Privacy Policy

Basic matters concerning the handling of personal information

Collection of personal information

The Company shall appropriately acquire our guests’ personal information only to the extent necessary for our business by the following methods.
・Collection directly from the person: Telephonically, verbally, in writing (including electromagnetic records), from business cards, via the Internet, etc., (including information entered when using hotels managed and operated by the Company, and information entered for membership registration, etc.).
・Collection from a person who is duly authorized by the person: applicants, introducers, travel agents, third parties such as business partners.
・Obtained from publicly available sources: newspapers, the Internet, telephone directories, books, etc.
・Collection from businesses that manage and operate hotels where the Company’s trademarks are used with the Company’s permission (together with hotels managed and operated by the Company, hereinafter referred to as “Royal Park Hotels Group hotels”), and from the Mitsubishi Eatate Group companies (Mitsubishi Estate Co., Ltd., and its affilliates listed in its securities report, hereinafter collectively referred to as “the Company’s Group companies, etc.”) : Information acquired by an appropriate method of collecting personal information for joint use as set forth in the privacy policy of the relevant businesses.

Purpose of using personal information

The Company will use guests’ personal information in the following cases:
・When providing services in the operation of the Company’s hotel facilities, such as accommodation, food and beverage, and banquet, etc.;
・When the Company sends information about its facilities, products, services, etc., to guests;
・When the Company requests guests to cooperate in a survey by sending them a questionnaire in order to improve the Company’s services;
・When using personal information to provide various types of information and services related to the Company’s membership program;
・When providing information to a third party with the consent of the person;
・When using personal information to support the commercialization of or in cooperation with the Company, Royal Park Hotels Group hotels, or the Company’s Group companies, etc.;
・When using personal information for various communications and guidance, etc., in public relations and IR activities of the Company, Royal Park Hotels Group hotels, and the Company’s Group companies, etc.;
・When using personal information in the operation and management of various communications, guidance, delivery of products and publications, etc., in connection with the environmental and CSR activities of the Company, Royal Park Hotels Group hotels, the Company’s Group companies, etc.;
・When using personal information for the operation of various organizations, etc., for which the Company, Royal Park Hotels Group hotels, or the Company’s Group companies, etc., serve as the secretariat;
・When using personal information in the Company’s recruitment and selection activities for job applicants; and
・When using personal information to respond to other matters ancillary or related to the Company’s business or using personal information within the scope of the purpose of use clarified at the time of collection of the personal information.

Shared Use of Personal Information

In order to provide high value-added services to our guests, the Company will share personal information as follows under strict control and with appropriate security measures
・Parties with whom personal information is shared: Businesses engaged in the management and operation of Royal Park Hotels Group hotels and the Company’s Group companies, etc.
・Purpose of sharing personal information:
(1) When providing services in the operation of facilities of Royal Park Hotels Group hotels, including accommodation, food and beverage, and banquet, etc.;
(2) When Royal Park Hotels Group hotels send information about their facilities, products, services, etc., to guests;
(3) When the Company requests guests to cooperate in a survey by sending them a questionnaire in order toimprove the services of Royal Park Hotels Group hotels;
(4)  When using personal information to provide various types of information and services related to the membership program of Royal Park Hotels Group hotels; and
(5) When using personal information to respond to other matters ancillary or related to the business of RoyalPark Hotels Group hotels or using personal information within the scope of the purpose of use clarified at thetime of collection of the personal information.
・Items of personal Information to be shared: Guest’s name, membership number, telephone and fax numbers,nationality, passport number, address, e-mail address (including other equivalent information such as socialmedia ID, etc.), age, gender, birthday, anniversary date, workplace information, and other items of specialcare-required personal information regarding requests, usage history, etc.
・Administrator of Personal Information subject to shared use: Mitsubishi Estate Hotels & Resorts Co., Ltd.

