Privacy Policy

ATLAS DOT ONE Privacy Policy (English) Version: Version 1.5 Created: 2026-09-27 Effective Date: 2026-09-27 Business Operator (Controller): ATLAS DOT ONE Japan株式会社 (the "Company") Representative: Akira Takezawa Address: Taira Maison 102, 1-15-14 Adachi, Adachi-ku, Tokyo 120-0015, Japan ──────────────────────────────────────── The Company handles User information obtained through ATLAS DOT ONE (the "Service") appropriately in accordance with the Act on the Protection of Personal Information (APPI) and other applicable laws and guidelines. ──────────────────────────────────────── 1. Definitions (1) "Personal Information" means personal information as defined in the APPI. (2) "Personal Data" means personal information that constitutes a personal information database, etc. (3) "Retained Personal Data" means Personal Data over which the Company has authority to disclose, correct, etc. (4) "User Information" means information about Users that the Company acquires and retains, including Personal Information. 2. Information We Collect The Company collects the following information to the extent necessary to provide the Service (methods: User input, automatic collection from devices, provision from third parties, etc.). (1) Account information: name, display name, email address, phone number, address, date of birth, company/department/person in charge, etc. (2) Identity verification information (if conducted): images of photo identification documents, images of identification documents without a photograph, images of supplementary documents, facial images of the individual, matching results, identity verification results, results of checks relating to anti-social forces, sanctions targets, adverse media reports, and other risk screening results designated by the Company, etc. (3) Transaction/contract-related information: applications, reservations, contract details, move-in/move-out details, cancellation/refund information, inquiry history, trouble-handling history, etc. (4) Payment-related information: payment method type, payment identifier, billing/payment status, refund status, bank account information (owners), receipt information, etc. * The Company generally does not store credit card numbers; payment processors handle such information. (5) Rental debt guarantee information: applications to the Company, screening status, rent arrears, guarantee performance, recourse status, etc. (6) Management and optional service information: requests for property management, tenant support, viewing assistance, cleaning, repairs and repair estimates, key assistance, move-out assistance and move-out packages; schedules, access methods, key handover records, photos/videos, estimates, reports, etc. (7) Communication information: dashboard messages, attachments, timestamps, etc. (8) Device/log information: IP address, cookies, device identifiers, OS, browser, access time, viewing history, etc. (9) Location information: if permitted by device settings. (10) Other information provided by Users to the Company. 3. Purposes of Use The Company uses User Information for the following purposes: (1) providing the Service, account management, identity verification, and screening (2) supporting property search, applications and contracting procedures; managing properties, responding to tenants, coordinating with Owners and providing dashboard functions (3) providing subscriptions, billing, payments, refunds, managing and collecting unpaid amounts (4) the Company's rent collection agency services, receipt management, settlement and payments to Owners (5) screening, contracting, performance and recourse conducted by the Company as the rental debt guarantor (6) receiving requests for, arranging, providing and reporting the Company's viewing assistance, cleaning, repairs and repair estimates, key assistance, move-out assistance and move-out packages (7) responding to inquiries, fact-finding for disputes, and improving quality (8) preventing unauthorized use, money laundering, and other improper conduct; ensuring security, including checks relating to sanctions targets and adverse media reports; and handling violations of the Terms (9) analyzing usage and improving functions (analytics) (10) providing information about the Company's products/services (where consent is required, after obtaining consent) (11) legal compliance, responding to authorities/courts, exercising and defending rights (12) procedures associated with transfer of rights/obligations due to business succession, reorganization, etc. 4. Provision to Third Parties (1) The Company will not provide Personal Data to third parties without the individual's consent except as permitted by law. (2) Where necessary to provide the Service and carry out Transactions, the Company may provide the minimum necessary Personal Data to the following independent third parties in accordance with paragraph (1): a. To Owners: tenant user's name, contact details, application details, move-in/move-out details, payment status, etc. b. To Tenant Users: owner's name/company name, contact details, property information, billing information, etc. c. To independent payment service providers: information necessary for payment services provided under their own responsibility (payment identifier, billing amount, etc.) (3) Before providing Personal Data to a third party, the Company obtains any legally required consent through consent screens, application procedures or other appropriate means. (4) Guarantee information handled by the Company as rental debt guarantor is used internally for the purposes in Section 3; it is not a disclosure to a separate guarantee provider. Entrusting information to contractors performing the Company's work is governed by Section 5. 5. Outsourcing (1) The Company may outsource all or part of its work and the associated handling of User Information within the scope necessary to achieve the purposes of use. Such work includes cloud services, payment processing, email delivery, customer support, identity verification, AML/CFT and anti-social force, sanctions and adverse media checks, as well as viewing assistance, property management and tenant support, cleaning, repairs and repair estimates, key assistance, move-out assistance and move-out packages. (2) Information entrusted to a contractor is limited to the minimum necessary for its work, such as addresses, contact details, schedules, access methods and photographs. The Company appropriately selects contractors, requires restrictions on use for other purposes, security and confidentiality, and exercises necessary and appropriate supervision. (3) Handling Personal Data through outsourcing necessary to achieve the purposes of use is governed by this Section to the extent it is not treated as third-party provision under applicable law. Use by a contractor for its own independent purposes is not treated as outsourcing and is subject to the procedures in Section 4 where required. Provision to contractors outside Japan is also subject to Section 6 and applicable law. 6. Provision to Third Parties Located Overseas If the Company provides User Information to third parties located outside Japan (e.g., cloud providers), the Company will notify or publicly announce required matters and obtain consent where necessary in accordance with applicable law. 7. Security Measures The Company takes organizational, human, physical, and technical security measures to prevent leakage, loss, or damage of Personal Data (access control, authority management, encryption, log monitoring, vendor management, training, etc.). 8. Response to Data Breaches If a data breach occurs or is suspected, the Company will investigate, prevent recurrence, and make necessary reports/notifications in accordance with applicable laws and guidelines. 9. Cookies / External Transmission (1) The Company may use cookies, SDKs, etc. for providing the Service, analytics, advertising delivery, security, etc. (2) Users may disable cookies through browser settings, but some functions may not work properly. (3) If the Company uses mechanisms that transmit information from User devices to third-party servers (external transmission), the Company will publicly explain in an easy-to-understand manner the destination, transmitted information, purposes, and available user controls (consent, opt-out, etc.). 10. Requests Regarding Retained Personal Data The Company responds to requests under the APPI for disclosure, correction, addition, deletion, suspension of use, suspension of third-party provision, disclosure of records of third-party provision, and similar requests relating to Retained Personal Data (collectively, "Requests"). (1) Contact: inquiry form within the Service (2) Identity verification method: presentation or submission of identity verification documents by the method prescribed by the Company (3) Fee: free of charge (4) Response method: email, written document, or other method prescribed by the Company 11. Joint Use The Company does not currently engage in joint use. 12. Retention Period The Company retains User Information only for the period necessary for the purposes or as required by law, and thereafter deletes or anonymizes it appropriately (depending on implementation/operations). 13. Amendments The Company may amend this Policy in accordance with law. For material amendments, the Company will notify Users within the Service. 14. Language The governing text of this Policy is the Japanese version. Any translations are provided for convenience only; in case of discrepancy, the Japanese version prevails. Supplementary Provision This Policy applies from 2026-09-27.