隐私政策

关于个人信息处理的基本事项

关于获取个人信息

我们将仅在业务需要的范围内通过以下方式适当获取您的个人信息。
・直接从个人获取：电话、口头、书面（包括电磁记录）、名片、互联网等）
・从本人正式授权的人处获取：第三方，如使用申请人、介绍人、旅行社、商业伙伴等。
・ 从公开渠道获得：报纸、互联网、电话簿、书籍等。
・经我们许可使用我们商标的经营者和管理和运营酒店的三菱地产（与我们公司管理和运营的酒店一起，以下称为皇家花园酒店Group Hotels”）从我们的集团公司和相关方收购，证券报告书或集团公司名录中记载的（以下称为本公司集团公司等）：相关事业者的隐私政策中规定的适当的个人信息取决于共同使用的方式

关于个人信息的利用目的

我们会在以下情况下使用您的个人信息。
・在我们公司提供住宿，饮食和宴会等酒店设施运营服务时
・当我们提供有关设施、产品、服务等的信息时。
・为了改善服务，向客户发送问卷等调查请求合作时
・用于提供有关我们会员系统的各种信息和服务时
・经个人同意向第三方提供时
・用于与我公司、皇家花园酒店Group 酒店、我们集团公司等的商业化支持和合作。
・用于本公司、皇家花园酒店Group酒店、本公司集团公司等的PR活动和IR活动的各种沟通和指导时。
・用于本公司、皇家花园酒店Group旗下酒店、本公司集团公司等的环境活动和CSR活动中的各种沟通和指导、交付物和出版物等的运营和管理。
・用于本公司、皇家花园酒店Group Hotels或集团公司等作为秘书处的各种组织等的运营时
・用于本公司求职者的招聘活动时
・我们在获取个人信息时明确的使用目的范围内使用个人信息的情况下，或者在回应附带或与我们的业务相关的事项时

论个人信息的共享利用

为了向客户提供高附加值服务，我们将在严格的管理和适当的安全措施下共同使用如下个人信息。
・共同使用个人信息的各方：参与皇家花园酒店酒店的管理和运营的经营者、集团公司等。
・共同使用的目的：
(1) 在皇家花园酒店集团旗下酒店提供住宿、餐饮、宴会等酒店设施管理业务服务时。
(2)皇家花园酒店酒店提供设施、产品、服务等信息时
(3) 为了改善皇家花园酒店集团酒店的服务，我们请求您配合调查，例如向我们的顾客发放调查问卷。
(4) 用于提供有关皇家花园酒店集团酒店会员制度的各种信息和服务时。
(5) 为了应对皇家花园酒店集团酒店业务附带或相关的事项或在获取个人信息时公开的使用目的范围内使用个人信息的情况。
・共同使用的个人信息项目：顾客姓名、会员号码、电话/传真号码、国籍、护照号码、地址、电子邮件地址（包括其他同等社交媒体ID等）、年龄、性别、需要考虑的信息项目关于生日、周年纪念日、工作信息、其他请求、使用历史记录等。
・共享个人信息管理负责人：三菱地所酒店及度假村株式会社

关于第三方提供个人信息

除以下情况外，我们不会向第三方提供或披露个人信息。
1. 顾客本人同意时
2. 法律要求时
3. 人的生命、身体或财产等特定权益可能受到侵害，需要提供个人信息保护时，难以取得客户本人的同意
4.为改善公共卫生或促进儿童健康发展特别需要，又难以征得本人同意时。
5. 政府机构等在执行法令规定的事务时，有必要取得民间企业等的合作皇家花园酒店合作的民间企业等）可能会妨碍就向相关国家的机构等提供个人信息，在征得客户同意的情况下执行相关事务。
6. 当第三方为学术研究机构等，且第三方需要为学术研究目的处理个人资料时（处理个人资料的部分目的为学术研究目的），但不包括以下情况存在不公正地侵犯个人权益的风险。）

个人信息咨询窗口 (主管部门) 等

关于本公司持有的个人信息的公开等请求手续和本公司个人信息的处理的咨询、意见等，请联系以下窗口。确认咨询等是本人的情况下，进行对应(但是，在某些情况下可能无法满足您的要求。)。

三菱地所酒店及度假村有限公司
个人信息咨询处
邮政编码：107-0062
地址：东京都港区南青山1-1-1新青山大厦东馆13楼

论个人信息管理体制

本公司将努力对个人信息进行适当的管理和保护，如下所示。

保护个人信息

我们成立了信息管理委员会，以促进信息管理并努力保护个人信息免受未经授权的访问。
・为确保个人信息的安全，我们从运营管理和系统两方面采取安全措施，以防止未经授权访问系统以及个人信息的丢失、破坏、篡改、泄漏等。
・登记个人信息的数据库存储在受外部访问机制（防火墙）保护的系统中。
・在本网站上，顾客与互联网之间的个人信息的收发，使用SSL（Secure Sockets Layer）加密通信，有可能无法访问或输入信息。
・我们可能会在我们的网站等上使用称为 cookie 的信息，以提高客户的便利性。您可以通过更改浏览器设置来禁用 cookie 功能，但因此您可能无法使用某些服务。
・我们可能会出于网站使用调查等统计分析的目的使用访问日志信息，但不包括可以识别个人身份的信息。

内部结构

・本公司为确保员工彻底保护客户的个人信息，实施必要的安全措施。
・在委托处理个人信息的全部或一部分时，公司将对受托方的个人信息处理等进行定期检查，以确保对受托个人信息的安全管理进行适当的监督。
・在国外处理个人信息时，公司定期收集和了解有关该国个人信息保护系统的信息，并采取安全控制措施。

链接目标中的个人信息

本公司的主页为了向客人提供更方便和有用的信息和服务，介绍了与第三者(其他公司、团体)的主页 (网站) 的链接。关于链接网站 (网站) 上进行的个人信息的收集、处理， 本公司概不负责。

其他

・如果公司需要更改“隐私政策”的内容，该内容将在公司网站等上公布。请注意，对于因未检查而造成的任何问题，我们概不负责。
・如果您的注册信息有任何变更，或者您希望删除它，请尽快联系注册的酒店，以便顺利提供服务。

信息管理经理
三菱地所酒店及度假村有限公司
社长大岛雅也

• 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.