Personal Information Protection Policy

Your personal information will be used for the following purposes:

1. (1)Target businesses
   Office building business related to urban development, residential business, commercial business, construction industry and power equipment consulting, planning, design, maintenance, operation and maintenance business, and other related businesses
2. (2)Purpose of use
   Regarding the business of item 1
   • For sales activities such as sending direct mail, pamphlets, etc., and soliciting via visits, telephone, and e-mail
   • To fulfill contracts and provide information and services
   • For various operations such as after-sales service and product information
   • To provide information regarding questionnaire surveys on customer satisfaction, etc.
   • For the purpose of analyzing customer trends as statistical information and for research and analysis of product development, etc.
   • To respond to accidents and disasters (including emergency contact) and for safety management

We will share personal information to improve the convenience of our customer services.

1. (1)Items of personal information to be jointly used
   Name, contact information (phone number, email address, etc.), name of organization (company name, organization name, etc.), job title, and other information that can identify a specific individual
2. (2)Scope of joint users
   NTT Urban Solutions Group companies, etc. 
   (See Appendix "Scope of parties using the information jointly")
3. (3)Purpose of use of joint users
   Purpose of use as described in 1 above
4. (4)Name and address of the person responsible for managing the personal information to be jointly used
   NTT Urban Development Corporation Co. Ltd.
   President and Chief Executive Officer Kou Ikeda
   Akihabara UDX, 4-14-1 Sotokanda, Chiyoda-ku, Tokyo

The joint use of information regarding our procurement partners will be in accordance with the Personal Information Protection Policy of NTT,Inc.

*Reference: "Regarding the joint use of information regarding business partners related to procurement" https://group.ntt/jp/protection/partners_procure.html

In addition to the above, we may share personal information with third parties. In that case, we will notify you of the following items in advance or make an announcement on our website, etc.

1. ①Purpose of joint use
2. ②Items of customer personal information to be jointly used
3. ③Scope of parties using the information jointly
4. ④Purpose of use of the joint users
5. ⑤The name or title and address of the person responsible for managing the customer's personal information, and in the case of a corporation, the name of its representative

If you have any questions or comments regarding your personal information, please contact the person in charge below.

We will respond to requests for notification of the purpose of use of personal data held about you, requests for disclosure, correction, addition, deletion, suspension of use, and erasure of personal data, requests for disclosure of records of provision of your personal information to a third party, and requests for suspension of provision of your personal information to a third party in accordance with the provisions of the Personal Information Protection Act. Requests for disclosure, etc. will be handled by sending us the specified form by mail, fax, email, etc. In any case, please contact the inquiry desk listed above.

Please note that for inquiries about your own retained personal data, we will ask you to follow our designated application procedures after going through our designated "identification" procedures. We also ask that you pay a handling fee (1,000 yen (incl. consumption tax) per inquiry), so we appreciate your understanding and cooperation.

When handling customer personal information, we will take appropriate organizational, personal, physical and technical safety control measures.

1. (1)Organizational safety management measures
   We have established an organizational management system that includes the establishment of a management system with committees and management officers in each organization, the development of internal regulations, the creation of statements such as management ledgers and process management tables, and continuous improvement.
2. (2)Personnel safety measures
   We will inform and raise awareness among all employees who handle customer personal information, regardless of whether they are executives, full-time employees, or temporary workers, of the importance of protecting customer personal information, and will have them sign non-disclosure agreements and conduct the necessary audits and supervision to ensure their effectiveness.
3. (3)Physical Security Measures
   We will take various measures such as controlling entrance and exit to buildings and floors where customer personal information is handled, preventing theft, taking measures against damage to customer personal information due to fire or lightning strikes, and locking up systems and documents when they are taken out, transported, or stored.
4. (4) Technical security measures
   We will take technical control measures such as access management including authentication, authority management, control and recording when accessing personal data, measures against malicious software and viruses in the system, measures during transfer and transmission such as encryption and clarification of responsibility, and monitoring of information systems.
5. (5)Understanding the external environment
   When handling customer personal information in a foreign country, we will understand the systems for protecting personal information in that foreign country and take appropriate measures.

WeWe may create anonymously processed information based on your personal information and provide it to third parties. In that case, we will publish the following items on our website etc.

1. ①Items of personal information contained in the anonymously processed information created by our company
2. ②Items of personal information included in anonymously processed information provided to third parties
3. ③Method of providing anonymously processed information to third parties
4. ④Details of safety control measures taken
   When handling Anonymously Processed Information, etc., the Company will implement the safety control measures described above in 5. In addition, the Company will provide necessary and appropriate supervision to employees and contractors (including subcontractors, etc.) who handle Anonymously Processed Information, etc.

We may create pseudonymized information based on your personal information. However, we will not provide it to third parties unless required by law. When handling pseudonymized information, we will take the safety management measures described in 5 above. In addition, we will provide necessary and appropriate supervision to employees and contractors (including subcontractors, etc.) who handle pseudonymized information, etc.

We handle personal information (information about a living individual that does not fall under any of the categories of personal information, pseudonymized information, or anonymously processed information; specifically, website browsing history, location information, etc.) as follows.

1. (1)When we provide personal information
   When it is expected that a third party will obtain Personal Information as personal data, we will not provide such information to such third party without first confirming that we have obtained the customer's prior consent (if the third party is located in a foreign country, obtaining consent will include providing the customer with the name of that foreign country, its system for protecting personal information, the measures taken by the third party to protect personal information, and other information that should be helpful to the customer), except in cases falling under any of the items of Article 27, Paragraph 1 of the Personal Information Protection Act.
2. (2)When we obtain personal information as personal data
   When acquiring personal information as personal data, the Company will obtain the prior consent of the customer. However, if the person to whom the personal data is to be provided has already obtained consent from the customer, this may be substituted for obtaining prior consent.

When providing customer personal information or personal-related information to a third party in a foreign country (excluding countries that have personal information protection systems that are recognized as being at the same level as Japan in terms of protecting the rights and interests of individuals), we will take the following measures.

1. (1). Provision of customer personal information to third parties in foreign countries
   ① Method by obtaining consent
   We will notify you of the following matters in advance and, with your consent, may provide your personal information to a third party in a foreign country.
   • Name of the foreign country to which the information will be provided
   • The system relating to personal information in the foreign country
   • Measures taken by third parties to protect personal information
   Please note that the "Personal Information Protection System in the Foreign Country" is posted on the website of the Personal Information Protection Commission below, so please check it out. (If it is not listed on the website below, we will notify you individually.)
   [Personal Information Protection Commission website]
   https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/#gaikoku
   ② Method by establishing a system by a third party in a foreign country
   In addition to the above ①, we may provide your personal information to a third party in a foreign country after taking the necessary measures to ensure the continued implementation of equivalent measures by that third party.
2. (2). Provision of personal information to third parties in foreign countries
   ① Method by obtaining consent
   We may provide personal information to third parties in foreign countries in accordance with the provisions of Section 8.(1) above.
   ② Method by establishing a system by a third party in a foreign country
   In addition to the above ①, we may provide personal information to a third party in a foreign country after confirming that we have obtained the consent set out in 8.(1) above (excluding the confirmation that the information in parentheses has been provided) and taking the necessary measures to ensure the continued implementation of equivalent measures by the third party in the foreign country.