Raysum Co., Ltd. (hereinafter referred to as the "Company") believes that it is important to respect the right to protect personal information among rights of individuals. Protecting customers' personal information is one of the Company's basic principles in doing businesses, and the Company also believes it is its social responsibility to protect personal information. The Company shall comply with laws, regulations and other rules regarding personal information, set forth its policy on protection of personal information as follows, and ensure that its officers and employees are fully committed to the policy.

1. Collection of Personal Information
   The Company shall collect customers' personal information through appropriate measures only to the extent necessary for performing the Company's businesses.
2. Purpose of Use
   The Company shall specify the purposes for use of customers' personal information in advance as follows.
   (1) For the purpose of acquiring, evaluating, investing in and selling real estate or rights regarding real estate.
   (2) For the purpose of purchasing or leasing property and property management.
   (3) For the purpose of developing, constructing, building, architecturally designing, and supervising the construction of, real estate.
   (4) For the purpose of planning, designing and implementing the construction of interiors of buildings
   (5) For the purpose of providing useful information regarding real estate through postal mails and other measures.
   (6) For the purpose of owning, renting and managing hotels, restaurants, or sports facilities, etc.
   (7) For the purpose conducting management consulting businesses.
   (8) For the purpose of investing in securities or certificates which are deemed as securities.
   (9) For the purpose of providing agency services for credit management and collection.
   (10) For the purpose of providing non-life insurance agency services.
   (11) When a customer individually agrees to other uses, such uses agreed to by the customer.
3. Use of Personal Information
   The Company shall use customers' information to the extent necessary for achieving the purposes of use as set forth above.
4. Provision of Personal Information
   The Company, in principle, shall not provide customers' personal information to any third party without obtaining the customers' prior consent; provided, however, that the Company may provide personal information to a third party pursuant to relevant laws and regulations if it is deemed necessary in achieving the purposes of use as set forth above.
5. Ensuring Accuracy of Personal Information
   The Company shall always endeavor to keep customers' personal information accurate and current.
6. Ensuring Security of Personal Information
   The Company shall implement organizational, personal, physical and technological security measures to prevent leakage, loss, damage, alteration and misappropriation of customers' personal information.
7. Appropriate Handling of Personal Information
   The Company shall carry out education and training for its officers and employees regarding protection of personal information, establish internal regulations, and implement thorough measures to ensure appropriate handling of personal information in its business activities.
8. Appropriate Supervision of Trustees
   If the Company entrusts a third party with handling of personal information retained by the Company, the Company shall exercise appropriate supervision over the trustee, including conducting periodical monitoring.
9. Compliance with Laws, Regulations and Other Rules regarding Protection of Personal Information
   The Company shall comply with laws and regulations regarding handling of personal information, guidelines regarding protection of personal information in the area regulated by the Ministry of Land, Infrastructure, Transport and Tourism, and other rules.

January 2008 Takeshi Tanaka President Raysum Co., Ltd.

Procedures for requesting notification of purposes of use and disclosure of retained personal data, etc. (hereinafter referred to as the "Request for Disclosure, etc.") are as follows.
The Request for Disclosure, etc. should be sent to the Company's Contact for Inquiries about Handling of Personal Information by postal mail. A request by telephone, facsimile or e-mail cannot be accepted, and also please refrain from coming in person to the contact office to make a request as it may cause confusion.

1. Obtaining Application Form
   When making the Request for Disclosure, etc., first, please send a postal mail to the Company's Contact for Inquiries about Handling of Personal Information. Please write in red as "Request for Application Form for Disclosure, etc. of Personal Information" on the surface of envelop, and enclose a self-addressed return envelope affixed with 80 yen stamp. On receiving the mail, the Company will immediately send you the Application Form for Disclosure, etc. of Personal Information.
   
   
2. Application Method
   Please fill out the Application Form for Disclosure, etc. of Personal Information you received and submit it by postal mail together with the following documents and a self-addressed return envelope affixed with 430 yen stamp. When requesting notification of purpose of use and disclosure of retained personal information, please enclose postal money order in the amount of 945 yen as a handling fee.
   
   Documents to be enclosed
   
   (1) Personal identification document
   A copy of one of the following: driver's license, passport, Identification booklet for the physically disabled, or foreign registration card. (Please submit a copy of the part identifying an individual.)
   
   In case none of the above is available, copies of two of the following: certificate of health insurance card, pension book, copy of family register, or certificate of seal impression.
   
   (2) A copy of certificate of residence
   Note 1: Please enclose one obtained within three months.
   Note 2: This is not required if a foreign registration card is submitted.
   
   
3. Disclosure Method
   Notification of purposes of use and disclosure of retained personal information will be made by mailing to the address indicated in the submitted certificate of residence. Please note that disclosure, etc. may not be made pursuant to relevant laws and regulations.