1. Compliance with laws, regulations and standards

The Company shall comply with laws and ordinances and other national guidelines and standards relating to protection of personal information regarding the handling of personal information and shall properly handle all personal information pertaining to its business.

2. Acquisition purpose and scope

The Company may only acquire, utilize and provide the Customer’s personal information through fair and legal means. Additionally, except in cases provided for in law, the Company shall acquire the Customer’s personal information after providing notice of the purpose of use, notify all parties who will be handling the personal information that it shall only be used within the scope of the purposes of use and take measures to prevent the information from being used for any reason other than the intended purposes.

3. Restriction of provision to third parties

Except in cases provided for in law, the Company shall not provide the Customer’s personal information to a third party without the advance consent of the individual.

4. Implementation of safety countermeasures

The Company shall make efforts to prevent and rectify risks including leaks, loss, damage and unauthorized access of the Customer’s personal information and take all possible measures for the safe management of personal information. When outsourcing the handling of the Customer’s personal information to an external party, the Company shall carefully select the consignee and conduct appropriate supervision. The measures taken by the Company for the safe management of personal data held by the Company are as follows.

1. Development of a system for the handling of personal information
   The Company has established its Personal Information Protection Regulations and stipulates the methods and procedures for handling personal information in each stage of handling, including the acquisition, use, storage, provision, deletion and disposal, etc. of personal information. We have also clarified the roles of those involved in handling personal information.

2. Systematic security control measures
   We have appointed a personal information protection manager to be the person responsible for handling personal information, clarifying the scope of the personal information handled by the employees who handle personal information, and ensuring compliance with the Personal Information Protection Law and Personal Information Protection Law. We have established a system for contacting the personal information protection manager and reporting to them when facts indicating a violation of regulations or signs that a violation may have occurred have been identified.
   Regarding the handling of personal information, we conduct regular self-inspections and conduct internal audits involving other departments.

3. Personnel security control measures
   The Company provides regular education to employees regarding points to note regarding the handling of personal information.
   In addition, matters related to confidentiality regarding the handling of personal information are stipulated in the employment regulations and related regulations.

4. Physical security measures
   In areas where personal information is handled, the Company manages the entry and exit of employees, restricts the equipment they bring into the building and also takes measures to prevent unauthorized people from viewing personal information.
   In addition, we take measures to prevent the theft or loss of equipment, electronic media, documents, etc. which are used in the handling of personal information.

5. Technical safety control measures
   The Company implements access control and limits the scope of the people in charge of handling personal information and the personal information database, etc. handled.
   In addition, we have built a system to protect the information system that handles personal information from unauthorized external access or unauthorized software.

5. Consultation and complaints regarding personal information

The Company shall provide appropriate and swift support for complaints and consultations regarding personal information. Regarding requests from the Customer for the disclosure of their personal information, the Company shall provide support using a predetermined method.

6. Continuous improvement of the personal information protection management system

The Company shall provide thorough education and training to all employees so that the Customer‘s personal information is properly handled, administer the internal system for protecting the Customer’s personal information, maintain the personal information protection management system and make efforts to continuously review and improve the system.

7. Inquiries regarding the personal information privacy policy

Casa Inc. Customer Service Center
Address: 2-6-1 Nishi-Shinjuku, Shinjuku-ku, Tokyo
Telephone Number: 03-6863-5968
Reception hours: 9:00AM-6:00PM on weekdays (excluding weekends, holidays and the year-end and New Year holidays)

Enactment date: December 1, 2009
Revision date: March 1, 2022
2-6-1 Nishi-Shinjuku, Shinjuku-ku, Tokyo
Casa Inc.
Representative Director and President Seigo Miyaji

1. Purpose of Use of Personal Information

The Company uses personal information for the purposes stated below. The Company does not use personal information beyond the purposes of use unless the prior consent of the individual the personal information identifies has been obtained.

