Handling Personal Information and Specific Personal Information

The Zenitaka Corporation (the Company) shall comply with laws and other regulatory criteria covering the protection of personal information in its handling of any personal information pertaining to customers and business associates used during the course of the Company's business activities. The Company shall also consider international trends when determining voluntary rules and systems for the purpose of establishing the following Privacy Policy and ensuring its on-going implementation.

1.Collection and Use of Personal Information

When collecting personal information, the Company shall clearly define how this information will be used and shall not use the information for any other purposes. The Company shall collect names, addresses, email addresses and other personal data considered necessary when customers access the various services offered on the Company's website. The purpose of any personal information input into the Company's website shall be stated, and the said information shall not be used for any other purposes.

2.Management of Personal Information

Personal information provided by customers shall be accurately maintained and kept up to date within the scope of its intended use, and shall be appropriately and carefully managed. The Company shall take all measures considered necessary to prevent illegal access to customers' personal information, and shall make every effort to ensure data security.

3.Disclosure of Personal Information

The Company shall not disclose or provide any personal information to a third party without the approval of the relevant customers. However personal information may be disclosed without customer approval when required by law or for other legitimate reasons.

4.Respecting the Rights of Data Subjects (Individuals)

The Company shall respect the rights of data subjects, and shall deal with matters in accordance with appropriate laws and practices when requesting the disclosure, amendment or removal of a data subject's personal information.

5.Compliance with Laws and Regulations

The Company shall comply with any laws or rules applicable to the personal information retained by the Company, and shall maintain and enhance the privacy protection activities described in preceding paragraphs.

April 1, 2005
The Zenitaka Corporation

For inquiries regarding personal information, please contact the Operations Section, General Affairs Department, Corporate Support Headquarters.
E-mail ： kojin@zenitaka.co.jp

The Company shall establish, implement and maintain a basic policy to ensure the proper handling of specific personal information (personal information that includes an identification number in its contents) and identification numbers (specific personal information and personal information shall be collectively referred to as "specific personal information").

1.Compliance with Relevant Laws and Guidelines

The Company shall handle specific personal information in the proper manner, and comply with the Act on Numbers to Identify a Specific Individual in Administrative Procedure, the Act on the Protection of Personal Information and Guidelines on the Proper Handling of Specific Personal Information (Commercial Version).

2.Items Pertaining to Security Control Measures

The Company shall take the appropriate and necessary security control measures to prevent the disclosure, loss or damage of specific personal information. The Company shall also conduct the appropriate and necessary supervision of employees and contractors (including subcontractors) handling specific personal information. Security control measures covering specific personal information shall be detailed in a separate document entitled Rules on the Handling of Specific Personal Information.

3.For queries on this basic policy

For inquiries regarding specified personal information at our company, please contact the Operations Section, General Affairs Department, Corporate Support Headquarters.
E-mail ： kojin@zenitaka.co.jp

December 7, 2005
The Zenitaka Corporation

The Company shall specify the extent and purpose of use of personal information in written form obtained directly from customers and business associates.
The handling and use of any other personal information obtained directly or indirectly shall be limited to the following purposes.

1. 1.Conducting operations related to the business objectives outlined in the Company's Articles of Association.
   (Articles of Association Business Objectives)
• Contracting, planning, design and management of construction projects
• Construction-related development projects and feasibility studies, planning, design and management for such projects
• Real estate activities
• Manufacturing and sale of construction materials
• Projects incidental to the aforementioned activities and all operations related to these activities
2. 2. Providing extensive guidance and other notifications on the Company's projects
3. 3. Providing information on new technology and services
4. 4. Managing the performance of operations provided to customers, delivering after-sales services, and preparing and providing performance records and other documentation
5. 5. Fulfilling the legal requirements of the Construction Business Act, Industrial Health and Safety Act and other relevant laws
6. 6. Enhancing labor and safety management
7. 7. Managing recruitment and other applications
8. 8. Credit screening of business transactions
9. 9. Employment management and welfare programs for employees
10. 10. Responding to other questions, comments and advice pertaining to the Company

The handling of personal shareholder information shall be limited to the following purposes.

