Privacy Policy

addoptions, Inc.
Representative Director: Yiqun Gong
Effective Date: August 1, 2026

addoptions, Inc. (hereinafter, the “Company”), in conducting its real estate leasing management business and related businesses, deeply recognizes the importance of personal information and, in order to thoroughly protect such information, complies with the Act on the Protection of Personal Information (hereinafter, the “APPI”) and other applicable laws, regulations, and guidelines. The Company handles personal information in an appropriate and transparent manner and establishes and maintains this Privacy Policy (the “Policy”) so that customers may use the Company’s services with confidence, as set forth below.　

Article 1 – Privacy Policy (Basic Principles)

The Company handles personal information appropriately in accordance with the following eight principles.
・Principle of lawful acquisition: The Company shall acquire personal information by lawful and fair means and shall not acquire it by deception or other wrongful means.
・Principle of purpose specification: The Company shall specify and clarify, to the extent possible, the purposes for which personal information is handled.
・Principle of use limitation: Except as permitted by law, the Company shall not handle personal information beyond the scope necessary to achieve the specified purposes of use without first obtaining the consent of the individual concerned.
・Principle of data quality: The Company shall endeavor to keep personal data accurate and up to date within the scope necessary to achieve the purposes of use.
・Principle of security safeguards: The Company shall take necessary and appropriate measures for the security management of personal data, including prevention of leakage, loss, or damage.
・Principle of openness: The Company shall place the purposes of use of personal information, and related matters, in a state where they can be known to the individual concerned (including publication of this Policy).
・Principle of individual participation: The Company shall respond without delay and appropriately to requests from individuals for disclosure, correction, suspension of use, and other actions regarding their personal information.
・Principle of accountability: The Company shall establish a system to respond appropriately and promptly to complaints and inquiries regarding the handling of personal information.

Article 2 – Acquisition of Personal Information

1. To the extent necessary for conducting its real estate leasing management business, the Company handles, as personal information, information such as name, date of birth, and other descriptions by which a specific individual can be identified, or information that can be readily cross-referenced with other information to identify a specific individual, including the following:
・Name, gender, date of birth, address, telephone number, fax number, and email address
・Workplace information (employer name, address, telephone number, department, job title, annual income, etc.)
・Family composition, information on cohabitants, emergency contact information, and information on joint guarantors
・Bank account information, insurance enrollment status, information stated in identity verification documents, property information, and other information necessary for contract procedures and management operations

2. The Company acquires personal information through tenancy application forms, lease agreements, joint guarantor consent forms, property management entrustment agreements, website inquiry forms, telephone, email, and other appropriate means, and shall clarify the purpose of use to the extent possible at the time of acquisition.

3. Except as permitted by the APPI or other applicable laws, the Company shall, after obtaining the clear consent of the individual concerned in advance, acquire Special Care-Required Personal Information (meaning information concerning race, creed, social status, medical history, criminal record, the fact of having suffered damage from a crime, and other information requiring special consideration so as not to cause unfair discrimination, prejudice, or other disadvantages to the individual) only to the extent genuinely necessary for the performance of its business.

4. When acquiring Special Care-Required Personal Information, the Company carefully considers the necessity thereof and clarifies the purpose of use more thoroughly than for ordinary personal information. The Company also limits the employees and subcontractors who may access such information to the minimum necessary, carefully determines on a case-by-case basis whether provision to third parties is required, and endeavors to promptly delete or erase such information once it is no longer needed, except where retention is required by law.

5. In handling Special Care-Required Personal Information in connection with tenant screening, contract management, and other operations, the Company shall establish handling procedures, verification processes, and internal management systems so as not to unfairly infringe upon the rights and interests of the individual concerned or lead to discriminatory treatment or inappropriate judgments.

Article 3 – Purposes of Use of Personal Information

The Company uses acquired personal information for the following purposes:

・To respond to inquiries and consultations regarding managed properties (apartments, condominiums, parking spaces, etc.)
・To respond to tenancy applications, conduct tenant screening and credit assessments (including inquiries to credit information agencies), verify identity, and notify results
・To execute, perform, and manage lease agreements, joint guarantee agreements, property management entrustment agreements, and other contracts
・To make introductions, applications, and provide information to rent guarantee companies, small-amount short-term insurance companies, fire insurance companies, and other related business operators
・To bill and collect rent and common area fees, settle security deposits, and otherwise manage receipts and payments
・To maintain, repair, clean, inspect, and replace locks for buildings and facilities, and to perform other management operations
・To receive reports of equipment malfunctions from tenants or other contracting parties, and to provide after-sales service, repairs, and inspections
・To carry out lease renewal procedures, cancellation procedures, move-out inspections, and restoration work
・To manage contract information, prepare transaction ledgers, and send and communicate various documents
・To respond to inquiries, consultations, and complaints from customers, verify identity, and retain records of such responses
・To provide various notices, administrative communications, emergency contact, and other guidance necessary for business operations
・For marketing activities related to the Company’s business (market research, data analysis, surveys, etc.)
・To improve the Company’s products and services, and to develop new products and services
・To provide information (direct mail, newsletters, etc.) regarding products, services, events, and campaigns of the Company and its business partners
・To manage and operate membership organizations operated by the Company and to provide services to members

