PRIVACY POLICY

Agent Growth Co., Ltd. (hereinafter referred to as "the Company") recognizes the importance of protecting personal information and complies with the Act on the Protection of Personal Information (hereinafter referred to as the "Personal Information Protection Act"). , we will strive to properly handle and protect personal information in accordance with the following privacy policy (hereinafter referred to as "this privacy policy"). Unless otherwise specified in this privacy policy, the definitions of terms in this privacy policy are in accordance with the provisions of the Personal Information Protection Law.

1. Definition of personal information

In this Privacy Policy, personal information shall mean personal information defined by Article 2, Paragraph 1 of the Personal Information Protection Law.

2. Purpose of use of personal information

2.1 We will use personal information for the following purposes.

  1. (1) Regarding real estate sales and leasing conducted by our company using trademarks that include the term "Keller Williams" or "KW" (meaning Keller Williams) (hereinafter referred to as "KW brand") To provide services and other services operated by the Company (hereinafter collectively referred to as "our services")
  2. (2) To provide guidance and respond to inquiries, etc. regarding services provided by the Company and business operators to whom the Company licenses the KW brand (sublicensees; hereinafter referred to as "KW Member Stores");
  3. (3) For information on our products, services, etc.
  4. (4) To respond to acts that violate our company's terms, policies, etc. (hereinafter referred to as "terms, etc.") regarding our services
  5. (5) To notify changes in terms of our services, etc.
  6. (6) To analyze information on the status of service usage, etc. and use it to improve our services, develop new services, etc.
  7. (7) (1) KW brand licensors (hereinafter referred to as “KW licensors”), (2) third parties that use the KW brand, and (3) third parties involved in the management of services that use the KW brand (both of which are located overseas) To provide personal information (including (i) information about customers in our services, (ii) property information, and (iii) information about KW agents) to KW Agent means an individual engaged in the business of a KW member store. In addition, information on customers means the portion of information on customers excluding property information.
  8. (8) To publish information about properties sold through our services on the portal sites, web advertisements, and other Internet sites of our company, KW licensors, and other businesses that use the KW brand
  9. (9) For employment management and internal procedures (personal information of officers and employees), and for selection and communication in recruiting activities (personal information of applicants)
  10. (10) Regarding information about KW Agents and the officers and employees of the Company and KW affiliated stores, such information may be posted on websites operated by the Company or KW licensors (websites operated by third parties entrusted by the Company or KW licensors). Site, including where such website is open to the public).
  11. (11) For shareholder management, corporate law and other legal procedures (personal information of shareholders, stock acquisition rights holders, etc.)
  12. (12) To create statistical data processed into a form that cannot identify individuals regarding the performance of real estate transactions conducted through our services
  13. (13) For other purposes incidental to the above purpose of use

2.2 Third parties who have received personal information pursuant to Section 2.1, item 7 may improve and develop systems using information obtained by analyzing the operation and usage of services related to our services, as well as marketing and advertising. Or we will use personal information for the purpose of advertising. However, if the individual who is the subject of personal information (hereinafter referred to as "the person") withdraws consent or objects to the use of personal information for these purposes, the Company will immediately We will notify the third party to that effect.

3. Change of purpose of use of personal information

The Company may change the purpose of use of personal information to the extent that it is reasonably recognized as having relevance, and in the event of such change, the Company will notify the individual or publicly announce the change.

4. Restrictions on use of personal information

4.1 We will not handle personal information beyond the scope necessary to achieve the purpose of use without obtaining the consent of the individual, except as permitted by the Personal Information Protection Law and other laws and regulations. However, this shall not apply in the following cases.

  1. (1) When required by law
  2. (2) When it is necessary to protect a person's life, body or property and it is difficult to obtain the consent of the individual
  3. (3) When it is particularly necessary to improve public health or promote the sound development of children, and it is difficult to obtain the consent of the individual.
  4. (4) When it is necessary to cooperate with a national agency, local government, or a person entrusted by them in carrying out the affairs stipulated by laws and regulations, and the execution of the affairs with the consent of the person When there is a risk of interfering with
  5. (5) When personal data is provided to an academic research institution, etc., and the academic research institution, etc. needs to handle the personal data for the purpose of academic research (part of the purpose of handling the personal data is academic research) (Including for the purpose of use, excluding cases where there is a risk of unjustly infringing on the rights and interests of an individual.)

