Privacy Policy

FDM Inc. (hereinafter referred to as “the Company”) recognizes the importance of personal information and has established this Privacy Policy to ensure its thorough protection. The Company declares that it will comply with this Privacy Policy and handle all personal information—including that of our customers—in a safe and appropriate manner.

Compliance with Laws and Guidelines

FDM Inc. (hereinafter referred to as “the Company”) complies with the Act on the Protection of Personal Information of Japan (“APPI”), related governmental guidelines, the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (“My Number Act”), and all other applicable laws and regulations relevant to the Company’s operations.

Acquisition of Personal Information

When acquiring personal information, the Company clarifies the purpose of use and obtains such information through lawful and fair means, including written forms or verbal communication.
Furthermore, when using, providing, or disclosing personal information entrusted to us by customers, the Company conducts such activities appropriately, taking into consideration the nature and scale of our business.

Use of Personal Information

1. Except where permitted by law or where the customer has provided prior consent, the Company uses personal information only within the scope of the purposes of use presented to the customer at the time of acquisition or publicly disclosed in advance. For details on our purposes of use, please refer to Section 4 below.
2. The Company may change the purposes of use only when the revised purposes are reasonably recognized as being related to the purposes before the change. When the purposes of use are changed, the Company will notify customers or publicly announce the revised purposes, such as on the Company’s website.

Purposes of Use of Personal Information

1. The Company uses personal information acquired in the course of its business solely within the following purposes. The Company may outsource part of its operations to third-party service providers to ensure smooth business processes, and may provide personal information to such contractors within the necessary scope. In such cases, the Company supervises the contractors appropriately, as described in Section 7 below.
   1. To perform contracts and provide information and services related to real estate brokerage, leasing, management, and appraisal businesses
   2. To perform contracts and provide information and services related to Type II Financial Instruments Business and Investment Advisory/Agency Services under the Financial Instruments and Exchange Act
   3. To perform contracts and provide information and services related to real estate construction, design, and construction supervision
   4. To conduct any other businesses incidental or related to the above items
2. Notwithstanding the preceding paragraph, the Company uses “Specific Personal Information,” including Individual Numbers defined under the My Number Act, only within the scope necessary to achieve the following purposes:
   1. Preparation of statutory documents requiring the inclusion of Individual Numbers under applicable laws
   2. Administrative procedures related to withholding tax, social insurance, labor insurance, corporate pension programs, and other filings or applications

Provision of Personal Information to Third Parties

1. Except where permitted by law, the Company does not disclose or provide personal information to third parties other than contractors without the customer’s prior consent. However, personal information may be disclosed without consent when required by law, or when a court, police authority, or other public agency formally requests disclosure.
2. When a customer uses services provided by the Company, the Company may, with the customer’s prior consent, disclose personal information to other customers as necessary for the use of such services. Recipients of disclosed information may use such information only within the purposes expressly stated in the relevant service terms.
3. When providing personal information to a third party located outside Japan, the Company obtains the customer’s prior consent unless such provision is permitted as an exception under applicable laws.

Shared Use of Personal Data

1. The Company may share personal data held by the Company within the following scope when necessary:
   1. Parties with whom data may be shared
      The FDM Group, including FDM Inc., FDM Asset Inc., and FDM Eat Inc.
   2. Purposes of shared use
      For surveys, analysis, information collection, notifications, provision of information, and various communications necessary for the operations conducted by the FDM Group
   3. Items of personal data subject to shared use
      Name, address, email address, date of birth, telephone number, transaction details, transaction history, and other information necessary for the above purposes
   4. Party responsible for managing shared personal data
      FDM Inc.

Management of Personal Information

1. The Company implements necessary and appropriate security measures (“Security Control Measures”) to prevent leakage, loss, or damage of personal data, including access control, restrictions on means of taking personal information off premises, and measures to prevent unauthorized external access.
2. The Company may outsource all or part of its personal data handling operations to third parties. In such cases, the Company selects contractors that are deemed capable of appropriately handling personal data, stipulates matters related to security measures, confidentiality, conditions for subcontracting, return of personal data upon contract termination, and other handling requirements in written agreements, and appropriately supervises such contractors.
3. The main components of our Security Control Measures are as follows:
   1. (Formulation of Basic Policy)
      The Company has established this basic policy to ensure the proper handling of personal data, including compliance with relevant laws and guidelines and the establishment of contact points for inquiries and complaints.
   2. (Development of Rules for Handling Personal Data)
      The Company has established internal rules that define the fundamental procedures for the acquisition, use, storage, and other handling of personal data.
   3. (Organizational Security Measures)
      The Company maintains a reporting and communication framework in which employees report to the designated personnel responsible for managing personal data.
   4. (Human Security Measures)
      The Company provides regular training to employees regarding precautions and best practices related to the handling of personal data.
   5. (Physical Security Measures)
      The Company implements measures to ensure that personal data cannot be easily viewed or accessed by anyone other than authorized employees and the data subject.
   6. (Technical Security Measures)
      The Company identifies and manages the devices and employees authorized to handle personal data in order to prevent unnecessary access. The Company also implements systems to protect such devices against unauthorized external access and malicious software.
4. For inquiries regarding details of our Security Control Measures, including those related to external environments, please contact the office listed below.

Procedures for Disclosure, Correction, Suspension of Use, etc.

1. Requests for disclosure, correction, suspension of use, or other actions regarding retained personal data should be submitted to the contact point listed below. Upon confirming the identity of the requester, the Company will respond appropriately and promptly in accordance with applicable laws. Depending on the method of response, the requester may be required to pay fees specified by the Company in advance. Complaints regarding the handling of personal information are also accepted at the same contact point.

Review and Improvement of This Privacy Policy

The Company reviews and improves this Privacy Policy from time to time. The Policy may also be revised due to amendments to laws or other necessary reasons. In the event of revisions, the updated Privacy Policy will be promptly published on the Company’s website.

Last Revised: April 1, 2022