to whom the personal information belongs cannot be obtained without difficulty
• Where cooperation with the execution by a national government organ, local government, or person entrusted thereby of affairs prescribed by law is needed and where obtaining the consent of the person to whom the personal information belongs might impede the execution thereof
• Where the handling of personal information, in whole or in part, is outsourced to the extent necessary for the attainment of the purpose of use in order to facilitate the execution of operations
• Where personal information is provided in connection with a merger or other form of business succession
• Where personal information is to be used jointly with specific persons and where the fact thereof, items of personal information to be jointly used, scope of joint users, purpose of use by users, and the name of the person responsible for the management of the personal information in question are notified in advance or made readily accessible to the person to whom the personal information belongs
• Where otherwise permitted by law or regulations

5. Outsourcing the handling of personal information

The Company may in some cases outsource the handling of personal information, in whole or in part, to the extent necessary for the attainment of the purpose of use. In such a case, the Company shall thoroughly examine the qualifications of the party to whom handling is to be outsourced, set forth matters related to the obligation to maintain confidentiality in the applicable agreement, and subject the party to whom handling is to be outsourced to necessary and appropriate supervision. The Company may in some cases jointly use obtained personal information, in whole or in part, in accordance with the provisions of the Act on the Protection of Personal Information.

6. Disclosing personal information

Where a request made by a client to disclose or otherwise modify the personal information (report the purpose for which personal information is used; disclose personal information; correct, add, or delete content; suspend the use of personal information; delete personal information; or suspend the provision of personal information to a third party) is received, the Company shall accommodate the request within reasonable limits subject to confirmation of the identify of the person to whom the personal information belongs.

7. Points to keep in mind when entrusting personal information to the Company

The failure to provide required personal information or the provision of required information in an inaccurate state may impede the smooth provision of services.

8. Obtaining personal information by way of a method that is generally unobtrusive to the person to whom the personal information belongs

The Company does not obtain personal information by using cookies or Web beacons or otherwise by way of a method that is generally unobtrusive to the person to whom the personal information belongs. The handling of personal information may in some cases be outsourced. In such a case, the Company shall thoroughly examine the qualifications of the party to whom handling is to be outsourced, set forth matters related to the obligation to maintain confidentiality in the applicable agreement, and subject the party to whom handling is to be outsourced to necessary and appropriate supervision. The Company may in some cases jointly use obtained personal information, in whole or in part, in accordance with the provisions of the Act on the Protection of Personal Information.

9. Complying with laws and regulations

The Company shall comply with all laws, regulations, national government guidelines, and other rules concerning the handling of personal information that it holds.

10. Dealing with complaints and requests for consultations

Where a complaint or request for consultation concerning the handling of personal information is received, the Company shall investigate the contents thereof and endeavor to address them promptly.