Privacy Policy (Global Data Protection)

We collect the following categories of personal data:

[Account & Authentication Data] Full name, email address, and professional title obtained via LinkedIn Sign-In or contact forms.

[Investment Preferences & Criteria] Your target budget (in JPY/USD/EUR), preferred prefectures, property types (commercial building, hotel, retail, residential), and target net yield (CAP rate).

[Interaction & Activity Data] Viewing history of 3D virtual walkthroughs, chat transcripts with our Gemini AI Concierge, saved properties, and property inquiry logs.

[Technical & Usage Data] IP address, browser type, device specifications, language preference, timestamps, and cookie identifiers.

[Business Card Creation Data] The full name, email address, phone number, messaging-app ID and languages spoken that Referral Partners and our affiliated agents enter in the business card feature, an optional face photo, and, for those registered as a Real Estate Transaction Specialist, the qualification information we set.

[Digital Business Card Page Data] When you turn on publishing, the page shows the items you chose to show on your business card (your name, title, face photo, email address, phone number, messaging-app ID and languages spoken), which anyone who has the link can view. The page is set so that search engines do not list it.

[Payment Information for Partners] To pay fees to our referral partners and affiliated agents: bank account details for payment, the result of the identity verification carried out before payment (performed through an online identity verification service), and the tax information we need (whether you are a taxable business for Japanese consumption tax and, if so, your registration number).

[Contact Details You Give Us When Booking or Making an Inquiry] The phone number (optional), nationality and residency status (Japan resident, foreign national living in Japan, or non-resident) you enter in the viewing or consultation booking form or the inquiry form. If you save them in your dashboard settings, or choose to save them on a form, we keep them in your account to fill in future forms automatically (we never import them from LinkedIn).

[Rental Management Information] For owners who entrust us with rental management: the managed property and the terms of the management agreement, monthly records of rent received, management fees, costs, deductions, amounts remitted and occupancy, a note of the account we remit to (bank name and the last four digits of the account number), management reports, and records of your consent to receive them electronically and of our explanations. For complaints from tenants and others, we record only the type of person (tenant, neighbor, etc.), the details and how we handled them, and never their name.

[Investment Proposal Requests] The answers you give in the questionnaire on your dashboard: how you plan to fund the purchase (own funds only, or also a loan), your nationality and country of residence, budget, priorities, preferences for the number of units, tenancy, seismic standard, area and property type, ownership, expected holding period and purchase timing, the language of the proposal, and any requests (optional). We do not ask for your income or assets. We also keep the proposals we send you, the time you first open them, and a record of any request from the referral partner who introduced you asking us to prepare a proposal (the partner and the date).

[Property Search Requests and Proposals] Your property search request (the version of the wording you agreed to, the date and time, the language, the screen on which you made the request, and the date and time of any withdrawal), the properties we propose to you, the dates and times of our proposals and the comments from the person in charge, your reactions in the Proposal Room (favorites, and passes with the reason), the dates and times we sent you notification emails, and the number used for your personal link.

[Identity Verification (Customer Due Diligence)] After you submit a purchase offer, we collect the following information through an online identity verification service, as the identity verification required under Japan's Act on Prevention of Transfer of Criminal Proceeds: images and details of your identity document such as your passport (name, date of birth, nationality, document type and number, issuing country and expiry date), the result of reading the IC chip of your identity document, images and details of a document showing your current address (document type, issuer, issue date, address and the name on the document), and, where the verification service performs a face match (comparing a photo of your face with the photo in your identity document), its result. We also record the date we mail a letter to your address, its international registered mail number, and the entry of the code printed in that letter. We do not store images of your face; we record only the result of the face match.

Your personal data is processed exclusively for the following purposes:

1. Providing real estate investment brokerage services in Japan.

2. Matching properties to your investment criteria and delivering automated personalized newsletters.

3. Delivering intelligent real estate consultations and advisory analysis through our interactive AI Concierge.

4. Guiding requests to the Gyoseishoshi Family Legal Office run by our representative, such as the preparation of residence status or company formation documents, and acting as the point of contact.

5. Maintaining platform security, authentication integrity, and fraud prevention.

6. Enabling Referral Partners and our affiliated agents to create business cards (print PDFs and images to share) from templates we have approved, including name, contact details, an optional face photo and, where applicable, the Real Estate Transaction Specialist qualification.

7. Publishing the items you chose to show on your business card on a public page of our website (the digital business card page) when you turn on publishing.

