Nomura Real Estate Holdings, Inc. (hereinafter referred to as the “Company”) shall position the proper protection of personal information as a priority for business operations, shall observe the Act on the Protection of Personal Information (Act 57 of 2003, hereinafter “Personal Information Protection Act”) and related laws and regulations, and shall carefully manage the personal information of its customers.

1. 1. Business Operator Name, Address, and Representative
   
   Name: Nomura Real Estate Holdings, Inc.
   Address: Shinjuku Nomura Building, 1-26-2 Nishi-Shinjuku, Shinjuku-ku, Tokyo
   Representative: Satoshi Arai
2. 2. Definitions
   ・The terms used in this Personal Information Protection Policy shall be based on the Personal Information Protection Act. Moreover, in this Personal Information Protection Policy, “Personal Information, etc.” shall refer to “personal information” and “personal data” as stipulated in the Personal Information Protection Act.
   ・In this Personal Information Protection Policy, “Customers” shall refer to people who have had contracts and transactions with the Company in the past up to now, and shall include people could potentially have contracts and transactions with the Company in the future. If the said person is a corporate body, it shall include the representative and person in charge from the said corporate body.
   ・In this Personal Information Protection Policy, “Nomura Real Estate Group” shall refer to the corporate group consisting of Nomura Real Estate Holdings Group companies, subsidiaries, and affiliated companies that are listed in the financial statements of the Nomura Real Estate Holdings, Inc. (hereinafter referred to as “Nomura Real Estate Group companies”).
3. 3. Compliance with Related Laws, Regulations, and Guidelines
   The Company shall comply with the Personal Information Protection Act and related laws and regulations as well as guidelines (hereinafter referred to as “laws and regulations, etc.”).
4. 4. Acquisition, etc., of Personal Information, etc.
   The Company shall carefully obtain personal information, etc., according to laws and regulations, etc., maintain accurate and updated contents, and shall endeavor to delete personal information, etc., without delay when it is no longer needed.
5. 5. Use, etc., of Personal Information, etc.
   The Company shall use personal information, etc., properly and shall not use it beyond the necessary scope for achieving the usage purpose.
6. 6. Provision to Third Parties
   The Company shall not provide personal information, etc., to a third party without the consent of customers except when pursuant to laws and regulations, etc.
7. 7. Supervision of Consigned Parties
   If the handling of personal information, etc., is consigned in whole or part to a third party, the Company shall properly supervise the consigned parties as needed to ensure that personal information, etc., is securely managed.
8. 8. Shared Usage of Personal Information, etc.
   The Company may use personal information, etc., by sharing it with companies that belong to the Nomura Real Estate Group in harmony with laws and regulations, etc., in order to provide comprehensive services as the Nomura Real Estate Group.
9. 9. Measures for Secure Management of Personal Information, etc.
   The Company shall implement necessary and appropriate measures for the secure management indicated below in order to prevent the leakage, loss, damage, and unauthorized usage of personal information, etc. according to the phase including acquisition, use, and storage.
   1. (Basic policy formulation)
      ・This Personal Information Protection Policy has been formulated for the purpose of ensuring proper handling of personal information, etc., and for notifying the information desk that receives questions and complaints from customers.
   2. (Establishment of rules related to the handling of personal information, etc.)
      ・Internal rules such as “Information Security Rules” on the handling method, and a manager / person in charge and their duties have been established according to the phase including the acquisition, use, storage, provision, and deletion/disposal
   3. (Measures for ensuring secure management as an organization)
      ・A manager for personal information, etc. (chief officer in charge of information security) has been appointed, officers and employees who handle personal information, etc., and the scope handled by relevant officers and employees have been clarified, and a system for allowing the manager to recognize violations of laws and regulations, etc., and internal regulations and rules as well as related indicators (hereinafter referred to as “Internal Rules, etc.”) have been established.
   4. (Human resource measures for ensuring secure management)
      ・Training is regularly provided on important points related to the handling of personal information, etc.
   5. (Physical measures for ensuring secure management)
      ・In areas where personal information, etc., is handled, access management of employees has been implemented by installing an access management system.
      ・Documents containing personal information, etc., are stored in lockable cabinets, vaults, etc., for preventing theft, loss, etc.
   6. (Technical measures for ensuring secure management)
      ・Proper access management has been implemented to limit handlers and the scope of the personal information database, etc.
      ・Systems have been implemented for protecting the information systems that handle personal information, etc., from unauthorized access or from unauthorized software from outside.
   7. (Understanding of the external environment)
      ・In the following countries where personal information, etc., is stored, measures for secure management have been implemented based on an understanding of systems related to the protection of personal information, etc
      
