Leopalace21 Group Basic Privacy Policy

Leopalace21 Corporation and its group companies* (including Overseas branches and Overseas group companies, hereinafter collectively referred to as the "Leopalace21 Group") recognize that Leopalace21 Group has a significant responsibility to ensure safe storage and use of your personal information as it provides its services. Accordingly, Leopalace21 Group promises to provide you with optimal services and sense of security by taking all possible measures for protecting and managing your personal information under the basic policy described below.

• Group companies herein refer to consolidated subsidiaries of Leopalace21 Corporation.

1. Compliance with laws and regulations

We will comply with the Act on the Protection of Personal Information and other laws and regulations related to protection of personal information, this Privacy Policy, and other rules.

2. Use of personal information only for the purposes of its use

We will specify the purposes of use of personal information and use it only for the specified purposes, except when the subject (a specific individual who can be identified by the personal information; the same shall apply hereinafter) has given prior consent or the use is handled as an exception by laws or regulations.

3. Proper acquision and use of personal information

We will acquire personal information by proper means. We will ensure not to use personal information in a way that may foster or cause illegal or improper act.

4. Notification, etc. of the purposes of use

When we acquire personal information, we will announce the purposes of its use to the public in advance, notify the subject of the acquisition, or announce the acquisition to the public immediately after acquiring the information. When we receive the information directly from the subject in writing or by other means, we will clarify the purposes of its use in advance and receive the subject's consent. When we change the purposes of use, we will give notice of the change or announce it to the public.

5. Safety management measures

We will strive to keep personal information accurate and updated, take every possible measure to prevent unauthorized access to it, its loss, destruction, alteration, leakage, or other problems, and take appropriate measures to prevent risks of these outcomes.

6. Response to requests concerning personal information

We will respond promptly and appropriately to requests from the subject to disclose, correct, or stop using the personal information, or to complaints from the subject, and strive to establish an internal system for this purpose.

7. Continuous improvement of internal system

We will strive to continue improving our system for the protection of personal information through means such as undertaking appropriate internal audits on personal information.

Handling of Personal Information by Leopalace21 Group

Purposes of Use of Personal Information

Purposes of Use of Personal Information by Leopalace21 Corporation

1. Personal information of customers

1. Responding to customer inquiries
2. Providing information about our services, properties and products, providing other information, and making contacts (including sending of direct mails and e-mails, including those from our affiliates)
3. Questionnaires for customers and analyses of their results
4. Providing insurance handled by Leopalace21 Corporation and services related to the insurance (Purposes of use of the information by insurance companies that outsource insurance solicitation to Leopalace21 Corporation are described on the individual websites.)
5. When we need to contact a customer for some other reason

We may provide personal information to a third party without obtaining the subject's prior consent when provisions of Article 27, paragraph (1) of the Act on the Protection of Personal Information apply.

We may also provide a required range of personal information (including name, address, phone number and new address and phone number of the subject who has moved) to related parties in writing, verbally, digital data, or other means for the purposes listed below. The subject may request that we stop providing the information to third parties. However, please understand that this may prevent us from providing the subject with necessary services. Please see "Disclosure, Corrections, Termination of Use, etc. of Personal Information of Customers" for information on termination procedures.

1. Presenting the information to an outsourcee when it is necessary for providing services to the customer
2. Presenting the information to a financial institution or the like when it is necessary for receiving payment for a service, product, etc. that a customer used or purchased
3. Presenting the information to a financial institution or the like when it is necessary for arranging a loan
4. Presenting the information to a credit information agency or the like when it is necessary for credit inquiry on a person desiring to use our service, or our customer
5. Presenting the information to the counterparty or prospective lessor when it is necessary for mediation or agent business related to real estate
6. Presenting the information to the counterparty or prospective counterparty when it is necessary for business alliance, capital alliance, sale of business or property, or other purpose
7. Presenting the information to financial institutions when it is necessary for cash management purposes concerning loans

2. Personal information of users of Azumi En
(for the purposes of use other than the ones described in the preceding Article 1. Personal information of customers)

