robot home, Inc. and its subsidiaries (collectively, the “Company”) hereby establish this Privacy Policy for the purpose of appropriately managing and protecting personal information handled in the course of their business activities, and building a personal information protection framework that provides assurance to the individuals whose personal information is handled.
This Privacy Policy is based on the Japanese-language version as the original. In the event that any conflict or inconsistency exists between the Japanese version and this English-language Privacy Policy regarding content or interpretation, the Japanese-language version shall prevail.

This Privacy Policy applies to customers, business partners, shareholders, job applicants, employees, and all other persons involved in the Company’s business activities (collectively, “Users”) who access or use the Company’s services, products, applications, websites, and similar offerings (collectively, the “Services”). In cases where the handling of personal information is individually prescribed in the Services, such individual provisions (the “Individual Provisions”) shall apply in addition to this Privacy Policy. In the event of any conflict or inconsistency between this Privacy Policy and the Individual Provisions, the Individual Provisions shall prevail.
The handling of personal information by third-party services, products, applications, websites, or similar offerings is outside the scope of this Privacy Policy.

The Company’s Personal Information Protection Manager is as follows:
Head of Compliance Division
Contact: robot home, Inc. Personal Information Inquiry Desk (please refer to Section 14 (Inquiries) below).

The Company shall comply with Japan’s Act on the Protection of Personal Information (the “APPI”), other applicable laws and regulations, guidelines, and similar provisions with respect to the acquisition, use, and all other handling of personal information.

The Company acquires personal information by appropriate means within the scope necessary for the performance of its business, taking the nature and scale of its business into account. The personal information acquired is as follows:

(1) Personal Information Provided by Users
Name, gender, address, date of birth, telephone number, email address, payment information, identity verification information, and similar information.
All or part of the personal information listed above is required to be provided by Users. If such information is not provided, Users may be unable to use all or part of the Services.
The Company may also acquire all or part of the personal information listed above through methods that are legally permissible, such as via certified copies of registration records and published materials.
(2) Personal Information Automatically Acquired by the Company
Cookies and similar technologies, access logs (information such as IP addresses, browser types, and browser languages), information regarding the usage of the Services, location information, device information (OS, device identification numbers, computer names), still images acquired through security cameras and similar devices, the contents of telephone calls, SMS messages, chats, and other communications with the Company, the contents of inputs into the Company’s services (including prompts submitted to AI services), and similar information.
When Users visit the Company’s website, enter information in the Company’s web forms, or use the Services, the Company may automatically acquire all or part of the information listed above.
The Company also uses cookies for the purpose of improving convenience and understanding usage conditions. Furthermore, depending on the Services, third-party services such as Google Analytics may be used. Users may choose whether or not to accept cookies; however, if Users refuse to save cookies, some features of the Services may become unavailable. For more details regarding cookies, please refer to the Company’s Cookie Policy.
(3) Personal Information Collected from Employees (including officers, employees’ family members, and former employees)
Name, gender, address, date of birth, telephone number, email address, payment information, identity verification information, information regarding career and work history, information regarding family members, information regarding attendance and leaves of absence, records of entry to and exit from premises, information regarding personnel evaluations, etc., as well as the results of health checkups and stress checks and other health-related information (including sensitive personal information).
The Company acquires and uses Individual Numbers (My Number) only within the scope of the affairs prescribed by the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures, and the purposes of use thereof are separately notified in writing.

The Company shall acquire, use, and provide personal information and retained personal data within the scope of the purposes set forth in each of the following items. Except with the prior consent of the individual concerned or as otherwise permitted under applicable laws and regulations, the Company shall not handle personal information beyond the scope necessary to achieve such purposes. The Company shall also implement the measures necessary to ensure that personal information is handled within the scope of such purposes. The Company may analyze the personal information of Users in order to estimate their interests, tendencies, and other information, and may use personal information within the scope of the purposes set forth in each of the following items. With respect to persons falling within any of the categories set forth in Sections 5.2 through 5.5, the Company shall use their personal information for the purposes set forth in the applicable category in addition to the purposes set forth in Section 5.1. The purposes set forth in Sections 5.6 and 5.7 apply to all categories. In this Privacy Policy, the term “group companies” refers to consolidated subsidiaries and equity-method affiliates as disclosed in the Company’s annual securities report and similar filings (of which the consolidated subsidiaries are included in the “Company” as defined at the beginning of this Privacy Policy).

