for Japanese Domestic Law

Privacy Policy

Linough Inc. (hereinafter referred to as "We") develops systems and applications for real estate management, operates real estate websites, and manufactures as well as sells hardware for real estate management. We will assure personal data protection by implementing this Privacy Policy, establishing the mechanisms for the protection of personal data, and thoroughly recognizing and addressing the importance of protecting personal data with all employees as follows. For the purposes of this Privacy Policy Linough Inc.will be acting as the Data Controller (as defined in applicable data protection laws and regulations), as it is identified as the entity that determines the purposes and the means of the processing of personal data.

１ Personal data protection management system

We recognize risks, such as unauthorized access to personal information, loss, destruction, falsification and leakage of personal data, and take necessary countermeasures to prevent and correct them. In addition, we have implemented a personal data protection management system that defines standards, rules, procedures, etc. for proper handling and operation of personal data.

２ Organizational activities to protect personal information

To specifically implement this Privacy Policy, we carry out the following activities.

1. The officers, officials and other relevant employees in charge must comply with the laws concerning personal data protection, the guidelines established by the government and other national and international laws and regulations.
2. We have appointed a person responsible for protecting personal data within our organization assigning such person with responsibility and authority concerning the implementation and operation of the personal data protection management system.
3. We have appointed a person responsible for the protection of personal data and to carry out regular internal audits of the practical implementation and status of protection of personal data.
4. We have requested our suppliers and other third parties to cooperate in protecting personal data in accordance with applicable laws.
5. By uploading and posting the Privacy Policy on our website, we will make available to anyone inside and outside the company at any time the relevant information concerning privacy of the individuals and data protection.
6. The personal data protection management system will be reviewed and updated as necessary and will be continually improved. Any relevant changes on the Privacy Policy that might affect the privacy or the rights and freedoms of individuals will be promptly notified to the affected individuals and, where relevant, consents will be requested in order to comply with applicable laws and regulations.

３ Appointment of a Data Protection Officer

You may contact at any time our Data Protection Officer for more information on how personal data is being processed, on our applicable security measures to protect personal data, as well as to address any concerns or complaints on your personal data is being handled.

４ Approach to Personal Information Protection

Respect for individual rights

We will respond within a reasonable period and appropriate limits and respect the rights of individuals pertaining to personal information if requested for disclosure, correction, deletion, suspension of use, complaints, consultation, etc. concerning personal information.

Collection, use and provision of personal information

Upon acquisition, use and provision of personal information, we clarify the purpose of use and the provision or non-availability for individuals, use them within the scope of purpose with consent, and take measures to avoid non-intended usage.

Implementation of safety measures

We will establish internal management regulations in order to avoid issues concerning the loss of personal information, leakage to the outside of the company, or improper tampering, and take as well as implement reasonable safety measures.

• Enforced on November 01, 2015
• Revised August 30, 2017
• Linough Corporation
• Representative Director Kiyoshi Takizawa

Handling of inquiries concerning personal information

Linough Co., Ltd. (hereinafter "We") handles personal information provided from inquiry forms provided by us as follows.
Please contact us if necessary after having confirmed the following contents.
Please note that we may not be able to respond to inquiries when no personal information was provided.

１ Purpose of personal information usage

We will use personal information of everyone who contacted us only for the extent necessary to reply. We will not use this information for other purposes without consent.

２ Safety management of personal information

We will take necessary and appropriate safety measures to store and manage information to avoid leakage of personal data from inquiries.

３ Personal information consignment

We will consign personal information to call centers within the necessary degree when responding to inquiries from our contractors’ call centers.

４ Person in charge of personal information protection management

• Enforced on August 30, 2017
• Linough Corporation
• Representative Director Kiyoshi Takizawa

Handling of personal information for recruitment

Linough Co., Ltd. (hereinafter "We") handles personal information provided by applicants as follows.
Please submit your application after having confirmed the following contents.
Please note that you may not be eligible for recruitment if not providing personal information.

１ Purpose of personal information usage

We will use personal information of applicants only to the extent necessary for our company to offer recruitment information, for recruitment selection and onboarding procedures for our staff. We will not use personal information for any other purpose without the applicant’s consent. In addition, please note that we will not return any documents (resumes, transcripts etc.) submitted by applicants.

２ Safety management of personal information

We will take necessary and appropriate safety measures to store and manage information to avoid the leakage of the applicant’s personal information. If selected through the recruitment process, the personal information of newly hired individuals will be appropriately managed as employee information after joining the company. Personal information of non-selected applicants will be disposed of (incinerated, shredded) and deleted in an appropriate manner at the end of the recruitment selection process.

