1. We may process the following Personal Data:

   • • Contact details and personal identifiers: such as your name, email address, telephone number, address, date of birth, gender, social networking IDs, workplace information, job title, customer number;
     • Transaction and Payment data: information relating to your bank account, credit/debit card details, payment and receipt details, information on solvency;
     • Records of your interactions with us: information such as, contact history, content of inquiry, information on whether an e-mail was opened or not, other information provided during inquiries;
     • Service and booking data: information on services used, contract information, booking details, contact history;
     • Internet information: including your use of and movements through our Website, the date and time of your visit or use of our Website, IP address, URL of the webpages viewed, referrer, device type and ID, OS, and browser information, country of access, browser type and plug-ins, and other IT system identifying information;
     • Application information: information obtained from your CV, photograph, content of your application;
     • Your marketing preferences: so that we know whether and how we should contact you. You can stop receiving our marketing communications at any time, free of charge, through the methods displayed as part of any communication such as the unsubscribe link in our emails. Or further information on this please see the section below on Direct Marketing.

1. We may share your personal data with the following recipients:

   • • Accommodation booking and travel agencies: Your Personal Data may be shared with travel and accommodation booking platforms to facilitate bookings and related services.
     • Group companies: We may share your personal data with our affiliated companies within our corporate group for internal administrative purposes.
     • Financial institutions: We may need to share your payment details with banks and credit institutions for payment processing and financial services.
     • Sub-contractors: such as our marketing and service technology providers, and other sub-contractors.
     • Event and hospitality services: to deliver booked services, we may share your data with event organizers and service providers in hospitality sectors, such as travel and relaxation services.
     • Consultants and accountants: such as legal or tax consultants and accountants, to comply with legal obligations.
     • Government and law enforcement agencies: where we are required to do so by law or to assist with their investigations or initiatives.

1. If you are located in the EU or UK you have the following rights in relation to your Personal Data:

   • • Right of Access - you have the right to be informed about how we are using your Personal Data and the right to access that data that we hold about you.
     • Right to Erasure or "Right to be Forgotten" - you have the right to ask us to delete your Personal Data provided that there are no valid grounds for us to keep it, for example we may have to keep some or all of the Personal Data to comply with legal obligation or in respect of any legal claims.
     • Right to Data Portability - you have the right to receive the Personal Data you have provided to us in a digital format or in certain circumstances and where technically feasible the right to ask us to transmit the data to another organization.
     • Right of Rectification - you have the right to ask us to amend the Personal Data that we hold about you where believe it is inaccurate or incomplete.
     • Right to Object - in certain circumstances, you have the right to object to the processing of your Personal Data and to ask us to block, erase and restrict our use of your personal data.
     • Automated Decision Making - we may process your Personal Data by solely automated means (without human intervention), including for profiling. Where such processing may have a legal or similarly significant effect on you, you have the right not to remain subject to any decisions based on such automatic processing, except as otherwise provided by law. You have the right to understand when and how automated decisions are made about you, and the factors involved and you have the right to challenge these decisions, request human intervention, express your point of view, and seek a review of the decision.
     • Right to Withdraw Consent or Right of Opposition - if you have provided your consent to the collection, processing and transfer of your personal data, you have the right to fully or partly withdraw your consent. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there is another legal ground for the processing.
     • Right of Limitation - you have the right to request the limitation of the Processing of your Personal Data, in the form of: (i) suspension of Processing or (ii) limitation of the scope of Processing to certain categories of Personal Data or purposes of Processing.
     • Right to complain - you have the right to complain to the supervisory authority, in addition to us.

1. Right to Know - you have the right to request that we disclose what personal information we collect, use, disclose, sell or share. Specifically, you may request that we disclose to you the following:

   • • The categories of personal information we have collected about you.
     • The categories of sources from which the personal information is collected.
     • The business or commercial purpose for collecting, selling or sharing personal information.
     • The categories of third parties with whom we disclose personal information.
     • The specific pieces of personal information we have collected about you.

   You may also request that we inform you about:

   • • The categories of personal information that we have sold or shared about you and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each third party to whom the personal information was sold or shared.
     • The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

1. To exercise any of the rights described above, please send us a verified request using the methods listed below. Your request must:

   • • Include enough information for us to confirm your identity or the identity of your authorized representative.
     • Clearly explain your request so we can understand, evaluate, and respond to it.

1. Contact us using one of the following methods:

   • • Email: soumu@miyakohotels.ne.jp
     • Phone: 1-833-622-6220
     • Mail: 6-1-55 Uehommachi, Tennoji Ward, Osaka City, Japan

1. If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, or your choices and rights regarding such use please do not hesitate to contact us by:

   • • Email at: soumu@miyakohotels.ne.jp
     • Post to: 6-1-55 Uehommachi, Tennoji Ward, Osaka City, Japan

1. (1) What is Cookie

   “Cookie” refers to a small text file that is stored in a browser storage of your computer or mobile device when you visit a website. They are generally used for purposes including provision of website’s functions, analyzing access status and other related information, improving the user experience, and delivering advertisements.

