DATA PROTECTION POLICY
Nomura Real Estate Hotels Co., Ltd. Personal Information Protection Policy and Data Protection Policy
Ⅰ: Personal Information Protection Policies
Nomura Real Estate Hotels Co., Ltd. (below, the Company) will comply with laws and regulations concerning the protection of personal information and other codes, establish a voluntary system and rules, and declare that they will be implemented and maintained in order to ensure the proper handling of personal information used by the Company in their operations.
- In order to implement this declaration, the Company has established internal rules for the protection of personal information, and will disseminate them to the Company Employees (including directors, employees in employment relationships and temporary staff) and other related parties, and implement them to improve and maintain them.
- In order to prevent the loss, destruction, tampering, and leakage of personal information, the Company have established internal rules for the safety management of information systems and will implement appropriate information security measures, such as measures to prevent unauthorized access and measures to prevent computer viruses.
- The following are the basic principles for protecting personal information at the Company.
- Prohibition of unauthorized collection
Personal information shall be collected by legal and fair means and shall not be collected by improper means.
- Prohibition of Utilization Other Than for Intended Purposes
The use of personal information shall be limited to the scope of the purpose of use and shall be prohibited from being used beyond the scope of the purpose of use.
- Ensuring safety
When handling personal information, we will pay attention to safety management and prohibit input/output, storage, transportation, transmission, and disposal in situations where safety cannot be assured.
- Prohibition of Provision to a Third Party
We prohibit providing personal information to a third party without the consent of the employee beyond the scope stipulated by laws and regulations. In the event personal information is provided to a third party in connection with the entrustment of business or personal information is shared with a third party, the Company shall enter into a necessary agreement with the third party and take other necessary measures under laws and regulations.
- Respect for the rights of the individual
We acknowledge that individuals who are the subject of personal information have the right to request disclosure, correction, suspension of use, etc. of their personal information, and will respond to such requests from individuals in accordance with the procedures stipulated by laws and regulations.
- Prohibition of unauthorized collection
Ⅱ: Matters concerning the acquisition
The Company acquire personal information through the following methods in connection with transactions involving the Company ' facilities and products (such as accommodations, banquets, food and beverage, sales of merchandise, provision and sale of other ancillary products, provision of services, and implementation of events), transactions with businesses affiliated with the Company (hereinafter referred to as "business partners") and other transactions (hereinafter referred to as "business transactions, etc.").
- Direct acquisition from the customer
Telephone, written (including electromagnetic record), business card, verbal, Internet, etc.
- Acquisition from a person duly authorized by the Customer
Applicants, referrers, travel agencies, alliance partners, and reception providers of packaged products, etc.
- Acquisition from publicly available information
Newspapers, Internet, telephone directories and publications
Ⅲ: Provisions regarding the purposes of use
The Company will use the personal information acquired for the following purposes.
- This information will be used for information and confirmation related to transactions, shipment of products, payment and reimbursement of charges, and other related matters.
- It may be used to notify and send to the person by telephone, facsimile, mail, home delivery, e-mail, or other means for guidance, advertising, advertising, questionnaires, etc. related to the management and sales of the Company and the business of the business partners of the Company.
- It may be used for statistics and analyses using computers, etc. to identify, improve, and develop the use of the Company and partner facilities and products and services.
- The Company are used to manage member information in each member organization and provide services to members.
Ⅳ: Matters concerning entrustment and joint use
In the event the Company entrusts all or part of its business, the Company will take measures to ensure the security management of personal information by entering into an agreement that includes the management and supervision of confidentiality of personal information. In addition, Nomura Real Estate Group (Nomura Real Estate Group refers to a corporate group consisting of Nomura Real Estate Holdings, Inc. and its subsidiaries and affiliates) and other businesses may jointly use all or part of their personal information within the scope of their purpose of use. When providing personal information to foreign subcontractors, Nomura Real Estate Group local corporations, and other businesses, we will take measures to ensure the same level of safety management as in Japan based on laws and regulations.
- 1.Package plans for accommodations, restaurants, etc.
We will use it with businesses that provide products and services in the hotel building.
- .Operation of each member organization, etc.
The membership registration procedures, data registration/management, points service,and other comprehensive services shall be used with the provider.
This service is used by businesses and alliance partners that provide comprehensive services, such as businesses that perform regular and irregular sending of direct mailings.
Ⅴ: Matters concerning disclosure, etc.
The Company will manage your personal information with the most accurate and up-to-date content. The Company will disclose registration information upon request from the Customer. In addition, in the event of an offer that the contents are inaccurate, the Company shall confirm the contents thereof and, if necessary, add, change, correct, or suspend the use of the registration information.