      People’s Republic of China, Republic of Singapore, Kingdom of Thailand, Hong Kong, Socialist Republic of Viet Nam, Republic of the Philippines, United Kingdom
      System related to the protection of personal information in the countries listed above: Please refer to here.
10. 10. Disclosure, Correction, Discontinued Usage, etc., of Personal Information, etc.
    At the request of the actual individual or their proxy, the Company shall disclose, correct, discontinue the use of, or take other action in accordance with laws and regulations, etc., and procedures established by the Company.
11. 11. Formulation and Implementation of Internal Rules, etc., on the Handling of Personal Information, etc.
    For implementing this Personal Information Protection Policy, the Company shall formulate internal rules, etc., on the handling of personal information, and shall thoroughly disseminate such rules to its officers, employees, and other related persons. Furthermore, the Company shall continuously maintain rules and make necessary improvements.
12. 12. Revisions to this Personal Information Protection Policy
    This Personal Information Protection Policy may be revised without prior notice when based on related laws and regulations, etc., or where the Company determines the need. The latest policy is posted on the Company website.
13. 13. Inquiries
    Please submit all questions, opinions, complaints, etc., concerning the Company’s handling of personal information via the Inquiries page.
    Purpose of Use of Personal Information, etc.

Purpose of Use of Personal Information, etc.

The Company shall use personal information, etc., for each business described in (1)[*1] according to the usage purposes stated in (2)[*2]. Moreover, if the Company notifies or clearly indicates to customers a usage purpose at the time the personal information, etc., is acquired that differs from the following contents, these shall be the usage purpose of personal information, etc., of Company in addition to the following purposes.

1. 1. Business
   (1) Residential Development Business
   ・Development and sales of condominiums and houses
   ・Housing with services for the elderly
   ・Development of rental properties
   ・Internet advertising services for housing
   ・Living assistance services
   
   (2) Commercial Real Estate Business
   ・Development, leasing, and management of office buildings, commercial facilities, logistics facilities, and hotels
   ・Development and sales of income real estate
   ・Fitness club management
   
   (3) Investment Management Business
   ・Asset management for the real estate securitization, including REITs and private placement funds
   
   (4) Property Brokerage & CRE Business
   ・Real estate brokerage & consulting
   ・Consignment sales of new condominiums and houses
   ・Insurance agency
   ・Management of real estate information website
   
   (5) Property & Facility Management Business
   ・Management of properties such as condominiums, office buildings, and educational facilities
   ・Renovation and repair work for tenants
   ・Remodeling of condominiums and housing
   ・Cleaning of condominiums and office buildings
   
   (6) Overseas Businesses
   ・Development projects including housing, rental properties, and mixed-use developments
   ・Brokerage and asset management for cross-border needs
   
   (7) Redevelopment & Rebuilding Businesses
   ・Participating in, promoting, and supporting urban development projects
   ・Reconstruction of housing complexes
   
   (8) Consideration and Implementation of New Business
   
   (9) Ancillary Businesses related to the Above Items
2. 2. Purpose
   (1) To engage in the following conduct in relation to contracts/transactions involving the Company
   （ⅰ）Preparations/negotiations for execution of contracts and carrying out of transactions
   （ⅱ）Execution/fulfillment of contracts and carrying out of transactions
   （ⅲ）Carrying out of various procedures before and after contracts/transactions
   （ⅳ）Delivery/communication of various introductions relating to contracts/transactions
   （ⅴ）Provision of various types of information and services relating to contracts/transactions
   （ⅵ）Various administrative processes relating to contracts/transactions
   
   (2) To engage in the following conduct whether by postal service, e-mail, telephone, door-to-door solicitation, or other method
   （ⅰ）Delivery of materials and provision of information
   （ⅱ）Introduction of and solicitation for products and services
   （ⅲ）Announcement of events
   （ⅳ）Collection of questionnaires
   （ⅴ）Other sales activities
   
   (3) To engage in activities such as analysis of customer/market trends, survey analysis for product development, etc., and preparation of statistical information
   
   (4) Operational management of customer membership organizations
   
   (5) To provide briefings to stakeholders (residents living near a development project, people with territorial rights, etc., and other customers who have direct/indirect interest in a project) and various introductions
   
   (6) To provide security, crime prevention, and safety management of facilities/buildings that are managed and operated by the Company and a company belonging to the Nomura Real Estate Group
   
   (7) To provide after-sales service and repair/inspection of defect areas to customers, etc., who have concluded a contract with the Company and a company belonging to the Nomura Real Estate Group
   
   (8) To provide personal information, etc., to third parties within the scope necessary for achieving the usage purposes mentioned previously (limited to cases where customer consent has been acquired or when pursuant to laws and regulations)
3. [*1] “Business” includes things performed by each company belonging to the Nomura Real Estate Group. For more details, see here.
   [*2]“Usage” includes cases where information related to persons[*3] acquired from the actual person or a third party (including group companies) is linked with personal information owned by the Company and used.
   [*3]The following shows examples of information related to persons acquired by the Company. (It shall not be limited to these.)
   （ⅰ）Cookies, Advertising Identifier [IDFA], Google Advertising Identifier [AA ID], etc.) and other identifier information
   （ⅱ）IP addresses
   （ⅲ）Attribute information (age, gender, etc.)

Purpose of Use of Shareholder Personal Information, etc.

Among our customers, the personal information, etc., of shareholders (name, address, etc.) shall be used for the following purposes. A “shareholder” shall refer to any shareholder and registered pledgee of shares or their legal representative who is an individual set forth or recorded in the shareholders registry.

