Last updated: February 14, 2009 Tokyo Dwell Co.,Ltd. We, Tokyo Dwell Co.,Ltd. , recognize personal information protection and its proper maintenance to be important social responsibilities. We have set up our personal information protection policy as follows and will realizeand maintain it:

Name of business proprietor handling personal information (the Personal Information Protection Law, Item 1 in Section 1 of Article 24):

Tokyo Dwell Co.,Ltd.

Basic policy

We respect and obey the applicable laws and social order concerning personal information and do our best to ensure proper handling and protection of personal information.

Acquisition, utilization and provision of personal information:

Acquisition of personal information is limited to lawful means such as direct acquisition from related documents of mediation contracts, purchase and sale agreements, lease contracts, etc., approach to home pages (web sites), public information ( e.g. house maps, telephone books, copies of registration books, public directories widely available in the market, etc. ) and REINS run by Real Estate Information NetWorks designated by the Minister of Land, Infrastructure and Transportation (refer to Note 1 at the end of this Privacy Policy “Concerning government-designated Real Estate Information NetWorks and so forth”) and/or provision by third parties and so on. We also publish, notify or express clearly the purposes of informationutilization and so forth withholding overuse of personal information surpassing the sphere of utilization purposes without the parties’ approval in person. In addition, provision or publication of personal information to third parties will be carried out in accordance with the procedures of the applicable laws and ordinances.

Utilization purposes of personal information

The utilization purposes of personal information are as follows: (1) Customers of business transactions: i. Utilizing property information of sale or lease objects, etc. for the purposes of searching for potential buyers, ii. Advertising sale or lease objects, etc. on internet sites, iii. Providing property information to customer agents, potential buyers and/or potential lessees, iv. Keeping and utilizing information of potential buyers or potential lessees for the purposes of sending property information and so forth at a later date, even if mediation or lease contracts were not concluded with them, v. Performing agreements on transactions of purchase and sale, mediation, lease and management of real estate as wel as management of transactions, keeping records of transactions, provision of information and service to customers, vi. Performing agreements and management of transactions, keeping records of transactions, provision of information and service to customers with regard to our newly-built Lions Mansions, vii. Provision of personal information to third parties within the limits of necessity in performing purposes in the foregoing ⅴand ⅵ, viii. Sales activities and marketing through regular mail, telephone, electronic mail, etc. for provision of merchandise, information and service (questionnaire requests, etc.) as well as customer trend analyses or product development research and analyses, etc. , ix. Non-life insurance business (also refer to the after-mentioned “6. Supplementary explanation for utilization purposes and provision of personal information to third parties”) x. Sales activities through sending direct mail and electronic mail in searching for potential purchasers and potential sellers, xi. Sending messages to customers regarding special and new information appropriately with regard to commodity, service, etc. , xii. Providing services or information that fit customers’ needs, xiii. Conducting research with regard to circumstances and environments of property utilization to comprehend customers’ satisfaction level, xiv. Communicating with customers when necessary, xv. Confirmation procedures required by audit, xvi. Provision of information to the following Tokyo Dwell group of companies for the purpose of total service by the group,

Notes: (a) Data items to be provided include customers’ information acquired in their answers to our questionnaires, etc. such as their names, addresses, phone numbers (including cell-phone numbers), mail addresses, desirable business terms, employment information, annual income and assets, etc. (b) The delivery means of the information are electronic data, printed matters such as address stickers, etc., and/or tabulated lists. (c) The above provision of customers’ information to the Tokyo Dwell group of companies will be discontinued at the request of the customer concerned. The customer window to be used is the after-mentioned “11. Customer service concerning personal information”. (d) Details of each member of the Tokyo Dwell group of companies are available on their respective home pages. (e) The Tokyo Dwell group of companies may change in the future because of new establishment or amalgamation of companies, etc. Changes may occur to their company names, main business line or points of contact, etc. Please also refer to “6. Supplementary explanation for utilization purposes and provision of personal information to third parties”. There will be cases in which calls from customers to our departments will be recorded to facilitate accurate comprehension of the content. (2) Directors and employees i. For analyses of the application procedure and the trends of those applicants that apply to us, ii. For salary calculation, personnel management such as personnel evaluation and labor management of our employees, iii. Keeping records of service data of employees who have retired from our company. There will be cases in which property, commodity and service information handled by Tokyo Dwell or its affiliates will be provided to customers through direct mail, E-mail, telephone or fax. This information and service provision will be discontinued at the request of the customer concerned.

