Privacy Policy

Tokyu Hotels Privacy Policy

Tokyu Hotels, referred to as “the entity" specified in 8. Joint Use, and hereinafter referred to as “the Company," recognizing our important social responsibility to protect and properly use personal information, as specified in 2. Contents of Personal Information, and hereinafter referred to as “personal information," entrusted to us by our guests and business partners, hereinafter referred to as “guests et al.," will enact and execute in good faith our policy for the protection of personal information, hereinafter referred to as “the Policy" or “this Policy."

1

Objectives of Privacy Policy

The objectives of the Policy are to ensure definitive protection of personal information, provide continuous peace of mind to guests and business partners, and inform guests and business partners about various rights regarding personal information and what personal information is obtained by the Company.

2

Contents of Personal Information

(1)

Information Entrusted by Guests et al.
Information obtained by the Company from guests et al. includes the following indispensible items in transaction: personal name; address; telephone number; email address; date of birth; gender; nationality; passport and visa information; marketing information; and information entered by guests et al. in the forms specified by the Company; information entered by our staff at the direction of guests et al.; information about previous stays, services used, and products purchased; information about the tastes of guests et al. that we may become aware of during their stay; information provided by guests et al. during use of Company services; information provided to travel agencies for hotel reservation; and information related to credit cards.

(2)

Information Collected by the Company When Company Website Is Accessed
The Company may collect information of devices in use, access logs, cookies and anonymous IDs, locations, IP addresses, and individual identification data when our website is accessed.

3

Objectives of Personal Information Usage

Regarding personal information handling, we collect personal information to receive the following items for the legitimate benefit of the Company, and for reasons of the necessity to have information of guests et al. to fulfill legal obligations borne by the Company, as well as our contractual obligations to parties involved in travel arrangements of guests et al. (travel agencies or persons employed by guests et al.) or vendors (third parties such as credit card companies, airline companies, etc.):

(1)

To contact guests et al. for confirming reservations and other matters;

(2)

To provide services, products, and information to guests et al.;

(3)

To perform marketing activities regarding the following:

(a)

Provision of advertisements and information on products, services, campaigns, etc., by means of invitations, e-mails, etc. (*1 *2);

(b)

Distribution of behavioral targeting advertisements using advertisement distribution companies such as Google, Yahoo, etc. (*1 *2);

(c)

Analysis of attribute information, behavior history, etc., acquired by the Company to understand the hobbies and preferences of guests et al. (*3 *4); and

(d)

Other matters equivalent to (a), (b), and (c).

Notes

*1

We analyze information such as website browsing history and purchase history obtained from guests et al., to provide services, advertisement distribution, etc.

*2

We may use such information as hobbies, tastes, browsing history, etc., of guests et al. acquired from third parties in association with personal information of guests et al. that we may already have on file. In this case, we will obtain in advance the consent of guests et al. and use their personal information within the scope of the purpose of uses listed above.

*3

Our website uses cookies so that our guests et al. can use our website more conveniently. For more information on the handling of cookies, please see “7. Cookies and Other Similar Technologies.”

*4

Our website uses a log analysis tool to understand the visit status of our website by guests et al.
Based on cookies we issue, the log analysis tool works to collect, record, and analyze the access history of guests et al.
The Company will receive the analysis results and grasp the visit status of our website by guests et al. The information collected, recorded, and analyzed by the log analysis tool does not include any information that identifies a specific individual. In addition, that information is managed in accordance with the privacy policy of the company that provides the log analysis tool.

(4)

To analyze for improvement of services and products;

(5)

To generate and send out questionnaires to guests et al. to further improve service;

(6)

To request compliance with the terms and conditions of the use of services provided through our website;

(7)

To protect the services provided through our website and guests et al.;

(8)

To verify the identity of guests et al. when they make a request about their personal information, in accordance with the Policy;

(9)

To fulfill the legal obligations of the Company (referring to the local laws, etc., including Japanese law);

(10)

To manage sweepstakes, lotteries, and other promotions;

(11)

To fulfill contractual obligations to parties involved in the travel arrangements of guests et al. (travel agencies, group travel organizers, employers of guests et al.) or external companies (credit card companies, airlines, etc.);

(12)

For purposes of usage separately specified or announced to guests et al.; and

(13)

To maintain a record archive of information usage.

4

Collection Method of Personal Information

We collect personal information as stipulated in 2. Contents of Personal Information by the following methods:

(1)

Method to Collect Directly from Guests et al.
With respect to the information contained in Paragraph 1 of 2. Contents of Personal Information, we may collect the personal information of guests et al. when they make reservations or use our accommodation facilities, create an account on our website, reply to questionnaires, participate in lotteries or sweepstakes, contact customer service, or apply for or use any services provided by the Company.