2. (2) Beacon

   Beacon (Also known as Pixel) refers to a technology that transmits information from your device to a server. Beacons can be embedded in websites, online contents such as videos or images, emails, etc. It allows servers to process certain types of information from your device, such as the data and time of your access, the IP address of your device, and the fact that you have viewed certain content or opened/previewed an email that you received.
   
   * Beacon used on the websites, like other content requests contained on websites, cannot usually be disabled. Beacons in emails can generally be disabled by not downloading the images contained in the received message, but this method relies on the capacity of the email software and may not always be feasible. If you are unable to disable Beacon through this method, please reject those emails.

1. (1) Categorization Based on Purposes

   Cookies are used for various purposes. The following are the categorizations of Cookie based on the purposes for which they are used.
   
   * Please note that cookies may fall into more than one of the following classifications. For example, some cookies are used to record your choices to improve your experience, as well as used to deliver online advertisements.

1. (2) Categorization Based on the Issuer

   Cookies are categorized as 1st party cookie and 3rd party cookie based on the issuer of the cookie.

2. 1st Party Cookie : The cookie issued by the domain of the website that you are accessing.

3. 3rd Party Cookie : The cookie issued by the domain other than the domain of the website that you are accessing (such as an ad-serving company).

1. (3) Categorization Based on Retention Period

   Cookies are generally categorized into two categories depending on how they will be stored on your device. Please refer to section 3 for the specific retention period of each cookie we use (although, depending on the type of browser you use, they may be erased in a shorter period of time than described in section 3.).

1. (1) Strictly Necessary Cookie

1. (2) Functionality Cookies

1. (3) Performance Cookies

1. (4) Targeting Cookies or Advertising Cookies

1. • • Apple Safari
       • Mac
       • iPhone, iPad, iPod touch
     • Google Chrome
     • Microsoft Internet Explorer
     • Miscrosoft Edge
     • Mozilla Firefox

1. (1) The Company will not acquire personal information by deception or other wrongful means.

2. (2) The Company will obtain prior consent from customers when acquiring sensitive personal information.

1. (1) The Company will use customers’ personal information for the following purposes, except when a separate utilization purpose is specified or when required by law. The Company will not use personal information for any purpose other than those listed below without the customer’s consent. Furthermore, the Company will not use personal information in a manner that may promote or induce illegal or improper activities.

   1. (i) To provide the Company’s services to customers
   2. (ii) To carry out payment and billing operations associated with business activities and to fulfill the Company’s obligations
   3. (iii) To respond to customer inquiries and requests for materials, as well as to contact customers when necessary, such as for reservation confirmations
   4. (iv) To notify individuals who have subscribed to the Company’s email newsletter about services and events
   5. (v) To request customers to provide opinions or feedback regarding the Company’s services
   6. (vi) To analyze the usage of the Company’s services, facilities, products, and website in order to improve them

2. (2) The Company will not use personal information in a manner that may promote or induce illegal or improper activities.

1. (1) Outsourcing

   The Company may outsource all or part of its business related to the handling of personal information after conducting necessary and appropriate supervision to ensure that the contractor implements proper safety control measures.

2. (2) Succession

   Personal data may be provided in the event of a business succession due to a merger or other reasons.

3. (3) Shared Use

   The Miyako Hotels & Resorts member companies will share certain personal data. If a separate policy regarding the handling of personal information is established, that policy shall take precedence.

   • (i) Shared Use by Miyako Hotels & Resorts Member Companies

     a. Items of personal data for shared use

     • Name, email address, phone number, gender, date of birth, and address
     • Information on their reservations for our facilities and services
     • Information on their use of our facilities and services (including payment information)
     • Information on their participation in various events, notifications, and surveys

   • (The following items apply to each Miyako Plus member only)

     • Information on the attributes of their Miyako Plus membership (membership rank, favorite facilities, and other registered information)
     • Information on their Miyako Plus Points
     • Information on their usage history of the Miyako Plus app and “My Page” (their dedicated web page) (including coupon usage information)
     • Information on their Miyako Plus membership number (Miyako Plus membership number and Kintetsu-ID)

   • b. Scope of shared use entities

   • Miyako Hotels & Resorts member companies
     (Reference) https://www.miyakohotels.ne.jp/hotel/

