PRIVACY POLICY

In this Privacy Policy, “Personal Data” refers to the term defined in article 2.1 of the Act.

TRIAD uses the Personal Data of its customers for the following purposes:

1. (1)to provide TRIAD services (defined as services that TRIAD provides as a real-estate broker or a specified joint real-estate venture) or related services (collectively, “Services”); to notify customers about the launch, update, or suspension of Services; and to supply other information;
2. (2)to conduct surveys related to Services;
3. (3)to provide maintenance and support for Services;
4. (4)to verify the usage of Services;
5. (5)to conduct sales and marketing activities as well as to use email and other methods to send notifications related to services provided by TRIAD and other companies;
6. (6)to conduct marketing, surveys, and analysis for the purpose of improving the quality or features of Services;
7. (7)to respond to inquiries etc. submitted to TRIAD;
8. (8)to deal with activity that violates TRIAD’s terms for Services;
9. (9)to notify people about changes to the Policy or provide other important information; and
10. (10)when using Personal Data is otherwise logically necessary to provide TRIAD services.

TRIAD may modify the purposes of use of Personal Data as described in the previous provision within a scope that it deems reasonable equivalent to the previous purposes of use. When making such changes, TRIAD will notify customers or announce the new purposes of use via methods established separately.

Unless permitted by the Act or other laws or regulations, TRIAD will not handle Personal Data beyond necessary to achieve the purposes of use defined in section 2 without the owner’s consent. However, this does not apply in the following situations:

1. (1)when doing so is based on laws or regulations;
2. (2)when doing so is necessary to protect the life, health, or property of an individual, and obtaining consent from the owner of the data is difficult;
3. (3)when the disclosure is necessary to improve public health or promote the health of children, and obtaining consent from the owner of the data is difficult; and
4. (4)when the disclosure is necessary to cooperate with the legally mandated work of national or local government agencies, and obtaining consent from the owner may obstruct the execution of that work.

1. 1.In accordance with the Guidelines for the Act on the Protection of Personal Information created by the Personal Information Protection Commission, TRIAD does not acquire, use, or provide to a third party any data related to political views, religious beliefs (affiliations,ideologies, and creeds), race, ethnicity, medical treatment, sexual activity, or criminal record (collectively, “Special Care Data”), except in cases involving one of the exceptional reasons listed in section 3-3-2 of those guidelines.
2. 2.When acquiring, using, or providing to a third party Special Care Data based on section 3-3-2 of the Guidelines, TRIAD shall handle the data with particular care so that said actions do not deviate from the exceptional reasons listed in that section.

1. 1.
   TRIAD acquires the following Personal Data from its customers:
1. (1)full name;
2. (2)date of birth;
3. (3)address;
4. (4)telephone number;
5. (5)email addresses
6. (6)information used to determine compatibility with customers;
7. (7)bank account information;
8. (8)personal identification numbers, corporate numbers, and other items stipulated in the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (Law No. 27 of 2013; includes subsequent revisions);
9. (9)information that customers register on TRIAD’s website or within applications provided by TRIAD;
10. (10)information provided by companies in capital tie-ups, business alliances, or outsourcing relationships with TRIAD;
11. (11)information related to the various inquiries submitted to TRIAD; and
12. (12)any other information provided to TRIAD by a customer.
2. 2.TRIAD acquires Personal Data properly and never through deception or other fraudulent means.

TRIAD does not provide Personal Data to third parties, except in cases where such disclosure is permitted by the Act on the Protection of Personal Information or other laws or regulations. However, the following situations are not considered provision to a third party as described above:

1. (1)when the customer has provided their consent (includes cases where consent was obtained for the terms and conditions connected to Services that have clauses for the provision of Personal Data to third parties, as well as cases in which the customer has acknowledged a Statement of Important Matters (a document provided before an agreement is established) connected to a Service that TRIAD provides;
2. (2)when TRIAD outsources all or a portion of the handling of Personal Data within the scope necessary to achieve the purpose of use described in section 2;
3. (3)when business operations containing the Personal Data of customers are inherited by another entity due to a merger, company split, transfer of business, or other reason;
4. (4)when the data is being jointly used in accordance with section 9;
5. (5)when the disclosure is necessary to protect the life, health, or property of an individual, and obtaining consent from the owner of the data is difficult;
6. (6)when the disclosure is necessary to improve public health or promote the health of children, and obtaining consent from the owner of the data is difficult; and
7. (7)when the disclosure is necessary to cooperate with the legally mandated work of national or local government agencies, and obtaining consent from the owner may obstruct the execution of that work.