Provision of personal Information to third parties

The Company shall not provide or disclose personal information to third parties except in the following cases:
1. When a guest gives their consent;
2. Cases based on laws and regulations;
3. When there is a risk of infringement of a specific right or interest, such as a human life, body, or property, and it is necessary to provide personal information to protect such rights or interests, and when it is difficult to obtain a guest’s consent;
4. Cases in which there is a special need to enhance public hygiene or promote the fostering of healthy children, and when it is difficult to obtain a guest’s consent;
5. Cases in which there is a need to obtain the cooperation of a private company, etc., in regard to a central government organization, etc., performing affairs prescribed by laws and regulations, and when there is a possibility that obtaining a guest’s consent for the cooperating private company, etc., (businesses engaged in the management and operation of Royal Park Hotels Group hotels) to provide personal information to the central government organization, etc., would interfere with the performance of the said affairs.
6. Where the third party is an academic research institution, etc., and it is necessary for the said third party to handle the said personal data for academic research purposes (including cases in which part of the purpose of handling the said personal data is for academic research purposes, but excluding cases in which there is a risk of unreasonable infringement on the rights and interests of individuals).

Personal information inquiry counter (department in charge), etc.

For inquiries and opinions regarding the procedures for requesting disclosure, etc. of personal information held by the Company and the handling of personal information by the Company, please contact the following contact point. We will respond after confirming that the inquiry is made by the person himself/herself (however, we may not be able to comply with your request in certain cases).

Mitsubishi Estate Hotels & Resorts Co., Ltd.
Personal Information Inquiry Desk
Postal Code: 107-0062
Address: Shin Aoyama Bldg. East 13F, 1-1-1, Minamiaoyama, inato-ku, Tokyo 107-0062 JAPAN

Personal information management system

We will strive to properly manage and protect personal information as follows.

Protection of personal information

We have established an information management committee to promote information management and strive to protect personal information from unauthorized access.
・In order to ensure the safety of personal information, we take safety measures from both operational management and system aspects in order to prevent unauthorized access to the system and loss, destruction, falsification, leakage, etc. of personal information.
・The database in which personal information is registered is stored in a system protected by a mechanism (firewall) that prevents access from the outside.
・The transmission and reception of personal information between customers and the Internet on our website uses encrypted communication using SSL (Secure Sockets Layer). You may not be able to access or enter information.
・ We may use information called cookies on our website, etc. for the purpose of improving customer convenience. You can disable the cookie function by changing your browser settings, but as a result you may not be able to use some services.
・ We may use access log information for the purpose of statistical analysis such as website usage surveys, but it does not include information that can identify individuals.

Corporate structure

・The Company implements necessary security measures to ensure that the Company’s employees protect the personal information of our guests.
・In the event that the Company outsources all or part of the handling of personal information, the Company shall conduct necessary and appropriate supervision, such as periodic inspections of the handling of personal information by the outsourcee, to ensure that the outsourced personal information is managed safely.
・When handling personal information in foreign countries, the Company regularly gathers and understands information on the personal information protection systems of those countries and takes security control measures accordingly.

Personal information on Third-Party linked sites

In order to provide guests with more convenient and useful information and services, the Company’s website introduces links to the websites of third parties (other companies and organizations). The Company shall not be responsible for the gathering and handling of personal information on such linked third-party homepages (websites).

Others

・If it becomes necessary for the Company to change the contents of its “privacy policy,” we shall notify guests of such changes on the Company’s website. The Company assumes no responsibility regarding any problems that may arise as a result of failure to confirm changes to this Privacy Policy.
・If you wish to change your registered information, or if you wish to have your information deleted, please contact the hotel where you registered your information, and we will process your request as soon as possible.

Information Management Officer
Mitsubishi Estate Hotels & Resorts Co., Ltd.
President and CEO Masaya Oshima

• PRIVACY POLICY（GDPR）

  MITSUBISHI ESTATE HOTELS & RESORTS Co., Ltd. PRIVACY POLICY (LAST UPDATED: [APRIL 1, 2022])

  Mitsubishi Estate Hotels & Resorts Co., Ltd. (the “Company”) is aware that information that could identify an individual customer of the Company (“Personal Information”) is valuable information, and has therefore established regulations on information management in order to handle Personal Information with the utmost care. Please review the Company’s basic policy on the handling of Personal Information set forth below.