(2)

Collection from Devices of Guests et al. and Our Network
With respect to the information contained in Paragraph 2 of 2. Contents of Personal Information, the personal information of guests et al. may be automatically collected from their entire devices through the use of cookies and related technologies when those guests et al. use our website or other content of our network.

(3)

Collection from Other Companies
In order for our guests et al. to use our services comfortably, we may collect personal information of guests et al. by using services on the Internet operated by other companies selected by us. In addition, we may collect personal information of guests et al. from those listed below:

  • Travel agencies used by guests et al.;

  • Persons who provide transportation to guests et al., such as airlines; and

  • Third-party card companies used by guests et al.

(4)

Collection from Social Media
If guests et al. voluntarily participate in activities or services on social media operated by the Company, then we may collect contact and identity information, accommodation and purchase information, Internet and network behavior information, and such other information as content posted on social media or included in the profiles of guests et al.

5

Information Handling

We will properly and carefully manage the personal information entrusted to us by our guests et al. and will take the necessary and rational safety management measures to prevent the risk of leak, loss, misuse, tampering, and unauthorized access.
In addition, when collecting personal information using communication means, we will strive to ensure security by security technology such as SSL- (Secure Socket Layer) encrypted communication in preparation for interception by a third party during communication.
Personal information entrusted to us by our guests et al. will always be managed in accordance with applicable laws.

6

Disclosure and Provision to Third Parties

In order to improve the quality of our service and to improve the convenience of guests et al., we may outsource a part of our personal information handling to an outside contractor. In that case, we will instruct and supervise the outsourced company to perform appropriate management.
e will not disclose or provide personal information of guests et al. to third parties except in the following cases (excluding joint use as described in 8. Joint Use):

(1)

When disclosure or provision has the consent of guests et al.;

(2)

When disclosure or provision is requested based on laws and regulations;

(3)

When it is necessary to protect the life, body, or property of a person, and it is difficult to obtain the consent of guests et al.;

(4)

When it is particularly necessary to improve public health or promote the sound development of children, and it is difficult to obtain the consent of guests et al.;

(5)

When it is necessary for a national institution or a local public body or a person entrusted with it to cooperate in carrying out the affairs stipulated by laws and regulations, and obtaining the consent of guests et al. may obstruct the execution of the subject affairs;

(6)

When disclosure or provision is made to outsourced companies to the extent necessary in providing services to guests et al.; and

(7)

When the personal information of guests et al. or the management right of the personal information is transferred as a part of the transferred business assets in accordance with the business transfer.

7

Cookies and Other Similar Technologies

The Company and other stakeholders may use cookie technology and other similar technologies on our website to evaluate and improve the functionality of our website. These cookie and other similar technologies also allow the Company, ad networks, social media companies, and other service providers to display advertising and customized content.
Regarding the use of cookies for advertising purposes, guests et al. may refer to the browser’s instructions for various control methods related to cookies, such as blocking specific cookies. The settings that guests et al. choose regarding cookies are specific to each website, device, and browser and will be deleted when the browser’s cache is cleared. If guests et al. refuse to accept cookies by modifying browser settings, then some functions of our website may not be available.
When guests et al. access our website and make reservations for airline tickets, car rentals, etc., for example, they may be moved from our website to one managed by a third party, hereinafter referred to as “external website.” In that case, except for some websites, external websites are outside the scope of our management responsibility. Therefore, when guests et al. send personal information directly to an external website that is not under our management responsibility, we are not responsible for the method of collecting personal information or the privacy policy of that website. Before accessing or providing personal information to such external websites, please check the privacy and security policies of those sites.

8

Joint Use

We will share the personal information of our guests et al. as follows:

(1)

Items of personal information used jointly: Items in “2. Contents of Personal Information”;

(2)

Joint Users: Corporations that manage facilities listed on the Tokyu Group website (https://tokyugroup.jp/about/grouplist/) and Tokyu Hotels Co., Ltd., and its affiliates;

(3)

Objectives of use by those who use it jointly: Objectives of use in “3. Objectives of Personal Information Usage”; and

(4)

Name of the entity responsible for managing user information: Tokyu Hotels Co., Ltd.

9

Compliance with Laws and Regulations

The Company will comply with personal information-related laws and regulations and related guidelines in order to ensure the protection of personal information.