※Please contact the hotel for details of procedures related to requests for disclosure (necessary documents, acceptance methods, methods of confirmation of customers, fees, etc.).
※For personal information obtained from the Compamy Website, please refer to the "Handling of Personal Information on the Company Website" and other information.
Handling of Personal Information on the Nomura Real Estate Hotels Co., Ltd. Website
Nomura Real Estate Hotels Co., Ltd. (below, the Company) recognize that information that can identify the individual customers who use the company's website (hereinafter referred to as "personal information") is important and are carefully handled.
We may request that you enter and transmit your personal information on the Company Website in order to provide the services. The information received on the Company Website is strictly controlled in accordance with "Handling of Personal Information on the Company Website."
The content described on this page is the basic policy for handling personal information on the Company Website, and the handling of personal information may be added to each of the services provided. In such cases, the usage rules of each service guide are shown separately, and please refer to them at the same time.
Ⅰ: When requesting the provision of personal information
On the Company Website, you are requested to enter and transmit your personal information in the following cases.
- Accommodation reservation
- Restaurant application
- Requests for various materials
- Responses to the questionnaire
- Others (In the event that personal information of customers is provided in services other than the above, the purpose, contents, and handling of personal information shall be clearly indicated.)
Ⅱ: Intended use of personal information
Personal information provided by customers is available on the Company Website only in the following cases and will not be used by customers other than for the purpose for which personal information was provided.
- If it becomes necessary for the Company to contact the customer in order to provide services
- When the Company conducts an analysis to improve the Company Website and the Company services and products (in this case, the analysis will only be statistically processed and will not be used at all to identify individual customers).
- Upon the consent or disclosure request of the Customer
Ⅲ: Scope of collection of personal information
Personal information provided by the Companyfrom customers is required to provide the minimum information necessary for the provision of services, and the provision of other information is not a condition for the provision of services. (For the minimum information you need to provide, you can clearly guide the items, such as adding a mark.)
Ⅳ: To store private information
The personal information provided by the customer will be stored only as a record of the service provided, and will be removed after a certain period of time.
Ⅴ: Provision and disclosure of personal information
Personal information provided by customers shall be handled with care and shall not be provided or disclosed to any third party except in the following cases:
- Outsourcing of the Company
- In the event of the consent of the customer
- Upon request under laws and regulations
Ⅵ: Security measures
In order to safely manage the personal information provided by our customers, we have implemented reasonable safety measures from the perspectives of management, operations, and systems in order to prevent unauthorized access, loss, destruction, tampering, and leaks.
Ⅶ: Personal information in the link destination
In order to provide more useful information and services to customers, the Company Website introduces links to the websites of other companies and organizations. The Company assumes no responsibility for the collection and handling of personal information conducted on the website of the Linkee. Used with your own judgment.
Ⅷ: Changes in the handling of personal information on the Company Website
Any changes in the content of this page will be announced within the Company Website.
For inquiries regarding the handling of personal information on the Company Website, please contact each Hotel.
Handling of Personal Information at Nomura Real Estate Hotels
Nomura Real Estate Hotels Co., Ltd. (below, the Company) The handling of personal information for customers on the Company Website is in accordance with the policy of "Handling of Personal Information on the Hotels Website." However, the use of e-mail magazines from the Company requires registration of customer information, including personal information, and as additional matters regarding the handling of personal information, the Company has established the following handling policies in addition to establishing rules for the use of e-mail magazines from the Hotel. We ask that you please read and understand this before agreeing to it.
Ⅰ: Registration of customer information
When using an e-mail magazine from our hotel, we have the customer's information, including personal information, registered. The registered information (hereinafter "registered information") will be strictly controlled in accordance with the handling policy stipulated in "Handling of Personal Information on the Company Website" and the following policy (additional items).
Ⅱ: Purpose of information registration
The registered information will be used in accordance with the "Handling of Personal Information on the Company's Website" and will be used only to provide the e-mail magazine service from the Company.
However, in order to provide useful information to customers, we may use it to select the product information provided based on the registered customer information and the usage status of our website.
Ⅲ: Elimination of registration information by the Company
If e-mail cannot be sent due to a change in information registered with the customer or an error in registration, the registration information may be removed.
If there is any change in the registration information, please contact us by email as soon as possible.
Nomura Real Estate Hotels Co., Ltd. Data Protection Policy
Nomura Real Estate Hotels Co., Ltd. (below, the Company) emphasize the protection of privacy. Accordingly, the Company have formulated and will develop data protection policies as follows.
The Company will protect all personal information ("Personal Data") on EU/EEA from the Company Website or otherwise as guests when reserving our hotels rooms and pledges to process personal data in accordance with the following Data Protection Policies.
