OpenDoor Inc. (the “Company”), as a contents service provider, recognizes that it is a social responsibility for the Company to protect Personal Information which is received from all customers including our affiliated companies (the “Customer”) since social concern about importance of protecting Personal Information is increased with the advent of a highly-networked information society in recent years.

Therefore, the Company hereby set forth the Personal Information protection policy as follows, according to which the Company establishes a scheme for protecting Personal Information and will continue to make every effort to protect such Personal Information by making all of the Company’s employees recognize importance of Personal Information protection and take necessary measures to protect Personal Information.

1. Acquisition and Use of Personal Information
   The Company will collect your Personal Information clearly specifying the purpose of utilization thereof (the “Purpose of Utilization”) in advance, and will use such Personal Information within the scope of the Purpose of Utilization. The Purpose of Utilization shall be expressly stated in the Company’s Personal Information management record, and verification procedure not to be used beyond the Purpose of Utilization shall be established and fulfilled under the responsibility of the Personal Information manager of each department handling such Personal Information. In addition, the Company will establish internal management system and take necessary security control measures in order to ensure that no Personal Information is used beyond the Purpose of Utilization.
2. Management and Protection of Personal Information
   The Company will strictly control Personal Information and will not disclose or provide any Personal Information to a third party without obtaining the individual concerned, as well as will take necessary security control measures to prevent divulgement, destruction or impairment. Further, the Company will establish and carry out a procedure for prevention of trouble occurrence, and in case of any occurrence of such trouble the Company will promptly make correction to prevent a recurrence of such trouble.
3. Compliance with Laws, Regulations and Codes
   The Company will comply with laws and regulations, guidelines and other codes set forth by the State which are applicable to handling of Personal Information held by the Company.
4. Dealing with Inquiries and Complaints
   The Company will establish a system and procedure for receiving and dealing with inquiries and complaints about Personal Information held by the Company, and will promptly deal with them.
5. Continuous Improvement of Management System and Scheme for Protecting Personal Information
   The Company will continuously review and try to improve management system and scheme for protecting Personal Information.