4.2 We will not use personal information in a manner that may encourage or induce illegal or unjust acts.

5. Appropriate acquisition of personal information

5.1 We will acquire personal information properly and will not acquire it by deception or other wrongful means.

5.2 The Company will not acquire special care-required personal information (as defined in Article 2, Paragraph 3 of the Act on the Protection of Personal Information) without the prior consent of the individual, except in the following cases.

  1. (1) Cases that fall under any of items 1 to 4 in Section 4.1
  2. (2) When acquiring special care-required personal information from an academic research institution, etc., and when it is necessary to acquire said special care-required personal information for academic research purposes (part of the purpose of acquiring said special care-required personal information is (Including for academic research purposes, excluding cases where there is a risk of unjustly infringing on the rights and interests of individuals.) limited.)
  3. (3)Persons listed in each item of Article 57, Paragraph 1 of the Act on the Protection of Personal Information, and other persons specified by the rules of the Personal Information Protection Commission if published by
  4. (4) When acquiring personal information that requires special care that is obvious in appearance by looking at or photographing the person
  5. (5) When receiving personal information requiring special care from a third party, and when the third party's provision falls under any of the items in Article 8.1.

5.3 When receiving personal information from a third party, we will confirm the following matters in accordance with the rules of the Personal Information Protection Commission. However, this excludes cases where the provision of the personal information by the third party falls under any of the items in Section 4.1 or falls under any of the items in Section 8.1.

  1. (1) The name or name and address of the third party, and in the case of a corporation, the name of its representative (in the case of an organization that is not a corporation and has a designated representative or administrator, the representative or administrator);
  2. (2) How the third party acquired the personal information

6. Security management of personal information

We will provide necessary and appropriate supervision to our employees so that personal information can be safely managed against risks such as loss, destruction, falsification and leakage of personal information. In addition, when outsourcing all or part of the handling of personal information, the Company will conduct necessary and appropriate supervision to ensure the safety management of personal information at the outsourcee. Details of the specific security control measures regarding personal data held by the Company are as follows.

Formulation of basic policy

In order to ensure the proper handling of personal data, this privacy policy has been formulated as a basic policy regarding "compliance with relevant laws and regulations, guidelines, etc." and "point of contact for inquiries and complaints."

Development of discipline related to the handling of personal data

Formulate personal data handling rules for each stage of acquisition, use, storage, provision, deletion, disposal, etc., regarding the handling method, the person in charge, the person in charge, and their duties, etc.

Systematic security control measures

1) When a person responsible for the handling of personal data is appointed, the employee who handles personal data and the scope of personal data handled by the employee are clarified, and facts or signs of violation of laws and handling regulations are identified. Established a system for reporting and contacting the person in charge of

2) Conduct regular self-inspections on the handling of personal data, and conduct audits by other departments and external parties.

Personnel security control measures

1) Provide regular training to employees on points to note regarding the handling of personal data

2) Describe matters related to confidentiality of personal data in the work regulations

physical security measures

1) In the area where personal data is handled, we will control the entry and exit of employees and restrict the equipment they bring in, as well as implement measures to prevent unauthorized persons from viewing personal data.

2) Take measures to prevent theft or loss of equipment, electronic media, documents, etc. that handle personal data, and when carrying such equipment, electronic media, etc., including movement within the office, personal data can be easily lost. Take measures to prevent it from being revealed

Technical safety control measures

1) Implement access control and limit the scope of the person in charge and the personal information database, etc. handled

2) Introduce a mechanism to protect information systems that handle personal data from unauthorized external access or unauthorized software.

Understanding the external environment

Implement security control measures after understanding the system regarding the protection of personal information in country A where personal data is stored

7. Reporting of leaks, etc.

In the event of leakage, loss, damage, etc. of personal information handled by the Company, if it is necessary to report to the Personal Information Protection Commission and notify the person in accordance with the provisions of the Personal Information Protection Act, We will make such reports and notifications.

8. Provision to Third Parties

8.1 We will not provide personal information to a third party without obtaining the prior consent of the individual, except in cases that fall under any of the items in Section 4.1. However, the following cases do not fall under the provision to third parties specified above.

