Privacy Policy

1. 1.Contact information: name, address, telephone number, fax number, and email address;
2. 2.Identifying information: date of birth (age), gender, nationality, place of origin, residence, licenses, photographs, passport, visas or other government-issued identification data, background (education, job history, etc.), company name, job title, and family structure;
3. 3.Other information about Stakeholders: customer code number, registered seal, or any other description;
4. 4.Audio and video information: The content of calls made to ORIA to when making inquiries and images from security cameras when at ORIA’s properties;
5. 5.Financial information: invoice address, credit or debit card number or other payment-related data, and bank account information;
6. 6.Details regarding inquiries of the Business;
7. 7.Locational information and actions on networks: IP address, mobile device locational information, access information for our home page, device settings, log information, usage time, browser version information, operating system, browsing history, user ID, types of information viewed, and cookie and similar data;
8. 8.Credit information: Information that must be collected pursuant to relevant laws and regulations, such as information for identity confirmation purposes; and
9. 9.Any other information Stakeholders elect to provide directly to ORIA in connection with the Business.

1. 1.Information provided by Stakeholders: acquired though face-to-face, telephone, mail and e-mail interactions, acquired through the filing out of applications, contracts, online forms, and questionnaires;
2. 2.Information provided by others: acquired through business associates, subcontractors, business partners, company-operated stores, franchise stores, and service providers, etc.;
3. 3.Technical information acquired during the use of services; and
4. 4.Information acquired as a result of merger and other transactions that result in business succession.

Stakeholders may refuse to provide personal information to ORIA but the decision not to provide certain personal information to ORIA may result in ORIA not being able to provide certain products, services (including the Business) and any other benefit to such Stakeholders.

1. 1.Stakeholders’ consent;
2. 2.Necessary for implementing the affairs of the Business;
3. 3.Necessary for ORIA to fulfill its legal obligations;
4. 4.Necessary to protect vital interests; or
5. 5.Required for ORIA’s legitimate interests or those of a third party, provided that if such interests are overridden by interests or fundamental rights and freedoms of Stakeholders, ORIA will not process personal information of Stakeholders. ORIA’s legitimate interests are specified in more detail in Section 8 “Purpose for Processing of Personal Information” below.

1. 1.ORIA may process personal information of Stakeholders (including former stakeholders to the extent necessary to achieve the purpose of processing; the same shall apply hereinafter in this Privacy Policy) within the scope of the purposes set forth below.
   1. ①To conduct operations relating to the management of assets entrusted to ORIA.
   2. ②To contact Stakeholders and respond to inquiries from Stakeholders or requests for materials.
   3. ③To report management results, asset balances, transaction results, and other matters to entrustors of asset management.
   4. ④To carry out ORIA’s settlement of accounts and other accounting and tax-related operations.
   5. ⑤To seek advice from professionals, including attorneys, certified public accountants, certified tax accountants, real estate appraisers, judicial scriveners, and licensed social insurance consultants, etc.
   6. ⑥To conduct operations incidental or related to the preceding items.
   7. ⑦To provide personal information to third parties in order to achieve the purposes set forth in the preceding items. Such third parties may include financial institutions with which entrustors of asset management conduct transactions, non-life insurance companies, professionals, real estate brokers, property management companies, prospective purchasers or tenants of Properties, information processing companies, research companies, and other similar parties.
2. Notwithstanding the foregoing, the following purposes of processing shall apply to the personal information of job applicants:
   1. ①To conduct screening for internships and recruitment selection, including interviews, examinations, and similar procedures.
   2. ②To conduct ORIA’s recruitment activities, including providing information on seminars and other matters related to recruitment activities, communicating with applicants, and using questionnaires and similar materials for reference in future recruitment activities.
   3. ③With respect to the personal information of persons hired as a result of recruitment selection, to manage such information as part of ORIA’s personnel records after they join ORIA, for all purposes relating to human resource development, employee benefits, and other personnel management.
   4. ④To conduct statistical and data analysis for recruitment operations.
3. 2.Restriction due to Purpose of Processing

   ORIA will not handle personal information beyond the scope necessary for achieving the purposes of processing specified as in any of items in paragraph 1 in Section 8 “Purpose for Processing of Personal Information” without prior consent of Stakeholders or except as admitted by laws and regulations.

4. 3.Change of Purpose of Processing, etc.

   In the event that ORIA is to change the purposes of processing specified in paragraph 1 and 2 in Section 8 “Purpose for Processing of Personal Information”, the method or means of provision to third parties and such, ORIA will promptly disclose the content of changes except for the cases below.