1. Personal information of customers

   ① To decide whether or not to conclude a guarantee consignment agreement (including validating phone numbers entered into the guarantee consignment application)
   ② To conclude and execute a guarantee consignment agreement or guarantee agreement (hereinafter collectively “Guarantee Agreements, etc.”) (including claims regarding the commissioning of counter guarantees and the receipt of confirmation of these counter guarantees)
   ③ To have proper control and properly execute operations for receivables including the execution of prior and post claims for damages concerning the execution of the Guarantee Agreements, etc.
   ④ To execute proper control of the Guarantee Agreements, etc. (including control after the Guarantee Agreements, etc. expire)
   ⑤ For rent control and collection services under the Guarantee Agreements, etc.
   ⑥ To execute and control rent agreements and to make adjustments regarding payables and receivables after the expiration of the agreement
   ⑦ To apply for household contents insurance and accident insurance
   ⑧ To implement mediation and broker real estate
   ⑨ For enrollment and withdrawal procedures for various services of the Company associated with or related to Guarantee Agreements, etc., and for the performance of these services
   ⑩ To implement employment support based on customer requests
   ⑪ To handle problems with locks, plumbing, window glass, gas-powered heaters, water heaters, electricity, etc. in rental properties, to provide information and respond to inquiries regarding rental properties, and to provide health, medical, and lifestyle consultations to applicants, as well as support for solving problems in the neighborhood, etc.
   ⑫ For confirmations, answers and other services regarding opinions, requests or consultations
   ⑬ To send catalogs, direct mail, samples, questionnaires, etc. regarding goods and services that may be useful to applicants that are offered by the Company or partner companies.
   

2. Personal information of business partners

   To fulfill obligations related to transactions and to communicate as necessary for business.

3. Personal information of shareholders

   ① To exercise rights and fulfill obligations under the Companies Act and other laws and regulations
   ② To provide various conveniences from the Company to the shareholder
   ③ To implement various measures to facilitate the relationship between shareholders and the Company and its subsidiaries
   ④ For shareholder management, such as the creation of shareholder data based on prescribed standards based on various laws and regulations
   

4. Personal information of job applicants

   To manage recruitment selection and prospective applicants.

5. Personal information of our officers, employees, retirees and their families

   To perform tasks related to personnel and labor management such as tasks related to attendance, labor and emergency contacts.

6. Personal information regarding all of the people in the above items and those who have contacted or visited our company

   ① For communication, correspondence management, sending of related materials, etc.
   ② To perform security management such as entry/exit management.
   ③ To carry out other incidental operations necessary for achieving the purposes of the above items.

   *The main debtor, main obligee, joint guarantor, emergency contact, cohabitant of the rental property (including each person scheduled at the screening stage) stated in the application form and contract regarding guarantee or consignment of guarantee, and those who have submitted an application or made an inquiry regarding the use of our services

2. Handling of sensitive information

To confirm that the party who is concluding the guarantee consignment agreement or lease agreement and the applicant are the same person, the Company may request the submission of an official certificate that contains sensitive information such as the individual’s legal domicile. In this event, the Company shall strictly handle personal information containing sensitive information by taking the protective measures stipulated in these provisions.