In order to provide Services to customers,
TRIAD sometimes jointly uses Personal Data within the scope necessary to achieve the purpose of use described in section 2. The custodian of the data that is being jointly used shall announce which items of Personal Data are being shared, who they are being shared with, and the purpose of the joint usage.

1. (1)Items of Personal Data that are jointly used
   The items listed in section 6 (excluding (8))
2. (2)
   Scope of joint usage
   TRIAD and its group companies etc. below

   • ・CANATA Co.,Ltd
   • ・LAETOLI Co.,Ltd
3. (3)Purpose of use for joint users
   The purposes of use defined in section 2
4. (4)Individual responsible for managing jointly used Personal Data
   D-LIFEPLACE Minami-Aoyama, 2-26-1 Minami-Aoyama, Minato-ku, Tōkyō-to
   107-0062
   TRIAD Co., Ltd.
   Masayuki Kuramochi, Representative Director

TRIAD sometimes generates statistical data from the Personal Data it obtains from customers, but only after processing that Personal Data so it cannot identify specific individuals or be returned to its original state. TRIAD shall properly use and provide to third parties this statistical data in accordance with the Act.

TRIAD sometimes outsources all or a portion of the handling of Personal Data obtained from customers. In such cases, TRIAD will select a contractor that it determines capable of properly handling the Personal Data, enter a confidentiality agreement with that contractor in advance based on the terms of this Privacy Policy, then supervise the contractor as necessary and appropriate to ensure the safe management of the Personal Data.

If a customer asks TRIAD to disclose their Personal Data (includes records provided to and received from third parties; same below) based on the provisions of the Act after opting for either an electronic or physical method, TRIAD will promptly disclose that Personal Data to the customer after verifying their identify (or inform them that none of their Personal Data is being stored, if that is the case). However, this does not apply in cases where TRIAD is not obligated by the Act or other laws or regulations to disclose the data. Please note that TRIAD charges a processing fee of ¥1,000 per request (tax not included) to disclose Personal Data.

If a customer asks TRIAD to amend,
supplement, or erase their Personal Data (those actions collectively, “amendments etc.”) in accordance with the Act because the information is not accurate, TRIAD will first verify the identity of the individual making the request (if the request is being submitted via proxy, this includes verifying that the proxy has the power to represent the owner of the Personal Data). Upon successful verification, TRIAD will promptly investigate the matter as necessary within the scope of achieving the purposes of use listed in section 2. Based on the results of that investigation, TRIAD will then make the amendments etc. and notify the customer (if TRIAD instead decides not to make amendments etc., it will notify the customer of this). However, this does not apply in cases where TRIAD is not obligated by the Act or other laws or regulations to make amendments etc.; in cases where requests to make amendments etc. to the same information are repeatedly submitted without a valid reason; or in cases where making the amendments etc. would technically require an excessive amount of work.

If a customer asks TRIAD to erase or suspend the usage of their Personal Data (those actions collectively, “suspension of usage”) in accordance with the Act, or if a customer asks TRIAD to stop providing their Personal Data to a third party (“suspension of provision”) based on the Act because it is being done without their consent, TRIAD will first confirm that the request is valid and verify the identity of the individual making the request (if the request is being submitted via proxy, this includes verifying that the proxy has the power to represent the owner of the Personal Data). Upon successful verification, TRIAD will promptly suspend usage or provision of the Personal Data and notify the customer. However, this does not apply in cases where TRIAD is not obligated by the Act or other laws or regulations to suspend usage or provision; in cases where requests to suspend usage or provision of the same information are repeatedly submitted without a valid reason; or in cases where suspending usage or provision would technically require an excessive amount of work.

TRIAD’s Services sometimes use cookies and similar technologies. These help TRIAD stay up-to-date on how the Services are being used, which is important for improving the Services. If you’d like to disable cookies, you may do so from the Settings page of your web browser. However, some features of TRIAD’s services may be unavailable if cookies are disabled.

All questions, comments, complaints, requests for disclosure, and other inquiries related to the handling of Personal Data will be accepted through the Inquiry form or by email at the address below.

• ・D-LIFEPLACE Minami-Aoyama, 2-26-1
  Minami-Aoyama, Minato-ku, Tōkyō-to
  107-0062
  Administrative Division, TRIAD Inc.
• ・Email : infocontact@triad.company
• ・Inquiry Form : CONTACT

TRIAD shall review its handling of Personal Data as appropriate and strive to make continuous improvements in that area. Therefore, this Privacy Policy is subject to change. If we do update the Policy, we will provide the new version on the Service websites. If the Policy changes require the consent of customers by law, TRIAD shall obtain their consent using its prescribed method.