Privacy Policy

Last Updated: February 28, 2025

NOTICE: This Privacy Policy is a preliminary draft for our US operations. THIRD is registered in Japan and is pending registration in the US. This document will be finalized and updated following US business registration.

INTRODUCTION

THIRD (registered in Japan, pending registration in the US) ("THIRD," "we," "us," or "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you visit our website or use our AI services for real estate and construction industries.

Please read this Privacy Policy carefully. By accessing or using our website and services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with our policies and practices, please do not use our website or services.

INFORMATION WE COLLECT

We may collect the following types of information:

Personal Information

Contact Information: Name, email address, phone number, mailing address
Professional Information: Company name, job title, industry
Account Information: Username, password, account preferences
Transaction Information: Payment details, purchase history, billing information

Non-Personal Information

Usage Data: Browser type, IP address, device information, operating system, time spent on pages
Log Data: Server logs, traffic data, site interaction patterns
Location Data: General geographic location based on IP address
Cookies and Similar Technologies: Web beacons, pixels, and other tracking technologies

HOW WE COLLECT INFORMATION

We collect information in the following ways:

Direct Collection: Information you provide when you create an account, sign up for newsletters, complete forms, or communicate with us
Automated Collection: Information collected automatically through cookies and similar technologies when you use our website
Third-Party Sources: Information we receive from business partners, marketing agencies, and other third parties

HOW WE USE YOUR INFORMATION

We may use your information for the following purposes:

To provide and maintain our services
To process and complete transactions
To send administrative information and service updates
To personalize user experience and deliver tailored content
To improve our website, products, and services
To conduct research and analysis to enhance our AI technology
To respond to inquiries, questions, and customer support requests
To send marketing communications, if you have opted in
To detect, prevent, and address technical issues and security breaches
To comply with legal obligations

DISCLOSURE OF YOUR INFORMATION

We may share your information with:

Third-Party Service Providers

We may share your information with third-party vendors and service providers who perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, and customer service.

Business Transfers

If we are involved in a merger, acquisition, financing, or sale of all or a portion of our assets, your information may be transferred as part of that transaction.

Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., court orders, government agencies).

With Your Consent

We may share your information with third parties when we have your consent to do so.

DATA RETENTION

We will retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

DATA SECURITY

We implement appropriate technical and organizational measures to maintain the security and integrity of your personal information and to protect it against unauthorized access, accidental loss, destruction, or damage.

However, please understand that no method of electronic transmission or storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

YOUR RIGHTS AND CHOICES

Depending on your location, you may have the following rights regarding your personal information:

Access: Request access to your personal information
Correction: Request correction of inaccurate personal information
Deletion: Request deletion of your personal information
Portability: Request transfer of your personal information
Restriction: Request restriction of processing of your personal information
Objection: Object to processing of your personal information
Opt-out: Opt-out of marketing communications or cookie use

To exercise these rights, please contact us using the information provided in the "Contact Us" section below.

CHILDREN'S PRIVACY

Our website and services are not intended for children under the age of 16. We do not knowingly collect personal information from children under 16. If you are a parent or guardian and believe your child has provided us with personal information, please contact us, and we will delete such information.

CALIFORNIA PRIVACY RIGHTS

California residents may have additional privacy rights under the California Consumer Privacy Act (CCPA) and other California privacy laws. Please visit our California Privacy Notice for more information about these rights.

DO NOT TRACK SIGNALS

Some web browsers have "Do Not Track" features that signal to websites not to track your online activities. Our website currently does not respond to Do Not Track signals.

THIRD-PARTY WEBSITES

Our website may contain links to third-party websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party websites or services. We encourage you to review the privacy policies of any third-party websites you visit.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Last Updated" date. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:

Email: third_intl@third-inc.com

ADDITIONAL INFORMATION FOR EU/EEA RESIDENTS

If you are a resident of the European Union or European Economic Area, please refer to our EU Privacy Addendum for additional information about the processing of your personal data and your rights under the General Data Protection Regulation (GDPR).

CALIFORNIA PRIVACY NOTICE

Last Updated: February 28, 2025

NOTICE: This California Privacy Notice is a preliminary draft for our US operations. THIRD is registered in Japan and is pending registration in the US. This document will be finalized and updated following US business registration.

This California Privacy Notice ("Notice") supplements the information contained in the Privacy Policy of THIRD (registered in Japan, pending registration in the US) ("THIRD," "we," "us," or "our") and applies solely to California residents ("consumers" or "you"). This Notice provides additional information about how we collect, use, disclose, and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively, the "CCPA").

Unless otherwise expressly stated, all terms defined in our Privacy Policy retain the same meaning in this Notice, and all other terms defined in the CCPA have the same meaning when used in this Notice.