3. Transfer of Personal Information to Third Parties

1. The Company shall not transfer personal information to third parties, except in the following cases.

① When the Company is required to send documents or mail items, make phone calls or use the internet, etc. to communicate with landlords, tenants, housing land building agents, rental property administration companies, guarantors, emergency contacts, cohabitants, lawyers, financial institutions, insurance companies or other parties (including people in countries or regions designated by the rules of the Personal Information Protection Commission as foreign countries that have personal information protection systems that are recognized to be at the same level as Japan) within the scope of the purposes of use in the individual items of the preceding article and within a reasonable scope necessary to perform the purposes of use
② When receiving an application for infrastructure services such as electricity, gas, water, or the Internet (hereinafter "Lifelines") regarding a rental property in conjunction with an application for a guarantee contract, the Lifeline application procedure agent and when providing the information necessary for the application procedure in writing, by post, by telephone, by the internet, etc.
③ When the Company obtains the consent of the individual the personal information identifies prior to the transfer
④ When the transfer is pursuant to law or ordinance
⑤ When the transfer of personal information is required to protect a person's life, body or property but obtaining consent for the transfer of personal information from the individual the personal information identifies (applicant) is difficult
⑥ When the transfer of personal information is particularly necessary to improve public sanitation or to promote the sound development of children but obtaining consent for the transfer of personal information from the individuals the personal information identifies (applicants) is difficult
⑦ When required to cooperate with a government agency, local municipal body or a party commissioned by such agency or body for the execution of operations stipulated in a law or ordinance but obtaining consent from the individuals the personal information identifies (applicants) is likely to hinder the execution of these operations



2. Providing information to credit information agency

The Company obtains the individual’s consent at the time of application, and then we may provide the personal information of the applicant, etc. described in the guarantee consignment application form and the guarantee contract form to the credit information agency which the Company joins (hereinafter the "Joined Institution") and the credit information agency affiliated with the Joined Institution (hereinafter the "Affiliated Institution"). If loan information and personal information such as information about applicants are registered, we will receive the information and use it only for the purpose of investigating repayment or solvency.

① Items of personal information to be provided
Name, date of birth, gender, address, phone number, work name, work phone number, symbol number such as driver’s license, information on contract details (contract type, contract date, guarantee start date, guarantee amount, lease application property information, etc.), repayment situation information (payment date, scheduled payment date, balance amount, repayment date, delinquency, delinquency resolution, etc.), and factual transaction information (debt collection, debt consolidation, guarantee fulfillment, bankruptcy filing, loan transfer, etc.)
② How to provide personal information
Enter the data in the dedicated form on the websites of the Joined Institution and Affiliated Institution.
③ Names of the Joined Institution and the Affiliated Institution
(Joined Institution)
Japan Credit Information Reference Center Corp.
(Affiliated Institution)
Japanese Bankers Association Personal Credit Information Center
CIC Co., Inc.

4. Measures to protect personal information

1. The Company shall make efforts to implement the necessary security measures to prevent risks from being realized including leaks, loss, damage and unauthorized access of the Customer’s personal information.

2. The Company shall make efforts to preserve the possessed personal information in a safe environment that can only be accessed by authorized users.

3. If the Company entrusts another business operator with all or part of the handling of personal information, or provides personal information to a third party with the consent of the person the information identifies, it must exercise the necessary and appropriate supervision of the business operator it entrusts so that the personal information is not leaked.

5. About the revision of provisions

Except in cases provided for in law, the Company may appropriately revise these provisions, and in the event that there is a risk that the revised content may significantly affect the person, the Company shall notify the person or make an announcement in a suitable manner through the Company’s homepage.

6. Acquisition of personal information through methods that cannot be easily recognized by the person

We record phone calls.

1. Personal information subject to disclosure

1. Basic information ・Matters relating to said person (Name, address, gender, telephone number, email address, etc.)
   ・Matters relating to the occupation or place of work (Name, location, telephone number, position, income, etc.)
   ・Matters relating to rental properties (Name, location, room number, monthly rent, parking fee, security deposit, etc.)
   ・Matters relating to the Guarantee Agreement (Guarantee Agreement date, guarantee period, guarantee commission, etc.)

2. Information relating to guarantee transactions Matters relating to the fulfillment of guarantee obligations (Rent payment situation, subrogation history, payment history, etc.)

3. Records of provision of personal information to third parties

2. Disclosure request procedures

When disclosing a notification of the purpose of use, basic information and guarantee transaction information or disclosing, adding, deleting, discontinuing use and provision of personal information to a third party, please download the written request for the disclosure of personal and written request to correct, add or delete personal information, respectively, fill in the necessary items, enclose an identification confirmation document and the disclosure service fee and mail it to the Company’s contact point stated in (6). Please note that the Company will not accept any requests through methods other than mailing them to the Company’s contact point.