  1. (1) When providing personal information in conjunction with entrusting all or part of the handling of personal information within the scope necessary to achieve the purpose of use
  2. (2) When personal information is provided along with business succession due to merger or other reasons
  3. (3) In the case of joint use based on the provisions of paragraph 9

8.2 Notwithstanding the provisions of Clause 8.1, the Company shall, except in cases falling under any of the items of Clause 4.1, apply to foreign countries (designated by the Personal Information Protection Commission rules based on Article 28 of the Personal Information Protection Law). country) (excluding those who have established a system that meets the standards specified by the Personal Information Protection Commission rules based on Article 28 of the Act on the Protection of Personal Information). When providing personal information, we will obtain the consent of the person in advance to the effect that the provision to a third party in a foreign country is permitted.

8.3 When obtaining the consent of the person for the provision to a third party located in a foreign country pursuant to Clause 8.2, the following matters shall be provided to the person. However, if the matters in Item 1 cannot be identified, instead of the matters in Items 1 and 2, the fact that the matters in Item 1 cannot be identified, the reason for that, and information that should be helpful to the person in lieu of said matters We will provide you with that information, if any.

  1. (1) Name of the foreign country concerned
  2. (2) Information on the system for the protection of personal information in the foreign country
  3. (3) Information on measures taken by the third party to protect personal information (if the information cannot be provided, that fact and the reason)

8.4 When we provide personal information to a third party, we will create and store records in accordance with Article 29 of the Personal Information Protection Law.

8.5 When receiving personal information from a third party, the Company shall, in accordance with Article 30 of the Personal Information Protection Act, conduct necessary confirmation, and create and store records related to such confirmation.

8.6 From the third party that provided the personal information to the third party, the Company will submit a record that proves that the person has consented to the provision of the personal information to the third party and the use of the provided personal information. We may provide such records to such third parties if requested.

9. Shared use

9.1 Regarding information obtained from customers who contact us through the inquiry form on the website operated by our company, we will jointly use personal information with KW member stores as follows. Hereafter, KW Member Stores shall mean businesses listed as KW Member Stores on the following websites operated by the Company.
https://kellerwilliams.jp/kamei-ten/

  1. (1) Items of personal information to be used jointly
    (i) Names, e-mail addresses, and other personal information of customers who contact us through the inquiry form on the website operated by us
    (ii) Information about properties (including ownership interests in properties) that you wish to sell or rent through our services;
  2. (2) Purpose of use by users
    (i) Regarding the information set forth in the preceding item (i), the Company or KW affiliated stores (including KW agents and officers and employees of KW affiliated stores) shall contact the customer specified in the preceding item (i).
    (ii) Regarding the information in the preceding item (ii), KW affiliated stores (including KW agents and officers and employees of KW affiliated stores) engage in sales activities and brokerage services for buying and selling or leasing properties. thing.
  3. (3) Name, address and representative name of the person responsible for managing the above personal information , the KW member store shall be responsible.)
    1-17-1 Toranomon, Minato-ku, Tokyo Representative Director Go Yamamoto

9.2 With regard to information on KW Agents and officers and employees of KW affiliated stores, the Company will jointly use personal information with all KW affiliated stores, including KW affiliated stores other than the affiliated store to which the individual belongs, as follows: increase.

  1. (1) Items of personal information to be used jointly
  2. (2) Purpose of use by the user Business or emergency contact (including property inquiries), payment of money, correspondence to various legally required procedures, posting in company brochures, etc. purposes incidental to the matters of
  3. (3) As stated in the personal information protection policy of each KW affiliated store to which the person belongs, such as the name or title, address, and representative name of the person responsible for the management of the above personal information.

10. Disclosure of Personal Information

10.1 When the person requests disclosure of personal information based on the provisions of the Personal Information Protection Law, the Company will disclose the personal information to the person without delay after confirming that the request is from the person himself/herself. (If the personal information does not exist, we will notify you to that effect.) However, this does not apply if the Company is not obligated to disclose it under the Personal Information Protection Law or other laws and regulations.

10.2 The stipulations in the preceding paragraph apply to the records related to the provision to third parties created based on Section 8.4 and the records related to the provision from third parties created based on Section 8.5 concerning personal information that identifies the person. shall apply mutatis mutandis.

11. Correction of personal information

If the person requests correction, addition, or deletion of the content (hereinafter referred to as "correction, etc.") based on the provisions of the Personal Information Protection Act on the grounds that the personal information is not true, the Company will After confirming that the request is from the person himself/herself, we will conduct necessary investigations without delay within the scope necessary to achieve the purpose of use, and based on the results, correct the content of personal information, etc. We will notify the person to that effect (if we decide not to make corrections, etc., we will notify the person to that effect). However, this does not apply if the Company is not obligated to make corrections, etc. under the Personal Information Protection Act or other laws and regulations.