As part of our efforts to protect our customers' personal data at our hotels, this data protection policy explains the following:
- Personal data collected and processed by the Compay with respect to customers
- Reasons, methods, periods and legal basis for the Company to collect and process their personal data
- Persons and locations with access to customers' personal data
- Customer rights and obligations of the Company relating to the processing of the Company’s services as a corporation (the "Administrator") that makes decisions regarding the processing of the customer's personal data
Ⅰ: Type of personal data collected and processed by the Company
The Company will collect and process the following personal data on customers.
- Identification information (name, gender, company name, e-mail address, home/company address, mobile phone number, date of birth, place of birth, photograph, nationality, passport, visa information, etc.)Information on hotel reservations and accommodations (arrival dates, departure dates, number of guests and relationships, products and services ordered during stays, special requests, monitoring of services selected by customers, including room and room exit choices, more generally, interaction between customers and the Company, etc.)
- Payment information (payment methods, credit card numbers, account information, etc.)
- Information required to respond to special requests (meal conditions, information on the health conditions of customers who need to arrange special accommodation facilities, reservations for delivery services, etc.)
- Marketing-related information (survey results, information included in responses to the provision of promotional purposes for the Company, etc.)
- Information provided by third parties, such as travel agencies and reservation intermediaries, who are counterparties to the Company (e.g., reservation times, where the reservation is made by, etc.)
Through the Company Website, the Company will also collect and process the following personal data.
- Electronic identification data (user account and password, device identifier, IP address, etc.)
- Technical information collected by cookies (browser and operating system types and versions, type of connected devices, information about pages visited, information searched, time when the company website was visited, time and region/country of access to the company website, number of users who visited the company website at a specific time, percentage of users who left the company website without registering, other statistics on experience on the company website, etc.)
- Information on the selection of customers on the Company Website
This information is provided directly by customers, corporate clients (such as when the client employer reserves a room for the client) or third parties (such as local travel agencies, Booking.com, Expedia and other on-line travel agencies) who reserve for the client.
To the extent permitted by law, the Company may also process so-called sensitive data, such as health data derived from food or disability conditions. The Company will do so only as strictly required in order to respond to customer requests and with the prior approval of the customer. In that case, the data will be accessed and processed only under the responsibility of the representatives of the Company who have statutory or contractual confidentiality obligations.
When personal data on customers is collected (through the use of the standard form on the Company Website, etc.), the Company displays whether or not it is essential to provide such data (on an asterisk, etc.) and also shows the impact of refusing to provide the requested personal data.
Ⅱ: Legal rationale and purpose for the Company to process personal data
- Legal basis for treatment
The Company will only process your personal data if any of the following occurs:
- In the event that such treatment is necessary to comply with the legal obligations of the Company
- In cases where such processing is necessary to fulfill the contractual obligations of the Company to customers or to perform the provisional contractual procedures in response to customer requests
- If the Company receives prior approval from the customer
- When such processing is required to protect the important interests of customers
- In the event that you need to process your own interests or basic rights and to the extent that they are not freely senior to the legitimate interests of the Company, the legitimate interests of the Company with respect to the processing of your personal data include:
- From cost-effective services (such as the use of platforms operated by third-party suppliers)To be gained
- Prevent fraud or criminal activities, misuse of our hotel website and the security of our hotels' IT systems, architectures and networks;
- Achieving the Corporate and Social Responsibility Targets of the Company
- Purpose of processing customers' personal data
The Company will process your personal data only for specific purposes and to the extent relevant to the achievement of such objectives. Specifically, it will be processed for the following purposes
- To manage the our hotel’s customers
- In order to carry out operations related to the reservation of customers' hotels and the preparation of corresponding accommodations, and to provide services that are even more suitable for customers
- To provide hotel accommodations and other goods and services and to facilitate services for customers (such as restaurants, transportation services, etc.)
- In order to fulfill contractual obligations to customers or to those engaged in arrangements for travel (travel agents, group travel organizers, customer employers, etc.) and traders (credit card companies, airlines, third party royalty programs, etc.)
- To ensure the safety and security of staff, guests and other visitors
- To manage the Company’s IT resources (infrastructure management, business continuity, etc.)
- For the purpose of archiving and managing the records of the Company
- To track the activities of the Company (e.g., sales, call count, and the number of visitors to the Company Website)
- To improve the comfort of browsing when viewing the Company website
- For invoicing
- To improve our hotel's existing services (or services under development) through customer and non-customer surveys, statistics and experiments
- To protect the economic interests of the Company
- To comply with legal requirements and to comply with formal requests from public or judicial bodies
- More generally to comply with the legal, accounting and tax obligations of our hotels relating to reservations and accommodations at the hotel
- If you have an e-mail address provided by a customer, use it to regularly send an e-mail for promotional purposes concerning the products, special proposals and information of the Company that you may be interested in.