  Ⅰ. Collection of Personal Information

  The Company collects Personal Information only to the extent appropriate and necessary to conduct the Company’s business using the methods set forth below.
  1. Direct collection from customers: Collection via telephone, orally, in writing (including electronic records), from business cards, online (including information that is input when using websites of hotels managed and operated by the Company and information input when performing member registration), and so on. The information we collect from you is likely to include.
  2. Collection from third parties duly authorized by customers: Collection from third parties such as users, potential users, referral agencies, travel trade professionals, and business partners. The information we collect from such third parties is likely to include
  3. Collection from publicly available sources: Collection from newspapers, online, telephone directories, books, and other such sources. The information we collect from such publicly available sources is likely to include　your name, telephone or fax number, nationality, address, email address (including social media IDs and the like associated with email addresses), age, gender, date of birth, anniversary date, employer information, requests, and use history.
  4. Collection from businesses engaged in the management and operation of the hotels that use the Company’s trademarks under license from the Company (referred to collectively with hotels managed and operated by the Company as “Royal Park Hotels Group Hotels”), Mitsubishi Estate Co., Ltd., its group companies listed in financial statements or on the list of group companies, and other relevant parties(“Mitsubishi Estate Group”): Personal Information will be collected by the relevant businesses and shared by means of shared use of Personal Information, as specified in the privacy policies of these businesses. The information we collect from such businesses is likely to include your name, membership registration number, telephone or fax number, nationality, passport number, address, email address (including social media IDs and the like associated with email addresses), age, gender, date of birth, anniversary date, employer information, requests, and use history.

  Ⅱ. Purposes of Use of Personal Information

  The Company uses Personal Information for the following purposes.
  1. To provide services through the operation of hotel facilities such as accommodation, dining, and banquet space.
  2. To provide information regarding its facilities, products, services, and so on.
  3. To facilitate customer surveys and the like presented by the Company intended to improve the Company’s services.
  4. To provide various information and services in relation to its membership program provided by the Company.
  5. Provision of personal information to third parties only when granted consent by the person concerned.
  6. For support and collaboration on commercialization of businesses of the Company and its group companies.
  7. For communication/notifications in corporate communication activities/IR activities.
  8. For various communication/notifications and operations/management of delivery of deliverables/publication in environmental activities/CSR activities.
  9. For operations of various organizations where the Company takes the role of administrative office.
  10. For conduct of employment application screening at the Company.
  11. To respond to other matters ancillary or related to its operations when use is within the scope of the intended use specified at the time that the Personal Information was acquired.

  Ⅲ. Shared Use of Personal Information

  In order to add high levels of value to the services provided to customers, the Company shares Personal Information as set forth below under strict controls and with appropriate security measures in place.
  1. Joint users of Personal Information: Businesses engaged in the management and operation of Royal Park Hotels Group Hotels, including guest service providers and Mitsubishi Estate Group.
  2. Purposes of Shared Use:
  (1) When providing services through the operation of hotel facilities such as accommodation, dining, and banquet space at Royal Park Hotels Group Hotels.
  (2) When Royal Park Hotels Group Hotels provide information regarding facilities, products, services, and so on.
  (3) When you participate in customer surveys and the like presented by the Company intended to improve Royal Park Hotels Group Hotel services.
  (4) When the Company provides various information and services in relation to its membership programs provided by Royal Park Hotels Group Hotels.
  (5) When Royal Park Hotels Group Hotels respond to other matters ancillary or related to their operations when use is within the scope of the intended use specified at the time that the Personal Information was acquired.
  3. Personal Information subject to shared use: your name, membership registration number, telephone or fax number, nationality, passport number, address, email address (including social media IDs and the like associated with email addresses), age, gender, date of birth, anniversary date, employer information, requests, and use history.
  4. Administrator of Personal Information subject to shared use: Mitsubishi Estate Hotels & Resorts Co., Ltd.

