PRIVACY POLICY

1.How We Collect Personal Information (Sources of Personal Information)

We collect your personal information mainly through interactions listed below. The personal information provided by you is necessary for us to provide our highest level of services to you. Certain services may not be available to you if your personal information is not provided to us.

• (1) Guest registration card submitted by you;
• (2) Application form for weddings/banquets;
• (3) Application form for use of our facilities;
• (4) Application form for our membership program and other similar documents;
• (5) Records made at the time of your visit or telephone calls to one of our Hotels; and
• (6) Booking information through certain websites.

2.Personal Information Which We Collect and its Purpose

We use personal information collected from you and share your information amongst our Hotel Group for the purposes shown in the below table.

If you are receiving our services through our website, the information listed in the below table is also used for the following purposes.

Even if the relationship between you and our Hotel Group terminates due to your withdrawal from our membership program or for any other reasons, we will continue to handle your personal information in accordance with this Policy as long as we retain your personal information subject to the provisions of Section 5.

We strive to keep personal data held by us as accurate and updated. If there are any changes to your personal information, please kindly inform us of such changes promptly.

3.Entrusting Your Personal Data to Third Parties

We do not provide your personal data to any third party unless we have obtained your consent. If we entrust the handling of your personal data to a third party to the extent necessary to achieve the purposes of use of your personal data, we will instruct such third party to properly safeguard your personal data, and we will also properly supervise such third party.
Please note, however, that we may provide your personal data to a third party in order to cooperate in responding to a request for disclosure of such personal data that has been made based on legal grounds by a person who is duly authorized by judicial or administrative authorities, or otherwise as permitted by the Laws.

4.The Basis for Processing Your Personal Information

We process your personal information based on one or more basis listed below:

• (1) you have given your consent to the processing of your personal data for one or more specific purposes set forth in Section 2;
• (2) processing of your personal data is necessary for the performance of a contract between you and our Hotel Group, or in order to take steps at your request prior to entering into a contract;
• (3) processing of your personal data is necessary for compliance with a legal obligation that our Hotel Group is subject to;
• (4) processing of your personal data is necessary in order to protect your vital interests or those of a third party;
• (5) processing of your personal data is permitted for the performance of a task carried out in the public interest or in the exercise of official authority vested in our Hotel Group; and
• (6) processing of your personal data is necessary for the purposes of the legitimate interests (which are listed below) pursued by our Hotel Group or a third party, except where such interests are overridden by your fundamental rights and freedoms):
  
  
  • a. our business operations;
  • b. improving our services and developing new services;
  • c. researching and analyzing your usage of our Hotel Group;
  • d. ensuring the safety of our guests, and employees and officers of our Hotel Group;
  • e. direct marketing to you;
  • f. making legal claims, insurance claims or other similar claims by us or a third party;
  • g. increasing vital public interests by us or a third party;
  • h. providing public authorities with information relating to a criminal offence or threat to public security.

As it is necessary to provide services to guests, we process personal information of guests that has been collected within the EEA (European Economic Area) after transferring such personal information from the EEA to Japan in accordance with Article 49, Paragraph 1 (b) of the GDPR.

5.Retaining and Deleting Your Personal Information

We retain your personal information under our safeguard and control only for the period required for achieving the purposes of its use and will delete such information within a reasonable period of time after the retaining period has elapsed.

6.The Rights of our Guests

You have the following rights if you satisfy certain requirements under the Laws (Please refer to Section 9 regarding the methods of exercising you rights or to contact us):

• (1) You have the right to request us to explain about your information held by us and how we use such information;
• (2) You have the right to obtain a copy of your personal data held by us upon payment of a fee set by us;
• (3) You have the right to have us correct your personal data held by us if such data is incorrect;
• (4) You may request us to erase your personal data under our control, and we will erase your personal data in accordance with your request. However, we may retain your personal data under certain circumstances as permitted by the Laws;
• (5) You have the right to receive your personal data and transfer it to another controller;
• (6) You have the right to object to any use of your personal data. However, even if you raise an objection, we may continue to process your personal data to the extent permitted by the Laws;
• (7) You have the right to request us to restrict our processing of your personal data. Specifically, you have the right to object to the use of your personal data for direct marketing purposes;
• (8) You may lodge a complaint with the supervisory authorities; and
• (9) You may withdraw your consent to us regarding use of your personal data.

7.Safeguarding Your Personal Data

We have adopted the highest standards of information security in order to protect your privacy and the confidentiality of your personal data.
We only allow authorized employees or agents to access your personal data.
In addition, we impose strict confidentiality obligations on our service providers.
We take physical, electronic and procedural safeguards to prevent loss, misuse, damage, falsification and leakage of, and unauthorized access to, your personal data.
The other features of our information security program include:

• (1) using specialized technologies such as Firewall;
• (2) testing the safety and operability of products and services that will be used on the internet before actually using them, and closely examining the generally known vulnerabilities of technologies on a constant basis;
• (3) conducting internal and external audits of services that are provided through our website or the internet;
• (4) striving to identify vulnerabilities or possible threats of hacking by monitoring the infrastructure of our systems;
• (5) controlling access to various websites and systems by verifying the identity and authority of persons; and
• (6) training our employees, and addressing new risks and development of technology in order to always keep our security measures updated.

8.About this Policy

This Policy is subject to change to reflect our actual collection and use of your personal information.
This Policy, after any such changes are made, becomes effective at the time when the changed policy is published on our website. The latest revision of this Policy was made on June 8th, 2021.

9.Contact Us

You may request us to disclose your personal data held by us. When requesting such disclosure, we will ask you to kindly submit an identification document to us in order to prevent the leakage of your personal data to any person other than you. We handle such request for disclosure in accordance with the Laws.

If we receive your request made in accordance with the Laws to correct, add or delete the content of your personal data held by us, or to stop using, delete or suspend the provision to a third party of your personal data held by us, we will handle such request in accordance with the Laws.

If you wish to request the disclosure, correction, etc. of your personal data held by us, or if you need detailed information on our Privacy Policy or the protection of personal information, please contact us below. (If you wish to request the disclosure, correction, etc. of your personal data held by us, please download the application form below on our website, complete it, and send it to the contact below by mail.)
Please note that our Hotel Group may charge you expenses actually incurred in association with the procedure for disclosure of your personal data held by us.

【Contact for inquiries regarding the protection of personal information】

Hotel Management Japan Co., Ltd. Personal Information Control Manager
Mail