Privacy Policy

1. Information we collect

We collect information you provide when inquiring about or applying for a property — including your name, email address, phone number, nationality, passport or residence card details, employment information, and preferred move-in dates.

We also collect usage data automatically when you browse our site, including pages visited, time spent, device type, browser, approximate location (city-level), and referral source. This data is collected through cookies and similar technologies, including Google Analytics, the Meta Pixel, and Microsoft Clarity (see Section 5).

2. How we use your information

We use your personal information for the following purposes:

• Processing rental inquiries and applications • Communicating with you about properties, contracts, and your stay • Coordinating with property owners on your behalf • Providing concierge services during your tenancy • Improving our website and services through analytics • Measuring the effectiveness of our advertising • Complying with legal obligations and regulatory requirements • Sending service-related updates (we do not send marketing emails without your consent)

3. Sharing with third parties

We may share your information in the following circumstances:

• With property owners and their agents, to process your application and manage your tenancy • With guarantor companies, to fulfil the guarantor requirement on your behalf • With service providers who assist our operations (payment processing, maintenance coordination) • With Google, through Analytics and Ads services, for website analytics and advertising measurement (see Section 5) • With Meta (Facebook/Instagram), through the Meta Pixel, for advertising measurement and optimisation (see Section 5) • With Microsoft, through Clarity, for website analytics including session recordings and heatmaps (see Section 5) • When required by law, regulation, or legal process • To protect the rights, safety, or property of HalfKey, our users, or the public

We do not sell your personal information to third parties.

4. Data security

We use SSL encryption to protect data transmitted through our website. Access to personal information is restricted to authorised personnel who need it to perform their duties. While we take reasonable measures to protect your data, no method of electronic transmission or storage is completely secure.

5. Cookies and tracking technologies

Our website uses cookies — small text files stored on your device — to improve your experience and help us understand how visitors use our site. Here is what we use and why:

We also use our own analytics to improve the user experience.

Google Analytics (GA4) We use Google Analytics 4 to collect anonymised usage statistics such as pages visited, session duration, and device type. GA4 sets the following cookies: • _ga — distinguishes unique visitors (expires after 2 years) • _ga_* — maintains session state (expires after 2 years) This data is processed by Google under their privacy policy. We do not use this data to personally identify you. IP addresses are anonymised by default in GA4.

Google Ads We use Google Ads conversion tracking and remarketing to measure the effectiveness of our advertising and to show relevant ads to people who have visited our site. Google Ads may set cookies to track ad interactions and conversions.

Enhanced conversions When you submit an application, we send a hashed (one-way encrypted) version of your email address to Google to help measure whether our ads led to your inquiry. Google cannot reverse this hash to read your email. This is used solely for advertising measurement.

Meta Pixel We use the Meta Pixel to measure the effectiveness of our Facebook and Instagram advertising and to show relevant ads to people who have visited our site. The Meta Pixel may set cookies to track page views, property inquiries, and application submissions. This data is processed by Meta under their privacy policy. We do not use this data to personally identify you.

Microsoft Clarity We use Microsoft Clarity to understand how visitors interact with our site through session recordings and heatmaps. Clarity may collect data such as mouse movements, clicks, scrolls, and page content. Clarity masks sensitive content by default. This data is processed by Microsoft under their privacy policy. We do not use this data to personally identify you.

You can disable cookies through your browser settings, though some features of the site may not function properly. You can also opt out of Google Analytics by installing Google’s opt-out browser add-on, control Google ad personalisation at adssettings.google.com, manage your Meta ad preferences at facebook.com/adpreferences, and learn more about Clarity’s data practices at clarity.microsoft.com.

6. Application form data

When you apply for a property, we collect:

• Your name, email address, and phone number • Your preferred move-in and move-out dates • Any special requests you include

This information is used to process your application and coordinate with property owners. We retain it for the duration of your tenancy and a reasonable period afterwards for legal and administrative purposes.

7. Data retention

We retain your personal information for as long as necessary to fulfil the purposes described in this policy, including for the duration of your tenancy and a reasonable period afterwards for legal and administrative purposes. You may request deletion of your data at any time by contacting us.

8. Your rights

You have the right to:

• Access the personal information we hold about you • Request correction of inaccurate information • Request deletion of your personal information • Request that we restrict processing of your data • Request your data in a portable format • Opt out of advertising cookies and tracking

To exercise any of these rights, please contact us using the details below. We aim to respond within 30 days.

9. Changes to this policy

We may update this privacy policy from time to time. Changes take effect when posted on this page. We encourage you to review this policy periodically.

10. Contact

For questions about this privacy policy or how we handle your data, contact us at hello@halfkey.jp.

HalfKey KK (ハーフキー合同会社) SHINO Building 4F, 1-4-40 Nishi-azabu, Minato-ku, Tokyo