Handling of Personal Information

1. Personal Information
   The term “Personal Information” means personal information relating to the Customer which can identify a specific Customer by name, address, date of birth, gender, telephone number, email address or other description contained in such information, including, but not limited to, such information as will allow easy reference to other information and will thereby enable the identification of a specific Customer.
2. Personal Information Manager
   The following manager shall be responsible to handle and manage any and all Personal Information regarding the Customer:
   Personal Information Manager
   Business Division, Open Door Inc.
   For more information, please click here.
3. Applicable Information
   We will be responsible to handle and manage any and all Personal Information supplied by the Customer to us on or through the websites for providing the service (including, but not limited to, “https://www.opendoor.co.jp/en/” and their respective mirror sites and sub-domains, hereinafter collectively called “Our Sites.”). Notwithstanding the foregoing, we shall in no manner have any responsibility in any of the following events:
   In the event where the Customer by her/himself discloses and/or makes known its Personal Information on and/or through any external website having a link to any of the Our Sites;
   In the event where the Customer’s Personal Information is disclosed or made known due to any third person’s act who has obtained or known the Customer’s password, email address and/or member ID; or
   In the event where the Customer by her/himself discloses and/or makes known its Personal Information by using any mean or way other than any of the functions or features of the service.
4. Purpose of Utilization of Disclosed Personal Information Collected
   We will use the Customer’s Personal Information which we obtained directly from the Customer (hereinafter called “Disclosed Personal Information”) for the following purposes, and, we will not use it for any other purpose without obtaining the Customer’s prior consent or except if the case is required and permitted by laws or regulations. Notwithstanding the foregoing, please note that we may change or modify any of the following purposes within the scope and only to such extent reasonably considered to be duly related to any of the aforementioned original purposes; provided, however, that such change or modification will be announced and made public to the Customer on Our Sites in advance:
   1. I. Personal Information regarding the Customer. •To provide our product and service to the Customer.
      •To correspond with the Customer regarding our product and service.
      •To disclose to who is necessary to provide our product and service (travel agency, accommodations, airlines, etc.), the Customer’s Personal Information upon the Customer’s consent.
      •To provide the Customer with log-in function at our Sites.
      •To provide the Customer information regarding our product and service.
      •To deliver e-mail newsletters to the Customer who wish to receive them.
      •To send our campaign present to the Customer who applied the campaigns and are chosen by us.
      •To carry out a questionnaire survey among the Customer who agree to such survey.
      •To respond appropriately to the Customer inquiries.
      •To research the Customer’ s attribute or/and usage situation.
      •To create statistical data which is processed not to be identified as an individual.
      •To disclose information (posted information)
      •To run our business appropriately and smoothly.
   2. Ⅱ. Personal Information regarding our business partners. •To contact our business partners.
      •To run our business appropriately and smoothly.
   3. Ⅲ. Personal Information regarding our investors.
      •To run and record our shareholders’ meeting.
      •To exercise rights and fulfill obligations based on Corporate Law and other applicable laws and regulations.
      •To make list of our shareholders and administrate shareholders’ registry.
      •To carry out measures for our shareholders.
   4. Ⅳ. Personal Information in recruitment activities
      •To assess candidates' qualifications with regard to available positions within the Company.
      •To contact and correspond with candidates regarding job applications.
      •To run procedures for hiring.
      •To contact candidates regarding hiring procedures.
   5. Ⅴ. Personal Information regarding the Company’s executive officers, employees and their family (the “Employees” )
      •To correspond in the course of business and/or in case of emergency
      •To calculate and pay salary, etc.
      •To operate labor management in matters of recruitment, personnel evaluation, personnel transfer, attendance, educational trainings, physical examination, crime prevention, disaster prevention, etc.
      •To run procedures on social insurance, payment of tax and other procedures required by laws and regulations.
      •To offer and operate fringe benefit
      •To run our business appropriately
   6. Ⅵ. Personal Information regarding inquiries
      •To respond appropriately to the Customer’s inquiries
   Personal Information obtained not directly from the Customer
   In regards to Personal Information obtained not directly from the Customer, we will use it for the following purposes, and will not use it for any other purpose.
   Personal Information given to us by our business partners.
   •To operate entrusted business activities appropriately and smoothly.
5. About Providing Personal Information to Third Parties We shall not provide to any third party or person with any Customer’s Personal Information without prior consent of the relevant Customer except the aforementioned case; provided, however, we may provide the Customer’s Personal Information to a third party in case required by any applicable law and/or regulation.
6. Entrustment of the Handling of Personal Information to an External Operator We may entrust the handling of the Personal Information to external operators in whole or in part within the scope necessary to achieve the purposes of utilization of the Personal Information, subject that such trustee is considered to meet certain standards and subject to the conclusion of a non-disclosure agreement between such trustee and us. In this case, we shall undertake periodic assessment of such trustee and shall exercise necessary and appropriate supervision over the trustee.
7. Voluntariness of Providing Personal Information, and Effects on the Customers in case of Non-Providing Personal Information The Customer may voluntarily provide its Personal Information to us, except for the information the provision of which is described to be essential; provided, however, in case the Customer does not provide us with its Personal Information necessary for us to provide each service on Our Sites, the Customer is likely not to receive the whole or part of the services.
8. Maintenance of the Accuracy of Personal Information We shall try to accurately handle the Customers’ Personal Information within the scope necessary for the achievement of the purpose of utilization of the Personal Information; provided, however, the responsibility to maintain the Customer’s Personal Information accurate and up-to-date shall be borne by the relevant Customer.
9. Procedures to Meet Requests for Disclosure, Correction and Discontinuance of Utilization of Personal Information The Customer can request for us to disclose, correct, delete and/or discontinue the　Customer’s Disclosed Personal Information. Upon receiving such requests from the Customer to disclose, correct, delete and/or discontinue such Disclosed Customers’ Personal Information, we, after confirming the identity of the Customer, will meet such requests to a reasonable extent. For making requests for aforementioned disclosure, etc., please contact the following “Personal Information Handling Section”.
10. Contact for Personal Information Please contact us at the following numbers if you have any inquiry, question or inquiry:
    "Contact for Handling Personal Information "
    Tel: +81-3-3586-8707 (from 10:00 to 18:00, except Saturdays and Sundays)
    Fax: +81-3-3586-8708
    For inquiry via e-mail please click here.
    For answering to inquiries, we may confirm the identity of the Customer based on information which enables to identify a specific Customer.
    We may use the Personal Information obtained at the time of the Customers’ inquiries for the purpose of answering such inquiries.
11. Change or Modification of this Privacy Policy We may change or modify this Privacy Policy at any time when we deem it necessary. In case we have changed or modified the Privacy Policy, we will post such changed or modified Privacy Policy on this Site. Such changes and/or modifications shall be deemed to be accepted by the Customers who have used this Site after such changes and/or modifications. So, please check and confirm the Site periodically.
12. About Cookies We may use one or more cookies. The term “Cookie” means a small piece of data sent by a web server to the Customer’s web browser and stored in a hard disk in such Customer’s computer to be used for the identification of the Customer’s computer. We use Cookies for the purpose of providing better services to the Customer, which Cookies enable us to respond independently to the Customer who repeatedly visit our Sites, and which enable us to take the statistics regarding the number of the Customer of Our Sites. The information collected by the Cookies used on Our Sites does not include any Personal Information, so that such Cookies cannot enable us to identify any particular Customer. The Customer may reject to accept the Cookies by changing their respective web browser setting. But, in such a case, the Customer may not receive the whole or part of the services on Our Sites. We may store and refer Cookies by or through a third party whom we entrust to distribute advertisements (*1).

    *1 The third party’s services which may store and refer Cookies through Our Sites are listed below

    Name of the servicesGoogle Analytics,Google AdWords and Firebase.

    Provider of the servicesGoogle

    To learn more about how the provider collect and use Cookies, please visit Google Analytics Terms of Service, How Google uses information from sites or apps that use our services and Google Privacy Policies

    To learn more about how to disable collecting Cookies, please visit Google Analytics Opt-out Browser Add-on

    Purpose of collecting Cookies is/are ・to improve our services that we provide on Our Sites,
    ・to survey numbers of the Customer and traffic of Our Sites,
    ・to provide the Customer an advertisement which suits Customer’s visiting history of Our Sites and/or;
    ・to refer to develop a new service

Enacted on December 20, 2005
Amended on July 1, 2008
Amended on August 1, 2014
Finally amended on December 3, 2018

OpenDoor Inc.
Daisuke Sekine, President and Representative Director