PERSONAL INFORMATION WE COLLECT

In the past 12 months, we have collected the following categories of personal information from consumers:

A. Identifiers:

Examples: Name, email address, postal address, IP address, account name
Collected: YES

B. Personal information categories listed in the California Customer Records statute:

Examples: Name, contact information, financial information, payment information
Collected: YES

C. Protected classification characteristics under California or federal law:

Examples: Age, gender
Collected: YES

D. Commercial information:

Examples: Products or services purchased, obtained, or considered
Collected: YES

E. Biometric information:

Examples: None
Collected: NO

F. Internet or other similar network activity:

Examples: Browsing history, search history, information on a consumer's interaction with a website
Collected: YES

G. Geolocation data:

Examples: Physical location based on IP address
Collected: YES

H. Sensory data:

Examples: None
Collected: NO

I. Professional or employment-related information:

Examples: Current employer, job title, work history
Collected: YES

J. Non-public education information:

Examples: None
Collected: NO

K. Inferences drawn from other personal information:

Examples: Profile reflecting preferences, characteristics, trends, behavior
Collected: YES

SOURCES OF PERSONAL INFORMATION

We collect the personal information listed above from the following categories of sources:

Directly from you. For example, when you create an account, complete forms, or communicate with us.
Indirectly from you. For example, from observing your actions on our website or through cookies and similar technologies.
From third parties. For example, business partners, marketing agencies, and service providers.

USE OF PERSONAL INFORMATION

We may use or disclose the personal information we collect for the business purposes described in our Privacy Policy, including:

To provide and maintain our services
To process transactions and send related information
To respond to inquiries and provide customer support
To improve our website, products, and services
To personalize your experience
To communicate with you about our products, services, and events
To conduct research and analysis to enhance our AI technology
To detect security incidents and protect against malicious or illegal activity
To debug and repair errors in our systems
To comply with laws, regulations, and legal processes

DISCLOSURE OF PERSONAL INFORMATION

In the past 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of third parties:

We have disclosed the following categories of personal information for business purposes to the following categories of third parties:

Identifiers:
- Disclosed to: Service providers, analytics providers, marketing partners
Personal information categories listed in the California Customer Records statute:
- Disclosed to: Service providers, payment processors
Protected classification characteristics under California or federal law:
- Disclosed to: Service providers
Commercial information:
- Disclosed to: Service providers, analytics providers
Internet or other similar network activity:
- Disclosed to: Service providers, analytics providers
Geolocation data:
- Disclosed to: Service providers, analytics providers
Professional or employment-related information:
- Disclosed to: Service providers
Inferences drawn from other personal information:
- Disclosed to: Service providers, analytics providers, marketing partners

SALE OR SHARING OF PERSONAL INFORMATION

In the past 12 months, we have not sold personal information to third parties as the term "sale" is traditionally understood. However, under the CCPA, some sharing of personal information may be considered a "sale" or "sharing" (for cross-context behavioral advertising purposes).

In the past 12 months, we have shared the following categories of personal information for cross-context behavioral advertising purposes:

Identifiers (such as online identifiers and IP addresses)
Internet or other similar network activity

If you wish to opt out of the sale or sharing of your personal information, please see the "Your Rights and Choices" section below.

YOUR RIGHTS AND CHOICES

As a California resident, you have the following rights under the CCPA:

Right to Know: You have the right to request that we disclose certain information to you about our collection, use, disclosure, and sale of your personal information over the past 12 months.
Right to Delete: You have the right to request that we delete personal information that we have collected from you, subject to certain exceptions.
Right to Correct: You have the right to request that we correct inaccurate personal information that we maintain about you.
Right to Opt-Out of Sale or Sharing: You have the right to opt-out of the sale or sharing of your personal information for cross-context behavioral advertising purposes.
Right to Limit Use and Disclosure of Sensitive Personal Information: You have the right to limit our use and disclosure of your sensitive personal information to certain business purposes.
Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your privacy rights.

HOW TO EXERCISE YOUR RIGHTS

To exercise your rights described above, please submit a request to us by:

Emailing us at third_intl@third-inc.com

Only you, or a person that you authorize to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a request to verify the requestor's identity or authority to make the request.

We will acknowledge receipt of your request within 10 business days and will respond to verifiable requests within 45 calendar days. If we require additional time, we will inform you of the reason and extension period.

FINANCIAL INCENTIVES

We do not offer financial incentives or price or service differences in exchange for the retention or sale of personal information.

CHANGES TO THIS NOTICE

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on our website and update the "Last Updated" date.

CONTACT INFORMATION

If you have any questions or comments about this Notice or our privacy practices, please contact us at:

Email: third_intl@third-inc.com

EU PRIVACY ADDENDUM

Last Updated: February 28, 2025

NOTICE: This EU Privacy Addendum is a preliminary draft for our US operations. THIRD is registered in Japan and is pending registration in the US. This document will be finalized and updated following US business registration.