1. 1. To engage in the following conduct at the Company.
   (1) Exercise of rights and fulfillment of duties under the Companies Act.
   (2) Provision of various benefits from the Company in regard to position as shareholder.
   (3) Implementation of various measures for maintaining good relations between shareholders and the Company.
   (4) Preparation of shareholder data in accordance with prescribed standards under laws and regulations, and other shareholder management.
2. 2. To provide personal information, etc., to third parties within the scope necessary to achieve the foregoing purposes of use. (Limited to cases where customer consent has been acquired or when pursuant to laws and regulations.)

The Company may share personal information, etc., acquired by the Company according to the provisions in laws and regulations, etc., as indicated below.

Ⅰ．Shared Use among Group Companies

1. 1. Items of Personal Data Subject to Shared Use
   Necessary personal information including name, address, date of birth, place of employment, telephone number, and e-mail address within the scope of fulfilling the usage purpose described in the above “Purpose of Use of Personal Information, etc.” as well as personal information, etc., acquired legally by the Company from publicly available information such as commercial registries, and real estate registries.
2. 2. Scope of Shared Users
   Companies of the Nomura Real Estate Group
3. 3. Purposes of Use by Joint Users
   (1) In order to engage in operations of "Nomura Real Estate Group Customer Club" and services ancillary to provision of services related to "Nomura Group Real Estate Customer Club".
   (2) Purpose of use by each company described in the above “Scope of Shared Users”
   For more details about the purpose of use by each company, refer to the website of each company.
4. 4. Party Responsible for Management of Personal Data
   
   Name: Nomura Real Estate Development Co., Ltd.
   Address: Shinjuku Nomura Building, 1-26-2 Nishi-Shinjuku, Shinjuku-ku
   Representative: Daisaku Matsuo

Ⅱ．Shared Use among the Nomura Real Estate Group Customer Club

1. 1. Items of Personal Data Subject to Shared Use
   Customer’s name, address, date of birth, phone number, e-mail address, gender, occupation, place of employment, move-in date, number of residents, annual household income, pet ownership status, etc.
2. 2. Scope of Shared Users
   

   Name: Nomura Real Estate Development Co., Ltd. Address: Shinjuku Nomura Building, 1-26-2 Nishi-Shinjuku, Shinjuku-ku Representative: Daisaku Matsuo https://www.nomura-re.co.jp/english/corporate/outline/

   Name: Nomura Real Estate Solutions, Co., Ltd. Address: Shinjuku Nomura Building, 1-26-2 Nishi-Shinjuku, Shinjuku-ku Representative: Kenichi Maeda https://www.nomura-solutions.co.jp/english/company/profile.html

   Name: Nomura Real Estate Partners Co., Ltd. Address: Shinjuku Nomura Building, 1-26-2 Nishi-Shinjuku, Shinjuku-ku Representative: Kazuhiro Toida https://www.nomura-pt.co.jp/corporate/outline/

3. 3. Purpose of Use by Shared Users
   (1) Purposes described in the above “Purpose of Use of Personal Information, etc.”
   (2) Regarding operations by the “Nomura Real Estate Group Customer Club” (hereinafter, the “Club”), to provide information related to products and services handled by the shared users and service partner companies (purchase, sale and lease of real estate, agency and brokerage, management, renovation and maintenance, interior and housing equipment, sale of housing-related products, etc.) to members of this Club.
   (3) Purpose of use by each company described in the above “Scope of Shared Users.”
   For more details about the purpose of use by each company, refer to the following.

   Purposes of use by Nomura Real Estate Development Co., Ltd. https://www.nomura-re.co.jp/english/privacy/

   Purposes of use by Nomura Real Estate Solutions Co., Ltd. https://www.nomura-solutions.co.jp/privacy_policy/mynumber.html

   Purposes of use by Nomura Real Estate Partners Co., Ltd. https://www.nomura-pt.co.jp/privacy/

4. 4. Party Responsible for Management of Personal Data Subject to Shared Use
   
   Name: Nomura Real Estate Development Co., Ltd.
   Address: Shinjuku Nomura Building, 1-26-2 Nishi-Shinjuku, Shinjuku-ku
   Representative: Daisaku Matsuo

Ⅲ．Shared Use for Corporate Transactions

1. 1．Items of Personal Data Subject to Shared Use
   If the customer is a corporate body, the name, department name/title/cellphone number/e-mail address of the representative and person in charge from the relevant corporate body, and dates/particulars of in-person meetings, etc., with the relevant representative or person in charge.
2. 2．Scope of Shared Users
   Companies of the Nomura Real Estate Group
3. 3．Purpose of Use by Shared Users
   (1) Purposes described in the above “Purpose of Use of Personal Information, etc.”
   (2) Purpose of use by each company described in the above “Scope of Shared Users”
   For more details about the purpose of use by each company, refer to the website of each company.
4. 4．Party Responsible for Management of Personal Data
   
   Name: Nomura Real Estate Development Co., Ltd.
   Address: Shinjuku Nomura Building, 1-26-2 Nishi-Shinjuku, Shinjuku-ku
   Representative: Daisaku Matsuo