  Ⅳ. Provision of Personal Information to Third Parties

  Except in the following cases, the Company shall not provide or disclose Personal Information to third parties. Subject to the requirements specified in Articles X and XI, the Company may disclose Personal Information to cloud service providers as long as such cloud service providers are precluded from using the Personal Information provided.
  1. When you consent.
  2. When the disclosure is based on laws and regulations.
  3. When there is a need to protect a human life, body or fortune, and when it is difficult to obtain your consent.
  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 the person.
  5. When there is a need to cooperate in regard to a central government organization or a local government, or a person entrusted by them performing affairs prescribed by laws and regulations, and when there is a possibility that obtaining your consent would interfere with the performance of the said affairs.5.When there is a need to cooperate in regard to a central government organization or a local government, or a person entrusted by them performing affairs prescribed by laws and regulations, and when there is a possibility that obtaining your consent would interfere with the performance of the said affairs.
  6. Where such third party is an academic research institution, etc., and it is deemed necessary for such third party to handle such personal data for academic research purpose (including cases where part of the purpose of handling such personal data is for academic research purpose, but excluding cases where it is deemed liable to unjustifiably infringe on individuals’ rights and interests).

  Ⅴ. Contact Information regarding Personal Information (Responsible Division)

  For inquiries regarding procedures for requesting disclosure, etc. of personal information held by the Company and the handling of personal information by the Company, please contact the following. We will respond after confirming that the inquiry, etc. is made by the person in question.
  

  Company name： Mitsubishi Estate Hotels & Resorts Co., Ltd.
  Address : Shin Aoyama Bldg. East 13F, 1-1-1, Minamiaoyama, Minato-ku, Tokyo 107-0062 JAPAN
  E-mail: privacy-data@rphs.jp

  Ⅵ. Protection of Personal Information

  The Company has established the Information Management Committee to manage Personal Information as it strives to protect Personal Information from unauthorized access. The Information Management Committee has implemented, and will continue to oversee, the following matters.
  - To ensure the security of Personal Information and prevent unauthorized access to systems and the loss, destruction, alteration, or leak of Personal Information, the Company has implemented security countermeasures concerning both operational management and systems.
  - Databases in which Personal Information is recorded are stored on systems protected by mechanisms (including firewalls) to prevent external access.
  - Transmission and receipt of Personal Information with you via the Internet on the Company’s website use encrypted transmissions that employ Secure Sockets Layer (SSL). In cases where you use a browser that does not support SSL, you may not be able to access SSL secure pages or to input information.

  Ⅶ. Internal Systems

  The Company has implemented security measures to ensure that its employees carry out comprehensive protection of your Personal Information, and to appropriately monitor outside contractors and others.

  Ⅷ. Personal Information on Third-Party Linked Sites

  In order to provide more useful information and services to you, the Company’s websites contain links to the websites of third parties (other companies and organizations). The Company assumes no responsibility regarding the collection and handling of Personal Information by such linked third-party websites.

  Ⅸ. Other

  - If it becomes necessary to revise this Privacy Policy, the Company shall provide notice to that effect on its website or by other means. The Company assumes no responsibility regarding any problems that may arise as a result of failure to confirm changes to this Privacy Policy.
  - If any changes occur to information registered with the Company or if you want Personal Information to be deleted, please promptly contact the hotel that registered the information so that the services can be effectively provided.

