JP
THE GRANDUO

PRIVACY POLICY

E-HOUSING Co., Ltd. Provided in Japanese. The Japanese text is the binding version.

E-Housing KK (the "Company," "we," or "us") handles the personal information of many individuals, including customers from Japan and overseas, in the course of conducting its real estate leasing brokerage business, real estate sales brokerage business, website development and operation business, and other related businesses (collectively, the "Business").

We recognize that the personal information we obtain from customers through the Business and the personal information of our employees (collectively, "Personal Information") are highly important information assets, and that protecting them reliably is one of our key social responsibilities.

To comply with the Act on the Protection of Personal Information of Japan (the "APPI"), other applicable laws, government guidelines and other norms, and to handle Personal Information accurately and in good faith, we have established this Privacy Policy (this "Policy") and will make every effort to protect our customers' Personal Information.

1. Business Operator Handling Personal Information

E-Housing KK

Jingumae Tower Building 14F, 1-5-8 Jingumae, Shibuya-ku, Tokyo 150-0001, Japan

CEO: Erkin Nasriddinov

2. Compliance with Laws and Regulations

We comply with laws and regulations concerning the handling of personal information, government guidelines and other norms, and protect and manage Personal Information appropriately.

3. Personal Information We Collect

We collect mainly the following Personal Information by lawful and fair means.

  • Name, date of birth, gender, nationality, address, telephone number, email address and other contact details
  • Information contained in identification documents such as residence cards, passports and driver's licenses (including status of residence and period of stay)
  • Employer, length of employment, occupation, income and other information required for tenant screening
  • Information about family members and other intended occupants, emergency contacts and joint guarantors
  • Desired property conditions, inquiry details, and history of viewings, contracts and transactions
  • Browsing history on our websites, cookies, IP addresses, device information and other online identifiers
  • Information about job applicants and employees

4. Purposes of Use

We use the Personal Information we obtain within the scope of the following purposes.

  • To respond to inquiries about properties, provide property information and show properties
  • To arrange viewing schedules and contact you regarding viewings
  • To process rental applications and tenant screening, and to conclude lease agreements and related agreements
  • To conclude real estate sale and purchase agreements and related agreements
  • To provide post-move-in support and guidance on renewals, terminations and other procedures related to lease agreements
  • To provide housing search services for the employees of our corporate clients
  • To send information about our services, properties, campaigns and the like (including by email, SMS and direct mail)
  • To respond to consultations, requests, complaints and other inquiries
  • To improve our services, develop new services, conduct marketing analysis and measure advertising effectiveness
  • To provide recruitment information and conduct recruitment screening
  • For personnel and labor management of our employees
  • To prevent and respond to fraud and other misconduct
  • For communications, record keeping and business management incidental to the above

5. Provision to Third Parties

(1) We do not provide Personal Information to third parties except with the consent of the individual concerned or as permitted by law.

(2) With your consent obtained through the rental application form or other written or electronic means, we provide Personal Information as follows in order to process rental applications and tenant screening, conclude lease agreements and carry out post-move-in procedures.

Recipients: rent guarantee companies, property management companies, landlords (property owners) and other real estate companies involved in the transaction

Information provided: among the information listed in Section 3, information from identification documents such as residence cards and passports, employment information, income information, information about family members and other occupants, information about emergency contacts and joint guarantors, and other information necessary for tenant screening and move-in

Method of provision: in writing, by email, by entry into each company's screening application system, or by other means

Recipients' purposes of use: tenant screening, conclusion and management of lease agreements and guarantee agreements, post-move-in property management, and related operations

(3) We may outsource all or part of the handling of Personal Information to service providers to the extent necessary to achieve the purposes of use. In such cases, we select service providers that handle Personal Information appropriately and exercise necessary and appropriate supervision over them.

6. Provision to Third Parties in Foreign Countries

For the purposes of delivering advertisements based on your use of our services and your interests, and measuring advertising effectiveness, we may use the following tools and provide hashed personal data (converted by a special calculation method into a format from which the original information is difficult to identify) to third parties located in foreign countries. Before such provision, we will obtain your prior consent in accordance with the law, after providing information on the name of the country where the recipient is located, that country's personal information protection system, and the measures taken by the recipient to protect personal information. However, Personal Information obtained through the THE GRANDUO website described in Section 7 is excluded from such provision.

(1) Meta Pixel and Conversions API

We use the "Meta Pixel" and "Conversions API" provided by Meta Platforms, Inc. ("Meta"). Through these tools, we may provide hashed Personal Information to Meta, located in the United States or Ireland, and such information is managed in accordance with Meta's privacy policy. The only information we obtain from Meta and use is information on users' browsing behavior used to optimize ad delivery.

(2) Google Ads Enhanced Conversions

We use "Enhanced Conversions" provided by Google LLC ("Google"). Through this tool, we may provide hashed Personal Information to Google, located in the United States, and such information is managed in accordance with Google's privacy policy. The only information we obtain from Google and use is information on users' browsing behavior used to optimize ad delivery.