(a) Providing the Services, and planning, developing, and improving the same
(b) Performing identity verification and communication in connection with various procedures
(c) Billing, collection, settlement, and reminders for consideration for the Services, and the management, preservation, and recovery of receivables
(d) Making communications as necessary, including important notices regarding the Services
(e) Responding to inquiries and requests, and recording the contents thereof and using such records to improve the quality of responses, verify facts, and provide internal training (including the recording of telephone calls)
(f) Conducting surveys for the purpose of improving the quality of the Services
(g) Introducing rental properties; screening applications for tenancy (including the verification of joint guarantors and emergency contacts); conducting procedures for the execution, renewal, modification, and termination of lease agreements; and responding to inquiries and emergencies during the term of tenancy
(h) Performing maintenance, repair, restoration to original condition, and construction work at rental properties under management, and reporting on management status to the lessors
(i) Communicating with brokerage agents and other counterparties, and providing vacancy information and other property information
(j) Conducting crime prevention and response to accidents and incidents at rental properties under management and other facilities managed by the Company, and conducting the prevention of illegal dumping, improper waste disposal, intrusion by suspicious persons, and other incidents (including the review of still images acquired by security cameras and similar devices)
(k) Performing delivery of advertising information (including the delivery of advertisements tailored to Users’ interests based on the results of analysis of their browsing history, purchase history, usage status, and similar information, whether on the Company’s websites, applications, or other media, or through advertising delivery service providers)
(l) Providing Services customized according to Users’ usage status, location information, device information, and similar information
(m) Conducting market research and customer trend analysis, and research and analysis for the development of products and sales methods, and creating statistical information, pseudonymously processed information, and anonymously processed information
(n) Providing information regarding the products, services, events, campaigns, and similar offerings of the Company, its group companies, or business partners, and conducting sales activities by postal mail, e-mail, telephone, or other means

(a) Engaging in communications, negotiations, meetings, and similar matters related to transactions
(b) Managing business partner information, and preparing and managing agreements and other documents
(c) Screening in connection with the commencement and continuation of transactions (including confirmation as to whether a counterparty falls under anti-social forces, and credit management)
(d) Billing, payment, and settlement of consideration, and the preparation of statutory records and similar documents

(a) Exercising rights or performing obligations based on applicable laws
(b) Providing information and various notices from the Company to shareholders
(c) Implementing various measures to facilitate the relationship between shareholders and the Company
(d) Preparing shareholder data based on prescribed criteria under applicable laws and other shareholder management

(a) Conducting recruitment activities (communications regarding selection, provision of information, etc.)
(b) Preparing statistical materials for the analysis and improvement of recruitment activities
(c) Recording and retaining selection results, and referring to such records in the event of a subsequent application

(a) Conducting personnel management, payment of salaries, and other labor management
(b) Conducting welfare benefits and occupational health and safety management (including the handling of results of health examinations and stress checks and other information relating to health)
(c) Conducting education and training programs
(d) Making business communications and emergency contacts
(e) Publishing names, affiliations, photographs, and similar information in internal newsletters, on the Company’s website, in recruitment media, and the like, and other public relations activities
(f) Managing entry to and exit from the Company’s offices and other facilities and ensuring the safety of such facilities

(a) Conducting business processing, analysis, content generation, and enhancement of Services utilizing AI (artificial intelligence)
(b) Monitoring and preventing illegal dumping, improper waste disposal, intrusion by suspicious persons, and other incidents at rental properties under management (including analyzing security camera images using AI)
(c) Managing the quality of responses to inquiries and detecting high-risk consultation matters (including analyzing telephone calls, SMS messages, chats, and similar communications using AI)

(a) Detecting and preventing unauthorized access, unauthorized use, and other wrongful acts, and ensuring information security
(b) Responding to matters based on laws, regulations, ordinances, guidelines, and the like (including responses to inquiries from public authorities)
(c) Exercising rights and performing obligations under agreements, resolving disputes, and responding to other legal proceedings
(d) Responding to internal and external audits

The Company may share acquired personal information with third parties as set forth below: sharing with the Company’s group companies for joint use; provision to advertising delivery service providers; entrustment to contractors (service providers) and other third parties; disclosure to public authorities as required under applicable laws and regulations; provision to a successor in connection with a business succession; or the provision of personally referable information to third parties. In making any of the foregoing provisions, the Company may provide personal information to providers located in foreign countries.