   • c. Purpose of shared use

     • Provision of accommodations, banquet, and restaurant services
     • Provision of reservation services for accommodations
     • Provision of Internet reservation service
     • Operation of Miyako Plus Cards and monitoring the usage status of privileges
     • Sending direct mail and distribution by email of product and service information
     • Basis for selecting the information to be provided to customers
     • Market research and product development, including marketing analysis
     • Response to inquiries

   • (ii) Shared Use by Kintetsu Group Companies

     a. Items of personal data for shared use

     • Name (phonetic characters used for Japanese names), email address, phone number, gender, date of birth, and address
     • Information on their reservations for our facilities and services
     • Information on their use of our facilities and services (including payment information)
     • Information on their participation in various events, notifications, and surveys

   • (The following items apply to each Miyako Plus member only)

     • Information on the attributes of their Miyako Plus membership (membership rank, favorite facilities, and other registered information)
     • Information on their Miyako Plus Points
     • Information on their usage history of the Miyako Plus app and “My Page” (their dedicated web page) (including coupon usage information)
     • Information on their Miyako Plus membership number (Miyako Plus membership number and Kintetsu-ID)

   • b. Scope of shared use entities

   • Kintetsu Group Holdings Co., Ltd. and Kintetsu Group companies (including subsidiaries and affiliates)
     (Reference) https://www.kintetsu-g-hd.co.jp/group-info/list.html

   • The Miyako Los Angeles and Miyako Hybrid Hotel Torrance, California, which are among the entities involved in the shared use of the above personal data, are operated by Kintetsu Enterprises Company of America, located in the State of California, USA.
     The following is information regarding the State of California, USA, where the Company is located, and the Company itself:

     • Name of the foreign country where the data is provided
       United States of America (State of California)
     • Personal data protection system in the above country/state
       Please refer to the following links:
       https://www.ppc.go.jp/files/pdf/USA_report.pdf
       https://www.ppc.go.jp/files/pdf/california_report.pdf
     • Measures taken by the Company to protect personal data
       The Company implements all measures corresponding to the eight principles of the OECD Privacy Guidelines. For details on the Company’s privacy policy, please refer to the following link:
       https://www.miyakohybridhotel.com/privacy-policy/

   • c. Purpose of use by parties sharing the information

     • To research and improve Kintetsu Group services and to plan and develop new services
     • For surveys and analysis to provide services tailored to customer needs
     • This applies only to customers who use Miyako Plus with their Kintetsu-ID and is intended to deliver advertisements and information tailored to individual customer needs.

   Entity responsible for managing the personal data mentioned in (i) and (ii):
   6-1-55 Uehonmachi, Tennoji-ku, Osaka, Osaka Prefecture
   Kintetsu Miyako Hotels International, Inc.

Procedures for Responding to Requests for Disclosure, etc.

1. 1. Retained personal data subject to requests for Disclosure, etc.

   In requests for Disclosure, etc., please specify the relevant retained personal data as clearly as possible.

2. 2. Address for sending requests for Disclosure, etc.

   When requesting Disclosure, etc., please send the request form provided by the Company [see 3. (1) below] to the following address together with proof of identity and the full handling fee, where applicable. Requests for Disclosure, etc., will be accepted by postal mail only.
   General Affairs Department, Kintetsu Miyako Hotels International, Inc., 1-55 Uehommachi 6-chome, Tennoji-ku, Osaka 543-0001
   *Please mark the envelope in red with: “Personal Information Disclosure Request Form.”
   *To ensure delivery of the documents, it is recommended that trackable mail be used regardless of whether the request requires a handling fee.

3. 3. Procedures regarding requests for Disclosure, etc.

   (1) Documents regarding requests for Disclosure, etc.

   [1] If the individual concerned requests Disclosure, etc.
   

   Download and print the request form a. below, fill it out and sign it, and send it to the Company together with the identification documents b. (see 2. above for the address).

   a. Request form (click here to open.)

   b. Identification document
   (a) Copy of an official certificate, such as a driver’s license, health insurance card, pension booklet, certificate of residence, passport (page with photo and address), or residence card
   *It should be currently valid and include the address, name, and date of birth.
   (b) If the address stated on the above certificate differs from the address for the reply, a copy of any of the following in addition to the above:
   i. Receipt of utility bill
   ii. Receipt of payment of national or local tax
   iii. Receipt of social insurance premium.
   *Must be within 6 months of the issuance date and contain the current address and name.
   In the case of a request for Disclosure, etc., by mail, all replies will be sent to the address stated on the identification documents [or (b), if (b) was submitted].

   [2] If an agent requests Disclosure, etc.
   

