Privacy Policy for HOMETACT Service

This Service Privacy Policy (the “Privacy Policy”) governs the handling of customers’ information (the “User Information”) that is obtained and used by Mitsubishi Estate Co., Ltd. (the “Company”) when customers use the HOMETACT Service (the “Service”) provided by the Company and the smartphone application “HOMETACT” which is used exclusively with the Service (the “App”). Please be sure to carefully read and agree to this Privacy Policy before using the Service and the App.

When the Company establishes rules with respect to the handling of User Information in the Company’s Policy for Personal Information Protection posted on the Company’s website, such rules shall also be applicable. In the event of a conflict between the provisions of the Policy for Personal Information Protection and this Privacy Policy, the provisions of this Privacy Policy shall prevail.

The Company obtains the following User Information, including personal information, through the Service and the App:

1. information that customers submit to the Company when applying to use the Service, including but not limited to name, address, telephone number, e-mail address, age, date of birth, and gender;
2. the following information input by customers or automatically obtained by the Company in connection with customers’ use of the Service and the App and the support services performed by the Company incidental to such use:

   a. information such as name, address, telephone number, e-mail address, age, date of birth, gender, family members, photographs, and user names;
   b. identification information required for login;
   c. identification information generated using a Cookie or similar technique;
   d. ID specific to a particular person who has entered into a contract or to a particular terminal (ID generated by OS (Android ID), unique terminal identification number (UDID), terminal identification ID (IMEI), SIM serial ID (ICCID), and MAC address, etc.);
   e. history of usage of the system such as history of usage of the App (including log information) and recorded data;
   f. location information measured by GPS device and location registration information transmitted to a base station; and
   g. any and all data automatically obtained by the designated equipment specified in Article 2 of the Terms of Use of Service

1. The Company uses User Information obtained pursuant to Article 3 for the following purposes:

   (1) registration of users with the Company’s system;
   (2) smooth provision of the Service;
   (3) enhancement and improvement of functions of the Service;
   (4) response to inquiries from customers, communications with customers, and other support;
   (5) analysis of customer trends or development and implementation of new services, with the use of the information set forth in items (a), (c), (d), (e), (f) or (g) of Article 3(2);
   (6) transmission or display of advertising, or marketing concerning products and services in accordance with customers’ preferences and tastes through the analysis of the information set forth in items (a), (c), (e), (f) or (g) of Article 3(2);
   (7) use of the information set forth in items (d), (e), (f) or (g) of Article 3(2) as IoT data;
   (8) confirmation of identity and qualification to use the Service, in accordance with laws and regulations, etc.;
   (9) study and analysis of trends and preferences of users of the Service;
   (10) review and implementation of improvement measures and new services, mainly in housing-related business and services, including the Service, with the use of the information set forth in items (a), (c), (e), (f), or (g) of Article 3(2);
   (11) providing information concerning products and services of third parties which collaborate with the Company; and
   (12) any other purposes incidental to the above-mentioned purposes of use

2. In addition to the preceding paragraph, the Company processes User Information into data by extracting common elements from information of multiple users and making tabulations by category, and then processes the data so that individuals and individual communications cannot be identified (the “Statistical Data”). The Company uses Statistical Data or provides it to a third party for the following purposes:

   (1) understanding of trends in the use of the Service;
   (2) development and implementation of new services;
   (3) analysis of customer trends or development and implementation of new services;
   (4) transmission and display of advertising, or marketing;
   (5) use as IoT data; and
   (6) any other purposes incidental to the above-mentioned purposes of use

1. The Company does not disclose to or provide any person with User Information other than third parties expressly stated in this Privacy Policy without obtaining the consent of the customer, except where:

   (1) Statistical Data is provided pursuant to Article 4.2;
   (2) User Information is disclosed or provided in accordance with laws and regulations;
   (3) the Company takes necessary measures in the event a customer, in using the Service or the App, prejudices another person’s interests, commits any act that violates public order and morals, or breaches the Terms of Use of Service or the Terms of Use of App, or attempts to do so;
   (4) the disclosure or provision of User Information is necessary to protect a person’s life, body or property, and it is difficult to obtain the consent of a customer;
   (5) the disclosure or provision of User Information is especially necessary for the enhancement of public hygiene or the promotion of fostering healthy children, and it is difficult to obtain the consent of a customer;
   (6) the disclosure or provision of User Information is necessary for the Company in cooperating with the Government of Japan or a local government, or a person entrusted by either of them, in the performance of their duties set forth in laws and regulations, and obtaining the consent of a customer risks hindering such performance;
   (7) the disclosure or provision of User Information is necessary for academic research institutions or similar institutions, and it is necessary for such institutions to handle such personal data for the purpose of academic research (including cases where part of the purpose of the handling of such personal data is for academic research, but excluding cases with material risk of unreasonable infringement of the rights and interests of individuals); or
   (8) the Company considers it necessary to disclose or provide User Information based on socially accepted standards, and it is difficult to obtain the consent of a customer, provided that such User Information is Statistical Data or other information not constituting personal data.