(1) Group Companies
The Company may jointly use personal information acquired directly or indirectly by the Company or its group companies through the sharing of written or electronic data between the Company and its group companies. The items and purposes of such joint use are as described in Sections 4 (Personal Information Acquired) and 5 (Acquisition, Use, and Provision of Personal Information and Retained Personal Data) above. The Company shall be responsible for the management of jointly used personal information. The person responsible for the management of jointly used personal data is robot home, Inc. (6-10-1 Ginza, Chuo-ku, Tokyo, Japan; Daisaku Furuki, Representative Director and CEO). The term “group companies” has the meaning set forth in Section 5 above.
(2) Provision to Advertising Delivery Service Providers
The Company may provide personal information to advertising delivery service providers in order to perform delivery of advertising information (including the delivery of advertisements tailored to Users’ interests based on the results of analysis of their browsing history, purchase history, usage status, and similar information, whether on the Company’s websites, applications, or other media, or through advertising delivery service providers) and to achieve the purposes of use described in Section 5 above (“Acquisition, Use, and Provision of Personal Information and Retained Personal Data”). For example, when using advertising delivery services provided by Meta Platforms, Inc. (located in the United States), the Company may transmit hashed versions of Users’ email addresses, telephone numbers, names, addresses, dates of birth, and other such information to Meta Platforms, Inc. via tags on the Company’s websites. By agreeing to this Privacy Policy after reviewing the information below, Users are deemed to have consented to the provision of their information to said company located in a foreign country.
Personal information protection system in the United States: https://www.ppc.go.jp/enforcement/infoprovision/laws/offshore_report_america#federal
Measures taken by the service provider company: The service provider company implements measures for personal information protection that align with the eight principles of the OECD Privacy Guidelines.
(3) Provision to Providers of Website Analytics Tools
The Company may provide personal information to providers of website analytics tools used to analyze usage of the Company’s websites. For example, when using Microsoft Clarity (provided by Microsoft Corporation, based in the United States), the Company may transmit information regarding Users’ browsing history, input actions, and other usage details to such analytics tool provider company. By agreeing to this Privacy Policy after reviewing the information below, Users are deemed to have consented to the provision of their information to said company located in a foreign country.
Personal information protection system in the United States: https://www.ppc.go.jp/enforcement/infoprovision/laws/offshore_report_america#federal
Measures taken by the analytics tool provider company: The analytics tool provider company implements measures for personal information protection that align with the eight principles of the OECD Privacy Guidelines.

(4) Contractors (Service Providers)
The Company may entrust all or part of its operations to third parties such as marketing companies and IT service providers (collectively, “Contractors”). In such cases, the Company may provide personal information to Contractors to achieve the purposes of use described in Section 5 above. Personal information provided to Contractors shall be used in accordance with the original purposes of use and under the Company’s instructions.
In utilizing AI for its business operations, the Company may entrust the processing of personal information to AI platform service providers. Such providers shall handle personal information under the Company’s instructions as contractors pursuant to Article 25 of the APPI.

(5) Legal Obligations
As required by applicable laws and regulations, the Company may disclose personal information to public authorities responsible for law enforcement in response to legal requirements, court orders, and requests from governmental agencies or law enforcement authorities (including governmental agencies and courts of countries in which the Company conducts business).

(6) Business Succession
In the event that the Company’s business is succeeded to by reason of a merger, a company split, a business transfer, or any other cause, the Company may provide personal data to the successor. In such event, such personal data shall be handled within the scope of the purposes of use applicable prior to the succession.
(7) Provision to Providers Located in Foreign Countries
In making the provisions of personal information set forth in (1) through (6) above, the Company may provide personal information to providers located in foreign countries. Except where the Company makes such provision after obtaining the individual consent of the Users to permit the provision to a third party located in a foreign country, the Company shall first confirm that such provider has established a system conforming to the standards prescribed in Article 28 of the APPI and the rules thereunder, and shall take the measures necessary to ensure the continued implementation of the equivalent measures by such provider. Information regarding the measures taken by such provider shall be provided upon request to the inquiry desk.
(8) Provision of Personally Referable Information to Third Parties
The Company may permit advertising delivery service providers and other third parties to acquire information such as Users’ browsing history and usage status of the Services through cookies, advertising identifiers, and similar technologies on the Company’s websites and other media. To the extent that the Company cannot identify a specific individual from such information, it constitutes personally referable information under the APPI.
In cases where it is anticipated that a third party will acquire such personally referable information as personal data, the Company shall, pursuant to Article 31, Paragraph 1 of the APPI, confirm in advance that the consent of the Users has been obtained before doing so.
For the types of cookies, their purposes, the relevant third parties, and how to control them (including how to opt out), please refer to the Cookie Policy posted on the Company’s websites. Users may refuse the storage of cookies through their browser settings and may also cease the use of cookies by each third party through such third party’s opt-out page.

