PRIVACY POLICY

1. Basic policy

West Japan Railway Hotel Development Ltd. (hereinafter referred to as "The Company") has established this privacy policy and the organizational system on the handling of the personal information of all stakeholders (customers, job applicants, external business partners of The Company, etc.) who use the corporate website of The Company (hereinafter referred to as "The Website") and strives for the appropriate protection of personal information.

• Acquisition of personal information
  The Company acquires the following personal information for the purpose of providing services or business operations of The Company. The Company acquires personal information within the scope of its intended purposes of use and clearly explains purposes of use, the scope of utilization, and the inquiries office of The Company, etc.
• Prohibition on the use of personal information beyond the intended purposes and the provision of personal information to third parties
  The Company uses personal information within the scope of its intended purposes of use, appoints a Personal Information Protection Manager and has established the organizational system for the protection of personal information. The Company deals with personal information adequately and does not provide or disclose personal information to third parties without the consent of Persons Concerned or request by laws and regulations.
• Assigning of personal information
  In case that The Company entrusts all or part of personal information, The Company prohibits entrusted persons from leaking or providing personal information to third parties by contract and supervises entrusted persons appropriately.
• The rights of Persons Concerned
  The specific individuals identified by personal information (hereinafter referred to as "Person/s Concerned") have the right to withdraw their consent to the use of personal information at any time even if they had consented to the intended purposes before. In addition, Persons Concerned have the right to request The Company for a utilization cease, disclosure etc. of the retained personal information pursuant to the provisions of applicable laws.
• Procedures of a utilization cease, disclosure etc. of personal information
  In case that Persons Concerned request The Company a utilization cease, disclosure etc. of the retained personal information, they shall contact the inquiries office specified by The Company. The Company shall respond as soon as reasonably possible.
• Observance of laws and regulations
  The Company observes applicable laws, regulations and standards, provides in-house education, informs employees of this privacy policy and strives for the improvement of understandings of employees on the handling of the retained personal information.
• The review and improvement of the system for the protection of personal information
  The Company will continuously evaluate and review this privacy policy and the systems for the protection of personal information. The Company will maintain and improve the actions for the protection of the retained personal information.
• Handling personal information by link destinations
  The Company shall bear no responsibility with regard to the handling of personal information by other entities or individuals linked to The Website.

2. Definition of personal information

The term "personal information" in this privacy policy means information related to a living individual that can identify a specific individual by name, date of birth or other description contained in. (This includes the "personal information" defined by Article 2(1) of the Act on the Protection of Personal Information.)

3. Acquisition and purposes of use of personal information

The Company acquires and uses the following personal information for the following intended purposes. The Company does not use personal information beyond the scope of intended purposes of use without the consent of the Persons Concerned.

• Personal information of customers
  
  • Personal information acquired
    Name, age, gender, date of birth, occupation, address, telephone number, email address, nationality, passport number and other information necessary for the following purposes of use.
  • Purposes of use
    • For performing works required to provide services at The Company (accommodation, restaurants, shops, banquets, wedding receptions, catering).
    • For offering on-line booking and other related businesses.
    • For handling inquiries and requests, etc.
    • For providing necessary information on the products, services, events and other related business activities of The Company.
    • For providing information on the products, services and events of The Company to the customers who have consented to sending by direct mail, email and LINE, etc.
    • For offering prizes or campaigns.
    • For grasping and analyzing state of usage of the products, services and events of The Company to improve their quality.
    • For exercising rights and performing duties based on laws and the provisions of terms and conditions for accommodation.
    • For other purposes of use indicated at the time of acquisition of personal information.
• Personal information of job applicants
  
  • Personal information acquired
    Name, age, gender, date of birth, address, telephone number, email address, and other information necessary for the following purposes of use.
  • Purposes of use
    • For performing works required for recruitment activities and the procedures and contracts of employment.
    • For handling inquiries and requests, etc.
    • For other purposes of use indicated at the time of acquisition of personal information.
• Personal information of external business partners of The Company
  
  • Personal information acquired
    Business card information and other information on external business partners of The Company necessary for the following purposes of use.
  • Purposes of use
    • For concluding and performing contracts with external business partners of The Company and other works required.
    • For handling inquiries and requests, etc.
    • For other purposes of use indicated at the time of acquisition of personal information.
• Personal information of members of the "JR Hotel Members" organization.
  