2. The Company may contract (including subcontract) with its affiliates stated in financial statements or quarterly reports (the “Group Companies”) and third parties for the handling of User Information to the extent necessary to achieve the purposes set forth in Article 4.1. When contracting with its Group Companies, the Company is responsible for management of personal information in a secure manner in accordance with the Company’s Policy for Personal Information Protection. In addition, when contracting with a third party, the Company executes an agreement with the third party concerning the contracting of personal information and supervises the third party in a necessary and appropriate manner.

The Company may use User Information jointly with others, within the following scope, and for the following items and purposes:

1. Scope of companies with which User Information is jointly used

   ・Group companies;
   ・Owner(s), etc. of the Property set forth in Article 2 of the Terms of Use of Service
   ・Companies providing designated equipment, etc. set forth in Article 2 of the Terms of Use of Service (the “Company Providing Designated Equipment”)
   ・DXYZ Co., Ltd. (“DXYZ")

2. Items of User Information to be jointly used

   ・Name, address, telephone number, e-mail address, age/date of birth, gender, family members
   ・Use history of the system such as use history of the App (including log information) and recorded data
   ・Any and all data automatically obtained by the designated equipment, etc.
   However, names, addresses, telephone numbers and e-mail addresses will not be used jointly with the Company Providing Designated Equipment. In addition, names, addresses, telephone numbers and e-mail addresses of the Users will be used jointly with DXYZ with respect to only the Users of the property where the face authentication security service provided by DXYZ, FreeiD (the “FreeiD”), is introduced.

3. Purposes of Joint Use
   Same as the purposes of use set forth in Article 4; provided, however, that User Information will only be used jointly with DXYZ for the purpose of providing functions and services where User Information is automatically registered on the FreeiD in concert with the registration for the Service.
4. Person responsible for joint use
   Same as the Person Responsible for Management set forth in the Company’s Policy for Personal Information Protection

If you have any inquiries and/or comments concerning procedures for requesting the disclosure of personal information held by the Company or suspension of provision of personal information to third parties, etc., or concerning the handling of personal information in the Company, please contact us as explained in Article 11. Concerning your inquiries, etc., you will receive a response from us after your identity is verified. Please note that there may be certain occasions when we cannot comply with your request.

Please refer to the Company’s Policy for Personal Information Protection and “3. Security Control Measures” for the security control measures implemented by us. If you have any other questions, please contact us as explained in Article 11.

The App incorporates an information collection module (a series of programs that are used by embedding into an application and have the function to acquire user information) through which the following business operators automatically acquire User Information. With respect to the information to be obtained, the purposes of use, provision to third parties and similar matters, please see the privacy policies of such business operators, as follows:

1. Firebase
   

   Business operator：
   Google LLC

   Policies on privacy and certain other matters：
   https://policies.google.com/privacy
   https://firebase.google.com/support/privacy?hl=ja

2. Google Analytics
   

   Business operator：
   Google LLC

   Policies on privacy and certain other matters：
   https://policies.google.com/privacy
   https://marketingplatform.google.com/about/analytics/terms/jp/

The App does not provide any means to stop obtaining User Information. For suspension of obtaining, changing, deleting, suspension of using, etc. the whole or part of User Information, please contact us as explained in Article 119.

For inquiries regarding the handling of User Information in the App, please contact us at the following address, using the prescribed format: Mitsubishi Estate Co., Ltd., Otemachi Park Building, 1-1, Otemachi 1-chome, Chiyoda-ku, Tokyo 100-8133, Japan

Attn: Residential Business Planning Department (Contact for Personal Information in the Residential Business Group)

The prescribed format is available at
https://www.mec.co.jp/assets/img/privacy/reference.pdf
Please fill in the required information in the prescribed format and send it to the above address.

The Company may change this Privacy Policy. A notice to the user is made on the screen of the App or posted on the Company’s website, or made in writing, by e-mail, or by any other method that the Company considers appropriate. In the event of any change in the items of User Information to be obtained, the purposes of use, or provision to a third party, the Company will again obtain the consent of customers following such change when legally required.

Revised on July 14, 2023