Article 4 – Provision to Subcontractors

1. To the extent necessary to achieve the purposes of use, the Company may entrust all or part of the handling of personal information to third parties (for example, data processing companies, building management companies, cleaning companies, construction companies, and call centers).

2. When entrusting the handling of personal information, the Company shall select subcontractors that satisfy an adequate level of protection of personal information and shall exercise necessary and appropriate supervision over such subcontractors, including by entering into confidentiality agreements.

Article 5 – Provision of Personal Data to Third Parties

Except as required by law, the Company shall not provide personal data to third parties without first obtaining the consent of the individual concerned. However, the Company may provide personal data to third parties within the scope necessary to achieve the purposes of use in the following cases:

・Provision to the owner of the subject real estate (landlord/owner), management association, management company, and others (for contract reporting, management reporting, and performance of management operations)
・Provision to joint guarantors and emergency contacts for the purpose of communication
・Provision to rent guarantee companies, small-amount short-term insurance companies, fire insurance companies, and other related business operators for screening applications, contract procedures, and incident response
・Provision to credit information agencies for tenant screening, credit management, and credit inquiries
・Provision to financial institutions, payment collection agents, and others involved in direct debit and remittance settlement of rent
・Provision to suppliers of electricity, gas, water, internet, and other utilities for move-in/move-out notifications and related purposes
・Provision to contractors engaged for building repair, cleaning, inspection, lock replacement, and other work, to the extent necessary for the performance of such work
・Provision to debt collection agencies or attorneys in the event of rent arrears
・Provision to attorneys, judicial scriveners, and other professionals as necessary for dispute resolution, consultation, or legal compliance
・Where necessary for the protection of a person’s life, body, or property, and it is difficult to obtain the consent of the individual concerned
・Where particularly necessary for improving public health or promoting the sound growth of children, and it is difficult to obtain the consent of the individual concerned
・Where it is necessary to cooperate with a national or local government agency, or a party entrusted by such agency, in executing affairs prescribed by law

Article 6 – Provision to Third Parties Located Overseas

The Company may, to the extent necessary for its business operations, use cloud services or other external services provided by third parties located overseas, and may thereby provide personal data to, or have such data handled by, third parties located in foreign countries. In such cases, the Company shall obtain the consent of the individual concerned and take other necessary measures in accordance with the APPI and other applicable laws.

When making such a provision, the Company shall disclose or provide to the individual concerned — by posting on the Company’s website or other appropriate means — the name of the destination country or region, information regarding the personal information protection system of that country or region, the protective measures taken by the recipient, and any other matters required by law to be placed in a state where the individual concerned may become aware of them.

The Company shall endeavor to ensure the appropriate protection of personal data through means such as entering into contracts with recipients, confirming appropriate security management measures, and continuously monitoring the status of operations.

Article 7 – Joint Use
The Company does not currently engage in the joint use of acquired personal data.

Should the Company begin joint use in the future, it shall, in accordance with the APPI and other applicable laws, publish in advance on the Company’s website or otherwise place in a state where the individual concerned may become aware of them, the items of personal data to be jointly used, the scope of joint users, the purposes of use, and the party responsible for management, among other matters, and shall implement such joint use appropriately.

Article 8 – Handling of My Number (Individual Number) and Specific Personal Information

The Company handles My Number (Individual Number) and Specific Personal Information (hereinafter collectively, “Specific Personal Information, etc.”) appropriately in accordance with the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures and other related laws.

The Company acquires My Number (Individual Number) only within the scope of purposes permitted by law, such as the preparation and submission of payment records for landlords and other payees, and shall not use it for any other purpose except as permitted by law.

The Company applies security management measures to Specific Personal Information, etc. that are stricter than those applied to ordinary personal information, and shall not provide such information to third parties except as permitted by law. Once retention is no longer necessary, the Company shall promptly dispose of or delete such information, except where retention is required by law.

Article 9 – Security Management Measures

The Company endeavors to ensure the accuracy and currency of the personal data it handles and, once personal information is no longer needed to achieve its purpose of use, shall delete or erase it by appropriate means, except where retention is required by law. In addition, the Company takes the following measures for the security management of personal data, including prevention of leakage, loss, or damage:

With respect to Special Care-Required Personal Information in particular, the Company treats such information as subject to stricter management than ordinary personal information, and takes additional protective measures as necessary, including limiting access authority, strengthening the management of storage locations and media, ensuring security during transmission or storage, reviewing access logs, and strengthening supervision of subcontractors.

