In recent years, society has become increasingly concerned about the importance of protecting Personal Information in the context of advanced information technology, and we, OpenDoor Inc. (hereinafter “we” or the “Company”), believe that it is our social responsibility as a content service provider to protect the Personal Information entrusted to us by businesses with whom we have connections, and by all of our customers.

Therefore, we have established the following privacy policy, have developed a system for protecting Personal Information, and have ensured that all employees recognize the importance of protecting Personal Information and are thoroughly involved in the protection of Personal Information.

Unless otherwise defined, the meanings of terms used below are as defined in the Act on the Protection of Personal Information (Act No. 57 of 2003, including any amendments, hereinafter referred to as the "Personal Information Protection Act").

  1. Acquisition and Use of Personal Information
    We will acquire Personal Information only after clarifying the purpose of use and will use it only within the scope of that purpose of use. The purpose of use shall be clearly stated in the personal information management ledger, and a confirmation procedure will be established and implemented under the responsibility of the administrator of Personal Information in each division that handles Personal Information, in order to prevent any use that deviates from the purpose of use. In addition, we will develop an internal management system and take security control measures to ensure that Personal Information is not used outside the scope of the purpose of use.
  2. Management and Protection of Personal Information
    Personal Information shall be strictly managed and shall not be disclosed or provided to third parties without the consent of the individual, except as permitted by law. In addition, we will take security control measures to prevent leakage, loss, or damage of Personal Information. Furthermore, we will establish and implement procedures to prevent problems from occurring, and if a problem should occur, then we will promptly take corrective measures to prevent recurrence.
  3. Compliance with Laws, Regulations and Standards
    We will comply with the Personal Information Protection Act and guidelines established by the Personal Information Protection Commission regarding the Personal Information Protection Act, as well as other applicable laws, regulations, and other standards regarding our handling of Personal Information in our possession.
  4. Responses to Inquiries or Complaints
    We have established a system and procedures for receiving and responding to inquiries and complaints regarding Personal Information in our possession, and we will respond promptly to such inquiries and complaints.
  5. Continuous Improvement of the Management System and Mechanisms for Personal Information Protection
    We will continuously improve our management system and mechanisms for the protection of Personal Information.

Adopted on December 20, 2005
Last Update: March 30, 2022

OpenDoor Inc.
Daisuke Sekine, President and Representative Director


Handling of Personal Information

Name, Address and Name of Representative of the Business Handling Personal Information
OpenDoor Inc.
Akasaka Tameike Tower 6th floor, 2-17-7 Akasaka, Minato-ku, Tokyo
Daisuke Sekine, Representative Director

Personal Information Protection Manager
The person responsible for our company's management of Personal Information is as follows.

Personal Information Protection Manager General Manager, Administration Division, OpenDoor Inc.
Telephone Number 03-3586-8707
E-mail kanri@opendoor.co.jp
Purpose of Use of "Retained Personal Data" Obtained by the Company
The purposes of use of "Retained Personal Data" obtained by the Company are as follows. When the purpose of use is individually communicated to an individual or publicly announced through the services of the Company used by the individual, then it shall be used for that purpose.
  1. Retained Personal Data About Customers
    • To provide products or services
    • To make contact in connection with the provision of products or services
    • To provide, with the customer's consent, Personal Information to parties (travel agencies, accommodation facilities, airline companies, etc.) who are necessary in order to provide products or services
    • To provide information regarding products or services
    • To authenticate members through websites
    • To distribute e-mail newsletters to those who wish to receive them
    • To send gifts to winners of gifts
    • To administer questionnaires to customers who have given their consent
    • To respond to inquiries and comments
    • To conduct research on the distribution of customer attributes and on usage conditions
    • To create statistical data that has been processed in such a way that individual customers cannot be identified
    • To make information public (contributed information)
    • To otherwise promote the appropriate and smooth operation of the business
  2. Retained Personal Data About our Business Partners
    • For business communications in connection with transactions
    • To ensure the appropriate and smooth performance of transactions
  3. Retained Personal Data About Shareholders
    • To administer and record shareholders' meetings
    • To exercise rights or perform obligations under the Companies Act and other laws and regulations
    • To prepare the register of shareholders and for other shareholder management purposes
    • To implement various shareholder policies
  4. Retained Personal Data About All Applicants for Employment
    • For selection for employment
    • For communications regarding employment selection
    • To carry out hiring procedures
    • For communications regarding hiring procedures
  5. Retained Personal Data About Directors, Officers, and Employees of the Company and their Families
    • For business communication or emergency communication
    • To calculate and pay salaries, etc.
    • For labor management, including recruitment, evaluation, transfer, attendance, education and training, medical examinations, crime prevention, and disaster prevention
    • For social insurance procedures, tax payment procedures, and other procedures required by law
    • To provide and manage employee welfare services
    • For any other appropriate business operations of the Company
  6. Retained Personal Data About Inquiries
    • To respond to inquiries and comments
  7. Retained Personal Data About Craft Artists
    • For registration of artist information
    • For business communications after registration
    • To ensure the appropriate and smooth performance of transactions
    • For the making of posts on websites
Provision of Personal Information to Third Parties
Personal Information that has been obtained will not be provided to third parties except with the consent of the individual concerned or as permitted by law.