   1. ①When the notification or disclosure of the purpose of processing to the Stakeholders concerned poses a risk of damage to the life, health, property, or other rights and interests of the Stakeholders or a third party.
   2. ②When the notification or disclosure of the purpose of processing to the Stakeholders concerned poses a risk to ORIA’s rights or legitimate interests.
   3. ③When it is necessary to cooperate with a national agency including administrative agencies, judicial courts, etc. or a local government in implementing the affairs prescribed by laws and regulations and notifying or disclosing the purpose of processing to the Stakeholders is likely to impede such implementation.
   4. ④When it is considered that the purpose of processing concerned is obvious in the circumstances of the acquisition.
5. 4.Accurate Retention

   ORIA will endeavor to keep the content of personal information accurate and up to date within the scope necessary for the achievement of the purpose of processing.

1. ①When the Stakeholder’s consent has been obtained.
2. ②When the provision of personal information is based on laws and regulations.
3. ③When the provision of personal information is necessary for the protection of life, body or property (including property of corporations) of the Stakeholders and it is difficult to obtain the consent of the Stakeholders.
4. ④When the provision of personal information is especially necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the consent of the Stakeholder.
5. ⑤When the provision of personal information is necessary for cooperating with a national agency, a local government or an individual or a business operator entrusted by either of the former two in implementing the affairs prescribed by laws and regulations and obtaining the consent of the Stakeholder is likely to impede such implementation.

1. 1.Notice of intended use of personal information
   Stakeholders can request ORIA inform them of the intended use for Stakeholders’ personal information that ORIA possesses. In the event Stakeholders make such a request, ORIA will respond to the request promptly and appropriately in accordance with applicable laws and regulations.
2. 2.Access to personal information
   Stakeholders have the right to verify whether or not ORIA processes personal information about them and, if ORIA processes such personal information, Stakeholders have the right to request access to it. Stakeholders also have the right to obtain a copy of their personal information that ORIA processes. In the event Stakeholders request ORIA disclosure personal information to them, ORIA will respond to the request promptly and appropriately in accordance with applicable laws and regulations.
3. 3.Correction of personal information
   If personal information of Stakeholders is inaccurate or incomplete, Stakeholders have the right to request that ORIA correct, supplement or otherwise complete such personal information ("Rectify"). In the event Stakeholders request ORIA Rectify personal information, ORIA will respond to such request promptly and appropriately in accordance with applicable laws and regulations.
4. 4.Deletion of personal information
   Stakeholders have the right to require ORIA to delete any of their personal information that ORIA processes. Provided, however, that ORIA is not obligated to take such action if retention of such personal information is necessary to comply with legal obligations or to assert, enforce or defend its legal rights.
5. 5.Restrictions on the processing of personal information
   If personal information of Stakeholders processed by ORIA is inaccurate, the processing by ORIA is illegal or it is no longer necessary for ORIA to process the personal information for a particular purpose, Stakeholders have the right to restrict the processing of personal information. However, if ORIA is unable to delete their personal information due to the need to comply with legal or other obligations or Stakeholders do not request deletion of their personal information, ORIA is not obligated to take such action.
6. 6.Data portability
   If personal information of Stakeholders is (1) personal information provided to ORIA by the Stakeholders, and (2) ORIA processes such personal information based on Stakeholders’ consent or in order to perform a contract with Stakeholders, Stakeholders have the right to obtain the personal information held by ORIA with respect to Stakeholders in a structured, commonly used and machine-readable format and the right to transmit such personal information to another controller. Stakeholders also have the right to have ORIA directly transmit such personal information to another controller, where technically feasible.
7. 7.Withdrawal of consent
   If Stakeholders consent to processing of their personal information, Stakeholders have the right to withdraw their consent at any time without charge. This includes cases where Stakeholders wish to stop receiving marketing communications.
8. 8.Complaints
   Stakeholders have the right to file a complaint about the processing of personal information by ORIA.
   
   If Stakeholders wish to exercise the right described above, please contact ORIA through the e-mail address listed in Section 19 “Contact Information for Inquiries about Personal Information” of this Privacy Policy. In order to respond to Stakeholder’s request and protect Stakeholders’ privacy and security, ORIA may request Stakeholders provide information necessary to confirm Stakeholder’s identity. In cases where ORIA is unable to confirm their identity based on the information that ORIA receive from Stakeholder and information in its possession, ORIA may request Stakeholder provide additional information. ORIA is committed to responding to Stakeholder’s request to exercise their rights in accordance with applicable laws and regulations.
   
   If Stakeholders believe that ORIA is not in compliance with applicable laws and regulations on the protection of personal information, Stakeholders have the right to file a complaint with the competent supervisory authority with oversight over data protection in accordance with applicable laws and regulations.