Personal Information Protection Statement

We acknowledge that protecting and properly managing personal information is an important social responsibility, and hereby establish this statement regarding the protection of personal information as described below. We are committed to safeguarding and appropriately managing personal information through our compliance with this statement.

1. Compliance with Relevant Laws and Regulations

We will comply with the laws, regulations, national guidelines and any other standards related to the handling of personal information (hereafter, “Laws and Regulations”).

2. Collection of Personal Information

When collecting personal information, we will clarify purposes of use as specific as possible, and will properly collect such personal information only to the extent necessary to achieve such purposes.

3. Use of Personal Information

We will not use, provide or outsource handling of, personal information held by us beyond the purposes of use agreed by the individual concerned or the scope required under Laws and Regulations.

4. Management of Personal Information

We will maintain personal information held by us in an accurate and up-to-date condition, and apply security control measures from organizational, human, physical and technological perspectives to prevent unauthorized access, leakage, loss and damage of personal information, or any other unfavorable information security-related accident, and ensure appropriate management of personal information.

5. Outsourcing of Handling of Personal Information

In the event that we outsource the handling of personal information, in part or in whole, to third-party service providers, we will exercise necessary and appropriate supervision of such service providers to ensure the secure management of personal information.

6. Contact Information for Requests and Inquiries

We will respond in good faith and in a timely manner to requests for disclosure, correction, addition, deletion, suspension of use and/or deletion of personal information, and any complaints or feedback or any other inquiry related to personal information.

April 2022
Tadahide Kameyama
Representative Director and President, CRE, Inc.
Toranomon Twin Bldg., East Tower 19F
10-1, Toranomon 2-chome, Minato-ku, Tokyo 105-0001, Japan

Policy for Handling of Personal Information

1. Purposes of Use of Personal Information

We will collect personal information by fair and lawful means, and use such information appropriately within the purposes of use described below.
If certain personal information needs to be used for the purpose which falls outside the scope described below, or if we collect personal information directly from an individual subject in writing, we will clarify the purpose of use each time such information is collected and use such personal information only after the subject concerned has given consent to such purpose of use.

(1) Personal information related to business activities

We will use personal information related to each of our business activities described below only within the following purposes of use.
Furthermore, we may collect personal information with due care from those media and other sources that are publicly available or commercially sold (i.e. personal information for which the individual subject has given prior consent to be disclosed in public, such as property registries, official maps, commercial registries, residential maps, telephone directories as well as information in the reports of credit bureaus or credit research companies), and may use such information for the following purposes.

Purposes of Use

• To identify individual subjects as clients and authenticate their identities
• To refine and improve our services provided to clients
• To plan, consider, research and develop new products and services
• To locate contractual counterparties, enter into contracts with them and perform such contracts or demand the performance of such contracts
• To contact business partners and manage their information
• To survey our clients using a questionnaire form
• To provide information and services to our clients
• To carry out marketing activities through such approaches as office visits, direct mail, telephone and email and the like
• To analyze client trends, or conduct research and analysis related to the development of our services
• To distribute behavioral-targeting advertisements using ad service providers such as Google and Yahoo
• To analyze data such as attribute information and activity history that we have collected to understand the client tastes and preferences, etc.
• To create and make publicly available statistical data about our products and services, but in a format that does not identify individual subjects

List of Business Activities

• Manage and operate rental real properties entrusted by respective owners as well as rental real properties we own
• Provide building information and undertake marketing activities to solicit tenants, and if the relevant conditions are set, provide services for executing contracts according to relevant leasing terms applicable to each property
• Provide real property sales when we are the relevant party in a real estate purchase agreement, and provide brokerage services when we undertake brokerage services for a real estate purchase agreement
• Provide agency services for general and life insurance companies
  The purposes of use for the collected personal information by such general and life insurance companies engaging us as their agent is stated on the respective website of each insurer (listed below).
  ◆General insurer partnering with us:
  Mitsui Sumitomo Insurance Co., Ltd. (https://www.ms-ins.com/english/)
  ◆Life insurer partnering with us:
  Mitsui Sumitomo Aioi Life Insurance Co., Ltd. (http://www.msa-life.co.jp/) (available in Japanese only)
  