３ Person in charge of personal information protection management

• Enforced July 20, 2017
• Revised August 30, 2017
• Linough Corporation
• Representative Director Kiyoshi Takizawa

Personal information disclosure

Cases subject to personal information disclosure by us are listed below.

１ Business operator’s name

• Linough Corporation

２ Person in charge of personal information protection management

３ Purpose of all disclosed target personal information usage

Personal information of customers / business partners

• 1. Response to inquiries and consultation
• 2. Sending products / postal items
• 3. Contacts, cooperation, negotiation, negotiation, contracts required for business
• 4. Sending information about products, services, seminars and entertainment
• 5. Proposal / offer of products / services / maintenance support
• 6. Research and analysis for product / service development
• 7. Customer / business partner information management, accounting processing, etc.

Personal information of shareholders

• 1. Exercise of rights and fulfillment of obligations under Company Law
• 2. Provision of various notices related to the position as shareholder
• 3. Implementation of various shareholder policies
• 4. Management of shareholders under various laws and regulations

Personal information of employment applicants

• 1. Provision of recruitment information, communication and recruitment decisions etc. to recruit applicants
• 2. Management of recruitment tasks at our company

Personal information of employees (including retirees)

• 1. Management of personnel, duties and work tasks
• 2. Management of salary, bonus etc.
• 3. Benefits
• 4. Health and safety management

４ Request for Provision of disclosed Personal Information

After personal identity confirmation, we will handle the request for purpose of our personal information usage regarding notification, disclosure, correction of content, addition or deletion, suspension of use or third party deletion and suspension of information (hereinafter referred to as "disclosure").
As processing by the user’s page or email are possible, please confirm the usage terms of each WEB service you utilize for procedures regarding disclosure of personal information related to our web services.

４-１ Inquiry contact

４-２ Replies to disclosure requests

In the case of received requests for disclosure, we will confirm the contents and notify the applicant in writing of the results at a later date. However, if we are unable to respond to requests, such as disclosure for the following cases, we will notify you about the effects and reasons.

• ・Cases in which we cannot verify your identity
• ・Cases of requests by an agent, when the authority of proxy cannot be confirmed
• ・Cases when incomplete documents were submitted
• ・Cases in which the purpose of request for disclosure is not "disclosure of target personal information"
• ・Cases in which there is risk of harming the life, body, property or other rights and interests of the person or a third party
• ・Cases in which there is a risk of significant hindrance to our business
• ・Cases of violating other laws and regulations

４-３ Purpose of personal information usage

Personal information acquired by us through the inquiry for disclosure will be handled only within the degree necessary for dealing with the request. In addition, we will promptly discard the inquiry after the request has been handled, so we cannot return any related documents.

• Enforced July 20, 2017
• Revised 05 October 2017
• Linough Corporation
• Representative Director Kiyoshi Takizawa

Concerning submission of complaints / consultations regarding personal information

The submission contacts for complaints and consultations related to our personal information policies are as follows.

Submission contact

• Enforced 05 October 2017
• Linough Corporation
• Representative Director Kiyoshi Takizawa

for EU

Privacy Policy

Linough Inc. (hereinafter referred to as "We") develops systems and applications for real estate management, operates real estate websites, and manufactures as well as sells hardware for real estate management. We will assure personal data protection by implementing this Privacy Policy, establishing the mechanisms for the protection of personal data, and thoroughly recognizing and addressing the importance of protecting personal data with all employees as follows. For the purposes of this Privacy Policy Linough Inc.will be acting as the Data Controller (as defined in applicable data protection laws and regulations), as it is identified as the entity that determines the purposes and the means of the processing of personal data.

１ Personal data protection management system

We recognize risks, such as unauthorized access to personal information, loss, destruction, falsification and leakage of personal data, and take necessary countermeasures to prevent and correct them. In addition, we have implemented a personal data protection management system that defines standards, rules, procedures, etc. for proper handling and operation of personal data.

２ Organizational activities to protect personal information

To specifically implement this Privacy Policy, we carry out the following activities.

1. The officers, officials and other relevant employees in charge must comply with the laws concerning personal data protection, the guidelines established by the government and other national and international laws and regulations.
2. We have appointed a person responsible for protecting personal data within our organization assigning such person with responsibility and authority concerning the implementation and operation of the personal data protection management system.
3. We have appointed a person responsible for the protection of personal data and to carry out regular internal audits of the practical implementation and status of protection of personal data.
4. We have requested our suppliers and other third parties to cooperate in protecting personal data in accordance with applicable laws.
5. By uploading and posting the Privacy Policy on our website, we will make available to anyone inside and outside the company at any time the relevant information concerning privacy of the individuals and data protection.
6. The personal data protection management system will be reviewed and updated as necessary and will be continually improved. Any relevant changes on the Privacy Policy that might affect the privacy or the rights and freedoms of individuals will be promptly notified to the affected individuals and, where relevant, consents will be requested in order to comply with applicable laws and regulations.