The Company may transfer personal information of Users residing within the European Economic Area (the “EEA”) to entities in countries outside the EEA. Even in such cases, the Company shall implement measures to ensure an adequate level of protection of personal information (including the execution of Standard Contractual Clauses under the General Data Protection Regulation (GDPR)).

6.3.1 The Company utilizes AI services through all of its employees for the purposes of achieving operational efficiency and service improvement. For details of the personal information protection systems relating to AI services, please refer to the Company’s AI Privacy Policy.
6.3.2 The use of AI services may lead to the personal information of Users being transferred to the country in which such services are operated (principally the United States). The measures taken by the Company in such cases are as set forth in Section 6.1(7) (Provision to Providers Located in Foreign Countries) above.
6.3.3 The Company shall implement appropriate measures, such as opt-out settings or the execution of enterprise agreements, to ensure that personal information is not used by each AI service for the training or improvement of AI models.
6.3.4 The Company shall retain the input/output logs, determination results, and review records of AI services for customers for the period necessary for providing such services, performing quality management, preventing unauthorized use, responding to inquiries, and ensuring traceability. The Company shall retain such logs in principle for a period of one year, and the personal information contained in such logs shall be promptly deleted, anonymized, or otherwise addressed upon the expiration of the retention period.
6.3.5 For details regarding the use of AI (the Company’s position with respect to AI, overview of AI services provided, legal classification of services, governance framework, etc.), please refer to the Company’s AI Privacy Policy and AI Service Terms of Use.

(1) Preventive Measures Against Leakage, Loss, and Damage of Personal Information and Retained Personal Data
The Company implements necessary and appropriate safety management measures to prevent the leakage, loss, damage, and similar incidents involving personal information and retained personal data. The Company also conducts employee education and supervision to ensure the proper handling of personal information and retained personal data. In cases where all or part of the handling of personal information and retained personal data is entrusted to a third party, the Company strictly selects Contractors and exercises necessary and appropriate supervision over such Contractors.
(2) Corrective Measures Against Leakage, Loss, and Damage of Personal Information and Retained Personal Data
In the event of an incident such as the leakage, loss, or damage of personal information or retained personal data, the Company shall prioritize preventing further damage, promptly implement corrective measures, investigate the cause, and endeavor to prevent any recurrence. Information regarding such incidents shall be reported to Users, relevant parties, and relevant authorities, to the extent necessary.

(3) Privacy Policy Based on JIS Q 15001
The Company has formulated personal information protection regulations and related provisions based on a privacy policy that conforms to JIS Q 15001, and operates a personal information protection management system with an understanding of the external environment, for the purpose of handling personal information with greater rigor.
(4) Measures Taken for the Safety Management of Personal Information
The Company implements the following safety management measures in handling personal information:
(a) Organizational Safety Management Measures: The Company has appointed a Personal Information Protection Manager, clarified the scope of employees who handle personal data and the range of such data, established a reporting and communication system for cases where violations of laws or regulations or signs thereof are identified, and conducts periodic self-inspections and internal audits.
(b) Human Safety Management Measures: The Company conducts periodic training for employees regarding points to pay attention to in the handling of personal data, and has established confidentiality provisions in its employment regulations.
(c) Physical Safety Management Measures: The Company implements measures for the management of areas where personal data is handled, the prevention of theft of devices and electronic media, the deletion of personal data, and the disposal of devices.
(d) Technical Safety Management Measures: The Company limits the scope of persons in charge and personal information databases handled through access controls, and has introduced mechanisms to protect against unauthorized external access and malicious software.
(e) Assessment of the External Environment: The Company utilizes AI platform service providers located in foreign countries (principally the United States) for the purposes of achieving operational efficiency and providing AI services for customers. The Company also utilizes a provider located in China for the communication and control of IoT devices through its applications. In addition, the Company may handle personal information in foreign countries (including the United States, Canada, Australia and Germany) depending on the locations of the servers of cloud service providers and the like. Please check the information provided by the Personal Information Protection Commission at the links below regarding the systems in the United States, China, Canada, Australia and Germany. The Company implements safety management measures with an understanding of the systems for the protection of personal information in these countries.
United States: https://www.ppc.go.jp/enforcement/infoprovision/laws/offshore_report_america#federal
California: https://www.ppc.go.jp/enforcement/infoprovision/laws/offshore_report_america#california
China: https://www.ppc.go.jp/enforcement/infoprovision/laws/offshore_report_china/
Canada: https://www.ppc.go.jp/enforcement/infoprovision/laws/offshore_report_canada/
Australia: https://www.ppc.go.jp/enforcement/infoprovision/laws/offshore_report_australia/
Germany (EU General Data Protection Regulation (GDPR)): https://www.ppc.go.jp/enforcement/infoprovision/EU/

Except as otherwise provided under applicable laws and regulations, the Company shall determine the retention period of personal information within the scope necessary for the purposes of use, and shall delete personal information without delay after the expiration of such period or the achievement of the purposes of use. In cases where there are technical limitations that prevent deletion or anonymization, the Company shall securely protect the personal information and restrict its active use.