• Undertake planning, construction, design supervision, repairs, maintenance, ordering, and appraisal and intermediary services for tenant-use real estate and real estate held for resale
• Acquire, own, sell and broker real estate trust beneficiary rights and other receivables
• Invest in specific purpose companies (tokutei-mokuteki-gaisha), special purpose companies (tokubetsu-mokuteki-gaisha) and real estate investment trusts, and then buy/sell, broker and manage equity (ownership) interest
• Provide consulting services related to effective property utilization, development, design and logistics operations
• Engage in investment management business, investment advisory/agency business, and comprehensive advisory services for real estate investment
• Provide security, mainly for logistics facilities, buildings, condominiums and parking lots
• Undertake packing/packaging operations, warehousing and truck transportation business
• Provide staffing services
• Sell equipment and tools, etc.
• Sell computer systems
• Engage in activities related to generation and sale of electric power
• Sell and lease containers
• Offer real estate information services
• Provide real estate information related to wired telecommunications
• Borrow funds and issue corporate bonds/shares for subscription
• Carry out all services incidental or related to the above business activities

(2) Personal Information related to Shareholders

• To perform management of shareholder-related information, including preparation of statutory records in accordance with Laws and Regulations.
• To send shareholders the convocation notice for a general meeting of shareholders, and any other relevant information such as shareholder perks/benefits and dividends
• To enable the exercise of rights and performance of obligations of shareholders based on the requirements under Laws and Regulations
• To implement various measures that promote smooth relationship between shareholders and us

(3) Personal Information related to Current and Former Employees

• To perform administrative work related to hiring and human resources management
• To fulfill obligations under the relevant labor Laws and Regulations
• To contact current and/or former employees for business reasons or in an emergency

(4) Personal Information related to Job Applicants

• To provide information about our company, our orientation meetings and other sources of corporate information
• To notify successful candidates for a position and to advise applicants of hiring decisions during recruitment process
• To contact applicants after informal offer is made and accepted and to provide information on procedures towards employment

2. Provision of Personal Information to Third Parties

We may share an individual subject’s personal information to a third party, which shall be based on prior consent from such individual subject except when such sharing is carried out in accordance with Laws and Regulations, or when it is necessary for protecting a person’s life, body or property and it is difficult to obtain such individual subject’s consent, or when it is particularly necessary for improving public health or promoting the sound development of children and it is difficult to obtain such individual subject’s consent, or when we need to cooperate with a national or local government office for them to perform their duties stipulated in Laws and Regulations and obtaining such individual subject’s consent may interfere with the performance of such duties.
We will cease providing the personal information to a third party upon request from the individual subject concerned to refrain from doing so. Please contact Personal Information Inquiry Desk listed in the last part of this page for such request.

Examples of Third Parties to Whom Personal Information may be Provided

• Companies belonging to the CRE Group and related parties within the scope necessary for achieving the stated purposes of use
• Counterparties or prospective counterparties to contracts
• Other real estate agencies
• Companies posting Internet ads, and real estate industry groups
• Designated distribution networks
• Real estate management companies
• Individuals, organizations, advertisers and lender financial institutions that provide building information either in written form or online
• Judicial scriveners involved in registration and assessment, licensed real estate appraisers and other professionals
• Our partnered general insurance company
• Companies providing guarantor services

3. Joint Use of Personal Information

We will use personal information jointly with other third parties, when necessary, within following scope.

(1) Personal Information subject to Joint Use

• All personal information shown on a business card, including address, name, phone number and information related to professional affiliation (such as a name of company and department, etc.)
• All personal information submitted through an application webpage or paper-based forms of seminars or exhibitions, and personal information contained in surveys.
• All personal information submitted through requests for information or inquiry forms.

(2) Scope of Joint Users

CRE Group companies, our Capital and business alliances, and co-sponsors of seminars and other events

(3) Purpose of Joint Use

Provision of various services offered by the CRE Group companies and our Capital and business alliances, and provision of information related to such services

(4) Person responsible for Management of Joint Use of Personal Information

Tadahide Kameyama
Representative Director and President, CRE, Inc.
Toranomon Twin Bldg., East Tower 19F
10-1, Toranomon 2-chome, Minato-ku, Tokyo 105-0001, Japan

4. Outsourcing of Handling of Personal Information

We may outsource the handling of personal information to a service provider who, in principle, has been contracted specifically for this purpose.
In such cases, we will carry out necessary and appropriate supervision of these service providers to ensure secure management of personal information.

