We, Capital Realty, Inc., operating as a Japanese company, will endeavour to protect private information that we hold on borrowers and others and will do our utmost to observe the Japanese Privacy Information Protection Law (2003 Law No. 57) and other relevant statutes. In order to make that happen in our day-to-day operations, we will follow the guidelines below:
1. Due and proper acquisition of private information
In acquiring private information, we will define the business purposes for its utilization, and acquisition will be done in a due and proper manner and only within the bounds necessary for achieving the business purposes.
2. Utilization and provision of private information
Utilization and provision of private information to third parties will be done only within the limits of that consented to.
3. Securing safety and integrity of privacy information
We will take Organizational, Physical and Technological Security Measures to ensure the safety and integrity of private information. Organizational Security Measures will define responsibility for administration of privacy information, supervision of employees, setting forth of further security measures, and audits.
Physical Security Measures will ensure against loss and theft.
Technological Security Measures will define principles for the use of systems and administration toward the safety and integrity of private information.
4. Announcement on private information
When the principal so requests, the following items regarding utilization of private information will be announced so that he/she will be in a position to know them. Purpose for the use of private data we hold.
Procedures for disclosure of private information we hold.
Contact point for complaints, requests for correction, amendment, deletion, suspension of use, and suspension of provision to third parties.
5. Compliance program
In order to promote the protection of private information and appropriate administration thereof, we will create a compliance program to provide training and supervision to employees. As laws and circumstances on these issues evolve, we will routinely update these programs.
April 2005
Capital Realty Inc.
Carl Nicholas Everett
Representative Director
Statement Regarding Protection of Private Information
Purpose for which we will utilize private information
Privacy information that we acquire will be used for: administration and servicing of specified monetary assets; administration work for asset purchasing companies; real estate brokerage, real estate management, asset management and property management that are ancillary and related to loan servicing business; money lending that is ancillary to loan servicing business.
Supervision of out-sourcees
When we entrust the handling of private information to out-side sources, we will choose entities that can observe our Private Information Protection Statement, and supervise them in their handling of such information. Should the task be further out-sourced, we will supervise the out-sourcee to ensure appropriate supervision over the information.
Disclosure on private data we hold
When the principal requests disclosure, correction, amendment, deletion, suspension of use or erasure regarding private data we hold, we will respond in accordance with the requirements of the law. Provided, we will require identification of the principal (in accordance with our internal procedures) or, in the case of agents, proof of agency as defined in the Ordinance; furthermore, in case of correction, amendment, deletion etc., official papers evidencing the new data will be required. Fees for disclosure will be JPY 1,000 (inclusive of consumption tax). For details, please contact the Private Information Inquiry Counter.
Privacy Policy Inquiries Counter
Business hours: Monday to Friday, 9:30 to 17:30 (excluding bank holidays and Year End and New Year holidays)
Tel: +81 (0)3-6439-7844
Fax: +81 (0)3-3423-9890
E-mail: privacysupport@capserv.com
Address
Capital Realty Inc.
Privacy Policy Inquiries Counter
Roppongi Hills Mori Tower 15F
Roppongi 6-10-1, Minato-ku
Tokyo 106-6115, Japan