  • Personal information acquired
    Member number, password, name, age, gender, date of birth, address, telephone number, email address, employer information and history of providing and use of points, and other information necessary for the following purposes of use.
  • Purposes of use
    • For performing works required within the scope of the purposes of use set forth in 3(1)2 of this privacy policy.
    • For performing works required for the operation of the "JR Hotel Members" organization (hereinafter referred to as "The Members' Organization") by The Company.
    • For providing important information such as changes to the membership agreement, terms of service or benefits of The Members' Organization.
    • For other purposes of use indicated at the time of acquisition of personal information.
  • Other agreements of The Members' Organization
    Membership agreement of the "JR Hotel Members" organization
    Terms of service of the "JR Hotel Members" organization

4. Handling of personal information

• Appropriate management of personal information
  

  The Company appropriately implements management of personal information, takes appropriate safety measures including reasonable technological measures to prevent unauthorized access, damage, falsification and leakage of personal information. The Company continuously strives to maintain and enhance the management system of personal information.
  The Company strives to keep the personal information accurate and up to date within the scope of purposes of use, limits the employees who can access or handle it and exercises appropriate supervision over them.
  The Company stores the personal information on the database of The Company or third-party service providers that The Company has concluded contracts with.
  The Company sets expiration dates for the storage of personal information within necessary period for purposes of use and deletes the personal information without delay after expiration dates unless otherwise specified in laws and regulations.

• Safety measures on the internet
  

  The Company implements the following safety technologies in the use of its on-line booking system though these do not guarantee a complete security environment.

  • SSL
    The Company uses SSL (Secure Sockets Layer) encryption technology on The Website where personal information is inputted.
    With SSL, data is transmitted to the registered computer through a network after being encrypted. (SSL is a technology that prevents theft or alteration of data by encryption and authentication in communication between the browser and the WWW server.)
  • Cracking by unauthorized access
    The Company installs a firewall to prevent unauthorized access from outside.

5. Sharing of personal information

The Company shares personal information within the scope of its intended purposes of use as follows.
When the sharing users have established policies for personal information, their policies shall be applied for their use.

• Sharing of personal information on the business of The Company (accommodation, restaurants, shops, banquets, wedding receptions, catering.)
  
  • Scope of the sharing users
    Member companies of The Members' Organization, the JR Hotel Group and JR-East Hotels.
  • Purposes of sharing use
    For providing services at The Company (accommodation, restaurants, shops, banquets, wedding receptions, catering) and offering on-line booking reservations, and other related businesses.
  • Categories of sharing Information
    Member number, password, name, age, gender, date of birth, address, telephone number, email address, employer information and history of providing and use of points and other information necessary for the above purposes of sharing use.
  • Name of a person responsible
    West Japan Railway Hotel Development Ltd.
• Sharing of personal information for the service at all tenant shops in the hotels that The Company operates
  
  • Scope of the sharing users
    All tenant shops in the hotels that The Company operates.
  • Purposes of sharing use
    For providing services at The Company (accommodation, restaurants, shops, banquets, wedding receptions, catering) and other related businesses.
  • Categories of sharing Information
    Name, age, gender, date of birth, address, telephone number, email address, and other information necessary in the scope of above purposes of sharing use.
  • Name of a person responsible
    West Japan Railway Hotel Development Ltd.

6. Provision of personal information to third parties

The Company does not provide personal information to third parties without obtaining the consent of Persons Concerned in advance except in cases set forth in the following categories.

• Cases where The Company provides personal information to third parties
  
  • Cases based on laws and regulations
  • Cases where there is a need to protect a human life, body or fortune, and when it is difficult to obtain the consent of Persons Concerned
  • Cases where there is a special need to enhance public hygiene or promote fostering healthy children, and when it is difficult to obtain the consent of Persons Concerned
  • Cases where there is a need to cooperate in regard to a central government organization or a local government, or a person entrusted by them performing public affairs, and when there is a possibility that obtaining the consent of the Persons Concerned would interfere with the performance of the said public affairs
  • Cases where disclosure or provision to a third party has been requested clearly by Persons Concerned
• Disclaimer regarding provision to a third party
  

  In the following cases, The Company will bear no responsibility whatsoever with regard to the acquisition of personal information by third parties.