5. Security Control Measures for Secure Management of Personal Information

We will maintain personal information held by us in an accurate and up-to-date condition, and apply security control measures from organizational, human, physical and technological perspectives to prevent unauthorized access, leakage, loss and damage of personal information, or any other information security-related accident, and ensure appropriate management of personal information. Key measures are described below.

(1) Formulation of Basic Policy

• Formulate this Privacy Policy

(2) Development of Rules for Handling Personal Information

• Develop internal rules for handling personal information, and comply with these rules in the execution of business and operating activities

(3) Organizational Measures to Ensure Information Security

• Establish organizational structures, including the assignment of a person responsible for handling personal information
• Establish a reporting system for detecting leakage of personal information or identifying signs of such leakage or any other issue related to personal information
• Understand the conditions surrounding the handling of personal information

(4) Human Measures to Ensure Information Security

• Implement training program, etc. for officers and employees

(5) Physical Measures to Ensure Information Security

• Establish and manage a restricted zone where personal information is handled
• Implement measures to prevent theft and other types of loss of equipment, electronic media and any other devices or documents containing personal information

(6) Technical Measures to Ensure Information Security

• Control access to the system(s) handling personal information

(7) Understanding of the External Environment

• Understand the regulations and systems, etc. for protecting personal information in foreign countries if personal information is handled in such countries

6. Providing Personal Information to Third Parties Outside Japan

If we provide personal information to a third party outside the territory of Japan (as shown in the following table), we will indicate the measures that these third parties take to protect personal information, and we will obtain the consent of the individual subject concerned before transferring any of their personal information to such overseas third parties.

Countries and their respective personal information systems

Country	Personal Information Protection System
Thailand	https://www.ppc.go.jp/files/pdf/thailand_report.pdf
Vietnam	https://www.ppc.go.jp/files/pdf/vietnam_report.pdf
Indonesia	https://www.ppc.go.jp/files/pdf/indonesia_report.pdf

Note: These materials are available in Japanese only.

7. Voluntary Provision of Personal Information

Any provision by you of your personal information is on a voluntary basis. However, if you do not provide your personal information including contact information and/or any other details necessary for a business relationship with us, we may not be able to offer our services or products fully or conclude relevant contracts with you.

8. Collection and Use of Cookies and Any Other Information

Our website automatically collects information about visitors, such as domain name, IP address and browsing history on our website. Cookies (small blocks of data created and sent by a web server while a user is browsing a website and stored on the user’s computer to enable the server to identify the users returning to the website) are used to smoothly provide the services offered through our website.
The above information collected through our website in this way is used as reference to smoothly operate our services offered through our website.
We may also utilize Google Analytics to understand traffic conditions of our website and services, etc. Google Analytics collects and uses cookies to analyze visitor interaction with our website without identifying any particular individual. For details on how Google Analytics collects and uses cookies, please see the Google Analytics Terms of Service (https://www.google.com/analytics/terms/?hl=en-US) and the Google Privacy Policy (https://policies.google.com/privacy?hl=en-US) as well as any other information on their website.

Personal Information Inquiry Desk

If you wish to request for disclosure, correction, addition, deletion, suspension of use or and/or deletion of your personal information, or voice any complaints or feedback, or inquire about anything else related to your personal information, please contact us at the following office.
Please note that personal information received at the time of an inquiry is used only to respond to the request or comment, and will not be used for any other purpose.

In writing:
CRE, Inc.
Toranomon Twin Bldg., East Tower 19F
10-1, Toranomon 2-chome, Minato-ku, Tokyo 105-0001
Attention: Personal Information Inquiry Desk, Legal Section, Corporate Planning Department, Corporate Planning HQ

By phone:
(In Japan) 03-5572-6600
(From outside of Japan) +81-3-5572-6600
Hours of operation (all Japan time): Monday to Friday, 9:30am–12:00pm, 2:00pm–5:00pm (excluding public holidays and December 29–January 4 end-of-year/New Year holidays)

Latest revision: August 2024