Policy for protecting personal information

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Tokyu Hotels Co., Ltd., and each of the Tokyu Hotels (hereinafter referred to as "Tokyu Hotels") fully recognize the importance of the personal information of our guests and are committed to handling such information carefully. Tokyu Hotels will strive to promote the following efforts in order for us to provide better products and services and assume the responsibility to protect the personal information of our guests.

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1.Compliance with laws and regulations
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Tokyu Hotels will comply with the Personal Information Protection Law and any other related laws and regulations.
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2.In-house system
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With respect to the handling of personal information and the required system, Tokyu Hotels will develop in-house regulations and other rules necessary for each service, improve the organization by appointing responsible managers, and establish a system to protect personal information.
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3.Collection of personal information
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In the event Tokyu Hotels collects any personal information from our guests, Tokyu Hotels will clearly specify the purpose of use, obtain consent from guests, and then collect personal information to the extent necessary for accomplishing the purpose.
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4.Use of personal information
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When using any personal information of our guests, Tokyu Hotels will use such information only within the scope of the foregoing purpose of use and will not use it beyond the scope of the purpose of use.
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5.Ensuring of accuracy
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Tokyu Hotels will take appropriate measures to ensure the accuracy of personal information of our guests and keep it up to date.
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6.Safety management measures
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Tokyu Hotels will strictly manage the personal information of our guests and implement any preventive and safety measure against unauthorized access, loss, destruction, alteration, leakage, or otherwise.
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7.In-house training
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Tokyu Hotels will provide adequate education and training to our employees with respect to the protection of personal information and keep every employee of Tokyu Hotels informed about the contents.
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8.Supervising parties to whom personal information is entrusted
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In using any personal information of our guests, Tokyu Hotels may entrust such personal information to any third party within the scope of reasonable use. Tokyu Hotels will obligate and supervise the parties to whom any personal information is entrusted to strictly manage such personal information.
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9.Restriction of provision to any third party
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Tokyu Hotels will not provide or disclose any personal information of our guests to any third party without the consent of the guests except as required by law.
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10.Disclosure or correction of personal information
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With regard to the personal information of any guest that Tokyu Hotels obtains, if such guest wishes to confirm or correct any personal information, Tokyu Hotels will promptly respond to the request to the extent reasonable and necessary.
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11.Continuous review
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Tokyu Hotels will strive to continuously review and improve the regulations for the handling of personal information and organizational structure to implement the regulations to ensure effective and proper operation in a sustained manner.
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Retained personal data held by the Company and purpose of use thereof

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Purpose of use of retained personal data held by the Company

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1. |
Sale of goods, provision of general and subscription services, and other responses associated with the preceding.
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2. |
Delivery and provision of information regarding merchandise, services, preferential treatment, events, and other services of each of the Tokyu Hotels and Tokyu Group companies.
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Handling of inquiries and requests for documents.
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Improvement of merchandise and services to reflect the comments and requests of our guests
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Creation of basic data required for the performance of analyses necessary for management, including customer trend analysis and market research, as well as the creation of statistical data, but which cannot be used to identify a specific individual.
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Performance of obligations and exercise of rights of Tokyu Hotels and other activities in relation to the operation of the hotel.
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Personal data held by Tokyu Hotels
- Complete data relating to prearranged accommodations and past results
- ID exclusive for online reservation
- Complete data relating to banquet reservations and past results
- Restaurant and bar reservations book
- Complete data relating to past results of use of restaurant and bar
- Complete data relating to Comfort Members
- Complete data relating to the Corperate Contract
- Complete data relating to the restaurant and bar members
- Complete data relating to general customers
- List of e-mail magazine subscribers
- List of participants in questionnaires concerning the organization and running of hotel events
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Concerning the access log (history) of our guests

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Tokyu Hotels will record information of those who access the websites via an access log (history) for the purpose of improving services and for the convenience of our guests. The information recorded will include the time and date of access, pages accessed, domain name, IP address, and type of browser (Internet browser software), but will not include any information that enables the identification of any individual. Tokyu Hotels will use such information only for the purpose of statistical analysis of the use of our websites and not for any purpose other than the foregoing.

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In recording the foregoing access log, a cookie and a Web beacon provided by the service provider with whom Tokyu Hotels entered into a contract will be used. The cookie is a piece of information sent to the user's browser from the server that manages the websites when browsing the websites. By using the foregoing cookie, the server will record which page of the website is visited by a certain computer but is unable to identify any individual visitor. Furthermore, the Web beacon will function together with the cookie and is a technology to determine how many times a certain page has been accessed.

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Any of our guests may refuse to accept cookies by changing the browser settings. Our guests may also refuse the Web beacon by refusing to accept the cookie. 
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Disclosure request

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1.Identification of the retained personal data covered by the disclosure request

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When requesting disclosure, our guests are requested to identify the retained personal data to be disclosed. However, please note that any personal information that falls under any one of the following will not be included in the information subject to disclosure.

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(1)Any information that does not fall under the retained personal data
- Any information related for which the Company has been entrusted for services and for which the Company has no authority to disclose;
- Any information that is scheduled to be erased within six (6) months.
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(2)Any information that is not subject to disclosure pursuant to the provisions of article 25 of the Personal Information Protection Law
- Any information the disclosure of which may impair the rights and interests of the person in question or any third party;
- Any information the disclosure of which may seriously affect the proper performance of the Company's business;
- Any information the disclosure of which may result in the breach of any other laws.
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(3)Any information the disclosure of which is prohibited by law.
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2.Scope of disclosure

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The scope of disclosure will be limited to the address and name of the person in question and to our purpose of use thereof as well as those included in the retained personal data collected and held by the Company.

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3.Non-disclosure of retained personal data

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Any retained personal data will not be disclosed in the event of the following. In the event such non-disclosure has been determined by us, we will notify the person who requested the disclosure with the reason for the non-disclosure.
Prescribed handling charge will be required even in the case of non-disclosure.

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- In the event the address listed in the application does not correspond to the identification documents or the documents registered with us or in the event we are unable to confirm that the relevant request is made by the appropriate person.
- In the event we are unable to acknowledge the right of representation with respect to an application submitted by an agent.
- In the event the application is incomplete.
- In the event any personal information the disclosure of which is requested does not fall under the "retained personal data".
- In the event the disclosure of any of the retained personal data threatens to impair the life, health, property, or any other rights and interests of the person in question or any third party.
- In the event such disclosure may seriously affect the appropriate implementation of our business.
- In the event such disclosure results in the violation of other laws and regulations.

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4.Purpose of use of personal information obtained in connection with the request for disclosure

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Such personal information as described in the application or any identification document submitted in connection with the disclosure request will be used only to the extent necessary for the response to the disclosure request, including disclosure request-related communication with the person in question or confirmation of any doubtful points arising between the person in question and the Company, if any. The submitted identification documents will be disposed of by the Company in an appropriate manner immediately upon completion of our response to the disclosure request.

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