GDPR Privacy Policy

The supplementary provision “GDPR Privacy Policy” (hereinafter collectively called “this supplementary provision”) mentions how to manage the personal information and rights of the guests residing within the EEA area (the member countries of EU, Iceland, Norway, and Liechtenstein)based on the EU General Data Protection Regulation (GDPR).
If an inconsistency occurs between this supplementary provision and our company “Basic Policy on the Protection of Personal Information”, the regulations of this supplementary provision will be prioritized.

1. Types of Personal Information

The personal information that are provided by the guests are as follows.

Basic information of the guest etc.
Address, name, classification of sex, age, date of birth, nationality, telephone number, mobile phone number, E-mail address, facsimile number, etc.
Added value information of the guest
Occupation, work information (name of company, address, telephone number, affiliated post, official position)
Wedding anniversary, family information (names, relationships, birthdays), etc.
Payment information
Credit card number, bank account number, billing address
Service usage information
Facilities usage status, commodity purchase, etc.
Notice contents
E-mail, website form input, facsimile, telephone memo, contents of questionnaire answers, etc.
Information collected through the security system
Security camera, card key, etc.
Automatically collected information through our company’s website
Cookies, IP address, types of browser, access date and time, etc.
Hotel Registry
Address, name, occupation, nationality, passport number, age, previous place of stay, destination, arrival date and time, departure date and time, guest room name, etc.

2. Providing personal information to a third party

Our company may provide the personal information that we received from our guest to a third party in the situations as follows. Furthermore, in case of entrusting a part or all of the guest’s personal information to a third party, for achievement the guest’s purpose of use, we will conclude a contract with the third party to prohibit the use other than for the purpose of use and secure the personal information with high confidentiality.

in case the guest’s consent is obtained
in case the information is offered under the law and ordinances

3. Transferring the personal information to a third party

In order for the guests to use our company, the personal information of the guests residing within the area of EEA will be transferred to Japan from areas within EEA.
Japan’s level to protect personal information is guaranteed by the European Commission. Our company will deal with the guest’s personal information with great caution and with an adequate safety management.

4. Storage stability of personal information

Our hotel will store the personal information for the necessary time to achieve the purpose of use (the storage stability of the basic information of the guests according to the Japanese law is three years).
The personal information that have elapsed the period of storage will be deleted or become anonymous with great caution within a reasonable period.

5. Purpose of use of the personal information

Our company will use the personal information for the purposes below.

To offer services to the guests (accommodations, food and drink, banquet, selling goods, other incidental goods supply and sales, service offers, use of facilities, event implementation, etc.)
For contact regarding negotiations with our company’s business partners and other companies, product shipping payment and liquidation, and related matters
To manage the member information of our company’s membership organization, and to offer services to the members
To manage inquiries, requests, etc. to our company
For the notification and delivery of our company’s, business partners’, and tenants’ notice, advertisement, publicity, and questionnaires for business use
For the improvement and development of service, commodities, facilities, etc. of our company, partners, and tenants
To analyze and grasp the utilization of the service etc. as an aim for marketing
To insure security and an appropriate information service of cookie, IP address, types of browser, the day and time, etc. of the access to our company’s website
For maintenance management of the website and the statistical analysis of the situation of utilization
Correspondence fixed by law and ordinances (hotel registry)
Other incidental matters related to the use of purpose mentioned above

6. Acquisition of the personal information

Our company will acquire personal information in the negotiation of our company’s facilities and merchandise (accommodations, banquet, food and drink, goods sales, and other incidental goods supply and sales offer service, hold an event etc.), and in the negotiation with our business partners and other negotiations through the following ways

Receive directly from the guest
Telephone, E-mail, document (including writing by electromagnetic means), business cards, viva voce, internet, etc.
From those authorized legitimately by the guest
User applicant, travel mediator, introducer, business partner, reception
business operators of package merchandise, etc.
Gaining information from what is publicized
Internet, newspaper, telephone directory, books, and other publications, etc.

7. Personal information of children

Upon receiving the personal information from children under sixteen years of age, the child’s parent (or person in parental authority) must consent to this.

8. About the legal grounds to use of the personal information and the legitimate profit required by our company or by the third party

Generally, our company’s use of personal information is based on legal grounds with the consent of the guest. In the case of not gaining the guest’s consent, the use of personal information must be based upon :the necessity to fulfil the contract, the necessity to fulfil the person’s requirement to execute the procedures of the contract before concluding, the necessity of our hotel or the third party to gain proper profit, or the necessity for our company to obey legal obligations based on legal grounds. The proper profit required by our company or by the third party corresponds to the increase of operating profit from marketing and improvement of service etc.,
together with the improvement of the accessibility of our company’s website and the improvement of the security.

9. The rights of the guests regarding personal information

The guests have the legal rights as follows, against our company, covering their personal information.
One may exercise their rights by getting in contact with our place of contact about their personal information. Upon receiving the proposition to exercise the rights,
our company will sincerely support the guest according to the laws after the guest’s identity is verified.

Rights to access to the personal information
After confirming if the personal information is used, there is a right to access to the personal information and to its concomitant.
Rights to correct personal information
There are rights to correct the guest’s inaccurate personal information to an accurate information.
Rights to delete the personal information
There are rights to delete personal information in certain cases.
Rights to retract an agreement
Guests have the right to retract the agreement concerning their personal information at all times. This retraction will not influence the legitimacy of the agreement of using the personal information before the retraction.
The guest can retract the agreement through our company’s website or through our company’s personal information section noted below.
Rights to raise a protest to the use of the personal information
The guest has the right to raise a protest to our company or to the third party’s demand of the use of the personal information for their legitimate profit.
Rights to restrict the management of the personal information
In certain cases, there are rights to restrict the management of the personal information.
Rights to obtain information service
There are rights to obtain certain information when we receive the personal information from the guests.
Rights to data portability
There are rights to receive personal information that are data structured, typically used, or readable by machine. Moreover, there are right to transfer that personal information to other business persons.
Rights to make objections to direct marketing
Guests have the right to make objections to our company’s direct marketing.
Rights not to obey to automatized decision including profiling
Our company does not make automatized decision including profiling of personal information.
Right to file of an objection to the supervising body
Guests have the right to file of an objection to the supervising body, in accordance with laws, regarding our how to manage the personal information, etc..

10. Contact details for inquiries regarding personal information

Personal information consultation desk
10-1, 6 Chome, Minatojima Nakamachi
Chuo-ku, Kobe, 650-0046 Japan
Tel: +81 78 302 1111 (Representative)
Monday through Friday excluding holiday, from 9:30 to 17:30 (JST)

April 1st, 2019
Tsuyoshi Ito, General Manager