12. Suspension of use of personal information

The Company will notify the person that (1) the person's personal information is being handled beyond the scope of the purpose of use that has been announced in advance, or is being used in a manner that may encourage or induce illegal or unjust acts. or because the personal information of the individual has been obtained by deception or other wrongful means, suspension or deletion of its use (hereinafter referred to as "suspension of use, etc.") in accordance with the provisions of the Personal Information Protection Law (2) suspension of provision of personal information (hereinafter referred to as "providing ), or (3) when the Company no longer needs to use the person's personal information, the personal information protection law Article 26 paragraph 1 regarding the person's personal information Suspension of use, etc., or provision of personal information based on the provisions of the Personal Information Protection Law for the reason that the handling of the personal information of the individual may harm the rights or legitimate interests of the individual, or if a stipulated situation occurs. In the event that a request for suspension is made and it is found that there is a reason for the request, after confirming that the request was made by the person himself/herself, suspension of use, etc. or suspension of provision of personal information will be made without delay. and notify the person to that effect. However, this does not apply if the Company is not obligated to suspend the use, etc. or the provision of personal information under the Personal Information Protection Act or other laws and regulations.

13. Provision of Personal Information to Third Parties

13.1 The Company shall not allow a third party to collect personal information (meaning information stipulated in Article 2, Paragraph 7 of the Act on the Protection of Personal Information, limited to information constituting a personal information database, etc. stipulated in Article 16, Paragraph 7 of the same Act). The same shall apply hereinafter) as personal data, excluding the cases listed in each item of Section 4.1, the following matters shall be confirmed in advance in accordance with the rules of the Personal Information Protection Commission. We will not provide the personal information to the third party without doing anything.

  1. (1) The person's consent has been obtained to allow the third party to receive personal-related information from the Company and acquire it as personal data that can identify the person.
  2. (2) When providing to a third party in a foreign country, in the case of obtaining the consent of the person in the preceding item, personal information in the foreign country shall be obtained in advance in accordance with the rules of the Personal Information Protection Commission. A system for protection, measures for the protection of personal information taken by the third party, and other information that should be helpful to the person are provided to the person.

13.2 When we provide personal information to a third party, we will create and store records in accordance with Article 31 of the Personal Information Protection Act.

13.3 When receiving personal-related information from a third party, the Company shall, in accordance with Article 31 of the Act on the Protection of Personal Information, conduct necessary confirmation, and prepare and store records related to such confirmation.

14. Handling of Pseudonymized Information

14.1 The Company reserves the right to collect pseudonymously processed information (meaning information stipulated in Article 2, Paragraph 5 of the Act on the Protection of Personal Information, and limited to information constituting the pseudonymously processed information database, etc. stipulated in Article 16, Paragraph 5 of the same Act. The same shall apply hereinafter. ), the personal information shall be processed in accordance with the standards stipulated by the Personal Information Protection Commission rules.

14.2 When creating pseudonymously processed information, or when the Company creates pseudonymously processed information, and deleted information, etc. related to the pseudonymously processed information When it is acquired, we will take measures for safe management of deleted information, etc. in accordance with the standards set by the Personal Information Protection Commission rules as necessary to prevent leakage of deleted information, etc.

14.3 The Company will comply with the following provisions regarding pseudonymously processed information (limited to personal information; hereinafter the same shall apply in Section 14.3).

  1. (1) Notwithstanding the provisions of Section 4.1, the Company shall not handle pseudonymously processed information beyond the scope necessary to achieve the purpose of use, except in cases based on laws and regulations.
  2. (2) Regarding the application of Paragraph 3 to pseudonymously processed information, the phrase "to change within the scope reasonably recognized to be relevant" in the same paragraph is replaced by "to change" and "to notify or "I will announce" shall be read as "I will announce" respectively.
  3. (3) Notwithstanding the provisions of Sections 8.1 to 8.3, the Company shall not provide personal data that is pseudonymously processed information to third parties, except in cases based on laws and regulations. However, the cases listed in each item of Section 8.1 do not fall under the provision to a third party specified above.
  4. (4) When handling pseudonymously processed information, the Company shall not collate the pseudonymously processed information with other information in order to identify the person related to the personal information used to create the pseudonymously processed information.
  5. (5) In handling pseudonymously processed information, the Company shall make a telephone call, send by postal mail or correspondence delivery, send a telegram, send by fax or electromagnetic means, or visit a residence, Contact information and other information contained in the pseudonymized information shall not be used.
  6. (6) The provisions of paragraphs 7 and 10 through 12 shall not apply to pseudonymized information.

