Corporate Informaiton

Supplemental Rules on Handling of Personal Information

Resorttrust, Inc. ("Company") makes every effort to protect personal information of customers of the Company. These Supplemental Rules, as a supplement of “Rules on Handling of Personal Information,” cover Company’s detailed policy on handling and protection of customer personal information where customers using the services of Company to ensure that customers can visit Company’s facilities and otherwise use its services comfortably.

1. ABOUT THE COMPANY AND THESE SUPPLEMENTAL RULES

Resorttrust, Inc. is incorporated in Japan and its registered office is at 2-18-31 Higashi-Sakura, Naka-ku, Nagoya-shi, Aichi, Japan.

These Supplemental Rules, as a supplement of “Rules on Handling of Personal Information,” explain how Company will handle the personal information of guests visiting its hotels, restaurants and other facilities (“Guests”). These Supplemental Rules do not form any contractual relationship between Guests and Company.

2. LAWFUL HANDLING

Company will only handle personal information of Guests:

  1. ①where Guests have given their consent (such consent may be withdrawn at any time, by making a request using the contact details set out below);
  2. ②where the handling is necessary to provide Company’s services to Guests;
  3. ③where the handling is necessary to respond to a request from Guests;
  4. ④where the handling is necessary for compliance with legal and regulatory obligations of Company; and
  5. ⑤for any other legitimate purposes.

3. WHAT PERSONAL INFORMATION COMPANY COLLECT ABOUT GUESTS

  1. 3.1Company may handle the following types of personal information about Guests:
  1. ①name, postal address, email address, telephone number and other contact details;
  2. ②Gender, date of birth, passport information and other information about Guests;
  3. ③Information about family members, companions, etc.;
  4. ④Information on travel itinerary, schedule, etc.;
  5. ⑤Information on special requests from Guests such as room preferences, dietary requirements;
  6. ⑥Employer/employment information;
  7. ⑦Car-related information such as car registration for car parking arrangements;
  8. ⑧Loyalty programme information;
  9. ⑨Information on prior stay, payment history, etc.;
  10. ⑩Information on preferences for types of marketing events or materials etc.;
  11. ⑪Information on access to Company’s premises, systems, websites, etc.（including Cookie）;
  12. ⑫Information on messages, feedback or contributions to customer surveys and questionnaires etc.;
  13. ⑬Information on goods and accessories that Company sell or trade directly or through other arrangement such as concession sales, such as order and payment history of such goods and accessories;
  14. ⑭Information available from official documents issued by public authorities such as a resident registration certificate which Company collect in a lawful and proper way;
  15. ⑮Information publicly available from official gazettes, telephone directories and residence maps; and
  16. ⑯Any other information Company uses for the provision of special offers and services to Guests or for marketing activities.
  1. 3.2It may be mandatory for Guests to provide Company with Guests’ personal information, to enable Company to manage Company’s business and operations, to provide its services to Guests or to comply with its legal and regulatory obligations. If Guests fail to provide their personal information when requested, Company may not be able to provide its services to Guests.
  2. 3.3Company makes every effort to maintain the accuracy and completeness of personal information of Guests which Company stores and to ensure all of personal information of Guests is up to date. However, Guests can assist Company with this considerably by promptly contacting Company if there are any changes to Guests’ personal information or if any Guest become aware that Company has inaccurate personal information relating to such Guest. Company will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal information that Guests provide to Company.

4. HOW COMPANY COLLECT PERSONAL INFORMATION

Company collects personal information of Guests when they make a reservation with Company on its websites or by phone or when Guests sign up for a newsletter or a loyalty programme, participate in a survey or promotional offer or order Company’s goods and accessories. Company also collects personal information of Guests when they visit Company’s hotels, restaurants and other facilities.

When Guests make a reservation with Company through travel agencies and third-party travel websites, Company collects personal information of Guests from the travel agencies and the operators of such websites.

Company may also collect personal information of Guests from other sources such as Joint Users (as defined in Section 5 of the Rules on Handling of Personal Information), its business partners, magazine publishers, PR firms and the records of governmental agencies.

5. HOW COMPANY USE PERSONAL INFORMATION

Company may handle personal information of Guests for the following purposes:

  1. ①to provide Guests with requested services, etc.;
  2. ②to respond or take other actions to messages or posts of Guests;
  3. ③to provide Guests with information about Company’s goods and services(including direct marketing);
  4. ④to manage Guests in accordance with contracts between Company and Guests, and provide Guests with goods and services;
  5. ⑤to offer and manage Guests’ participation in loyalty programmes;
  6. ⑥to manage, develop and improve Company’s goods, services, hotels, restaurants, other facilities, information technology systems and websites;
  7. ⑦to provide Guests with promotional and marketing information and materials about goods and services of the Joint Users;
  8. ⑧for monitoring and assessing compliance with law and Company’s policies and standards;
  9. ⑨to comply with legal and regulatory obligations and requests, including reporting to and/or being audited by regulatory bodies;
  10. ⑩for fraud and crime prevention and detection purposes;
  11. ⑪for administrative purposes in relation to the security of and access to Company’s websites and applications;
  12. ⑫to comply with court orders and exercise and/or defend legal rights;
  13. ⑬for any other legitimate business purpose; and
  14. ⑭as otherwise permitted or required by any applicable law or regulation.

