WHERE Inc. (hereinafter referred to as "the Company") has established the following privacy policy (hereinafter referred to as "this Policy") regarding the treatment of all personal information handled by the Company, and is committed to building a framework for personal information protection, making all employees recognize the importance of personal information protection, and thoroughly implementing these initiatives to promote the protection of personal information.

Article 1 (Personal Information)

"Personal information" refers to "personal information" as defined in the Act on the Protection of Personal Information (Act No. 57 of 2003, hereinafter referred to as the "Personal Information Protection Act"), and refers to information concerning living individuals that can identify a specific individual by name, date of birth, or other descriptions, including personal identification codes.

Article 2 (Purpose of Use of Personal Information)

The Company will obtain personal information within the scope necessary for the following purposes and utilize the obtained information. If the Company intends to use personal information beyond the scope of the purposes listed below, it will obtain the consent of the individual in advance through appropriate means.

1. Personal information of individual customers and contact persons at business partners (hereinafter referred to as "users")

(1) To provide the Company's services (hereinafter referred to as "the Service")
(2) To improve or enhance the content of the Service or to develop new services
(3) To provide information about new functions, update information, campaigns, etc. regarding the Service as well as other services provided by the Company (including sending emails, flyers, and other direct mail)
(4) To contact users as necessary for maintenance, important notices, etc.
(5) To respond to opinions and inquiries from users regarding the Service (including identity verification)
(6) To report on the usage status of the Service to users
(7) To request cooperation in surveys, interviews, etc. related to the Service and to invite participation in various events, or to report results
(8) To investigate and analyze usage history of the Service and utilize the results for improvement, development of the Service, and distribution of advertisements
(9) To provide personal information to participating companies at Company-hosted events based on the consent and application of users
(10) To identify users who violate the terms of use or attempt to use the Service for illegal or unjust purposes and refuse their use

2. Personal information contained in information obtained by the Company from public data such as commercial registration, real estate registration, public notices, and tax offices

To provide personal data that has been database-processed from real estate registration information and commercial registration information obtained from the Japan Real Estate Agents Association as support for collecting real estate, corporate, and map information, conducting sales activities, credit judgment, management operations support, and analyzing information of customers, companies, organizations, and individuals.

Article 3 (Use of Cookies, etc.)

1. The Company may use cookies and other information-gathering modules (hereinafter referred to as "cookies, etc.") for analyzing access to the Service and may obtain access information and browsing information of users. The information obtained through cookies, etc. (hereinafter referred to as "cookie information") does not include information that alone can identify and specify the user.

2. Users can set preferences concerning the use of cookies, etc., on the Service. If users do not wish to allow the use of cookies, they can disable cookies, etc., in their browser settings. However, disabling cookies, etc. may impair the convenience of the Service or limit the range of services provided.

3. The Company will utilize cookie information for the operation, quality maintenance, and improvement of the Service, as well as for the development and improvement of the Company's products and services, and tailored advertisement distribution to match the user's usage status of the Service.

Article 4 (Management and Protection of Personal Information)

1. The management of users' personal information will be conducted strictly, and except in the cases listed below, personal information will not be disclosed or provided to third parties without the consent of the individual. Additionally, preventive and corrective measures will be taken against risks such as unauthorized access to personal information, loss, destruction, alteration, and leakage of personal information.

(1) When it is necessary to protect human life, body, or property, and it is difficult to obtain the consent of the individual.
(2) When it is particularly necessary for the improvement of public health or the promotion of sound child-rearing, and it is difficult to obtain the consent of the individual.
(3) When it is necessary to cooperate with a national agency or a local public entity or a person entrusted by them in the performance of legal affairs and obtaining consent from the individual could hinder the performance of such affairs.
(4) When otherwise permitted by law.

2. Personal information contained in information obtained by the Company from public data such as commercial registration, real estate registration, public notices, and tax offices will be provided to third parties as follows based on Article 27, Section 2 of the Personal Information Protection Act. If an individual requests the cessation of providing their identifiable personal data to third parties, such provision will be halted. If opting out of providing personal data to third parties is desired, please contact "Article 15 (Contact for Inquiries)."

(1) Purpose of use: Purpose outlined in Article 2, Section 2
(2) Items of personal data to be provided to third parties:

A. Matters related to (1) real estate, standing timber, factory foundations, ships, or construction machinery listed in the following registrations, (2) the name, address of the registrant, rights holder, obligor, property owner, beneficiary, security rights holder, delegator, and trust administrator, (3) the name of the registration officer
① Real estate registration (including common collateral catalog and trust catalog), maps, building location diagrams, land location diagrams, area measurement diagrams, building blueprints, and floor plans of each floor, servitude diagrams (Real Estate Registration Act)
② Timber registration (Law relating to standing timber)
③ Factory foundation registration (Factory Mortgage Act)
④ Ship registration (Ship Registration Order)
⑤ Construction machinery registration (Construction Machinery Registration Order)

B. Matters related to (1) companies or corporations listed in the following registries, (2) addresses and names of representatives, officers, auditors, merchants, managers, employees, directors, advisors, and agents, (3) the name of the registration officer
① Commercial registration (Commercial Registration Act)
② Registration related to corporations (excluding (1)) or associations for the purpose of publicizing items that must be registered by law

C. Matters related to (1) transferred movable property or claims listed in the following registrations, (2) names and addresses of the registrant, transferor, transferee, original claim holder, and debtor, (3) the name of the registration officer
① Movable property transfer registration (Law regarding special rules concerning the requirement for counterclaims on the transfer of movable property and claims)
② Claims transfer registration (Law regarding special rules concerning the requirement for counterclaims on the transfer of movable property and claims)

(3) Methods of provision: Cloud services, sending via email, providing electronic records, communication by phone, and providing in printed materials

Article 5 (Entrustment of Handling of Personal Information)

The Company may entrust all or part of the handling of personal information within the scope necessary to achieve the purpose of use. In this case, the Company will adequately examine the eligibility of the entrusted party and will establish matters related to confidentiality obligations in the contract, conducting necessary and appropriate supervision of the entrusted party.