8. Paying fees to our referral partners and affiliated agents (including checking the bank account for payment, identity verification before payment, and tax procedures)

9. Providing rental management services after purchase and the periodic reports to owners required by Japan's Rental Housing Management Business Act (including providing monthly income statements and management reports on your dashboard and explaining them)

10. Preparing investment proposals at your request (property comparison, costs, and general information on financing and procedures) and delivering them to your dashboard and by email (including sharing with the affiliated agent assigned to prepare them)

11. To verify your identity (customer due diligence), to prepare and keep verification records under Japan's Act on Prevention of Transfer of Criminal Proceeds, and to fulfil our other obligations under that Act

12. In response to your property search request, proposing properties that match your investment criteria (including properties that are not publicly listed) in the Proposal Room and notifying you by email

In accordance with GDPR Article 6, we rely on the following legal bases for processing personal data:

[Consent] For LinkedIn login authentication, marketing newsletters, non-essential cookies, showing a face photo on a business card, and publishing a digital business card page (you may withdraw consent at any time).

[Performance of a Contract] For fulfilling brokerage services, Letters of Intent (LOI), viewing bookings, and purchase agreements, and for providing the business card feature to Referral Partners and affiliated agents.

[Legitimate Interest] For securing our web application, preventing fraudulent activity, and enhancing user experience.

[Legal Obligation] For compliance with Japanese real estate licensing laws, Japan's Act on Prevention of Transfer of Criminal Proceeds (identity verification before a property purchase and keeping its records), and tax record-keeping requirements.

[Performance of a Contract] For paying fees to our referral partners and affiliated agents (including checking the bank account for payment, identity verification before payment, and tax procedures).

[Performance of a Contract / Legal Obligation] For providing rental management services, and for the periodic reports to owners and the record-keeping required by Japan's Rental Housing Management Business Act.

[Performance of a Contract] For preparing and delivering the investment proposals you request.

[Performance of a Contract] For making proposals in response to your property search request and keeping records of them.

As a Japanese corporation, your personal data is stored on secure servers in Japan and globally hosted on Google Cloud Platform / Firebase infrastructure.

Transfers of personal data from the EU/EEA to Japan are conducted lawfully pursuant to the European Commission's Adequacy Decision for Japan (GDPR Article 45).

Where international transfers occur outside jurisdictions with adequacy decisions, we implement Standard Contractual Clauses (SCCs) and robust technical safeguards.

[Identity Verification Service] Identity verification is carried out through an identity verification service provider engaged by us (a company incorporated in the United States). The provider processes and stores identity verification data within the European Union (EU). We have an agreement with the provider on the handling of personal data, require it to handle the data only within the scope of our instructions, and supervise it as necessary and appropriate. Information on the personal data protection system of the provider's country and on the measures taken by the provider is available on request through the contact point in Section 11.

We implement rigorous technical and organizational security measures, including Firebase Security Rules, Firebase Secret Manager, encryption in transit and at rest, and strict role-based access control.

[Third-Party Disclosure Restrictions] We will never sell, trade, or rent your personal data to third-party data brokers. Disclosure is limited to:

1. Certified professionals with your prior consent (e.g., judicial scriveners for property registration, or the Gyoseishoshi Family Legal Office for preparing residence status application documents).

2. Competent administrative or judicial authorities when strictly required by applicable law.

3. Emergency situations to protect vital human interests or property.

[Entrustment to Contracted Agents] We may allow contracted agents (individuals or companies) who introduce clients or guide property viewings to handle your information to the extent necessary to perform those services. Agents are bound by confidentiality obligations and are contractually required to comply with this Privacy Policy, and we supervise them as necessary and appropriate. In the agent-facing screens, clients are shown only as name initials together with the transaction stage and the status of any investment proposal (requested, answers received or sent, with the date); email addresses, identity verification data, asset information, the answers given for an investment proposal and the contents of the proposal are not displayed.

[Provision to the Real Estate Company Handling the Property] To arrange viewings, purchase applications and contracts, we share the information needed for the arrangement, such as your name and the booking date and time, with the real estate company handling the property (the seller's brokerage or management company). We share it only after informing you and obtaining your consent when you book or apply.

[Subcontractors for Rental Management] For properties where we subcontract part of the management work to a local management company, we share with that company the information needed for the work from among the property details, the owner's name and contact details, and tenant information, and we supervise that company.