6. WHERE COMPANY HANDLE PERSONAL INFORMATION

Company is based in Japan and stores and handles personal information of Guests mainly in Japan. The Joint Users include the entities located outside Japan, such as the U.S., and Company will take appropriate measures to ensure that such Joint Users will handle personal information of Guests in accordance with the Rules on Handling of Personal Information, these Supplemental Rules and applicable privacy law.

Where Company (or IT service providers maintaining the servers containing personal information of Guests) transfers personal information of Guests outside Japan, Company will take appropriate measures to ensure that such personal information will be handled in accordance with the Rules on Handling of Personal Information and these Supplemental Rules.

7. WHEN COMPANY MAY DISCLOSE PERSONAL INFORMATION

  1. 7.1Company will only disclose personal information of Guests to the following recipients:
  1. ①to the Joint Users for the purposes set out in these Supplemental Rules;
  2. ②to companies approved or designated by Guests;
  3. ③to third parties who handle personal information of Guests on behalf of Company (such as cloud providers);
  4. ④to third parties who handle personal information of Guests on their own behalf but through providing Guests with a service on behalf of Company;
  5. ⑤to companies which manage or operate (or cooperate with Company to manage or operate) facilities, equipment or systems, and tenants and lessees of Company’s facilities;
  6. ⑥to business partners of Company’s businesses such as travel agencies, tourism business operators, event promotors, travel companies, transportation companies;
  7. ⑦to service providers or governmental bodies for fraud and crime prevention;
  8. ⑧to any third party to whom Company assigns or novates any of its rights or obligations;
  9. ⑨to any prospective buyer in the event Company sells any part of its business or assets;
  10. ⑩to any government, regulatory agency, enforcement or exchange body or court where Company is required to do so by applicable law or regulation or at their request;
  11. ⑪to business partners and intermediaries of the Joint Users; and
  12. ⑫to other third parties necessary for legitimate purposes relating to Company’s business.
  1. 7.2Company jointly use personal information set out in Paragraph 3 for the purposes set out in Paragraph 5 under joint use agreements between Company and the Joint Users. For the purpose of the joint use, Company will be the person who is responsible for the management of personal information.

8. HOW COMPANY PROTECT PERSONAL INFORMATION

Company is committed to safeguarding and protecting personal information of Guests and will implement and maintain appropriate technical and organisational measures to ensure a level of security appropriate to protect such personal information from accidental or unauthorized destruction, loss, alteration, disclosure or access.

9. REQUESTS IN RELATION TO PERSONAL INFORMATION COMPANY MAINTAIN

Company recognizes that privacy is important to Guests and commit to resolving any concerns or complaints Guests may have about Company’s use of personal information of Guests. If Guests have any questions, would like to request to access, rectify, delete, or restrict processing of their personal information Company holds or have any other requests, please contact Company using the details set out below.

For other information about request to access and other requests, please also see Sections 6 to 8 of “Rules on Handling of Personal Information.”

10. HOW LONG COMPANY WILL HOLD PERSONAL INFORMATION FOR

Company will only retain personal information of Guests as long as necessary to fulfill the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.

11. DIRECT MARKETING

If any Guest tell Company that such Guest does not wish Company to provide him/her with information about Company’s services and other marketing materials, Company will not contact such Guest further for the purpose of direct marketing. Any Guest can contact Company using the contact details set out below.

12. HOW COMPANY UPDATE OR CHANGE THESE SUPPLEMENTAL RULES

Company may change or update parts of these Supplemental Rules in order to maintain Company’s compliance with applicable law and regulation or following an update to its internal policies. Guests will not necessarily be directly notified of such a change or update. Therefore, please ensure that Guests regularly check the latest Supplemental Rules on Company’s website or other materials so Guests are fully aware of any changes or updates.

13. HOW GUESTS CAN CONTACT COMPANY

If Guests have any queries or requests about the contents of these Supplemental Rules or their personal information, please contact Company using the details set out below:

Resorttrust, Inc. Information Centre (RIC) / phone numbers from Japan: TEL:0120-500-705 phone numbers from outside Japan : TEL:052-933-6000

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