14.4 The Company shall comply with the following provisions regarding pseudonymously processed information (excluding personal information; hereinafter the same shall apply in Section 14.4).

  1. (1) The Company will not provide pseudonymized information to third parties, except as required by law. However, the cases listed in each item of Section 8.1 do not fall under the provision to a third party specified above.
  2. (2) The Company shall exercise necessary and appropriate supervision over its employees to ensure the safe management of pseudonymized information against risks such as leakage of pseudonymized information. In addition, when outsourcing all or part of the handling of pseudonymously processed information, the Company will conduct necessary and appropriate supervision to ensure the safety management of personal information at the outsourcee.
  3. (3) When handling pseudonymously processed information, the Company shall acquire deleted information, etc., or use such pseudonymously processed information in order to identify the person concerned with the personal information used to create said pseudonymously processed information. Information shall not be matched.
  4. (4) In handling pseudonymously processed information, the Company shall make a telephone call, send by postal mail or correspondence delivery, send a telegram, send by fax or electromagnetic means, or visit a residence, Contact information and other information contained in the pseudonymized information shall not be used.

15. Handling of anonymously processed information

15.1 The Company shall collect anonymously processed information (meaning the information stipulated in Article 2, Paragraph 6 of the Act on the Protection of Personal Information, and limited to the information constituting the anonymously processed information database, etc. stipulated in Article 16, Paragraph 6 of the same Act. The same shall apply hereinafter. ), the personal information shall be processed in accordance with the standards stipulated by the Personal Information Protection Commission rules.

15.1 The Company shall collect anonymously processed information (meaning the information stipulated in Article 2, Paragraph 6 of the Act on the Protection of Personal Information, and limited to the information constituting the anonymously processed information database, etc. stipulated in Article 16, Paragraph 6 of the same Act. The same shall apply hereinafter. ), the personal information shall be processed in accordance with the standards stipulated by the Personal Information Protection Commission rules.

15.2 When we create anonymously processed information, we will take measures for security management in accordance with the standards stipulated by the Personal Information Protection Commission rules.

15.3 When we create anonymously processed information, we will disclose the items of personal information contained in the anonymously processed information in accordance with the rules of the Personal Information Protection Commission.

15.4 When providing anonymously processed information (including information created by the Company and information provided by a third party; the same shall apply hereinafter unless otherwise specified) to a third party, Pursuant to the rules of the Information Protection Commission, we will announce in advance the items of personal information included in anonymously processed information provided to a third party and the method of providing such information, and will notify the third party of the provision of such information. We will clearly indicate that the information related to is anonymously processed information.

15.5 When handling anonymously processed information, the Company shall (1) collate the anonymously processed information with other information, and (2) ) Acquisition of information regarding the description, etc. or individual identification code deleted from the relevant personal information, or the method of processing performed pursuant to the provisions of Article 43, Paragraph 1 of the Act on the Protection of Personal Information ((2) is provided by a third party (Only for the anonymously processed information that has been received) shall not be performed.

15.6 The Company shall take necessary and appropriate measures for the safe management of anonymously processed information, handle complaints regarding the creation and other handling of anonymously processed information, and take other necessary measures to ensure proper handling of anonymously processed information. and endeavor to publicize the details of such measures.

16. Use of Cookies and Other Technologies

Our services may use cookies and similar technologies. These technologies help us understand how our services are being used, and contribute to improving our services. Users who wish to disable cookies can do so by changing their web browser settings. However, if you disable cookies, you may not be able to use some functions of our services.

17. Contact

For requests for disclosure, etc., opinions, questions, complaints, and other inquiries regarding the handling of personal information, please contact the contact below.

Name, address and representative name of business operator handling personal information
E-mail: kwjapan@kwj.jp
(Reception hours are from 9:00 to 17:00 on weekdays.)

18. CONTINUOUS IMPROVEMENT

We will review the operational status of the handling of personal information from time to time and strive for continuous improvement, and we may change this privacy policy as necessary.

[Revised on April 1, 2022]