ARNEST ONE (hereinafter, the “Company”) complies with all laws and regulations related to the protection of personal information, including the “Law concerning the Protection of Personal Information,” and endeavors to adhere to both the spirit and the letter of the law as regards protecting personal information (e.g., names, addresses, birth dates, phone numbers, email addresses, and other information that enables individuals to be identified) of customers, business partners, and others in the course of its business activities.
The Company has formulated the following policies on the handling of personal information to facilitate smooth and appropriate administration.

The Company will never attempt to acquire personal information through deceitful or other fraudulent means.
When the Company acquires personal information, it identifies the purpose for which the information will be used, and will publish such purpose on its website or otherwise notify all parties involved of such purpose.

The Company will not use personal information for purposes other than those specified in advance in order to conduct the real-estate sales business, construction-related business, or other business indicated in the Company’s Articles of Incorporation. Additionally, when business processes are outsourced in part or in full and personal information is provided to vendors within the scope necessary for these purposes, the Company will conclude confidentiality agreements, etc., with the vendors, mandate strict management of personal information, and conduct all necessary and appropriate supervision.

The Company will not provide personal information to third parties except in the following cases:

• (1)
  When permission is obtained in advance from the individual involved.
• (2)
  When the content to be provided to the third party is disclosed, and the provision of such content will be discontinued if so requested by the individual involved (via an opt-out clause).
• (3)
  When it is in accordance with the law.
• (4)
  When it is necessary to protect a person’s life, physical well-being, or property, and obtaining the permission of the individual involved would prove exceedingly difficult.
• (5)
  When it is necessary to address a public health issue or promote child development, and obtaining the permission of the individual involved would prove exceedingly difficult.
• (6)
  When cooperating in administrative work being executed under the law by a government agency, local government body, or its contracted party, and obtaining the permission of the individual involved would potentially hinder the execution of such work.

The Company diligently works to manage personal information in a secure way, and further implements rational and appropriate information security and other security measures in order to prevent unauthorized access to personal information and the loss, damage, or divulgence of personal information. The Company also has established rules related to personal information, along with management systems for protecting personal information, and it conducts training and awareness-raising for executives and other employees.

This policy may be changed as necessary. Any such changes will be disclosed on the Company’s website or disclosed using rational and appropriate means deemed necessary based on the nature of the changes, and notify the individuals involved of the changes.

Revised on April 1, 2010

The Company may use personal information it has acquired for the following purposes:

• (1)
  To provide products and services.
• (2)
  To conduct sales activities (e.g., sending or delivering leaflets or other information materials on products and services).
• (3)
  To provide house plans, etc., or to conduct surveys necessary for this purpose.
• (4)
  To develop and improve products and services.
• (5)
  To prepare for, conclude, or execute construction contracts, sales contracts, or other contracts.
• (6)
  To provide after-sales service or after-sales maintenance, or to respond to cases of equipment failure (e.g., when requested to send personal information to housing equipment manufacturers due to a recall of housing equipment).
• (7)
  To assist or mediate between various procedures related to products and services (e.g., financing, certifications, or registrations).
• (8)
  To accommodate audits or investigations of the Company.
• (9)
  To conduct confirmation work for account audit purposes.
• (10)
  To conduct marketing surveys for management analysis (e.g., the administration, compilation, and analysis of questionnaires)
• (11)
  To conduct matters ancillary to the above items.

• *
  In addition to the above purposes, the personal information of shareholders may be used for the purpose of managing shareholder records.
• *
  Employment and HR information on employees can also be used for purposes that have been disclosed publicly or that the party involved has received notice of using means as separately defined by the Company.

Within the scope necessary to fulfill the above purposes of use, the Company may provide personal information to the following third parties. Provision to third parties will be discontinued if so requested by the individual involved in accordance with the prescribed procedures.

• (1)
  Third parties to which personal information is provided:

  • 1)
    Other registered real-estate brokers
  • 2)
    Advertising agencies
  • 3)
    Judicial scriveners related to registration, as well as land and housing investigators
  • 4)
    Financial institutions related to financing
  • 5)
    Real-estate management companies and security companies related to real-estate management, etc.
  • 6)
    Sales agencies, intermediaries, design companies, construction companies, and survey companies involved in real-estate sales and construction
  • 7)
    Maintenance contractors and housing equipment manufacturers for the purposes of after-sales service, after-sales maintenance, or responses to equipment failure
  • 8)
    Government agencies that process applications for approvals and licenses related to development projects, etc.
  • 9)
    Other recipients within the scope necessary to fulfill the purposes of use listed in “1” above.
• (2)
  Personal data items provided
  Name, address, telephone number (including mobile phone number), fax number, email address, place of employment (including position/department), and other items within the scope dictated by the purposes of use
• (3)
  Method of provision to third parties
  In writing or electronically

The Company jointly uses personal information as follows:

• (1)
  Personal data items used jointly
  Name, address, telephone number (including mobile phone numbers), fax number, email address, date of birth, sex, transaction history, and other information related to transactions with the Company
• (2)
  Scope of joint-use companies

  • 1)
    Iida Group Holdings Co., Ltd.
    Hajime Construction Co., Ltd.
    Jounan Construction Co., Ltd.
    Iida Sangyo Co., Ltd.
    Paradise Resort Co., Ltd.
    Built Home Co., Ltd.
    Oriental Home Co., Ltd.
    Home Trade Center Co., Ltd.
    Touei Housing Corp.
    Tact Home Co., Ltd.
    ID Home Co., Ltd.
  • 2)
    A ONE PLUS CORPORATION
    Arnest Wing Co., Ltd.
• (3)
  Purposes of use of joint-use companies

  Purposes of use of companies listed in 1) above

  • Responses to inquiries, records retention, product development, marketing, and the development of other reference materials

  Purposes of use of companies listed in 2) above

  • Housing repair/maintenance and damage insurance agency services and other customer support related to the detached housing and contract business of the Company and joint-use companies
  • Provision of information on products and services of the Company and joint-use companies

• (4)Company responsible for management of joint use
  General Affairs Division, ARNEST ONE CORPORATION
• (5)Joint use will be promptly discontinued if so requested by the individual involved.

The individual involved may request that the Company disclose, revise, suspend use, or delete his or her personal data. Additionally, when disclosure procedures are necessary, the Company will send, fax, or e-mail the prescribed forms, and requests can be made using these forms.
If you request disclosure of your own personal information, the Company will ask you to follow the procedure to verify your identity. A certain number of days and a processing fee of \840 are required to extract the personal data that the Company retains and to prepare an appropriate explanation, so your understanding in advance is appreciated. (A processing fee is not charged for requests pertaining to the revision, suspension of use, or deletion of data.)

Requests, inquiries, or complaints regarding the handling of personal information should be directed to the following division of the Company:

(Revised April 1, 2010)