・Organizational security management measures: Appointment of a Personal Information Protection Manager, establishment of internal rules, and periodic inspection and audit of the handling of personal information, among other measures
・Human security management measures: Regular training and education for employees, awareness-raising regarding the handling of Special Care-Required Personal Information, and inclusion of confidentiality obligations in work rules, among other measures
・Physical security management measures: Access control for areas where personal information is handled, measures to prevent theft or loss, physical protection of devices and media, and irrecoverable disposal methods, among other measures
・Technical security management measures: Access control limiting the personnel and scope of personal information databases handled, authority management and review of access logs for data containing Special Care-Required Personal Information, and security measures against unauthorized external access (such as firewalls and antivirus software), among other measures

Article 10 – Procedures for Disclosure, Correction, and Suspension of Use of Personal Information

Upon receiving any of the following requests, the Company shall, after confirming that the requester is the individual concerned or a duly authorized representative, respond in accordance with the prescribed method as set out below. The Company may charge a fee separately determined by the Company for notification of the purpose of use or disclosure of retained personal data or records of provision to third parties. For specific procedures and fees, please contact the inquiry desk set out in Article 14.

(1) Notification of the purpose of use, or disclosure of retained personal data or records of provision to third parties
An individual may request the Company to notify the purpose of use of personal information, or to disclose retained personal data or records of provision to third parties, to the extent permitted under the APPI. However, the Company may decline to disclose such information where grounds for non-disclosure under applicable law exist.

(2) Correction, addition, or deletion
Where the content of a customer’s personal information managed by the Company is factually incorrect, or where other grounds set out in the APPI apply, the individual concerned may request the correction, addition, or deletion of such personal information. The Company shall, after conducting the necessary investigation without delay, correct, add to, or delete the personal information in accordance with applicable law where it determines that the request is justified.

(3) Suspension of use, erasure, or suspension of provision to third parties
Where personal information is being handled beyond the scope of the purpose of use without a legally permitted reason and without the consent of the individual concerned, or where other grounds set out in the APPI apply, the individual concerned may request the suspension of use, erasure, or suspension of provision to third parties of such personal information. The Company shall, after conducting the necessary investigation without delay, respond in accordance with applicable law where it determines that the request is justified.

(4) Identity verification and verification of representatives
When making a request for disclosure or other action, the Company will verify the identity of the individual concerned by requiring submission of identity verification documents. Where the request is made by a representative, the Company may request submission of a power of attorney or other document evidencing the authority of the representative, together with identity verification documents for the representative.

Article 11 – Deletion and Erasure of Personal Information

After the conclusion of a transaction (contract termination, move-out, final settlement, etc.) or after the purpose of use has been achieved, and once the retention period prescribed by applicable law has elapsed, the Company shall, under its own responsibility, safely and completely delete or erase the relevant personal information.

Article 12 – Cookies and Access Analysis

1. The Company may use cookies, web beacons, and other similar technologies (collectively, “Cookies, etc.”) to improve the convenience of the Company’s website, understand browsing conditions, improve services, optimize content, and prevent unauthorized use, among other purposes.

2. Information collected through Cookies, etc. may include pages viewed, date and time of viewing, usage environment, device information, browser information, IP address, referrer information, and other information regarding the use of the Company’s website. While such information alone may not identify a specific individual, it may be treated as personal information when combined with other information held by the Company.

3. The Company may use access analysis tools provided by third parties to analyze the usage of the Company’s website. In such cases, the relevant third party may collect, record, and analyze information through Cookies, etc., and the handling of such information shall be governed by the terms of use or privacy policy established by each service provider.

4. Customers may refuse to accept Cookies, etc., or delete Cookies, etc. already stored, by changing their browser settings. However, doing so may result in some functions of the Company’s website or services becoming unavailable.

Article 13 – Continuous Improvement
The Company shall continuously review and improve this Policy and its internal systems in response to changes in social conditions and amendments to applicable laws regarding the handling of personal information. Where the Company revises all or part of this Policy, it shall post the revised content on the Company’s website or otherwise, and the revised Policy shall apply from the time of such posting, except where otherwise provided by law.

Article 14 – Inquiry Desk

For inquiries regarding the Company’s handling of personal information, or requests for disclosure, correction, or suspension of use, please contact the desk below.

Personal Information Inquiry Desk
Address: BI Building 6F, 3-1-16 Akasaka, Minato-ku, Tokyo 107-0052, Japan
Company Name: addoptions, Inc. – Personal Information Protection Officer
Email: info@addoptions.jp