   Download and print the request form a. below, fill it in and sign it, and send it to the Company together with the identification documents b. and proof of agent qualification c. (see 2. above for the address). Please make sure to state the address and name of the individual concerned, as well as the agent’s signature.

   a. Request form (click here to open.)

   b. Identification documents for both the individual concerned and the agent (both are required).
   (a) Copy of an official certificate, such as a driver’s license, health insurance card, pension booklet, certificate of residence, passport (page with photo and address), or residence card
   *Must be currently valid and contain the address, name, and date of birth.
   (b) If the address stated on the above certificate differs from the address for the reply, a copy of any of the following in addition to the above:
   i. Receipt of utility bill
   ii. Receipt of payment of national or local tax
   iii. Receipt of social insurance premium.
   *Must be within 6 months of the issuance date and contain the current address and name.
   In the case of a request for Disclosure, etc., by mail, all replies will be sent to the address stated on the identification documents [or (b), if (b) was submitted].
   
   c. Identification documents for agent qualification
   (a) If requested by a statutory agent
   Certificate of Items Stated in Resident Register and/or another certificate for the statutory agent’s qualification
   (b) If requested by any other agent
   A letter of proxy is prepared and signed by the individual concerned to designate the relevant agent (the letter of proxy must bear the registered seal of the individual concerned and be accompanied by a seal registration certificate of the individual concerned).
   If requested by an agent, the Company will send the reply to the agent’s address stated in the identification documents under (b) [or (b), if (b) was submitted] and deem the procedures of Disclosure, etc., to have been completed. The Company will not be liable in any manner for the delivery of the reply between the individual concerned and their agent.

   (2) Handling fee for request for Disclosure, etc.

   [1] For request for disclosure or notice of purpose of utilization
   

   a. Handling fee
   500 yen (including consumption tax, etc.) per request
   b. Payment method
   Send the request form along with 500 yen in cash by registered mail.

   [2] For requests for correction, addition, or deletion, use suspension or deletion, or suspension of third-party provision
   

   For requests for correction, addition, or deletion, use suspension or deletion, or suspension of third-party provision, with the retained personal data specified, no handling fee is required.

   (3) Notes regarding requests for Disclosure, etc.

   [1] When requesting Disclosure, etc., make sure to use the above request form prepared by the Company [see 3. (1)]. Requests in any other format cannot be accepted.
   
   [2] Any costs required in submitting a request for Disclosure, etc., such as costs for obtaining identification documents, will be borne by the individual concerned.
   
   [3] The official certificates and other identification documents submitted in requests for Disclosure, etc., will be returned after the completion of the procedure
   
   [4] In the case that any identification document to be submitted as part of a request for Disclosure, etc., contains a statement not necessary for the request for Disclosure, etc. such as the registered domicile or basic pension number, such parts may be blacked out or otherwise made unreadable.
   
   [5] Unless caused by a reason attributable to the Company, the Company will not be liable in any manner for accidents to a request for Disclosure, etc., such as accidents occurring during mail delivery.

4. 4. The Company’s response to request for Disclosure, etc.

   The Company will start processing the form, etc., regarding a request for Disclosure etc. once it has received all necessary documents without deficiencies. Please note that it may take several days in some cases as it takes time to identify the retained personal data or for other work.

5. 5. Cases where the request for Disclosure, etc., may not be accepted

   [1] The Company may not accept a request for Disclosure, etc., in the following cases:
   
   [2] When identification documents are not enclosed, or the identification of the individual concerned, or the agent cannot otherwise be confirmed
   
   [3] When the handling fee is not enclosed, or the amount is insufficient
   
   [4] If the request falls under any of the cases specified in the proviso to Paragraph 2, Article 32, the proviso to Paragraph 2, Article 33, Paragraph 1, Article 34, and the provisos to Paragraph 2, Paragraph 4, and Paragraph 6, Article 35 of the Act, or if there are deficiencies in the submitted documents, the Company will notify you at the address stated on the request form.
   
   If you fail to make the necessary correction or resubmission within a given period after such notice, the request for Disclosure, etc., will be deemed not to have been made. If the request for Disclosure, etc., cannot be accepted, the Company will send a reply to that effect. Please note that for requests for disclosure and notice of purpose of utilization, a handling fee prescribed by the Company [see 3. (2) above] will still be charged even if the request is not accepted.

6. 6. Purpose of Utilization of Personal Information Obtained in Relation to Request for Disclosure, etc.

   The personal information obtained through a request form or identification document, etc. submitted in association with a request for Disclosure, etc. will be used exclusively to the extent required for the response to the relevant request, such as communications or replies to the individual concerned or the agent, identification, or collection of handling fees.
   The submitted identification documents will be returned after dealing with the request for Disclosure, etc.
   
   Contact regarding the treatment of personal information as above:
   Personal Information Protection Promotion Secretariat, General Affairs Department, Kintetsu Miyako Hotels International, Inc. Tel. 06-6774-7658