May 24, 2022 Osamu Osada, CEO of Choei Inc.

Choei Inc. (hereafter referred to as "the Company") considers customer and shareholders information entrusted to us is important property of the individual, we have social responsibility to protect private information and takes the following measures. In addition, we have set the following items as privacy protection basic policy (privacy policy), and we will make effort to ensure that all board of directors and employees carry out it.
For customers to whom the EU General Data Protection Regulation (GDPR) applies, it will be subject to separate provisions.
Handling of personal information based on GDPR

1　Definition of personal information

"Personal information" as used in this Act means information about living individuals as follow:
(1)　Name, date of birth and other descriptions contained in the information (documents, drawings or electromagnetic records, or expressed using voice, movement or other methods) Those that can identify a specific individual
(2)　Those containing a personal identification code

2　Formulation and continuous improvement of compliance & programgre

Our company establishes standards, rules, business procedures, etc. for handling personal information appropriately, and formulates compliance & program regarding the protection of personal information. The compliance & program will be continuously improved through regular audits and reviews.

3　Acquisition and use of personal information

When we acquire personal information, we will acquire it within reason for the purpose of use by appropriate and fair means, and will notify or announce the purpose of use in advance. The acquired personal information will be used within the scope of the purpose of use and will be managed appropriately. In addition, except in the following cases, personal information will not be provided to the third party without the prior consent of the customer. However, in the case of each item of Article 27, Paragraph 5 of the Act on the Protection of Personal Information, the person who receives the personal information from us shall not be regarded as third party in accordance with the provisions of the same paragraph.

• (1)　When providing personal data to a third party based on laws and regulations other than the Personal Information Protection Law
• (2)　When it is necessary to provide personal data to a third party for the protection of human life, body or property without the customer's consent
• (3)　When it is particularly necessary to improve public health or promote the development of child's healthy growth without the customer’s consent
• (4)　When cooperate with a national institution or a local public community or an assignee on affairs, probably interfere with public function

4　Respect for information subject rights

We will respect the rights of individuals regarding personal information, and will request for disclosure, correction, or deletion of personal information within a reasonable period of time and within reason. In addition, we will set up a contact to respond the inquiries from customers.

5　Implementation of safety measures

In order to ensure the accuracy and safety of the personal information of customers and shareholders, we implement safety measures for illegal access to personal information, loss, destruction, falsification, leakage, etc. of personal information.

6　Compliance with laws and norms

In handling personal information, we will comply with laws and other norms such as the "Act on the Protection of Personal Information" to protect personal information.

Handling of personal information

Handing of personal information of customers is as follows. Please view here as references about handing of personal information of shareholders.

1　Personal information held by Choei

Our company hold the personal information of tenants who wish to live rental housing, tenants, contractors, joint guarantors, resident families, cohabitant, who wish to apply or purchase properties, owners, who live in accommodation facilities operated by our company in the past, who use mail-order business, rental business, agency business, application agency business, etc., who use our business (hereafter collectively referred to as "customers"). We will use the personal information such as name, gender, date of birth, address, telephone number, fax number, email address (including work place), type of company, annual income, credit card number, payment information, and other information.

2　Purpose of use of personal information

(1) We will not only use your personal information when sign contract, but also for other purposes as follows

• ・For conclusion, performance, information and service provision for contracts of property management, brokerage, rent, business, consulting, construction etc.
• ・For introduction of properties, communication of application results, credit inquiry to credit information agencies, occupancy examination, lease contract, joint guarantee contract, management consignment contract, sublease original contract, conclusion ,performance, and contract management of mediation contract, implementation of management and after-sales service after signing contract
• ・For introduction of other real estate and services of our company, the introduction of products and services of our business partners that we think are useful to our customers, to send questionnaires, etc. (include no deal)
• • For concluding contracts, fulfilling obligations, and providing information to service providers regarding sales of products such as groceries and daily necessities, mail-order sales, service agency, rental business, application agency business, etc.

(2) Our company will use the personal information obtained regarding the insurance solicitation business entrusted by the following insurance company within necessary limit . The purpose of use is as follows, and it will not be used for any other purpose.