  • Cases where personal information is disclosed to an accommodation facility by Persons Concerned (if Persons Concerned discloses personal information of companions at the time of reservation, it is assumed that the consent of those companions is obtained at the responsibility of the Person Concerned)
  • Cases where personal information is disclosed to third parties by Persons Concerned
  • Cases where personal information is provided to or used on external websites linked to The Website by Persons Concerned
  • Cases where third parties obtain information that could identify an individual (password, etc.) for reasons not attributable to The Company
• Appropriate management and supervision over entrusted persons
  

  In case of The Company entrusts the handling of personal information to third parties within the scope of intended purposes of use, The Company shall take appropriate consideration for the selection of entrusted persons, conclude a non-disclosure contract with them, guide them for the proper management of personal information and exercise appropriate supervision over them.

7. Transfer of personal information outside of the European Economic Area (EEA)

The Company may transfer the personal information of Persons Concerned who reside in the European Economic Area (EEA) to the terrain outside of the EEA and use within the scope of intended purposes of use. In these cases, The Company shall appropriately and strictly handle the personal information under applicable laws.
Please see below for the handling of the personal data of persons who are in the EEA.

8. Rights of Persons Concerned

Persons Concerned have the right to demand actions such as the notification of the purposes of use, disclosure, correction, deletion, utilization cease, or ceasing of provision to third parties (hereinafter referred to as "Utilization cease, Disclosure, etc.") of the retained personal information pursuant to the provisions of applicable laws. Persons Concerned have the right to withdraw their consent to the use of personal information at any time even if they had consented to the intended purposes before.
Persons Concerned have the right to object to their local supervisory authorities with jurisdiction over the protection of personal information if they are dissatisfied with the handling of personal information by The Company.

9. Procedures of Utilization cease, Disclosure, etc.

In case that Persons Concerned request The Company for Utilization cease, Disclosure, etc., The Company shall respect the will of the Persons Concerned, confirm the identification of the Person Concerned and respond for the reasonable period pursuant to the provisions of applicable laws.

However, The Company may refuse said request:

• where there is a possibility of violating the laws or regulations,
• where there is a possibility of harming third party’s life, body, fortune or other rights and interests,
• where there is a possibility of interfering with The Company implementing its business,
• where the said personal information does not exist,
• where The Company cannot confirm the identification of the Persons Concerned,
• and where Persons Concerned do not pay the prescribed fee.

When Persons Concerned request Utilization cease, Disclosure, etc., please contact the personal information inquiries office below.

• Personal information inquiries office

  [Personal information inquiries office]
  Address:JR Kyoto Station Central Exit, Shiokoji-sagaru, Karasuma-dori, Shimogyo-ku, Kyoto 600-8216
  Personal Information Inquiries Office:General Affairs Department, West Japan Railway Hotel Development Ltd.

• Purpose of use of personal information acquired due to requests for Utilization cease, Disclosure, etc.
  The Company will use personal information acquired due to requests for Utilization cease, Disclosure, etc. within the scope of purposes required for the procedures for Utilization cease, Disclosure, etc. The Company will appropriately dispose of the documents submitted in the procedures for Utilization cease, Disclosure, etc.

10. Protection of the personal information of minors

The Company handles the personal information of minors appropriately in accordance with this privacy policy. When Persons Concerned is minor, The Company may require the consent of persons in parental authority for acquiring the personal information. If Persons Concerned is less than 13 years of age, The Company shall require the consent of persons in parental authority and give special consideration to the handling of their personal information.

11. Use of cookies

The Website may use cookies to improve the information and services provided and to offer comfortable use of The Website.
For details, please refer to the "Cookie policy" of The Website.

12. Handling of access logs

The Website may acquire access logs to improve the use of The Website and to analyze statistical data. The Company does not disclose access logs to third parties unless otherwise provided by laws and regulations. If you refuse to send access logs, you may not use The Website properly.

13. Revision of this privacy policy

The Company will revise this privacy policy to respond to changes in related laws, regulations or the social environment, etc. The Company will post the revised privacy policy on The Website.

14. Personal information inquiries office

Please contact the personal information inquiries office below when you have any inquiries about this privacy policy.