robot home, Inc. and its subsidiaries (collectively, the “Company”), as a real estate technology enterprise, position artificial intelligence (“AI”) at the core of their business operations, and actively utilize AI in both the business operations of all employees and the development and provision of AI services for customers.
This AI 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 AI Privacy Policy (this “Policy”) regarding content or interpretation, the Japanese-language version shall prevail.
The Company duly recognizes both the benefits and value that AI provides and the risks pertaining to the protection of personal information and safety. The Company hereby establishes this Policy in accordance with applicable laws and regulations and guidelines published by relevant governmental authorities, and discloses its policies regarding the handling of personal information in connection with AI to its customers and the general public.
This Policy shall form an integral part of the Company’s Privacy Policy (the “Privacy Policy”) (https://corp.robothome.jp/en/privacy_policy). For the terms and conditions applicable to AI services for customers, please refer to the separately established AI Service Terms of Use (https://corp.robothome.jp/en/privacy_policy/ai-terms).

AI shall be positioned solely as a tool to augment and support human judgment and capabilities. With respect to matters that may materially affect the rights and interests of customers, no final determination shall be made based solely on the output of AI, and human review and approval shall be required in all cases.

The Company is engaged with AI in the following two capacities with reference to the classification of entities defined in the AI Business Operators Guidelines:

(1) Position as an AI Business User
The Company utilizes external generative AI services for the purpose of operational efficiency and quality improvement by all employees. In its capacity as an AI Business User, the Company implements the following measures: preventing the inappropriate input of personal information; implementing countermeasures against privacy infringements; preventing the use of input data for AI model training; and ensuring a final human judgment.

(2) Position as an AI Provider
The Company develops and provides AI-powered services to support the asset management, investment decisions, rental property management, and other utilization of services by its customers. In its capacity as an AI Provider, the Company implements the following measures: providing privacy by design; disclosing service terms and privacy policies; promoting appropriate use; implementing countermeasures against privacy infringements; and disclosing the limitations of AI output.

The Company shall disclose the types of AI utilized or provided by the Company and the purposes thereof in a manner comprehensible to customers and the general public.

The Company shall comply with Japan’s Act on the Protection of Personal Information (the “APPI”), and other applicable laws and regulations, and shall continuously implement technical and organizational measures to prevent the leakage, unauthorized use, and privacy infringement of personal information through AI services.

The Company shall manage data quality and monitor outputs to ensure that AI outputs do not contain biases or unfair discrimination.

This Policy applies to the scope set forth in the following items:
(1) All AI services utilized by the Company for the performance of duties by its employees;
(2) AI-powered services developed and provided by the Company for its customers; and
(3) The handling of personal information acquired, used, or provided by the Company in connection with the preceding items.

The input of information into AI services and AI platform services utilized by the Company may constitute the provision of personal information (cross-border transfer) to the country in which the service providers are located (principally the United States). The Company shall carry out such transfers only after confirming, pursuant to Article 28 of the APPI and the rules thereunder, that such provider has established a system conforming to the standards prescribed therein. The Company shall implement measures necessary to ensure the continued implementation of the equivalent measures by such provider, and information regarding such measures shall be provided upon request to the inquiry desk.
For information regarding the personal information protection systems in foreign countries such as the United States, please refer to the website of the Personal Information Protection Commission (https://www.ppc.go.jp/enforcement/infoprovision/laws/).

The categories and purposes of use of the AI services for customers provided by the Company are set out in Section 3.2 (Categories of AI Services Provided) of the AI Service Terms of Use. The purposes for which the Company handles personal information through AI used in its business operations are as prescribed in Section 5 (Acquisition, Use, and Provision of Personal Information and Retained Personal Data) of the Privacy Policy.
In cases where the Company handles personal information in connection with the use of AI, such handling shall be conducted in compliance with the following:

(1) Scope of Information Input
Information that directly identifies individuals, such as names, addresses, and contact details, shall be anonymized or pseudonymized to the extent practicable prior to input.

(2) Handling of Sensitive Personal Information
In cases where sensitive personal information, including medical history, disability information, and criminal records, is to be processed by AI services, the prior approval of the Personal Information Protection Manager must be obtained.

(3) Prohibition of Use for AI Model Training
The Company shall implement appropriate measures, such as opt-out settings or the execution of enterprise agreements, to ensure that customers’ personal information is not used for the training or improvement of AI models by any AI service.

(4) Prohibition of Automated Decision-Making
No determination that materially affects the rights and interests of customers shall be made solely on the basis of the output of AI.

(5) Profiling
In the Property Recommendation service, the Company analyzes customer attributes and app activity logs to generate recommendations (profiling).

The Company shall retain 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. Any personal information contained in such logs shall be promptly deleted, anonymized, or otherwise addressed upon the expiration of the retention period. The Company shall retain such logs in principle for a period of one year.

The AI-related services approved by the Company for business use shall be limited to those approved in accordance with the Company’s internal regulations, and the use of any unapproved services for business purposes is prohibited.
Employees shall verify and validate the output of AI in all cases and shall not provide such output to external parties without factual confirmation. In the event that personal information is inadvertently input or a suspicion of information leakage arises, the matter shall be reported immediately to the Personal Information Protection Manager.

The person bearing ultimate responsibility for the protection of personal information in connection with the utilization of AI shall be the Personal Information Protection Manager as designated in the Privacy Policy.

The Personal Information Protection Manager shall conduct periodic audits to confirm the following: the compliance status of employees with this Policy; the existence and impact of any amendments to the privacy policies and terms of use of each AI service provider; the continued adequacy of the personal information protection systems of cross-border transfer recipients; and the status of incident occurrence and the implementation of corrective measures.

The Company shall conduct education and training programs regarding the safe use of AI for all employees on a regular basis.

For the procedures for exercising the rights set forth below, please submit a request in accordance with the procedures prescribed in Section 10 (Requests for Disclosure of Personal Information) of the Privacy Policy.

The Company may amend this Policy at any time in response to amendments to applicable laws and regulations, the addition, modification, or discontinuation of AI services, changes in social circumstances, or other relevant factors. In the event of any material amendments being made, the Company shall notify customers by publication on the Company’s website or by other appropriate means.

Any questions, complaints, or comments regarding this Policy or the Company’s use of AI, or requests for the exercise of rights relating to personal information, should be directed to the Company through the inquiry desk set forth in Section 14 (Inquiries) of the Privacy Policy (https://corp.robothome.jp/en/privacy_policy).