1. 1. Responding to the execution of rights by shareholders as prescribed by the Companies Act and other relevant laws
2. 2. Providing information related to Company and Group activities as reference for shareholders to exercise voting rights
3. 3. Collecting data supplementary or related to paragraphs 1 and 2 for statistical processing

The Company shall limit its handling of specific personal information to the following purposes.

1.Specific personal information (including the administrative duties detailed on the right) of Company executives (including that of dependents).

• Administrative duties related to withholding tax
• Document preparation and administrative duties associated with declarations for exemption of dependents (reassignments) and declarations for insurance premium deductions / special spousal deductions for salaried workers
• Document preparation and administrative duties associated with salary payment reports
• Document preparation and administrative duties associated with reassignment notifications for salaried workers in relation to special collection of salary payment reports
• Document preparation and administrative duties associated with applications to convert to special collection
• Document preparation and administrative duties associated with special payments records for recipients of retirement allowances
• Document preparation and administrative duties associated with declarations pertaining to retirement income
• Document preparation and administrative duties associated with declarations, notifications and applications pertaining to the accumulation of financial assets for housing construction or pension savings
• Administrative duties for filing of health insurance, welfare pensions and company pension
• Administrative duties for filing of national pension plans (3rd grade)
• Administrative duties for applications / claims for health insurance, welfare pensions and company pensions
• Administrative duties for filing of employment and accident insurance
• Administrative duties for applications / claims for employment and accident insurance
• Document preparation and administrative duties associated with employment and accident insurance certificates
• Preparation and delivery of statutory documents related to the dealing of financial products involving shareholders

2.Specific personal information of individuals not holding executive positions (including the administrative duties detailed on the right)

• Document preparation and administrative duties associated with payment records for remuneration / fees
• Document preparation and administrative duties associated with the distribution of dividends and surpluses, as well as payment records for interest on funds
• Document preparation and administrative duties associated with payment records for real estate rental fees

The personal information of customers or business associates shall not be disclosed or provided to third parties without the prior approval of the individual, except in the following cases.

• When required by law
• When required to protect human life, physical well-being or property and it is difficult to obtain the approval of the individual
• When specifically required to improve public health or promote healthy childhood development and it is difficult to obtain the approval of the individual
• When required to cooperate with legally prescribed administrative duties conducted by state institutions, local government organizations or persons contracted by such bodies, and there is a risk of hindering the completion of this work if approval is sort from the individual

The Company shall not use specific personal information of customers, business associates or employees beyond the scope of its intended purpose. However, when it is necessary to protect human life, physical well-being or property, specific personal information may be used for purposes other than those stated, either with the individual's approval or when it difficult to obtain such approval.

1.Disclosure

The Company shall reply to any requests made by customers or business associates for the disclosure of an individual's own personal information or specific personal information retained by the Company once the applicant has been identified as the owner of the said information.

2.Amendments

The Company shall abide by any requests made by customers or business associates to amend, add or remove an individual's own personal information or specific personal information retained by the Company once the applicant has been identified as the owner of the said information and the content is deemed incorrect.

3.Suspension / Cancellation of Use

The Company shall abide by any requests made by customers or business associates to suspend or cancel the use of an individual's own personal information or specific personal information retained by the Company once the applicant has been identified as the owner of the said information. Please note that if the use of part or all this information is suspended or cancelled, the Company may no longer be able to provide the desired services.

4.Accepting Requests for Disclosure / Point of Contact

The Company shall use the following method to accept requests for disclosure of personal information or specific personal information retained by the Company. The same method shall be used for inquires related to the Company's handling of such information.
Please note that the Company may be unable to comply with requests for disclosure made using a different method.

For inquiries or complaints regarding personal information and specified personal information, please contact the General Affairs Department, Corporate Support Headquarters, using the details below.

1.Postal Address

For postal mail to ： The Zenitaka Corporation
General Affairs Department, Corporate Support Headquarters
2-2-4 Nishi-Honmachi, Nishi-ku, Osaka-shi, Osaka 550-0005

2.Email

Email ： kojin@zenitaka.co.jp

3.Telephone and in-person requests

Please note that the Company cannot accept telephone or in-person requests.