Provision of personal information to third parties

Personal information held by us will be provided to third parties in the following cases: (1) Customers of business transactions: (1) The said person agrees to such provision, (2) Such provision is required by applicable laws or ordinances, (3) Such provision is required for the protection of physical health or property in emergent cases in which it is difficult to get the persons’ approval, (4) Such provision is particularly required for enhancement of public health or promotion of healthy juvenile growth in emergent cases in which it is difficult to get the persons’ approval, (5) Such provision is required to cooperate with state or local governments or their assignees in performing their assignments by applicable laws or ordinances, in which getting the persons’ approval obstructs the attainment of the assignments, (6) In the case of newly-built property sale, the customers’ names, addresses, etc. required for the transactions are provided to third parties such as the parties of the agreements, banking facilities, caretaker companies and others through written documents, regular mail, telephone, electronic mail, etc. within the limits of necessity for the attainment of utilization purposes. Such provision of information will be at the request of the customer concerned in person. (7) In the case of purchase-sale mediation, the property information, customers’ names, addresses, etc. required for the transactions are provided to third parties through written documents, regular mail, telephone, internet, electronic mail, advertising media, etc. Such provision of information will be discontinued at the request of the customer concerned. (Examples of potential third party recipients of personal information in the case of purchase-sale mediation, etc.) Please refer to the details of provided data, means of provision, etc. in the Note 2, “Details of potential third party recipients of personal information at the end of this Privacy Policy.” i. The parties of the concerned agreements and such potential parties, ii. Third party real estate agents, iii. Agents who advertise through internet media and real estate business organizations, iv. Real Estate Information NetWorks designated by the Minister of Land, Infrastructure and Transportation (their tasks: registration of properties, reports of conclusion of transactions and research of market and prices using their data), *Please refer to Note 1, “Concerning government-designated Real Estate Information NetWorks and so forth”) at the end of this Privacy Policy. v. Judicial scriveners and real estate surveyors who deal with the property registration, vi. Banking facilities which deal with financing, vii. Caretaker companies of property maintenance, viii. Tokyo Kantei Co., Ltd. and other dedicated real estate information service and research organizations, ix. Credit information organizations (8) With regard to our sublease properties, if the resident sub-lessees or potential sub-lessees ask us to disclose owner information or if the owners ask us to disclose information of resident sub-lessees or potential sub-lessees, we will disclose personal information to the extent we consider necessary. Such provision of information will be discontinued at the request of the customer concerned. *Collective information obtained from statistically-treated personal information will be used or published for research, but those collective data will not contain any customer identity information. Please refer to “6. Supplementary explanation for utilization purposes and provision of personal information to third parties”.

Security procedures for protecting personal information

We keep personal information properly and discreetly, and take all and necessary security measures for preventing unauthorized access, loss, falsification and/or leak of private information. [SSL encrypted communications] On our website, customers can use SSL encrypted communications when they send personal information. (an SSL corresponding browser is required for SSL communications. Some SSL corresponding browsers cannot use SSL encrypted communications due to configuration or connection environment problems.) [IP address] Tokyo Dwell sometimes use customers’ IP addresses recorded in our log for the purposes described below, however you are assured that IP addresses in themselves cannot identify individuals: ●To determine and solve troubles to web servers, ●To maintain our websites [Cookies] Tokyo Dwell sometimes uses cookies as a means of gathering information for service enhancement. Cookies are small text files recorded in website-visitors’ computers, and are mainly used for identification of individual customers by our system. However, recorded information never includes customers’ names, E-mail addresses, telephone numbers or regular addresses. Please be assured that information contained in our website cookies has no meaningful information except for using our websites. If you are opposed to the gathering of information through cookies, you can set your computer to reject cookies. However, please be advised that you may find our website service or function does not operate properly. [Linkage to other sites] Our websites list linkages to other websites. Please be advised in advance that we will bear no responsibility for privacy protection at those linked websites.

Consignment of handling personal information

We delegate our direct mail dispatch, in-house system repair and maintenance, etc. to external companies. We will bring further transparency to the consigned work choosing privacy-sensitive agents and giving consignees necessary and proper supervision

Service quittance due to requests from customers in person

We will respond to requests from customers in person and discontinue providing services such as dispatching direct mail, etc. Please contact us using the after-mentioned customer service window or concerned business departments.

Procedure for disclosure, correction, etc.

We will also respond to requirements of our customers’ in person concerning disclosure or correction of personal information, or quittance of service, etc. without delay in accordance with the Personal Information Protection Law and our separate in-house procedures. *Click here to view procedures for disclosure, correction, quittance of service. *Before initiating the procedure, let us confirm that the requests have been placed by the customer in person.

Customer service concerning personal information

Please contact us at this window concerning this privacy policy and personal information handling: (Customer service window) Company name: Tokyo Dwell Co.,Ltd.