10

International Transfer of Personal Information

Since the Company is based in Japan, if guests et al. access our website from a country other than Japan, then the personal information of guests et al. may be transferred to Japan or other countries where our server or the database is located. We will make efforts to protect the personal information of guests et al. in an appropriate manner, but the laws and forms of protection of personal information in Japan and other countries may not be as thorough as those in the countries where guests et al. reside or the countries from which guests et al. access our website.

11

Choice of Information Provision

Guests et al. can always select the type of personal information to be provided to the Company, the method of receiving or rejecting contact from us, etc. Should guests et al. choose not to furnish some personal information, then some services provided by the Company may not be available.
The Company may contact guests et al. based on the furnished personal information so as to inform them of services and events that may be of interest. Guests et al. can refuse to receive such information or change the method of contact from the Company at any time by contacting the inquiry desk described in 16. Inquiry Desk, hereinafter referred to as “inquiry desk.”

12

Retention Period

In order to achieve the objectives described in this Policy, the Company will retain the personal information of guests et al. for the period deemed necessary by the following standards:

(1)

When there is a continuous business relationship with the guests et al. and the service is provided to them (for example, the period during which guests et al. have accounts with the Company or continue to use the service);

(2)

When there is a legal obligation that the Company must comply with; and

(3)

When it is deemed necessary to hold personal information of guests et al. in consideration of the legal position of the Company (vis-à-vis some statute of limitations, lawsuit, investigation by regulatory authorities, etc.).

13

Personal Information of Minors

The Company does not sell products or services to minors, and does not knowingly request or collect personal information from guests under the age of 18.

14

Respect for the Rights of Guests et al.

We shall respect the rights of our guests et al., and if guests et al. make requests for disclosure, correction, restriction, or deletion of personal information, or for the exercise of data portability rights or of formal objection based on laws and regulations, then we shall verify the identity of the guests et al. and respond within a reasonable and necessary period. In addition, guests et al. may retract their previous consent by contacting the inquiry desk.

15

For Residents of California, USA

The California Consumer Privacy Act of the United States allows guests et al. residing in the state to make the following claims in accordance with applicable law. The Company shall not treat guests et al. unfairly or discriminatorily, because they have made the following claims.

(1)

Access Right
Guests et al. can request from the inquiry desk the disclosure of personal information for instances occurring in the past 12 months as described below:

  • Types of personal information and institutions that collect personal information;

  • Specific personal information collected;

  • Business or commercial objectives related to the collection or sale of personal information;

  • Whether personal information is sold, the type of personal information when it is sold, and information on third parties to whom it is sold; and

  • Types of personal information shared or disclosed and information of third parties who provided it.

(2)

Deletion Right
Guests et al. can request deletion of personal information that the Company stores by contacting us (with some exceptions).

(3)

Sale of Personal Information of Guests et al.
The Company does not sell personal information of guests et al. to other businesses or third parties. In this Policy, “sale” refers to selling, lending, publishing, disclosing, disseminating, providing, transferring or communicating orally, in writing, or electronically or otherwise, personal information of guests et al. from one business to other businesses or third parties for money or other valuable consideration.
We will verify the identity of the guests et al. by appropriate procedures before responding to a request from such guests et al.
Upon request of the guests et al., the Company will verify the name, account number, email address related to the account with the Company, and phone number, in case the guests et al. have an account with the Company. In case guests et al. do not have an account with the Company, we will verify the name, reservation ID number of the Company’s accommodation facility, email address linked to the reservation, and phone number. If guests et al. are residents of California, then they can appoint an agent to make the request set forth in the preceding paragraph, if necessary. When guests et al. make a request via an appointed agent, be sure that the agent not only has been authorized to act as an agent of a guest et al. but also has the information necessary to carry out the identity verification procedure.

16

Inquiry Desk

For comments, questions, or requests regarding this Policy, and for inquiries or complaints regarding personal information handling, the Company provides the following inquiry desk:
Tokyu Hotels Co., Ltd.
Personal Information Inquiry Desk
TEL. 03-3477-6567

17

Revisions of Privacy Policy

We may review the Policy from time to time and make changes as necessary. If we revise the Policy, we will take appropriate measures including publishing the revised Policy on the Tokyu Hotels website.

18

Procedure for Requesting Disclosure, etc.

(1)

Specification of the Stored Personal Data Subject to Disclosure Requests
When requesting disclosure, please specify the stored personal data subject to disclosure. Moreover, please note that the personal information below is not subject to disclosure.

(a)

Data not defined as stored personal data
We are only outsourced, and we do not have the authority to disclose the data.