  Ⅹ. Handling of Personal Information of EEA and UK residents

  In addition to Articles I-IX above, the provisions in this Article X and Article XI below shall apply to the handling of Personal Information of persons in the European Economic Area (EEA and UK) that is subject to the General Data Protection Regulation (REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL). If any provision of these Articles X and XI conflicts with the provisions of Articles I-IX above, the provisions of Articles X and XI shall prevail.
  1. Legal basis for processing: The Company will process and use Personal Information to manage its contractual relationship with you, to pursue a legitimate interest, and/or to comply with a legal obligation.
  It will be necessary for the Company to use your Personal Information to complete a booking you have made with us. For example, we will need to use information such as your contact details and payment information to provide you with the stay and/or restaurant booking you have requested and paid for.
  Alternatively, we may collect and use your Personal Information where you have given your specific consent to us doing so.
  2. Collection of access data: In addition to the information specified in Article I, we automatically collect data related to you when you visit our websites. This data that we obtain from you when you visit us (“access data”) includes access logs, web beacons (also known as pixel tags), cookies, etc. For more information about how we use your access data, please see Article XI below.
  3. Disclosure of your Personal Information to recipients： We may share your Personal Information with businesses engaged in the management and operation of Royal Park Hotels Group Hotels for the purpose described in “III Shared Use of Personal Information”. We may also share your Personal Information with internet service providers, cloud service providers, guest service providers, Most of these recipients are located in Japan. We will ensure an adequate level of protection of your Personal Information when they are disclosed to a recipient located outside the EEA and UK.
  4. Transfer of your Personal Information: Your Personal Information may be transferred to and stored by the Company and our service providers in countries outside the country in which you are located and outside the EEA and UK. The Company operates businesses in multiple jurisdictions, some of which are not located in the EEA and UK, such as Japan, China and the USA. Where we transfer your Personal Information outside the EEA and UK, we will ensure that:
  (a) the recipient destination has been subject to a finding from the European Commission that it ensures an adequate level of protection for the rights and freedoms that you possess in respect of your Personal Information; or
  (b) the recipient enters into standard data protection clauses with us that have been approved by the European Commission.
  You can obtain more detailed information about the protection given to your Personal Information when it is transferred outside the EEA and UK (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Information) by contacting us in accordance with the contact information provided above.
  Retention of Your Personal Information: The Company will keep your information for as long as we need it for the purpose it is being processed for. For example, where you book a stay with us we will keep the information related to your booking, so we can fulfill the specific travel arrangements you have made and after that, we will keep the information for a period which enables us to handle or respond to any complaints, queries or concerns relating to the booking. The information may also be retained so that we can continue to improve your experience with us and to ensure that you receive any loyalty rewards which are due to you.
  We will actively review the information we hold and delete it securely, or in some cases anonymize it, when there is no longer a legal, business or customer need for it to be retained.
  5. Your Data Protection Rights: Under certain circumstances prescribed by law, you have the right to:
  - Request information about whether we hold Personal Information about you, and, if so, what that information is and why we are holding and using it.
  - Request access to your Personal Information (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Information we hold about you and to check that we are processing it lawfully.
  - Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  - Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no basis for us to continue to process it. You also have the right to ask us to delete or remove your Personal Information where you have exercised your right to object to it being processed.
  - Request restriction of processing of your Personal Information. You may request restriction in certain circumstances. For example, you can request it when you dispute the accuracy of your Personal Information or when you want to confirm the legal grounds for the lawful processing of your Personal Information.
  - Object to the processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and you want to object to processing on this ground owing to some aspect of your particular circumstances. You also have the right to object where we are processing your Personal Information for direct marketing purposes.
  - Object to automated decision-making including profiling. You may request not to be the subject of any automated decision-making which uses your Personal Information or profiles you.
  - Request transfer of your Personal Information in an electronic and structured form to you or to another party (commonly known as the right to “data portability”). This enables you to receive your data from us in an electronically useable format and to transfer your data to another party in an electronically useable format.
  - Withdraw consent. Where you have provided your consent to the collection, processing and transfer of your Personal Information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. If you withdraw this consent, in some circumstances, we will not be able to provide all or parts of the services you have requested from us and you will not be able to earn points, cancel your booking or obtain a refund of any charges you have paid.
  If you want to exercise any of these rights listed above, please send an email to privacy-data@rphs.jp
  You also have the right to lodge a complaint with the competent data protection authority if you think that any of your rights have been infringed by the Company.

  Ⅺ. Use of Access Data

  1. The Company collects and uses the following types of access data from visitors to our websites and users of our services.
  - In some cases, the Company makes use of information known as cookies on its websites and so on for the purpose of enhancing customer convenience. You can disable cookie functionality by changing browser settings, but it may not be possible to use some services as a result. To find out how to change your cookie settings, please select “Help” from the menu bar of your browser and search for the word “cookie”.
  - Access logs. The Company may use access log information for the purpose of statistical analysis such as investigating the number of times that the Company’s website is used, but such information does not include personally identifiable information.
  2. The following third-party providers may have access to the access data collected by us.
  Google Analytics. Google Analytics sets and accesses cookies on your computer or other device to collect information such as the numbers of visitors to our websites, where visitors have come to the websites from, and the pages they have visited. Our websites use Google Analytics to help collect and analyze certain information to engage in analysis, auditing, research and reporting. You may review Google Analytics’ security and privacy principles by clicking here, and opt out of the use of cookies in web browsers by Google Analytics by clicking here.

  Masaya Oshima
  President and Chief Privacy Officer
  Mitsubishi Estate Hotels & Resorts Co., Ltd.