Raysum Co., Ltd. (the “Company” or “we”) has established the following privacy policy (this “Policy”) to protect the personal information of customers (including representatives of our business partners), shareholders, employees, and job applicants. We handle personal information appropriately in accordance with this Policy.
The terms used in this Policy have the meanings ascribed to them in the Act on the Protection of Personal Information (the “Personal Information Protection Act”).

1. Purposes of Use

We collect and use customers’ personal information for the following purposes (the “Purposes of Use”):

1. ①To acquire, evaluate, invest in, and sell real estate or rights thereto, and to act as an intermediary in such transactions
2. ②To own, lease, manage (including property management services), and operate real estate
3. ③To conduct real estate development, land preparation, construction, and architectural design supervision
4. ④To plan, design and carry out interior construction work
5. ⑤To own, lease and operate hotels, restaurants, sports facilities, and similar facilities
6. ⑥To provide management consulting services
7. ⑦To buy, sell, hold, and manage securities and instruments deemed to constitute securities
8. ⑧To conduct other financial instruments business and business under the Act on Specified Joint Real Estate Ventures, as well as related operations of the Company and our affiliates
9. ⑨To purchase receivables and perform administrative services related to their management
10. ⑩To act as an agent for non-life insurance services
11. ⑪To accept reservations for, and provide, accommodation, saunas, workrooms, and other services offered by the Company and our affiliates
12. ⑫To buy and sell works of art (paintings, ceramics, sculptures and prints)
13. ⑬To provide support for the establishment and operation of hospitals and clinics
14. ⑭To design, develop, manufacture, sell, lease, install and maintain gas engine generators
15. ⑮To respond to inquiries and communicate with customers
16. ⑯To perform administrative tasks related to shareholder management
17. ⑰To pay salaries, submit withholding tax certificates and other required documents to public authorities, and conduct recruitment-related operations
18. ⑱To handle personnel affairs, labor management, compliance with labor-related laws and regulations, employee benefits, and other administrative communications concerning employees
19. ⑲To provide customers with information on products and services, including real estate and investment products, offered by the Company and our Group companies (as defined in 3.(3)), or trusted third parties, and to conduct other marketing activities
20. ⑳To provide personal information to third parties in the manner set forth in this Policy

We may also collect and use customers’ personal information for operations related to the above purposes within our group companies.

2. Provision to Third Parties

1. 1)Except as permitted by laws and regulations, we will not provide any personal information we handle to third parties without obtaining the prior consent of the individual concerned.
2. 2)Notwithstanding paragraph 1) above, we may provide personal information we handle to third parties in the following cases:
   1. ①(i) For the purposes described in items ①, ②, ⑦, and ⑧ of Section 1, we may provide personal information, such as real estate information, transaction details, account information, financial information, asset information, workplace information, names, addresses, telephone numbers, and email addresses, relating to property owners, tenants, and contracting parties, to:
      • counterparties to relevant contracts
      • transferees of property
      • property management companies (including repair contractors and their subcontractors)
      • guarantee companies
      • affiliated insurance agencies
      • other real estate brokers or financial instruments business operators
      • trust service providers, intermediaries, and credit research companies
      • financial institutions involved in loans or other financing
      • designated distribution organizations
      • professionals such as attorneys and judicial scriveners
   2. ②(ii) For the purpose described in item ⑯ of Section 1, we may provide shareholders’ personal information to credit research companies
   3. ③(iii) For the purpose described in item ⑰ of Section 1, we may provide personal information submitted by employees and job applicants to credit research companies

3. Shared Use

We share personal information as follows.

1. 1.Items of personal information to be shared
   Names, addresses, telephone numbers, email addresses, transaction details, account information, financial information, asset information, workplace information, emergency contact details, and information concerning customers’ relatives
2. 2.Purpose of shared use
   The Purposes of Use described in Section 1 above
3. 3.Scope of shared users
   Our group companies (see list below).
4. 4.Party responsible for managing shared use
   Company name: Raysum Co., Ltd. (Representative Director: Tsuyoshi Komachi)
   Location: 2-1, Kasumigaseki 3-chome, Chiyoda-ku, Tokyo
   

4. Outsourcing the Handling of Personal Information

To ensure the smooth and efficient operation of our business, we may outsource the handling of personal information to third parties with whom we have entered into outsourcing agreements. The personal information entrusted to such service providers will be handled only within the scope of the Purposes of Use, and we will exercise necessary and appropriate supervision to ensure that such providers do not disclose, use, or dispose of the information beyond that scope.

5. Security Control Measures

We take necessary and appropriate measures to prevent the leakage, loss, or damage of the personal information we handle, and to ensure the secure management of such information. For details about our security control measures, please contact our Inquiry Desk.

6. Requests for Disclosure, etc.

When we receive, from a customer in accordance with applicable laws and regulations, requests for disclosure, etc. (meaning requests for notification of the purpose of use, disclosure of personal information or records of provision to third parties, correction, addition, or deletion of personal information, or suspension of use or provision to third parties), we will respond in accordance with our prescribed procedures. Please note that a handling fee will be charged for processing a request for disclosure, etc.

7. Handling of Cookies

1. 1)Use of cookies
   Our website uses cookies and other similar technologies for tracking and analysis (collectively, “cookies”).
   1. ①(i) Cookie overview
      A cookie is a small file containing a string of characters that is exchanged between a web server and a visitor’s Internet browser and stored on the visitor’s device when the visitor accesses a website. By using cookies, we may obtain non-personally identifiable information such as customers’ browsing histories, service usage histories, and location information.
      Customers can configure their browsers to display a notification when a website uses cookies, disable the use of cookies, or delete stored cookies. Please note that disabling or deleting cookies may limit the functionality available on our website.
   2. ②(ii) About Google Analytics
      We may use Google Analytics, a service provided by Google LLC. When we use Google Analytics, Google collects and analyzes browsing histories based on cookies set by us or by Google. We may receive the results of this analysis and use them to understand website usage and improve our services. For more information on how Google handles data in connection with Google Analytics, please refer to the following page on Google’s website:
      How Google uses information from sites or apps that use our services
      https://policies.google.com/technologies/partner-sites?hl=en
2. 2)Acquisition of information from third parties
   We may obtain customers’ browsing histories, service usage histories, location information, and similar data from other group companies and partner businesses (including, but not limited to, DMP operators, advertising companies, research and analysis firms, media companies, and database management companies). We may link such data with customers’ personal information and use it for the purposes listed in Section 1.

8. Inquiries Desk

Please contact us if you have any comments, questions, complaints, or other inquiries regarding our handling of personal information.

＜Contact＞
100-0013
Company name: Raysum Co., Ltd.
Address: Kasumigaseki Common Gate West Tower 36th Floor, 3-2-1 Kasumigaseki, Chiyoda-ku, Tokyo
Telephone: 03-5157-8890

*List of Group Companies

• Etajimasou Co., Ltd.
• Karuizawa Oiwake Resort Co. Ltd.
• Nami Co. Ltd.
• Nature Inn Osekan Co. Ltd.
• RayPower Inc.
• Raysum Capital Co. Ltd.
• Raysum Fukuoka Inc.
• Best Medical Co. Ltd.
• LIBERTE JAPON Co. Ltd.
• LIVLA Co. Ltd.
• WeBase Co. Ltd.
• Reiju Medical Co. Ltd.

Enacted: April 4, 2025
Raysum Co., Ltd.
Tsuyoshi Komachi, President and Representative Director