[Entrustment to the Identity Verification Service] For identity verification, we entrust the handling of the information on your identity document and proof of address (including your face photo, where a face match is performed) to the identity verification service provider (Section 6). The images of your identity document and proof of address kept as our verification records are stored on our servers in a location that cannot be accessed from public pages, and only administrators can view them.

We use essential cookies and local storage to remember your language preference, selected currency (JPY/USD/EUR/etc.), area unit preference (sqm/tsubo/sqft), and authentication state.

[3D Walkthroughs & Maps] Interactive 3D virtual tours and maps (Google Maps / Mapbox) are embedded via secure iframe and API integrations. Use of these features is subject to the respective providers' standard privacy terms.

[Referral Records] If you arrive through a referral link issued by one of our agents (a URL containing a referral code), we store that referral code and the channel it came from in your browser's local storage for up to 90 days, and send it to our servers when you complete registration, so that agent commission can be calculated correctly. You can erase this record at any time by clearing local storage in your browser settings.

[Referral Link Opens] If you arrive through a referral link, we count how many times the link was opened, by referral partner and by channel, and both that referral partner and we can see these counts. The counts do not include any information that could identify you (such as your IP address, device identifiers or cookies).

[Traffic Source Records] When you first visit our site, we store how you arrived (tracking parameters in the URL, the name of the referring website, and the first page you viewed) in your browser's local storage for up to 90 days, and send it to our servers when you complete registration. We use this only to understand which of our outreach activities are useful, and never for ad delivery. You can erase this record at any time by clearing local storage in your browser settings.

We retain your personal data only for as long as necessary to fulfill the stated purposes or as required by Japanese real estate transaction laws (typically 5 to 10 years for official transaction logs).

Upon account deletion or newsletter unsubscribe requests, promotional and profile data is promptly anonymized or deleted from our active production servers.

Business card data (including a face photo) is stored only to create your business card and is deleted when your contract as a Referral Partner or affiliated agent ends. You can delete your face photo at any time. You can also unpublish your digital business card page at any time, and it stops being visible when your contract ends.

Payment information for partners (bank account details, the result of identity verification and tax information) is kept as payment and tax records for the period required by law.

Contact details saved in your dashboard (phone number, nationality and residency status) are kept until you delete them in your settings or close your account.

Rental management records (the terms of the management agreement, monthly income records, management reports and complaint records) are kept, together with the books required by Japan's Rental Housing Management Business Act, for five years from the end of the business year in which the management agreement ends.

Your investment proposal requests and the proposals we send you are kept until you close your account.

Records of your property search request and our proposals (your agreement and any withdrawal, the properties we proposed and the comments from the person in charge, your reactions in the Proposal Room, records of notification emails, and the number used for your personal link) are kept until you close your account, and are deleted when you do.

Identity verification records (images and details of your identity document and proof of address, the verification results, and the records of the letter we mail to you and its international registered mail number) are kept for seven years from the date of your transaction (the sales contract), as required by Japan's Act on Prevention of Transfer of Criminal Proceeds (or, if you make later transactions relying on the same verification, seven years from the date of the last transaction). If no transaction takes place, they are also kept for seven years from the date of verification. They are deleted after that period. The identity verification service provider's own records are set to be deleted one year after we import them into our verification records.

You are entitled to exercise the following rights regarding your personal data free of charge:

1. Right of Access: Request a copy of your personal data and details of processing.

2. Right to Rectification: Correct inaccurate or outdated profile or investment criteria data.

3. Right to Erasure ('Right to be Forgotten'): Request deletion of your personal account and data.

4. Right to Restriction: Restrict how your personal data is processed.

5. Right to Data Portability: Receive your data in a structured, machine-readable format.

6. Right to Object & Withdraw Consent: Object to automated newsletters or withdraw consent at any time.

Even if you request deletion, records that we are required by law to keep (such as identity verification records) cannot be deleted until their retention period ends (GDPR Art. 17(3)(b)). During that period, we use them only to fulfil our legal obligations.

If you have any questions regarding this Privacy Policy, your personal data, or wish to exercise your data subject rights, please contact our Privacy Office:

Company: Japan Real Estate LLC (Japan Real Estate Godo Kaisha)

Office: Privacy & Compliance Office

Address: 2-11-18 Mokusei-no-Mori, Akishima-shi, Tokyo, Japan

Email: info@japan-real-estate.com