Article 6 (Disclosure of Personal Information)

Individuals can request the disclosure of their personal information held by the Company according to the procedures stipulated in Article 9. When the Company receives such a request from an individual, it will disclose the information without delay. However, in cases where disclosure could fall under any of the following categories, the Company may decide not to disclose all or part of the information and will notify the individual of such decision without delay.

(1) When there is a risk of harming the life, body, property, or other rights and interests of the individual or a third party
(2) When there is a risk of significantly hindering the proper implementation of the Company’s business
(3) When there is a risk of violating other laws

Article 7 (Correction, etc. of Retained Personal Data)

1. When an individual’s information held by the Company is incorrect, they may request the correction, addition, or deletion (hereinafter referred to as "correction, etc.") of their personal information following the procedures stipulated in Article 9.

2. Upon receiving such a request, the Company will conduct the necessary investigation without delay and if it determines that there is a valid reason for the request, it will promptly carry out the correction, etc.

3. If the Company makes a decision regarding the implementation or non-implementation of the correction, etc., it will contact the individual without delay.

Article 8 (Suspension, etc. of Use of Personal Information)

1. Individuals may request that the Company suspend, delete, or stop providing their retained personal data to third parties (hereinafter referred to as "suspension, etc.") following the procedures stipulated in Article 9.

2. Upon receiving a request for the previous item, the Company will conduct the necessary investigation without delay, and if it determines that there is a valid reason for the request, it will proceed with the suspension, etc. However, if there are substantial costs associated with the suspension of personal information or it is otherwise difficult to implement the suspension, the Company will take alternative measures necessary to protect the rights and interests of the individual.

3. If the Company makes a decision regarding the implementation or non-implementation of the suspension, etc., it will contact the individual without delay.

Article 9 (Procedures for Disclosure, etc. of Personal Information)

When a person wishes to make requests stipulated in Articles 6 to 8, they should send the identity verification documents stipulated in (1) below along with their request to the address specified in (2). Please note that a fee of 1,000 yen will be charged for each request for the disclosure of personal information.

(1) Identity verification documents
① A copy of the individual’s driver's license, passport, or health insurance card (any one of these)
② (If the request is made by an agent) A copy of the agent’s driver’s license, passport, or health insurance card (any one of these)
③ (If the request is made by an agent) A letter of proxy proving that the agent is acting on behalf of the individual.

(2) Address
113-0023 Bunkyo-ku, Tokyo, Mukogawa 2-3-10, 3rd Floor, TODAI-MAE HiRAKU GATE
Personal Information Department, Penetrator Co., Ltd.

Article 10 (Procedures for Changing the Privacy Policy)

The Company will review the contents of this Policy as necessary and strive for improvement. The contents of this Policy may be changed unless otherwise stipulated by law or otherwise stated in this Policy. The revised privacy policy will take effect upon notification to users or publication on the Company’s website in the method specified by the Company.

Article 11 (Compliance with Laws and Regulations)

The Company will comply with applicable Japanese laws and other regulations regarding the personal information it holds.

Article 12 (Response to Complaints and Consultations)

The Company will accept complaints and consultations from users regarding the handling of personal information and will respond appropriately and promptly. The Company will also respond swiftly and appropriately to requests from users regarding the disclosure, correction, addition, deletion, suspension, or refusal of personal information.

Article 13 (Security Management Measures)

The personal information entrusted to the Company will be safeguarded by implementing organizational, physical, human, and technical measures such as access restrictions to personal information files, recording access logs, and taking security measures to prevent unauthorized access from external sources. In the event of a personal information breach, the Company will promptly report to the supervisory authorities in accordance with the Personal Information Protection Act and relevant guidelines, and will take necessary measures to prevent similar incidents and to prevent recurrence in accordance with the instructions of the supervisory authorities. For details, please refer to the attached "Measures for the Security Management of Personal Information."

Article 14 (Company Address, Name of Representative, and Personal Information Protection Manager)

The address of the Company, the name of the representative, and the personal information protection manager are as follows.
Address: 2-3-10 Mukogawa, Bunkyo-ku, Tokyo, 3rd Floor, TODAI-MAE HiRAKU GATE
Representative / Personal Information Protection Manager: Takeo Akutsu

Article 15 (Contact for Inquiries)

For inquiries regarding the handling of personal information by the Company, please contact as follows.
113-0023 Bunkyo-ku, Tokyo, Mukogawa 2-3-10, 3rd Floor, TODAI-MAE HiRAKU GATE
Personal Information Department, WHERE Inc.
TEL: 03-6826-0460
Mail: info@pntwhere.com

Established and enacted on October 30, 2023