Privacy Policy

Sakia Hospitality Co., Ltd. (the “Company”) regards the protection of personal information as one of the important responsibilities it has to society and has established the following Policy on the Appropriate Protection and Use of Personal Information (“Privacy Policy”) based on the Act on the Protection of Personal Information (the “Act”). When personal information is handled as a part of the Company’s business activities, the Company conducts appropriate procedures and measures while putting top priority on maintaining the trust of customers. In accordance with this policy, the Company’s executives and employees work to appropriately handle and manage personal information both internal and external to the Company.

1. Compliance with Related Laws and Regulations

In the handling of personal information, the Company complies with the Act on the Protection of Personal Information (Act No. 57 of May 30, 2003) and other related laws and regulations

2. Collection and Acquisition of Personal Information

(1)Collection of personal information is conducted appropriately, legally and through fair means. (2) In the course of business operations, the Company acquires personal information using the following methods. a. From the customer directly by telephone, written correspondence, digital records, business cards, verbally or the Internet, etc. b. From a person authorized by the customer by telephone, written correspondence, digital records, business cards, verbally or the Internet, etc. c. From publically available information (newspaper, television, radio, Internet, publications, phonebooks, etc.) d. Other means connected with the Company’s general service offerings

3. Use, Provision and Disclosure of Personal Information

(1) Personal information is only used within the scope defined by the following purposes of use and is not used outside that scope. Purposes of Use for Personal Information a. Notification, communication, confirmation, payment and settlement in connection with Company transactions, and other related uses b. Presentations, marketing materials and questionnaires related to sales, operations and management c. Items listed in the preceding two items related to stores, restaurants, business offices, information counters, etc. managed by entities other than the Company within facilities owned, or managed and operated, by the Company d. Analysis conducted to ascertain usage of the Company’s facilities, products and services and for their improvement and development e. Management of member information for membership organizations related to facilities owned, or managed and operated, by the Company and provision of information and services to those members f. Investment services for real estate, stocks and bonds, etc. g. Management of hotels, etc. h. Contract management of hotels, etc. i. Asset management services for hotels, etc. j. Consulting services related to management and investment for hotels, etc. k. Real estate buying and selling, exchange and leasing l. Agency and intermediary services related to real estate buying and selling, exchange and leasing m. Financial instruments business (Type II Financial Instruments Business and Investment Advisory and Agency Services) n. All operations incidental to the above items

4. Security Measures for Personal Information

(1) An officer responsible for the handling of personal information is designated and the personnel who handle the information are limited to the minimum number necessary. The Company conducts necessary security management measures and works to prevent unauthorized access to personal information, and the loss, destruction, alteration and divulgence, etc. of personal information. (2) When personal information processing, etc. is outsourced, vendors are selected that have been deemed by the Company to maintain appropriate personal information protection and management standards for the handling of personal information and information security measures. Additionally, when outsourcing, the Company stipulates items related to the handling of personal information in the contract, etc. and makes every effort to ensure its security.

5. Provision of Personal Information to Third Parties

The Company does not provide personal information to third parties except in the cases stipulated below. a. When the customer has agreed to provision to third parties b. When disclosing to third parties within the scope necessary to achieve the purposes of use listed in 3 above c. When providing the information to vendors as stipulated in 4 above d. When providing the information for joint usage purposes as stipulated in 6 below e. When a disclosure request is received based on the law, etc. from a government institution, local public body or an entity contracted by them

6. Joint Use of Personal Information

The Company may use the personal information of customers jointly with its group company in accordance with the following. The Company does not provide personal information to third parties except in the case stipulated below. (1) Scope of joint users Hotel Value Operations Co., Ltd. (2) Purpose of joint use: Same as the purposes of use stipulated in 3 above (3) Personal information items used jointly: Name, address, birth date, telephone number, credit information, transaction information and other items within the scope necessary for the purposes for use of the joint user above. (4) Party responsible for management related to joint use: Hotel Value Advisors LLC.

7. Procedures for Personal Information Disclosure and Revisions, etc.

When there is a request directly from a customer for disclosure, revision, or suspension of use, etc. of personal information possessed by the Company, the Company promptly responds in accordance with procedures it has stipulated separately.

8. Maintenance and Improvement of Personal Information Protection

The Company conducts regular audits of the training and handling status of executives and employees in connection with personal information protection so that personal information handling is conducted smoothly, and implements this policy while working continually to make improvements.

9. Website-related Matters

In connection with the website operated by the Company (the “Site”), maximum care is taken to handle and protect personal information in accordance with this policy to enable users to use services securely and comfortably. The Company bears no responsibility however for ensuring the security of customers’ personal information on other websites linked to the Site. It is recommended that customers closely examine the content of handling standards related to personal information protection of websites other than the Site and that they confirm the security of their own personal information, such as by directly confirming with the website’s department or manager responsible if there are no handling standards, etc. listed.

10. Revisions to this Policy

(1) The Company continually works to make improvements by appropriately revising this policy based on legal requirements and changes, etc. in the social environment related to personal information protection. (2) Important changes to this policy are announced on the Site. This policy is subject to change without advance notice, so please confirm the latest information on the Site as necessary.

11. Inquiries related to Personal Information Protection

Aska V Nihonbashi 7F, 1-3 Nihonbashi Odenmacho, Chuo-ku, Tokyo 103-0011 Tel: 03-6667-0790 Hours: 10:00-18:00 (except Saturdays, Sundays, national holidays and the New Year’s holiday period)

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