Revision of this policy

This policy will be reviewed and revised appropriately according to requests by the applicable laws and improvement of personal information protection. When it is revised the latest update date will be renewed on the top of the first page. When an important revision is added to this policy, we will notify our customers using our “Privacy Policy” on our home page or directly using the postal service. This policy tries to convey Tokyo Dwell’s basic policy for protection of customers’ personal information collected by us. Please be advised to consult it periodically. (Note1: Concerning government-designated Real Estate Information NetWorks and so forth) Real Estate Information NetWorks are public interest corporations designated by the Minister of Land, Infrastructure and Transportation based on Section 2-2 of Article 502-2 of the Real Estate Business Law. The businesses they are performing are as follows: (I). Registration of land or buildings specified and confirm for covered by sole mediation contracts and other contracts related with real estate business, (II). Providing information with regard to the lands and buildings in the previous item to real estate agents periodically or at the request of such agents, (III). Taking statistics of the information in the previous item and other fairness and smoothness ensuring operation for land and building transactions adding to the performance described in the two previous items. We will take the following measures in accordance with the provisions with regard to Real Estate Information NetWorks of the Real Estate Business Law, etc.: i. We will register the property information with Real Estate Information NetWorks to search for potential buyers when we are asked to mediate to sell properties and conclude such contracts. The registered information of property and the names, addresses, etc. of selling parties will be provided to the members of Real Estate Information NetWorks. ii. We will send data regarding contract date, sale price, etc. to Real Estate Information NetWorks upon conclusion of contracts for our registered properties. iii. Real Estate Information NetWorks will use received property and contract information (outline of properties, contract dates, sale prices, etc. without sellers’ or buyers’ names) for their business performance in accordance with the Real Estate Business Law, within which provision of property and contract information to their member agents and public organizations through electronic measures is included. ix. As for sole mediation contracts and exclusive sole mediation contracts, the above-mentioned registration and notices, etc. will be carried out based on the provisions of the Real Estate Business Law. v. Interested parties or future [[parties who have decided to purchase one of our properties but have not yet concluded a purchase agreement]] purchasers of our properties are requested to buy the properties based on the measures with Real Estate Information NetWorks described in the above i. -ix. vi. When we mediate to buy properties using property information, etc. of Real Estate Information NetWorks, we will provide property information, etc. to the interested buying parties, meanwhile, such parties’ names, addresses, etc. will be provided to seller agents and selling parties. This provision will be discontinued at the request of the interested parties in person. vii. We will provide contract information received from Real Estate Information NetWorks (excluding names of purchasers and sellers) or acquired from our involvement in the dealings to our customers, etc. as evidence for our idea of sale or purchase price or our estimation. At that time some measures will be taken to make identification of the contracted property difficult. This provision will be discontinued at the request of the concerned parties in person. (Note 2) (Details of potential third party recipients of personal information from us) (1) The parties of the concerned agreements and such potential parties Common to both sale and purchase agreements and lease agreements of real estate, personal information such as customers’ addresses and names, outlines of properties, contract prices, contract date, etc. covered by the said agreements and instructions of important matters will be provided to the counterparts of the agreements. In the process to contract conclusion also, personal information such as customers’ addresses and names, outlines of properties, etc. documented in property advertisements and introductions, real estate purchase intention certificate and sale intention consent, and real estate lease application will, in some cases, be provided to potential buyers. (2) Third party real estate agents In the process to contract conclusion, soliciting for potential buyers widely, personal information such as customers’ addresses and names, outlines of properties, desirable prices, etc. (“PROPERTY INFORMATION”) will, in some cases, be provided to third party real estate agents. (3) Agents who advertise through internet media and real estate business organizations In the process to contract conclusion, soliciting for potential buyers widely, PROPERTY INFORMATION will, in some cases, be provided to agents who advertise through internet media and real estate business organizations. (4) Real Estate Information NetWorks designated by the Minister of Land, Infrastructure and Transportation Please refer to the above “Note1: Concerning government-designated Real Estate Information NetWorks and so forth”. (5) Judicial scriveners and real estate surveyors who deal with the properties, In the case of registration for transfer of real estate or deletion of mortgages, etc. through judicial scriveners or description registration or ownership preservation registration of buildings, or property extinction registration, etc., or land survey, etc. through real estate surveyors, personal information such as customers’ addresses and names, outlines of properties, etc. will be provided to those concerned. (6) Banking facilities which deal with financing In the case that customers use a house loan, private information such as customers’ addresses and names, birth dates, outlines of properties, annual income, etc. written in the loan application documents and life insurance application documents, such as preliminary application, group credit life insurance application and salary voucher will, in some cases, be provided to the banking facilities for loan purposes. (7) Caretaker companies of properties In the case that customers use services of contract overseeing, house cleaning, equipment management, etc., personal information such as customers’ addresses and names, outlines of properties, etc., will, in some cases, be provided to the caretaker companies of properties. (8) Dedicated real estate information service and surveillance companies ● Personal information such as customers’ addresses and names, outlines of properties, etc. , will, in some cases, be provided to house surveillance companies for checking building construction, equipment, etc. ● Private information such as customers’ addresses and names, outlines of properties, etc., will, in some cases, be provided to soil contamination surveillance companies. ● Personal information such as outlines of customers’ properties, contract dates, contract prices, etc. and lists of the properties and rents for lease (excluding customers’ names and telephone numbers, etc. which identify the customers directly) , will, in some cases, be provided to real estate price research companies dedicated for price research, etc. when necessary.　However, the information will be processed so that the properties cannot be identified easily by the organizations. (9) Credit information organizations Personal information such as applicant residents’ addresses and names, etc., will, in some cases, be provided to credit information organizations for credit reference when necessary.