[Establishment, revision]

LIFULL Group Privacy Policy
Established March 25, 2005; revised October 1, 2017
[This English version is provided solely for the reference purpose. If there is any discrepancy between Japanese version and English version, Japanese version will take precedence and be applied.]

Scope of Application

This Policy sets forth rules on the handling of personal information and Action History Information (as defined below) concerning our customers (including general users of the Services [“Users”] and those engaged in business with the LIFULL Group) obtained by the LIFULL Group (as defined below) in or in connection with the services it operates (“Services”). Where a separate privacy policy has been established or an individual agreement (“Individual Agreement”) has been made, such separate policy or Individual Agreement shall take precedence and be applied.

Compliance with Laws and Regulations

The LIFULL Group recognizes the importance of personal information. To ensure the protection of personal information, the LIFULL Group will comply with all laws concerning the protection of personal information, guidelines related to such laws, and other applicable laws and regulations. Terms defined in such laws and regulations have the same meanings when used in this Policy.

Definition of Terms

  • (1)Action History Information

    As used in this Policy, the term “Action History Information” refers to information that, through its accumulation, enables us to analyze customer interests and preferences and lacks the specificity needed to identify particular individuals. Examples of such information include a history of services used and advertisements viewed by a customer; a history of a customer’s operations within a site; and a customer’s IP address, location information, and unique terminal identifier.

  • (2)LIFULL Group

    As used in this Policy, the term “LIFULL Group” refers to LIFULL Co., Ltd., and its Japanese subsidiaries (other than LIFULL FinTech Co., Ltd.).

Collection of Personal Information

The LIFULL Group will obtain the following types of personal information concerning customers. Please note that the list below is not exhaustive and does not indicate all types of information the LIFULL Group will collect. This information may include items that could not be regarded as personal information because no particular individual can be identified on the basis of such information.

  • (1)Personal information concerning Users

    • A User’s name, address, telephone number, facsimile number, email address, place of employment and other contact information, day and year of birth, sex, and the like
    • Information on a User’s use history of Services linked to information identifying individual Users
    • IP address used when a User’s computer is connected to the Internet, information about mobile device identification, and other information automatically obtained when a User accesses a server managed by the LIFULL Group
  • (2)Personal information concerning business partners

    • Information on officers and employees of a business partner, such as names, telephone numbers, facsimile numbers, email addresses, sections and positions, and transaction history records
    • IP address used when a business partner’s computer is connected to the Internet and other information automatically obtained when a business partner accesses a server managed by the LIFULL Group

Handling of Personal Information

The LIFULL Group will use personal information concerning customers within the scope of purposes described below (“Purposes of Use”).

  • (1)Purposes of Use

    • To authenticate personal identification at and after login and automatically display membership information on various screens when a customer uses services as a registered service member of the LIFULL Group
    • To forward a customer’s application to an advertising corporation, organization, or other source of information
    • To furnish information and send questionnaires concerning the Services by email (including email newsletters), regular mail, telephone, short message services (SMS), applications, and the like
    • To receive applications for campaigns offered by the LIFULL Group, notify prize winners, and send gifts and gratuities
    • To perform analysis, sampling, and the like in order to enhance the quality of services and advertisements offered by the LIFULL Group
    • To personalize advertisements placed in conjunction with content viewed by a customer based on the customer’s sex, age, place of residence, hobbies, tastes, and other individual attributes; a history of the customer’s visits to websites operated by the LIFULL Group; a history of the customer’s use of services offered by the LIFULL Group; and the like
    • To furnish advertisements, PR, and other information the LIFULL Group deems useful to a customer
    • To respond to inquiries from a customer in person
    • For use as statistical data in forms that do not enable identification of an individual
    • To furnish advertisements, PR, and other information concerning the services of the LIFULL Group
    • In addition to the purposes set forth in a to j above, for use in providing services to a customer and other appropriate business actions
    • To perform services subcontracted by a third party
    • To provide services to a third party who subcontracts such services to the LIFULL Group in accordance with the provision of (2).g below, but only to the extent necessary to render such services
  • (2)Provision to third parties

    The LIFULL Group may provide personal information to third parties only in the following cases:

    • The customer has accepted an individual privacy policy and has expressly permitted the provision of his or her personal information to the third party;
    • Such provision is required by laws or regulations;
    • Such provision is necessary to protect the life, health, or property of the customer or another customer (including its employees) under circumstances in which obtaining the customer’s consent is difficult;
    • Such provision is essential to improve public health or promote healthy development of children under circumstances in which obtaining the customer’s consent is difficult;
    • The acquisition of the customer’s consent would be detrimental to the execution of administrative procedures provided for in laws by a national government agency, local government, or contractor thereof when the LIFULL Group is required to cooperate for such execution;
    • Data containing personal information is disclosed or provided after processed into a form that does not enable identification of an individual; or
    • The LIFULL Group undertakes services subcontracted by a third party who provides the LIFULL Group with personal information for that purpose; in this case, however,
      • (1)The items of personal data provided to the third party are limited to information related to the customer’s action history, such as website visits and search results;
      • (2)The methods of provision to the third party are limited to electronic mail and other electronic means; and
      • (3)At the customer’s request, we will stop providing personal information on the basis of which the customer can be identified to the third party.

    In cases in which the LIFULL Group provides a third party with customers’ personal information under any of the subparagraphs a through g above, the personal information is placed under the control of such third party upon such provision. Both the LIFULL Group and the third party shall handle customers’ personal information in compliance with their respective privacy policies; neither is responsible for the other party’s handling of personal information.

  • (3)Sharing

    The LIFULL Group shares customers’ personal information to the extent necessary for the Purposes of Use, as set forth below:

    • The personal information shared is the same as that described in the “Collection of Personal Information” section above.
    • The information is shared by LIFULL Co., Ltd., and the companies listed on the following page:
      https://LIFULL.com/company/group/
    • The purposes of sharing this information are identical to the Purposes of Use set forth above, provided that “LIFULL Group” in the “Purposes of Use” statements shall be deemed replaced by “each joint user.”
    • Responsibility for information sharing rests with LIFULL Co., Ltd.
  • (4)Subcontracting to a third party

    The LIFULL Group may subcontract the handling of personal information in whole or in part to third parties.

  • (5)Point of contact for inquiries about the handling of personal information

    If you have any inquiries concerning our management of personal information or notifications of Purposes of Use, disclosure, correction, deletion, suspension of use, or discontinuation of provision to third parties, please contact the section indicated below.

    Point of contact for inquiries about personal information at
    LIFULL Co., Ltd.
    1-4-4, Kojimachi, Chiyoda-ku, Tokyo 102-0083, Japan

Sensitive Personal Information

The LIFULL Group will not seek to obtain or provide to third parties sensitive personal information unless required by laws or the customer’s consent has been obtained.

Action History Information

The LIFULL Group will obtain and use Action History Information within the scope of the specified Purposes of Use. The Action History Information itself does not enable identification of an individual; however, if it can be readily collated with other pieces of information to identify a particular individual, it will be treated as personal information. Please see the following page for more information on Action History Information, including Purposes of Use and the opt-out rule:

Acquisition and Use of Action History Information

Revision

The LIFULL Group may revise this Policy at any time.

LIFULL Websites with Separate Privacy Policies

Please see the following page for the privacy policy for our recruitment activities:

Privacy Policy for Recruitment Activities