For sales of non-life insurance handled by our company and provision of the related service, various events・campaigns・seminars, provision of various information.

Changes of the purpose of use as above will be done in reasonable limit, if the purpose changes, we will inform customers by document or announced on our homepage（https://www.kk-choei.co.jp） in principle. The purposes of the solicitation business entrusted by insurance company are stated on the homepage (as follows) of insurance company.

• ■JI Accident & Fire insurance Co., Ltd.（https://www.jihoken.co.jp）
• ■AIG General Insurance Company, Ltd.（https://www.aig.co.jp/sonpo）
• ■Sompo Japan Insurance Inc.（https://www.sompo-japan.co.jp）
• ■Mitsui Sumitomo Insurance Company, Limited（https://www.ms-ins.com/）

3　3 Share of personal information

We will share personal information with our group companies for the purposes listed in above-mentioned 2nd item.

• ・Items of sharing personal information
  Personal information listed in above-mentioned 1st item, necessary personal information of customers and users be used for the purposes listed in above-mentioned 2nd items within reason.
• ・Extent of joint users
  Choei Building Service Inc., Green Guarantee Inc.
• ・Purpose of sharing
  As above-mentioned
• ・Responsible company for sharing
  Choei Inc. (Choei)

4　About outsourcing of personal information

When we outsource personal information held by our company, we will conclude the necessary contract to ensure to manage and supervise personal information safely.

Handling of personal information of shareholders

1 Personal information held by Choei

In order to ensure shareholders to exercise and the execution of business stipulated by relevant laws and regulations such as the Companies Act, our company will acquire and use name, address, number of shares owned, share acquisition date, e-mail address, etc. personal information by legitimate means. The term 「Shareholders Sama」 as used herein means a shareholder, a registered share pledgee, or its legal representative, who is recorded in the shareholder list as an individual.

2 Purpose of use of personal information

We will use personal information of shareholders for the following purposes.

• ・To perform rights and obligations based on the Companies Act and other laws and regulations
• ・To provide various benefit from our company to shareholder
• ・To implement various measures to facilitate relationships with shareholders
• ・To make data of shareholders, manage information of shareholders based on various laws and regulations
• ・For the implement of various events , campaigns, questionnaires or other projects held by our company
• ・For our business management and internal management
• ・To respond inquires, requests, etc.

3 Share of personal information

We will share personal information with our group companies for the purposes listed in above-mentioned 2nd item.

• ・Items of sharing personal information
  　Personal information listed in above-mentioned 1st item, necessary personal information of customers and users be used for the purposes listed in above-mentioned 2nd items within reason.
• ・Extent of joint users
  　Choei Building Service Inc., Green Guarantee Inc.
• ・Purpose of sharing
  　As above-mentioned 2nd item
• ・Responsible company for sharing
  　Choei Inc.

About inquiries of personal information

Requests for disclosure, etc. and complaints regarding the personal information held by our company, please contact the following window. Please inquire by email or mail. We cannot answer telephone inquiries, please understand in advance.

Choei Inc. Personal information counter
No.60 Karasuma Manjuji Building 6th floor, 369 Gokuishi-cho, Shimogyo-ku, Kyoto 600-8429
Email address: chuoc@choei-net.ne.jp

Procedures for personal information publicity

Regarding the personal information publicity of our business, based on the provisions of the Act on the Protection of Personal Information (hereafter referred to as the "Act"), regarding the "Retained Personal Data" stipulated in Article 2.5 of the Act, Choei will respond to requests for disclosure, correction, suspension of use, etc. by the person or agent as follows.

1．Personal Information Publicity

• Who can request
  In principle, only the person himself / herself. However, agent entrusted by the person, legal representative of minor or adult guardian can request personal information disclosure on behalf of the person.
• About the method of requesting
  Please fill in the required items on the "Request for Personal Information Publicity" designated by Choei, attach the following documents, and post it to the designated place as the following ③ . We apologize for the inconvenience, but please pay the postage. We appreciate it if you could write "Request for Personal Information Publicity" in red on the envelope.
  