1. Disclosure requesters A) Person in question
   B) Authorized representative concerning disclosure procedures

2. When requested by the person in question • Written request for the disclosure of personal information or written request to correct, add or delete personal information
   • Identity confirmation document
   • Disclosure service fee

3. When requested by an authorized representative • Written request for the disclosure of personal information or written request to correct, add or delete personal information
   • Power of attorney
   • Certificate of registered seal
   • Identity confirmation document of the authorized representative
   • Disclosure service fee

4. Identity confirmation document A confirmation of identity will be conducted for the said person and requester as part of the disclosure request procedures. Please bring the original or a copy of a form of identification that contains your name and address issued by a public institution exemplified below within three months after it has been created or is currently valid.
   
   • Driver’s license (excluding one's legal domicile)
   • Passport
   • Basic resident register card with photo
   • Health insurance card
   • Pension book
   • Residence card

5. Disclosure service fee When the request is for the disclosure of personal information or for the notification of the purpose of use, the following disclosure service fees are required for each request. Please prepare a postal money order for the disclosure service fees. The disclosure service fees may not be returned in the event that the Company does not possess the applicable personal information or cannot disclose possessed information in accordance with the provisions of laws and regulations.
   
   A) Disclosure of personal information or notification of the purpose of use: 1,100 yen (tax included)
   B) Disclosure of information relating to guarantee transactions: 2,200 yen (tax included)

6. Mailing address Please confirm the content filled out in the prescribed disclosure request form and that the necessary documents are enclosed, and mail it to the following address:
   Casa Inc. Personal information consultation desk
   Shinjuku Sumitomo Building 30F
   2-6-1 Nishishinjuku, Shinjuku-ku, Tokyo 160-0023

7. Method of response to inquiries The Company shall send the “responses relating to the disclosure of personal information” or the “responses relating to the correction, addition or deletion of personal information” to the address of the requesting party by certified mail with delivery restricted to the addressee. However, the following requests may not be disclosed. In these events, the Company shall provide notification together with the reason therefor.
   
   A) When the said person or representative cannot be identified.
   B) If the disclosure request or identity confirmation document is incomplete.
   C) In the event that the information matters subject to the disclosure request procedures do not apply with the personal information subject to disclosure.
   D) In the event that there is a possibility of informing said person or a third party would harm his/her or the third party's life, body, fortune, or other rights and interests.
   E) In the event that there is a possibility of interfering seriously with the said personal information handling business operator implementing its business properly.
   F) In the event that it may be a violation of other laws or regulations.

8. Purpose of use of personal information acquired through the procedures The personal information acquired by the Company through the disclosure request procedures may be used to investigate said procedures, and for responses regarding the identity confirmations of the person in question and representative and disclosure request procedures.

9. Job title and contact information of personal information of the personal information protection administrator General Manager of Human Resources & General Affairs Department : 03-6863-5968

10. Contact information for complaints regarding the handling of retained personal information data Casa Inc. Personal information consultation desk
    Address : Shinjuku Sumitomo Building 30F, 2-6-1 Nishishinjuku,
    Shinjuku-ku, Tokyo
    Tel : 03-6863-5968
    Business hours : 9:00AM-6:00PM on weekdays (excluding weekends,
    holidays, and the year-end and New Year holidays)

11. Name of the authorized personal information protection organization belonging to the Company and contact information for complaints Name of authorized personal information protection organization: Japan Institute for Promotion of Digital Economy and Community
    Contact information for complaints: Personal information complaint consultation office
    Address: Roppongi First Building, 1-9-9 Roppongi, Minato-ku, Tokyo 106-0032
    Telephone number: 03-5860-7565 / 0120-700-779