The Company implements necessary and appropriate human, organizational, and technical safety management measures to prevent unauthorized access to personal information and the leakage, loss, and damage of personal information. The Company also periodically reviews these safety management measures, has established processes for correction, and endeavors to continuously improve its personal information protection management system.

10.1 Users who wish to request notification of the purposes of use, disclosure, correction, addition or deletion of contents, suspension of use, erasure, cessation of provision to third parties, or disclosure of third-party provision records (collectively, “Disclosure Requests”) with respect to retained personal data, must submit a request in accordance with the Company’s prescribed procedures. For the procedures for Disclosure Requests, please refer to the “Procedures for Disclosure Requests Regarding Retained Personal Data” posted on the Company’s website (https://corp.robothome.jp/en/privacy_policy#publicnotice_en).

(a) The right to object to the Company’s collection, processing, or use of personal information;
(b) The right to receive necessary information when the Company collects personal information;
(c) The right to access personal information;
(d) The right to request correction of personal information;
(e) The right to request deletion of personal information;
(f) The right to request the restriction of processing applicable to personal information;
(g) The right to data portability of personal information;
(h) The right to withdraw consent; and
(i) The right to lodge a complaint with a supervisory authority
Users who wish to exercise the rights set forth in this Section 10.2 are requested to contact the robot home, Inc. Personal Information Inquiry Desk (please refer to Section 14 (Inquiries) below).

The Company does not intentionally acquire personal information from Users under the age of 16. Users under the age of 16 must have a parent or guardian review the content of this Privacy Policy and obtain the consent of such parent or guardian before using the Services. Please contact the robot home, Inc. Personal Information Inquiry Desk (please refer to Section 14 (Inquiries) below) if it becomes known that a User under the age of 16 has consented to this Privacy Policy and accessed or used the Services without the review and consent of a parent or guardian. Please note that the AI Services are provided only for persons aged 18 years or older (Section 2(4) of the AI Service Terms of Use).

With respect to the handling of personal information of Users residing in regions other than Japan or countries within the EEA, the following provisions shall apply based on the laws and regulations of such regions:

(1) California
Users residing in California, United States, have the right to request certain information regarding the Company’s sharing of their personal information with third parties for direct marketing purposes. Users who wish to exercise this right are requested to contact the robot home, Inc. Personal Information Inquiry Desk (please refer to Section 14 (Inquiries) below).

(2) China
Users residing in China shall acknowledge in advance that the Company may transfer their personal information to third parties outside of China.

The Company reserves the right to amend this Privacy Policy at any time to reflect the latest privacy practices. When the Company amends this Privacy Policy, the Company shall notify Users of the amended Privacy Policy through publication on the Company’s website or other appropriate means. The amended Privacy Policy shall take effect on the designated date of revision.

Any questions, complaints, consultations, or other inquiries regarding this Privacy Policy or the Company’s handling of personal information should be directed to the following:
robot home, Inc. Personal Information Inquiry Desk
https://corp.robothome.jp/en/contact

15.1 The Company may create pseudonymously processed information and anonymously processed information from the personal information it has acquired, within the scope of the purposes of use set forth in Section 5.
15.2 In cases where the Company creates anonymously processed information, the Company shall publicly announce the categories of information relating to individuals contained in such anonymously processed information.
Sensitive personal information and Individual Numbers (My Number) are not used to create anonymously processed information.
15.3 In cases where the Company provides anonymously processed information to a third party, the Company shall, in advance, publicly announce the categories of information relating to individuals contained in such anonymously processed information and the method of provision, and shall expressly indicate to such third party that the information provided is anonymously processed information.
15.4 In handling anonymously processed information, the Company shall not collate such information with other information for the purpose of identifying the individual relating to the personal information used to create it.
15.5 With respect to pseudonymously processed information, the Company shall, pursuant to Article 41 of the APPI, not provide such information to third parties except as required by laws and regulations, not collate such information with other information for the purpose of identifying the individual, and not use contact details or other information contained therein to contact the individual.