(3) Cloud Services and Customer Relationship Management (CRM) Systems

We use cloud services and customer relationship management (CRM) systems provided by businesses located in foreign countries to store and manage Personal Information. Where we entrust the handling of Personal Information to such businesses, we establish, through contracts or other means, a system that meets the standards prescribed by the APPI and take the measures necessary to ensure its continued implementation. Information on these measures will be provided upon request.

Countries where the main service providers are located: United States of America (Pipedrive) and Spain (Typeform)

(4) For information on the personal information protection systems of the countries where the above recipients are located, please refer to the information published on the website of the Personal Information Protection Commission of Japan.

7. Personal Information Obtained Through the THE GRANDUO Website

(1) Through the inquiry forms and other forms on the website of THE GRANDUO (the "GRANDUO Website"), a luxury rental residence brand operated by Faith Network Co., Ltd. ("Faith Network") and developed, maintained and operated by us, we and Faith Network each obtain customers' Personal Information directly from the customers.

(2) The Personal Information obtained includes name, telephone number, email address, inquiry details and other information entered in the forms.

(3) We use such Personal Information within the scope of the following purposes.

  • To respond to inquiries about properties listed on the GRANDUO Website
  • To provide property information and show properties
  • To arrange viewing schedules and contact you regarding viewings
  • To communicate with you and carry out procedures for rental applications, tenant screening and the conclusion of lease agreements
  • To respond to consultations, requests, complaints and the like
  • For communications, record keeping and business management incidental to the above

(4) After a form is submitted, we will mainly be the party contacting you by email, telephone or other means regarding property showings, viewing schedules, rental applications and other matters.

(5) Such Personal Information is stored only on servers located in Japan, is handled within Japan, and is not provided to any third party located in a foreign country. It is also not stored in the cloud services or CRM systems provided by foreign businesses described in Section 6(3).

(6) Faith Network is the party responsible for managing such Personal Information and serves as the primary point of contact for requests for disclosure and other requests, as well as complaints. If you submit a request or complaint to us, we will also respond in accordance with the law in cooperation with Faith Network. For details on how Faith Network handles personal information, please refer to its privacy policy.

8. Security Management

We take necessary and appropriate security measures to prevent unauthorized access to, and leakage, loss or damage of, Personal Information, and respond appropriately and promptly if any problem occurs. Our main measures are as follows.

  • Organizational measures: appointing a person responsible for handling Personal Information, checking handling practices, and establishing a reporting system for leaks and similar incidents
  • Human measures: regular training for employees and confidentiality undertakings
  • Physical measures: controlling areas where Personal Information is handled and preventing theft or loss of documents and devices
  • Technical measures: managing access rights, protecting against unauthorized access and monitoring access
  • Understanding the external environment: where we handle personal data using cloud services or other services of businesses located in foreign countries, we implement security measures after understanding the personal information protection systems of those countries (the United States of America and Spain).
  • Supervision of service providers: selecting appropriate service providers and exercising necessary and appropriate supervision over them

9. Use of Cookies

Our websites may use cookies to collect information such as browsing activity in order to improve accessibility and convenience.

A cookie is information sent from a web server to a user's browser and stored there. A cookie can only be read by the web server that sent it. Cookies are not programs; they do not run on their own and do not contain computer viruses.

Most browsers are set to accept cookies by default, but you can change your browser settings to display a warning before accepting cookies or to refuse them. Please note that if you refuse cookies, some features of our websites may not be available.

10. Use of Google Analytics

Our websites use Google Analytics provided by Google to collect and analyze data such as website usage, in order to provide better services and improve usability. In doing so, Google may collect information such as users' IP addresses through cookies. The collected data is managed in accordance with Google's privacy policy. We do not use information obtained through Google Analytics to identify specific individuals.

You can disable data collection by Google Analytics by using the opt-out browser add-on provided by Google.

11. Requests Regarding Retained Personal Data

If you or your agent request notification of the purposes of use, disclosure (including disclosure of records of provision to third parties), correction, addition, deletion, suspension of use, erasure, or cessation of provision to third parties of retained personal data held by us, we will respond without delay in accordance with the law after verifying your identity. Please submit requests to the contact point in Section 13. We will explain how to submit a request, the documents required to verify your identity, and the method of disclosure (including provision by electronic records) when you contact us. We may charge a prescribed fee for requests for notification of the purposes of use or for disclosure. Requests concerning the Personal Information described in Section 7 will be handled as set out in Section 7(6).

12. Continuous Improvement

We will strive to continuously improve our personal information protection efforts in line with changes in our internal and external environment. We may amend this Policy as required, including in response to changes in the law. Any amended Policy takes effect when posted on our website.

13. Contact Information

Please direct any questions, requests or complaints regarding our handling of Personal Information to the contact point below.

Personal Information Protection Manager: Administration, E-Housing KK

Contact: Administration, E-Housing KK (Email) contact@e-housing.jp

This Policy is originally written in Japanese, and the English version is a reference translation. In the event of any discrepancy between the Japanese and English versions, the Japanese version shall prevail.

Established: September 16, 2026

E-Housing KK