３ Appointment of a Data Protection Officer

You may contact at any time our Data Protection Officer for more information on how personal data is being processed, on our applicable security measures to protect personal data, as well as to address any concerns or complaints on your personal data is being handled.

４ Data protection rights

We will attend any data protection rights as soon as possible and within 30 days or within any statutory period. Individuals have the right of information to be aware of how the personal data is being processed. Any individual has the right to access its personal data; to rectify inaccurate or incomplete personal data; to erase personal data concerning him or her (“right to be forgotten”); to restrict the data processing where consent is the legal basis for the processing; to data portability; to object to the data processing; and to object, where relevant, to any automated individual decision-making process. Moreover, any individual may address complaints in the event they deem that their data protection rights have been contravened.

５ Information transparency

Individuals will always have available on our website the Privacy Policy describing how personal data is processed, shared and protected. The Privacy Policy will also describe the purposes for the personal data processing and will inform of the data protection rights that may be exercised by the individuals.

６ Implementation of security measures

We have established internal management procedures in order to avoid risks and issues concerning the loss, theft or unintended access to personal data by implementing appropriate data security measures according to best industry standards and to applicable laws and regulations.

７ Purposes of the data processing

Personal data may be processed for the following purposes

Customer Data

• ・Handling responses to questions and queries on our products received by customers and potential customers.
• ・Promoting our products through various channels and launching marketing campaigns for the promotion of our existing and new products.
• ・Managing the contractual relationship with our existing customers, distributors and vendors.
• ・Managing terms and conditions for proper delivery to customers, distributors and vendors.
• ・Managing continued maintenance services on our products.
• ・Providing relevant information to public authorities and regulators where so requested and required by applicable laws and regulations.

Employee Data

• ・Managing candidate data in employment recruiting processes.
• ・Managing employee data for human resources management purposes including without limitation handling with payroll payments, social benefits, social security obligations, employee performance and health and safety management.
• ・Providing relevant information to public authorities and regulators where so requested and required by applicable laws and regulations.

８ Data Protection Principles

Lawful, fair and transparent processing

In order to ensure that the data processing is lawful, fair and transparent, we will maintain a register of our systems and applications which is reviewed on an annual basis.

Lawful purposes

All personal data processed by us is done on one of the following lawful bases: consent, contract performance, legal obligation, vital interest, public task or legitimate interest. We assign the appropriate legal basis in the register of our systems. Where consent is required we keep evidence of the fact that consent has been granted. Individuals have the right to withdraw consent at any time. Accordingly, where consent is withdrawn appropriate measures are taken within the company to avoid further data processing.
In general terms, personal data processing for marketing and promotional purposes will be based on the consent of the recipients of the communications. Personal data processing for contract management with customers and vendors, support services and human resources management, will be based on the need to process personal data for the performance of the contractual obligations and to comply with legal obligations by the organization.

Data minimization

We ensure that personal data is adequate, relevant, up to date and limited to what is necessary in relation to the purposes for which personal data is processed.

Accuracy

We take reasonable steps to ensure personal data is accurate. Where necessary for the lawful basis, internal processes are in place to ensure that personal data is kept up to date.

Data Retention

Only relevant personal data is maintained and processed. Personal data is not kept for longer than it is strictly necessary. Once personal data is not necessary anymore, personal data will be blocked by us but may be kept for an additional period which will not exceed 10 years to comply with statutory limitation periods according to applicable laws and regulations.

９ Complaints with a supervisory authority

Individuals have the right to lodge a complaint with a data protection supervisory authority if they consider that their data protection rights have been contravened. A list and contact details of the relevant data protection supervisory authorities in Europe are available through the following link to the European Commission website:
http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

１０ International Data Transfers

International data transfers are covered by the relevant Data Transfer Agreements among the affected third parties containing contractual clauses in accordance with the statutory obligations to carry out international data transfers. The affected parties acknowledge that the appropriate safeguards are in place to protect personal data with adequate level of protection according to European standards.

１１ Contact Us

If you need any additional information or need any further clarification on the terms of this document, please contact us in the following address

If you would like to reach any of our representative offices in Europe or overseas, please contact us at the address indicated above.

• Enforced on May 25, 2018
• Linough Corporation
• Representative Director Kiyoshi Takizawa