Privacy Policy

1. Who we are and what this policy covers

This policy covers our property planning, sales and rental brokerage services, Kakehashi Realty and Kakehashi Prime, clinic management consulting, imports and exports of equipment and related products, related overseas business support, recruitment and agent applications, and our websites.

Clinics and other separate legal entities are responsible for information they collect and use for their own purposes under their own policies. This policy does not replace a clinic’s patient privacy notices or consent procedures. Where a service has an additional notice, we explain which activities it covers.

2. Information we collect and its sources

We collect information needed for the relevant purpose through enquiries, meetings, membership registration, transaction applications, contracts and recruitment. We may also obtain information lawfully provided by transaction partners or referrers, from public records such as property registers, and through use of our websites.

This may include your name, contact details, address, organisation and role, preferred language, consultation records, membership details, property requirements and budget, details of properties you own or are considering, and records of contracts, payments, invoices, delivery and maintenance. For job and agent applications, we collect relevant experience, qualifications, application details and selection records.

When identity checks, transaction verification or financing arrangements become necessary, we explain the purpose and request the relevant details, which may include your date of birth, country of residence, occupation, identification documents and funding plans. We do not request unnecessary asset statements, identity document images or medical information at the initial enquiry stage.

Website use may generate IP addresses, device and browser details, browsing and interaction records, and identifiers such as cookies. Section 10 explains external services and data transmissions.

3. How we use information

We send ongoing property updates, product or service information, and event invitations to people who have chosen to receive them. We distinguish these choices from communications needed to answer an enquiry or fulfil a contract, and honour requests to stop promotional messages.

Any change in the purposes of use will be made within the limits permitted by law, with the required notice, publication or consent.

4. Sensitive information and information entrusted to us

We apply safeguards appropriate to the sensitivity and risks of financial details, identification documents and confidential property information. These categories are not all “special care-required personal information” under the APPI. When we collect information in that legal category, such as medical history or treatment records, we obtain prior consent unless a legal exception applies.

Where a client entrusts us with personal information, we follow the agreed instructions, contract and applicable law. We avoid receiving patient information that is unnecessary for the work and reduce identifiable details where possible. We collect Japan’s Individual Number (My Number) only through a designated process for legally authorised purposes.

5. Prime and off-market property information

We share off-market property details after checking the seller’s instructions, our authority to recommend the property and the stage of the enquiry. We may ask for identity verification, confirmation of the intended use and confidentiality commitments. Membership does not give unrestricted access to the personal information of other members, sellers or tenants.

Before sharing leases, rental statements, reasons for sale or financial documents, we minimise disclosure, including redacting names, contact details or bank details that are not needed. Permission to market a property or a confidentiality agreement does not, by itself, authorise disclosure of another person’s personal information.

6. Service providers and other recipients

We may engage providers for systems and cloud services, communications, translation, delivery and administrative work within the scope needed for the relevant purpose. We select providers appropriately, set handling requirements through contracts or other arrangements, and exercise necessary and appropriate oversight.

We do not disclose personal data to third parties without prior consent unless an exception under applicable law permits it. For disclosures to buyers, sellers, landlords, other brokers, property managers, lenders, legal or tax professionals, manufacturers or logistics providers, we assess the recipient’s role, purpose and required information, and obtain consent or establish another lawful basis as required. A transaction need or professional duty of confidentiality alone does not dispense with those requirements.

Access between departments of the same company is limited by purpose and responsibility. A separate group company is not treated automatically as an internal department. Before relying on the APPI’s joint-use provisions, we give notice or publish the required particulars, including the information involved, the scope of participants, purposes and the responsible entity’s name, address and representative.

7. Handling outside Japan

Information may be handled outside Japan when overseas transaction partners, specialists, cloud platforms or communication services are involved. We assess the recipient’s role, country and handling arrangements, and meet the applicable requirements for overseas transfers of personal data.

Where an overseas transfer relies on your consent, we first provide the information required by law, including the destination country, its personal information protection framework and the recipient’s safeguards. Where we rely on an arrangement that continuously ensures legally required equivalent measures or another permitted mechanism, we take the required steps to maintain it and provide information on request as required.

Reading this policy, submitting an enquiry, becoming a member or using a messaging app does not replace any separate consent required for a particular overseas transfer.

8. Safeguards and incident response

We apply necessary and appropriate safeguards according to the nature, volume and handling of the information. These include defined responsibilities and rules, staff training, access and authentication controls, transmission safeguards, controls for equipment and paper records, and oversight of service providers. We consider local legal frameworks where information is handled overseas. Further information about our safeguards is available from our contact points, except where disclosure could compromise security.

If a breach or similar incident occurs, we act to contain its effects, establish the facts, correct the issue and prevent recurrence. We report to the competent authority and notify affected individuals where required by law.

9. Retention and disposal

We retain information only for as long as needed for its purpose, contractual obligations, legal record-keeping requirements and matters such as disputes. Retention periods and their starting points depend on the type of record and applicable law, including property transaction, identity verification and accounting records. We do not apply one blanket period to all information.

Information no longer needed is securely deleted or disposed of. Where a legal or other valid retention requirement prevents immediate deletion, we retain it to that extent. Information entrusted by a client is returned or deleted in accordance with the agreed terms.

10. Cookies and external services

Our websites may use cookies and similar technologies for functions such as display, authentication, security and usage analysis. You can restrict cookies in your browser, although some functions may then be unavailable.

Where analytics, advertising or embedded services are used, the relevant website notice or cookie settings explain the actual information transmitted, recipients, purposes and available choices. We obtain consent where required and carry out legally required checks, including where a recipient is expected to associate personal-related information with identifiable personal data.

External services such as LINE, WeChat and WhatsApp also operate under their own providers’ policies. Please wait for instructions on a suitable submission method before sending identity documents, bank details or medical information through a general enquiry form or chat.

11. Requests and complaints

You or an authorised representative may, within the scope provided by law, request:

• notification of purposes of use
• access to retained personal data
• correction, addition or deletion
• cessation of use or erasure
• cessation of third-party disclosure
• access to records of third-party disclosure

Contact us using Section 14 with your name, reply details, the relevant service and your request. We will explain the proportionate steps needed to verify identity or authority and identify the records, then respond without delay as required by law. Do not attach identity document images to your first message.

We provide access in your requested format where required by law. If we cannot meet all or part of a request, we explain the outcome and reasons. We do not charge a fee for these requests. Where we hold information solely on a client’s behalf, we may direct or refer the request to that client.

12. Information about minors

For transactions or information involving minors, we check whether parental or other legal representative consent or involvement is required, taking account of age, the transaction and applicable law. If information has been obtained inappropriately, we investigate and take steps such as stopping use or deleting it, subject to legal retention obligations.

13. Updates and language versions

We announce material changes on the relevant website. Where a change requires your consent under applicable law, we seek it separately. Continued use of a website is not treated as a substitute for that consent.

The Japanese, English and Chinese versions are intended to convey the same practices. Please contact us if any wording is unclear. Translation differences do not restrict your rights under applicable law.

14. Contact us

Personal Information Enquiries, BIB & Co.

Please tell us whether you prefer Japanese, English or Chinese. The appropriate member of our team will assist with your enquiry.