This EU Privacy Addendum ("Addendum") supplements the information contained in the Privacy Policy of THIRD (registered in Japan, pending registration in the US) ("THIRD," "we," "us," or "our") and applies to the processing of personal data of individuals located in the European Union, European Economic Area, and the United Kingdom (collectively, "EU/UK"). This Addendum provides additional information required by the EU General Data Protection Regulation ("GDPR") and the UK GDPR.

CONTROLLER

THIRD (registered in Japan, pending registration in the US) is the controller of your personal data and is responsible for its processing. Our contact details are:

THIRD (registered in Japan, pending registration in the US)
Email: third_intl@third-inc.com

LEGAL BASIS FOR PROCESSING

We process your personal data on the following legal bases:

Creating and managing your account
- Legal basis: Performance of a contract
Providing our AI services for real estate and construction
- Legal basis: Performance of a contract
Processing payments
- Legal basis: Performance of a contract
Sending service notifications
- Legal basis: Performance of a contract
Customer support
- Legal basis: Performance of a contract
Improving our services and website
- Legal basis: Legitimate interests
Direct marketing communications
- Legal basis: Consent
Analytics and usage statistics
- Legal basis: Legitimate interests
Complying with legal obligations
- Legal basis: Legal obligation
Protecting our rights and preventing fraud
- Legal basis: Legitimate interests

Where we rely on legitimate interests as a legal basis, we have conducted a balancing test to ensure that our legitimate interests are not overridden by your interests, fundamental rights, and freedoms.

Where we rely on consent, you have the right to withdraw your consent at any time by contacting us or by using the unsubscribe function in our marketing communications.

INTERNATIONAL TRANSFERS

THIRD is based in Japan, and your personal data will be transferred to and processed in Japan and potentially in the United States. These countries may not have the same level of data protection as the country in which you initially provided the information.

When we transfer your personal data outside the EU/UK, we ensure an adequate level of protection through one or more of the following safeguards:

Transferring to countries that have been deemed to provide an adequate level of protection by the European Commission
Implementing appropriate safeguards, such as Standard Contractual Clauses approved by the European Commission
Obtaining your explicit consent to the proposed transfer after informing you of the possible risks

You may contact us to obtain a copy of the Standard Contractual Clauses or other safeguards we use for international transfers.

DATA RETENTION

We retain your personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider:

The amount, nature, and sensitivity of the personal data
The potential risk of harm from unauthorized use or disclosure
The purposes for which we process your personal data
Whether we can achieve those purposes through other means
The applicable legal requirements

AUTOMATED DECISION-MAKING AND PROFILING

Our AI services for real estate and construction may involve automated decision-making and profiling. This may include analyzing property data, market conditions, and user preferences to provide recommendations, valuations, or other insights.

Where we make a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you, we will:

Inform you that we are engaging in such activity
Give you information about the logic involved
Explain the significance and envisaged consequences
Implement suitable safeguards, including the ability to obtain human intervention, express your point of view, and contest the decision

YOUR RIGHTS UNDER GDPR

Under the GDPR, you have the following rights regarding your personal data:

Right to Access: You have the right to obtain confirmation as to whether personal data concerning you is being processed and, if so, access to that personal data and related information.
Right to Rectification: You have the right to have inaccurate personal data corrected and incomplete personal data completed.
Right to Erasure (Right to be Forgotten): You have the right to have your personal data erased under certain circumstances.
Right to Restriction of Processing: You have the right to restrict the processing of your personal data under certain circumstances.
Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit this data to another controller.
Right to Object: You have the right to object to the processing of your personal data under certain circumstances, including processing based on legitimate interests and direct marketing.
Rights Related to Automated Decision-making and Profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
Right to Withdraw Consent: You have the right to withdraw your consent at any time where we rely on consent to process your personal data.
Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority, particularly in the EU member state of your habitual residence, place of work, or place of the alleged infringement.

HOW TO EXERCISE YOUR RIGHTS

To exercise any of the rights described above, please submit a request to us by:

Emailing us at third_intl@third-inc.com

We will respond to your request within one month. In some cases, we may need to extend this period by up to two additional months, taking into account the complexity and number of requests. If we extend the response period, we will inform you of the extension within one month of receiving your request.

If we decide not to take action on your request, we will inform you of the reasons for not taking action and of your right to lodge a complaint with a supervisory authority and to seek a judicial remedy.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

DATA PROTECTION OFFICER

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Addendum. If you have any questions about this Addendum, including any requests to exercise your legal rights, please contact the DPO at:

Data Protection Officer
THIRD, Inc.
Email: third_intl@third-inc.com

CHANGES TO THIS ADDENDUM

We may update this Addendum from time to time. The updated version will be indicated by an updated "Last Updated" date. We encourage you to review this Addendum periodically to stay informed about how we are protecting your personal data.

PRIORITY

In case of any conflict between this Addendum and our Privacy Policy regarding the processing of personal data of individuals in the EU/UK, this Addendum shall prevail.