Outsourcing the Handling of Personal Information
We will not outsource to third parties all or part of the handling of acquired Personal Information, except as expressly stated in our Privacy Policy or with the consent of the individual concerned.

Procedures for Responding to Requests for Disclosure, Etc.
The procedures for responding to requests for the disclosure, etc., of "Retained Personal Data" or "Records of Provision to Third Parties" are as follows.
  1. Point of Contact for Requests for Disclosure, Etc.
    OpenDoor Inc. [Personal Information Inquiry Desk]
    107-0052
    Akasaka Tameike Tower 6th floor, 2-17-7 Akasaka, Minato-ku, Tokyo
    Phone Number : 03-3586-8707
    Hours: 10:00 - 18:30 (except Saturdays, Sundays, national holidays, and year-end and New Year's holidays)
    Email: kanri@opendoor.co.jp
  2. Method of Making Requests for Disclosure, Etc.
    Please fill out the "Retained Personal Data Disclosure, Etc. Request Form" prescribed by the Company (hereinafter referred to as a "Request Form"), and send it, together with the identity verification documents described under Identity Verification Method in Item 3, by postal mail or e-mail to the Personal Information Inquiry Desk identified as the contact person for requests for disclosure, etc., in Item 1. If you need a Request Form, please contact the Personal Information Inquiry Desk identified as the point of contact for requests for disclosure, etc., in Item 1.
    In principle we will respond via the requested response method, but if considerable expense is required or other difficulties are involved, then we may respond in writing.
  3. Identity Verification Method
    <By the Individual Concerned>
    A copy of one of the following: driver's license, health insurance card, pension book, passport, or resident certificate
    <By an Agent>
    A copy of one of the following for the person concerned: driver's license, health insurance card, pension book, passport, or resident certificate
    +
    A power of attorney (in the case of an Agent by power of attorney) or a document certifying status such as a copy of family register (in the case of a legal representative)
    +
    A copy of one of the following for the representative: driver's license, health insurance card, pension book, passport, or resident certificate
    *If any of the above documents include your legal domicile, then please submit them with all mention of your legal domicile blacked out.
  4. Other
    • Please note that we may not be able to respond to a request for disclosure, etc., if the Request Form or documents for identification are incomplete, if identification cannot be confirmed, or if the request is subject to any of the exemptions under the Personal Information Protection Act, such as not constituting Retained Personal Data.
    • Personal Information obtained in connection with a request for disclosure, etc., shall be handled only to the extent necessary to respond to the request for disclosure, etc. Please note that we will not return any documents sent in connection with a request for disclosure, etc.
    • Depending on the nature of your request for disclosure, etc., we may take some time to respond.
    • We may contact you if necessary in order to respond to your inquiry.
    • If the Request Form or identity verification documents are incomplete, then we will inform you to that effect. However, please understand that if you do not respond within a prescribed period, then we will treat it as if there was no request for disclosure, etc.
Voluntary Nature of the Provision of Personal Information by the Individual and Consequences of Not Providing Such Personal Information
Customer provision of Personal Information to our Company is voluntary. However, please understand that if you do not provide us with your Personal Information, then we may not be able to respond to your inquiry.

About Cookies
We may use cookies on the websites that we operate (hereinafter referred to as the "Websites"). A cookie is a small piece of data that a web server sends to a user's browser, which is stored on the hard disk of the user's computer and used to identify the user's computer. We use cookies to provide better service, such as to enable us to respond to repeat visitors individually or to compile statistics on the number of users.
Cookies used by the Websites do not contain Personal Information and cannot identify individual users.
It is also possible to configure your browser to reject the receipt of cookies, but in this case, you may not be able to receive some or all of the services provided by the Websites.
In addition, we may store and refer to cookies via third parties to whom the delivery of advertisements has been outsourced. The Websites may store and refer to cookies via the following third party services.