1. Purposes of use related to use at the facilities
   1. Care services provided by Leopalace21 Corporation to users of its care services, etc.
   2. Handling of nursing care insurance
   3. The following practices included in management and operation of business establishments and other facilities related to users of care services
      ・Management of admission to and withdrawal from facilities, accounting practices, reporting of accidents, etc.
      ・Improvement of care services provided to users
      ・Use of the information as basic data for maintaining and improving care services and operations
      ・Use of the information as basic data for training of facility staff that is aimed at improving their qualifications and quality
2. Purposes of use involving provision of the information to other business operators, etc.
   1. The following practices included in care services provided by Leopalace21 Corporation to users, etc.
      ・Cooperation with other home care service providers, home care support providers, etc. (including conferences of service personnel)
      ・Response to inquiries, outsourcing of other operations, explanations of users' physical and mental conditions to their families, and other practices
   2. The following practices included in handling of nursing care insurance
      ・Submission of medical practitioners' receipts for health insurance claims to medical claims review and payment organization
      ・Response to inquiries from medical claims review and payment organization or insurers
      ・Outsourcing the handling of nursing care insurance
   3. Consultation with or submission of notification to insurance companies, etc. with which we have concluded insurance contracts concerning our services including liability insurance
   4. When use of the information is necessary for accepting interns under training programs, etc. or volunteers

3. Personal information of our shareholders

We will use the information for sending our shareholders business reports and convocation notices of general meetings of shareholders, paying dividends to them, granting shareholder special benefits to them, and for contacting them for other purposes.

4. Personal information of job applicants

1. Recruiting activities (selection, necessary contact, provision of information, etc.)
2. Creation of statistics and other data

5. Personal information of our prospective employees

1. Taking procedures related to employment (pension, labor insurance, etc.)
2. Management of health for occupational safety and health
3. Provision of education and training
4. Making contact necessary for work or in the event of an emergency
5. Creation of statistics and other data

6. Personal information of our former employees

1. Disclosing data we own to the subject or to a person to whom the subject wants us to disclose the data, at the subject's request
2. Making contact necessary for work or in the event of an emergency

7. Personal information of dispatched workers under our supervision

1. Attendance management
2. Taking procedures with temporary employment agencies that dispatch the workers
3. Management of health for occupational safety and health
4. Internal disclosure or presentation of personal information, which are conducted for internal communications or employee management
5. Provision of education and training
6. Making contact necessary for work or in the event of an emergency
7. Management of facilities, equipment, instruments, vehicles used for operations, and others
8. Submission of notifications to regulatory agencies or trade organizations or provision of information to parties related to the Company, which applies when submission of notifications of license holders, etc. is necessary for our operations
9. Business analyses
10. Creation of statistics and other data

8. Personal information of interns experiencing work under our supervision

1. Taking procedures with parties involved in the internship program, such as universities
2. Management of health for occupational safety and health
3. Making contacts necessary for the internship or in the event of an emergency
4. Management of facilities, equipment, instruments, vehicles used for operations, and others
5. Creation of statistics and other data

Purposes of Use of Personal Information by Leopalace21 Group

1. Leopalace Leasing Corporation

Click here for details. (Japanese only)

2. Plaza Guarantee Co., Ltd.

Click here for details. (Japanese only)

3. ASUKA SSI

Click here for details. (Japanese only)

4. Purposes of use of personal information by LEOPALACE GUAM CORPORATION

1. Reservation for hotel or condominium accommodations, banquets, restaurants, sports facilities, golf courses, spas, and other facilities, provision of various services, and ensuring safety of customers
2. Undertaking all related operations for achieving the above purposes
3. Responding to inquiries and requests

5. Purposes of use of personal information by Azu Life Care Co., Ltd.
(for the purposes of use other than the ones described in the preceding Article 1. Personal information of customers, Purposes of Use of Personal Information by Leopalace21 Corporation)

1. Purposes of use related to use at the facilities
   1. Care services provided by Azu Life Care Co., Ltd. to users of its care services, etc.
   2. Handling of nursing care insurance
   3. The following practices included in management and operation of business establishments and other facilities related to users of care services
      ・Management of admission to and withdrawal from facilities, accounting practices, reporting of accidents, etc.
      ・Improvement of care services provided to users
      ・Use of the information as basic data for maintaining and improving care services and operations
      ・Use of the information as basic data for training of facility staff that is aimed at improving their qualifications and quality
2. Purposes of use involving provision of the information to other business operators, etc.
   1. The following practices included in care services provided by Azu Life Care Co.,Ltd. to users, etc.
      ・Cooperation with other home care service providers, home care support providers, etc. (including conferences of service personnel)
      ・Response to inquiries, outsourcing of other operations, explanations of users' physical and mental conditions to their families, and other practices
   2. The following practices included in handling of nursing care insurance
      ・Submission of medical practitioners' receipts for health insurance claims to medical claims review and payment organization
      ・Response to inquiries from medical claims review and payment organization or insurers
      ・Outsourcing the handling of nursing care insurance
   3. Consultation with or submission of notification to insurance companies, etc. with which we have concluded insurance contracts concerning our services including liability insurance
   4. When use of the information is necessary for accepting interns under training programs, etc. or volunteers