  

  ① When the person be requested

  ・The documents to prove that you are the person
  （ア）Resident card
  （イ）A copy of the ID card with the address and name of the person issued by a public institution (driving license, passport, health Insurance card, etc.)

  ② When an agent makes a request

  ・Documents of the person listed in above-mentioned ①
  ・Documents to identify the agent
  （ア）Resident card of the agent
  （イ）A copy of the ID card with the address and name of the person issued by a public institution (driving license, passport, health Insurance card, etc.) ・Documents can certificate the qualification as agent
  If you are a legal representative, documents that can prove that you are a legal representative (a copy of your family register, Adult guardianship registration certification, etc.)
  If you are a voluntary agent, the power of attorney and the seal certification of the person's seal stamped on the power of attorney

  ③ Contact

  No.60 Karasuma Manjuji Building 6th floor, 369 Gokuishi-cho, Shimogyo-ku, Kyoto 600-8429
  Choei Inc. Personal information counter

  Driving license

  Please copy the face photo so that can identify. If you have changed your address, please also attach a copy of the back side.

  Passport

  Please attach a copy of the photo and address page.

  Health insurance card

  If the address is not stated or has been changed, please write the current address in the margin of the copy and attach it.

  *Please attach the original resident card and seal certification within 3 months from the date of issue.

• •Responses to disclosure of personal information
  
  

  ① When accepting requests of disclosure

  We will process the disclosure when the personal information disclosure request and necessary documents arrive.
  In addition, the department in charge may contact you to confirm the contents of the personal information disclosure request form you filled out.
  If the required documents are insufficient, we may ask you to submit additional documents.

  ② About Sending Response Letter

  In principle, we will send response letter (including introduction that some information can’t be disclosed) by registered mail within two weeks since the personal information disclosure request arrives. However, if there is a valid reason such as there are difficulties in business processing, delivery time will be extended.

  ③ Information that cannot be disclosed

  We may not disclose all or part of personal information when belongs to the following cases. In that case, the reason will be stated in the response letter.
  ・When document of personal information is insufficient or incorrected after requesting to revise
  ・When there is a risk of harming the life, body, property or other rights and interests of the person or a third party
  ・When there is a significant risk of harming proper implementation of our business
  ・When violates other laws and regulations
  ・When the type and scope of personal information subject be requested is not specified
  ・When the subject be requested does not correspond to personal data be held by Choei
  ・When the subject of personal data be requested is not be held by Choei
  ・When response letter doesn’t arrive, and be sent back
  ・When we have no obligation for disclosure according to other laws and regulations

2．Correction, addition, deletion of personal information

If you think the content of your personal information is not true, you can request us to correct, add, or delete your personal information (hereafter referred to as "correction, etc."). In that case, we will correct within necessary limit of business operation. When contents not be corrected after making corrections, the reason will be stated in the response letter.

• Who can request for corrections
  In principle, only the person himself / herself. However, the agent entrusted by the person, legal representative of minor or adult guardian can request personal information disclosure on behalf of the person.
• About the method of requesting for correction, etc.
  Fill in the necessary items on the "Request for correction of personal information", attach the document as above-mentioned [personal information publicity], post documents to the person in charge.

3．About suspension and deletion of personal information

If you think that we are acquiring or using your information illegally, you can request us to suspend or delete your personal information (hereafter referred to as "suspension of use, etc.").In this case, we will conduct the necessary investigation, and when the fact of violation is confirmed, we will suspend the use of personal information within the scope of law and send response letter that content states. If the fact of the violation cannot be confirmed, we will send response letter.

• Who can request suspension of use
  In principle, only the person himself / herself. However, the agent entrusted by the person, legal representative of minor or adult guardian can request personal information disclosure on behalf of the person.
• About the method of requesting suspension of use, etc.
  Fill in the required items on the "Request for suspension of use of personal information" , attach the document as above-mentioned [personal information publicity], post documents to the person in charge.

4．Fees and Payment Method

1,000 yen (tax included) each time for applying "Personal Information Disclosure Application". Please enclose Teigakukogawase worth 1,000 yen with "Personal Information Inquiry Application Form ". We do not charge any fees for correction of personal information or suspension of use.