(b)

Data defined as not subject to disclosure by the Personal Information Protection Law

  • Data whose disclosure may violate personal or third-party rights or interests

  • Data whose disclosure may lead to severely damaging effects toward the correct conduct of the Company’s business

  • Data whose disclosure may violate other laws regarding disclosure

(c)

Data governed by other laws

(2)

Extent of Subjectivity to Disclosure
The extent of data subject to disclosure will include personal names, addresses, objectives of the use of the Company, as well as stored personal data, and data previously obtained by the Company and stored, and no other data.

(3)

Point of Contact for Disclosure Requests
Please send requests for disclosure by registered mail to the following address, using the designated forms for disclosure and also including the necessary documents for the identification of the person in question and disclosure handling fees.
Moreover, please be aware that direct requests in person at hotel front desks and other such points of contact cannot be accepted.
1-10-7 Dogenzaka, Shibuya-ku, Tokyo 150-0043
Tokyu Hotels Co., Ltd.
Personal Information Inquiry Desk
TEL. 03-3477-6567

(4)

Documents (Forms) to Submit When Making Disclosure Requests
For requests made for disclosure of one's own personal information, print out (A) Request Form (Request for One's Own Personal Information), enter the information required, and sign or affix personal seal, put together with (B) documents required for personal identification in a sealed envelope, and mail to Personal Information Inquiry Desk of the Company, specified in (3) above.
In the case of requests through an agent, please use (A) Request Form (Request by Agent).
Note: Please be aware that all request forms and documents must be those designated by the Company. Any other forms or documents will not be accepted.
Please also note that the documents (including identity verification documents) submitted when requesting disclosure will not be returned. After we have responded to your request for disclosure, we will dispose of them in an appropriate manner without delay.

(A) Forms for Disclosure Requests Designated by the Company

(5)

In the Case of a Request Through an Agent
In the case that the disclosure request is being made by an agent for the person in question, include in a sealed envelope for mailing the form from (A) Personal Information Disclosure Request (Request by Agent), and the personal identification document of (B).

  • Authorization of agent printed and signed (or with personal seal) regarding disclosure of personal data of the person subject to disclosure;

  • Certificate of personal seal registration for personal seal affixed to authorization of agent (certificate to be issued within 3 months of date of authorization of agent);

  • Copy of official bulletin notice or family court notice of determination (only in case of guardian);

Note:

Please use the form designated by the Company for authorizations of agent.

(6)

Procedure and Payments Regarding Disclosure Requests

(a)

Requests for disclosure and notification of objectives for use
Fee: 500 yen (tax included) for 1 case of stored personal data
Payment method: Please include payment of the fee amount by postal money order together with the application documents.

(b)

Requests for revisions, cessations of use, or deletion
There is no fee for requests for revisions, cessations of use, or deletion of stored data. Please specify the stored personal data in question when making requests.

(7)

Method of Response to Disclosure Requests
Responses in writing will be sent by simple registered mail to the address entered on the request form.

Note:

If disclosure by electromagnetic records such as email is requested, please indicate accordingly in the request form and specify the method. If the requested method requires a large amount of money or if disclosure by the requested method is difficult, we will disclose it in writing.
Moreover, the time between initiation of the disclosure procedure and response to request will be at least 2 weeks. In addition, please be aware that in cases that the point of contact is overwhelmed with requests, or the Company's business situation is difficult, it is possible that the delay in response may exceed 2 weeks.

(8)

Nondisclosure of Stored Personal Data
In the following cases, data will not be disclosed. Notification of a decision for nondisclosure will be made in these cases. A prescribed fee will be charged even in the case of nondisclosure.

  • In such cases as the address entered on the request form not being identical to the address entered on the documents that identify the person in question, and it is not possible to verify that the request is indeed from the person in question;

  • In cases that it is not possible to verify that a request by agent is being made by a person empowered to do so;

  • In cases of incorrect information entered on request documents;

  • In cases that the personal information requested for disclosure is not identical to the stored personal data;

  • In cases that may cause damage to life, body, or assets of the person in question or of a third party, or violate rights or damage the interests of same; and

  • In cases that would lead to the violation of other laws.

(9)

Objectives for Use of Personal Information Obtained Through Disclosure Requests
Request forms submitted with disclosure requests and personal information from identification documents for persons in question, as well as cases in which verifications regarding doubts that arise with the person in question, will be handled to the extent necessary to respond to the disclosure request.
With regard to the documents submitted for identification of the person in question, after responding to the disclosure request, these will be destroyed without delay using the appropriate methods.

Name, Address, Name of Representative of Business Operator Handling Personal Information:

Name:

Tokyu Hotels Co., Ltd.

Address:

5-6 Nanpeidaicho, Shibuya-ku, Tokyo

Name of Representative:

Jun Murai