6. Leoplex21 Business Consulting (Shanghai) Co., Ltd.

Please view here

7. Leopalace21 Overseas branch

Seoul, Korea Branch Office
Please view here

Taipei, Taiwan Branch Office
Please view here

Shared Use of Personal Information

1. Leopalace21 Group uses its comprehensive strengths to respond to diverse requests from customers. Therefore, as described below, the Group may make shared use of customers' personal information retained by Leopalace21 Corporation or Group companies, within Leopalace21 Group.

1. Shared users
   Leopalace21 Group (including Overseas branches and Overseas group companies)
2. Items of personal data to be subject to shared use
   
   1. Customer's name, address, telephone number, fax number, e-mail address, organization to which he or she belongs (name of the company/organization, department, and position), and information concerning deals with a Leopalace21 Group company (records of the process of the deals and negotiations and other facts)
   2. Information about the contents of inquiries made to each Leopalace21 Group company (provision of services, etc., confirmation of the provision, and provision of information about services)
3. Purposes of use by shared users
   1. Undertaking management tasks needed for business administration, including recognition of status of accounts receivable and assets and risks in Leopalace21 Group
   2. Operations for introducing services, properties, and products offered by companies belonging to Leopalace21 Group
4. Company responsible for management concerning shared use:
   Leopalace21 Corporation
   2-54-11 Hon-cho, Nakano-ku, Tokyo
   Bunya Miyao, President & CEO

2. To provide better services to customers, Leopalace21 Group may make shared use of customers' personal data with companies that have concluded affiliation contracts with Leopalace21 Corporation.

1. Shared users
   Leopalace21 Group and Leopalace Partners* (including Overseas branches and Overseas group companies)
   • Leopalace Partners refers to companies that have concluded affiliation contracts with Leopalace21 Corporation. Click here (Japanese only) for details of Leopalace Partners.
2. Items of personal data to be subject to shared use
   Information concerning contracts or information that will be needed for management of properties, including customer's name, address, telephone number, fax number, e-mail address, organization to which he or she belongs (name of the company/organization, department, and position)
3. Purposes of use by shared users
   Responding to customer inquiries, operations for introducing services, properties, or products of Leopalace21 Group including provision of information or making suggestions about them, management of properties, and operations related to these
4. Company responsible for management concerning shared use
   Leopalace21 Corporation
   2-54-11 Hon-cho, Nakano-ku, Tokyo
   Bunya Miyao, President & CEO

3. Leopalace21 Group may make shared use of customers' personal data with partner companies such as subcontractors. In that case, the Group will notify in advance the items of personal data to be subject to shared use as well as the personnel responsible for management.

Security control measures in place for the personal data

Leopalace21 Group has put in place following security control measures to prevent leakage of information that the Group acquired from the customers.

1. Set up a basic policy
   The Group has set up the basic policy for complying with the relating laws, regulations and guidelines, and defining the focal point of responding to the inquiries by the customers in order to ensure proper handling of the personal data,.
2. Maintain internal regulations in handling personal data
   The Group has set up the internal regulations and maintains the regulations on handling method, responsible managers and persons in charge, and their respective duties related to the handling of data acquisition, use, storage, provision, and deletion/disposal.
3. Systematic security control measures
   The Group has assigned the responsible managers for handling personal data and the persons in charge of handling personal data along with defined scope of personal data and required way of reporting when noticing facts or indications of violating the Act on the Protection of Personal Information or the internal regulations.
4. Human security control measures
   The Group has provided the employees with training regarding key points on personal data handling and with notice of calling for attention.
5. Physical security control measures
   The Group has implemented the control measures for entering and leaving a specific room with restriction of portable devices where personal data are handled and for prevention of viewing personal data by unauthorized persons. The Group ensures to take appropriate preventive measures against theft or missing of hardware devices, electronic storage or documents relating to personal data and protect against access to the personal data contained in the hardware devices, electronic storage or something similar when being carried around in and outside the office.
6. Technical security control measures
   The Group has implemented the accessibility control in terms of person and scope of personal information database. The information systems containing personal data are protected against unauthorized access or malicious software.
7. Locational attentions
   In case the Group retains outside Japan the personal data of the customers, it will see to implement security control measures in light of the local system to protect personal information in the relevant countries.