  1. Google Analytics, Google AdWords and Firebase
    Provider:
    Google LLC
    Manner of Collection and Use of Cookies:
    As stated in Google Analytics Terms of Service, How Google Uses Information from Sites or Apps that Use Our Services and Google Privacy Policy.
    Method of Deactivating the Collection of Cookies:
    Google Analytics Opt-out Browser Add-on
  2. Advertising Distributed by Yahoo Japan Corporation
    Provider:
    Yahoo Japan Corporation
    Manner of Collection and Use of Cookies:
    As stated in Yahoo! Japan Privacy Center and Use of Personal Data in Advertisements Distributed by Yahoo! Japan.
    Method of Deactivating the Collection of Cookies:
    As stated in Use of Personal Data in Advertisements Distributed by Yahoo! Japan.

    Purposes of Use

    • For improvement of the user experience on the Websites and the services provided on the Websites
    • For surveying user numbers and traffic on the Websites
    • For distributing advertisements that correspond to browsing history on the Websites
    • As reference materials in connection with the development of new services, etc.
    • For confirming the status of requests for travel, questions, and other transactions that users have had with travel agencies, etc.

Inquiries About Handling of Personal Information
Please contact the following for any inquiries or complaints regarding our handling of Personal Information.
OpenDoor Inc. "Contact for Inquiries Regarding Personal Information and Privacy Policy"
Personal Information Protection Manager General Manager, Administration Division, OpenDoor Inc.
Address 107-0052
Akasaka Tameike Tower 6th floor, 2-17-7 Akasaka, Minato-ku, Tokyo
Telephone Number 03-3586-8707
Hours 10:00-18:30 (except Saturdays, Sundays, national holidays, and year-end and New Year's holidays)
E-mail kanri@opendoor.co.jp


Name of Authorized Personal Information Protection Organization and Contact for Complaints
Name of Authorized Personal Information Protection Organization Japan Institute for Promotion of Digital Economy and Community
Contact for Resolution of Complaints Personal Information Protection Complaint Consultation Office
Address Roppongi First Bldg., 1-9-9 Roppongi, Minato-ku, Tokyo 106-0032, Japan
Telephone Number 03-5860-7565
0120-700-779
[This is not a contact for inquiries regarding our products or services.]
Details of Measures Taken for the Secure Management of Retained Personal Data
  1. Formulation of Basic PolicyWe have established the Privacy Policy as stated above to ensure the proper handling of Retained Personal Data and to provide a point of contact for questions and complaints.
  2. Rules for the Handling of Personal DataFor each stage of acquisition, use, storage, provision, deletion/disposal, etc., Basic Rules for Personal Information Management and related manuals have been established regarding handling methods, responsible persons and persons in charge, and their duties.
  3. Organizational Security Management Measures
    • In addition to appointing a person responsible for the handling of personal data (the Personal Information Protection Manager), the Company will clarify the employees who are to handle personal data and the scope of personal data to be handled by such employees.
    • A system is in place for reporting to and communicating with the Personal Information Protection Manager if there should arise any facts or indications of a violation of the Personal Information Protection Act, related guidelines, or internal rules.
    • The Company will carry out periodic self-inspections of the status of personal data handling in accordance with its internal rules, and will undergo audits by outside parties.
  4. Human Security Management Measures
    • Regular training will be provided to officers and employees on important points regarding the handling of personal data.
    • Compliance with internal rules on the handling of Personal Information, prohibition of disclosure or divulgement of Personal Information, and prohibition on the use of Personal Information for purposes other than its intended use are provided for in the Rules of Employment.
  5. Physical Security Management MeasuresIn areas where personal data is handled, entry/exit controls and lock controls will be implemented for officers and employees, and measures will be taken to prevent access to personal data by unauthorized persons.
  6. Technical Security Management Measures
    • The number of persons in charge and the scope of their handling of personal data information will be limited by implementing access controls with respect to information systems that handle personal data.
    • We have established mechanisms to protect information systems that handle personal data from unauthorized external access or unauthorized software.

Last Update: March 30, 2022