PALACE HOTEL GROUP'S EFFORTS
TO PROTECT PERSONAL INFORMATION

June 2018

Hotel Grand Palace Co., Ltd

1. Purpose of Use of Personal Information and the Legal Basis for Use

(Guests’ personal information)

Palace Hotel Group (“PHG”) will use guests’ personal information, based on consent of the guests or where the use is necessary for the performance of a contract for the following purposes;

• For responding to various inquiries and requests for various information on hotel services or properties
• For acceptance of reservations for hotel and provision of hotel services
• For acceptance of reservations for food and beverage outlets and provision of these services
• For acceptance of reservations for weddings, banquets, functions or other services or products and provision of these services
• For delivery services of email newsletters
• For responding to applications for our campaigns or answers to our surveys
• For statistical operations such as grasp and calculation of your past usage for the purpose of improving our services
• For improving our services in other areas

(Business partners’ personal information)

PHG will use business partners’ personal information, based on consent of the data subject or where the use is necessary for the performance of a contract for the following purposes;

• For provision of our services for guests
• For the performance of a contract between business partners and PHG
• For responding to various inquiries from business partners
• For informing business partners about the guidance of our products or services

2. Sharing Personal Information with or Disclosing Personal Information to Third Parties

We will never share your personal information with nor disclose it to third parties except when;

• We disclose the information for use as stated in the above 1 of this Policy, to our outsourcing agents with whom PHG has concluded secrecy agreements.
• We have your consent to disclose your personal information.
• We receive legal request from such public institutions as courts or other law enforcement agencies.

3. Storage Period of Personal Information

In the event that the storage period stipulated by laws has expired or if the use is no longer necessary for the achievement of the use objectives described in the above 1, we will delete the personal information without delay.

4. Establishing and Maintaining Compliance Program

PHG is committed to establishing a compliance program that obligates its directors and employees including staff members from outsourcing personnel agents, etc. (“the employees”).

5. Appointment and Authorization of Personal Information Administrator

PHG appoints a Personal Information Administration Officer for each hotel who is in charge of PHG’s personal information protection. The authority of such Officer is to be clearly defined in the corporate organization and the Officer is to receive organizational support so that he or she may be able to properly manage the responsibility of personal information protection.

6. Establishing In-house Rules & Regulations

PHG establishes in-house rules and regulations to protect the privacy of personal information and establishes a clear policy for handling personal information. PHG notifies all the employees that their leakage of information and similar acts shall be subject to severe penalties.

7. Information Security Measures

PHG is determined to take necessary measures both for maintaining accurate and secure personal information and for preventing improper access to, loss, destruction, falsification and/or leakage of personal information.

8. Reviewing and Improving of Outsourcing System

PHG continues to review and improve its outsourcing procedures, in order to ensure the security of the privacy of personal information. In concluding contracts with outsourcing agents, PHG thoroughly reviews its outsourcing agents from the viewpoint of their qualification and capability to protect personal information.

9. Compliance with Laws and Regulations

PHG declares its strict compliance with the governmental laws, guidelines and standards concerning protection of personal information.

10. Intensified Education of the Employees

PHG educates all the employees who handle personal information so that they fully understand the importance of information security.

11. Reviewing and Improving of Internal Auditing Function

PHG continues to review and improve its internal auditing function by introducing an organizational mechanism to review whether the systems and procedures for protecting personal information are properly operated or not.

12. Disclosure, etc. of Retained Personal Data

If you or your attorney request us to disclose the retained personal data, PHG will respond to such requests without delay except as otherwise provided under the following cases;

• Cases in which the disclosure, etc. is likely to harm the rights and interests, property, body or life of a person or a third party.
• Cases in which the disclosure is likely to interfere with the proper execution of our businesses.
• Cases in which the disclosure is violation of the law.

PHG will investigate and respond to following requests regarding retained personal data when;

• You or your attorney request us to correct, add or delete such personal data because the contents are contrary to fact.
• You or your attorney request us to disuse, erase or suspend the provision to a third party because such personal data is handled in violation of the law.
• You or your attorney lodge complaints, objections, etc.

You can withdraw your consent to the use of personal information at any time.

If you have any inquiries, please contact us at the following contact point;

Personal Information Administration Officer
Hotel Grand Palace Co., Ltd.
1-1-1 Iidabashi, Chiyoda-ku, Tokyo, 102-0072, Japan
somu@grandpalace.co.jp

A data subject can lodge complaints with the Personal Information Protection Committee and other supervisory authorities regarding the use of personal information.

1. Registration of Your Personal Information

Generally you may visit our websites in anonymity and without providing any personal information, but PHG will ask you to register your personal information (name, address, telephone number, email address, etc.) in the following cases;

• Inquiring or making reservations for accommodations, dining, weddings, banquets, functions and other hotel services
• Requesting information on our services or properties
• Purchasing our services and products
• Subscribing to our email newsletters
• Participating in our special offers and promotions or in our online surveys

In case we ask you to register your personal information for purposes other than the above, you will be advised accordingly of the purpose, content and methods of handling your information.

2. Maintenance of Security and Accuracy of Personal Information

PHG strives to manage and secure the privacy of your personal information and taking reasonable and proper measures to prevent improper access to, loss, destruction, falsification and/or leakage of personal information in our websites. In addition, in order to maintain accuracy of particular personal information transmitted through the Internet, we are taking proper measures by employing SSL (Secure Sockets Layer) coding system and other systems.

3. Scope of PHG’s Website Privacy Policy

This Website Privacy Policy applies only to the websites administered by PHG hotels. We do not assume responsibility for the protection of personal information to other websites linked to our websites, with which you are recommended to check their privacy policies.

4. Use of Cookies

Our websites issue and use cookies to enhance your visit with web contents suited for you and for your convenience.
A cookie is a small text file that a website stores in a computer or a mobile terminal when you access a website.
Our website uses cookies for the following purposes;

• For specifying you on our websites and provision of the functions of our websites
• For analyzing your browsing behavior, etc. on our websites
• For delivery of online advertisement

By adjusting your browser setting, you may be able to see in advance that a website uses cookies, and to accept or reject cookies. In case you set your browser to reject cookies, there may be some features that are not available to you.
If you wish to withdraw your consent to the use of cookies, please contact us at the contact point described in “Palace Hotel Group’s Personal Information Protection Policy.”

5. Access-log Recording

Our websites can keep track of your visiting histories. Our access-log contains your domain names, browsers, access dates, links used, etc. but such information does not identify individual names. Our access-log is utilized only for the purpose of maintaining our websites and statistically analyzing the customer usage of our hotel.

6. PHG’s Personal Information Protection Policy

For more details on our policy regarding the protection of your personal information, please refer to “PHG’s Personal Information Protection Policy.”