Use of Cookie

Leopalace21 Group may use cookie* for the benefit of users visiting the Group website to use the services offered in the website and to be informed of the Group's goods and services.

• A cookie is a small text file that is placed on a user's-visitor's computer and contains information that the user-visitor left on that website. Usage of a cookie is in no way linked to any personally identifiable information and therefore not invading the user's-visitor's privacy. The user-visitor can set their browser to notify them when they receive a cookie, giving them the chance to decide whether to accept it.

1. Leopalace21 Group may use the collected data through cookies for analyzing the usage of the web site for the user-visitor access status, traffic and routing, to improve the website performance, and improve marketing offers to the user-visitor. The following access analysis tools are mainly used for the purpose.
   

   Google Analytics (Google Inc.)
   Please visit the following URL for Google's privacy policy.
   https://policies.google.com/privacy?hl=en
   Information to be collected by use of the above tool: user-visitor access status, traffic, and movement within the website and the like.

2. Leopalace21 Group serves advertisements to users-visitors when they visit a specific page based on their prior visits to Leopalace21 Group website, by using the services provided by third party advertisement vendors, including Google, Yahoo!, Facebook and Instagram. The Group uses cookie to acquire the user's-visitor's historical details for visiting the website.

Recording of Telephone Calls from Customers

We may record telephone calls made by customers to call centers, service centers, and other customer contacts of Leopalace21 Group to improve call quality and correctly understand contents of interactions such as inquiries with and consultations for customers in order to effectively handle them.

Termination of Delivery of Direct Mails, etc.

If you wish to stop receiving information about services or products and other notices sent from Leopalace21 Group, please contact the respective organization that issues the notices (such as a branch or center).

Disclosure, Corrections, Termination of Use, etc. of Personal Information of Job Applicants, Employees, Former Employees, etc.

Contact the following to request disclosure, corrections, termination of use, etc. of personal information about people such as job applicants, employees, and former employees that is retained by Leopalace21 Corporation.

Contact for Inquiries (Japanese only)

Department handling personal information of people, including job applicants, former employees, dispatched workers, and interns, that Leopalace21 Corporation retains

Disclosure, Corrections, Termination of Use, etc. of Personal Information of Customers

Customers requesting disclosure, corrections, termination of use, etc. of their personal information must send request forms to the following, by attaching identification documents (such as copies of a driver's license or passport). Please note that we cannot respond to requests from customers if submitted documents are in any way inadequate.

Procedures for Request

1. Enter required information for the Request for Disclosure, etc. of Personal Information.

Click below to download the request form.

• Personal Information Disclosure Request Form (PDF file)(Japanese only)
• Personal Information Disclosure Request Form (Word file)(Japanese only)

2. Prepare a copy of your identification document, etc.

1. If you are the subject of the personal information, prepare a copy of any one of the following.
   • Driver's license
   • Passport
   • Health insurance card
   • Basic resident registration card (with a photo)
   • Foreign resident registration card
2. If you are not the subject of the personal information, prepare documents specified in A and B below.
   1. Copies of any of the following identification documents, one each of the subject of the personal information and their proxy
      ・Driver's license
      ・Passport
      ・Health insurance card
      ・Basic resident registration card (with a photo)
      ・Foreign resident registration card
   2. Any one of the following identification documents of the proxy
      ・Proxy statement and seal registration certificate
      ・Certificate of registered matters of adult guardianship
      ・Copy of family register or resident card that proves your relationship with the subject

3. Send the request form by mail or e-mail to the following address.

Address:

• We will use the personal information obtained via your requests for disclosure, etc. only in ways necessary for responding to requests for disclosure, etc.

Contact for Inquiries (Japanese only)

Department handling personal information retained by Leopalace21 Corporation

• For inquires, questions, complaints, or other matters related to our operations, please contact the individual branch or center, or call our toll-free number.

Leopalace21 Group may change the contents of this Privacy Policy as necessary without prior notice.

Leopalace21 Corporation
2-54-11 Hon-cho, Nakano-ku, Tokyo
Bunya Miyao, President & CEO

Revision History: Revised May 1, 2023