- To engage in mergers and acquisitions involving each company or the Company and other investments or withdrawals of investments
Ⅲ: Personal data access rights holders and sharing destinations
- Within the Nomura Real Estate Group
The Company may transfer personal data to Nomura Real Estate Group (Nomura Real Estate Group refers to a corporate group consisting of Nomura Real Estate Holdings, Inc. and its subsidiaries and affiliates, hereinafter referred to as the "Nomura Real Estate Group"). Nomura Real Estate Group may act as an individual independent manager or process personal data of customers on behalf of the Company and at the request of the Company (in this case, act as processors). In any case, personal data is processed only for the purposes described in II-2. Purposes of Processing Your Personal Data.
- Outside Nomura Real Estate Group
The Company may also transfer personal data to third parties acting on behalf of the Company to the extent such third parties are necessary to perform instructions from the Company in order to achieve the objectives described in "II-2. Purposes of Processing Customer Personal Data." The Company do not transfer personal data to such third parties for commercial use.
Such third parties include the Company's (IT) systems, cloud services, data center and database providers, website providers and consultants related to the Company’s business activities.
As processors, such third parties must enter into agreements with our hotels to process their personal data prior to accessing their personal data.
If necessary, the Company may also transfer your personal data to the following persons:
- A third party to whom the Company contractually assigns or renews the rights or obligations of any of the Company related to the processing of the customer's personal data
- National or international public or judicial authorities where the Company must transfer your personal data in order to comply with laws and regulations, as required by applicable laws and regulations or by national or international public or judicial authorities
- Relocation outside the European economic domain
Personal data transferred within and outside the Nomura Real Estate Group in "III Personal Data Access Rightholders and Shareholders" is processed outside the European Economic Area ("EEA") (i.e., EU Member States and Iceland, Liechtenstein and Norway). Specifically, your personal data will be transferred to Japan and may be transferred to other countries where the Acquiror described in Sections 3.1 and 3.2 above is located.
If a customer's personal data is transferred to a country outside of the EEA that is not recognized by the EU Commission as a country providing an appropriate level of personal data protection, the Company will ensure that such transfer is performed in compliance with applicable laws, either by taking protective measures required by law or by relying on the related legal effect mitigation.
Such safeguards may include entering into standard contractual provisions approved by the EU Commission prior to such transfer in order to ensure the level of protection required for the personal data to be transferred.
You may request additional information in this regard and obtain copies of the applicable protective actions by exercising your rights as follows:
Ⅳ: Period during which the Company store customer data
The Company hold their personal data only for the period necessary to meet their collection objectives and to comply with the legal obligations of the Company, after which their personal data is quickly eliminated from the Company’s systems. Notwithstanding the foregoing, if your personal data is disposed of in the context of a dispute, it will not be deleted until (i) amicable settlement is reached, (ii) a judgment of a final instance is rendered or enforced, or (iii) the claim becomes prescription.
In addition, the Company will hold the personal data of customers collected in the framework of the operation of the Company Website for three years after the customer visits the Company Website.
Ⅴ: Using Cookies on the Company Website by the Company
Our hotels use a third-party analysis cookie (i.e., a cookie that tracks the statistics of our hotel homepage) to identify and record the company homepage accessed by our customers, to gather information detailed in Article 1 and to improve the customer's viewing experience on our homepage.
Data collected by Cookies will remain in the Company's system for up to three years from the last use of the Company Website by the applicable user and will be subsequently eliminated from that system.
Keep in mind that you can change your browser settings to notify you when a cookie is sent. If you don't want to receive cookies, you can also reject any cookies by enabling the relevant settings in your browser. Finally, you can also delete a cookie that has already been set. Please note that the blocking of cookies may affect some functions of the Company website or your own browsing experience.
For more information on how to manage cookies on your device, please refer to the help function of your browser or visit http://www.aboutcookies.org that provides comprehensive information on how to manage cookies on a wide variety of browsers.
Ⅵ: Customers' Rights and Exercise Methods
- Customer's rights
To the extent permitted by law, subject to the terms and conditions provided by law, you have the following rights:
- Right to access and obtain copies of the personal data of customers processed by the Company
- Right to require modification or renewal thereof
- Right to request the deletion of your personal data
- Right to require restrictions on the processing of your personal data
- If the Company processes the customer's personal data based on the customer's approval, the customer's right to withdraw the approval (such withdrawal does not affect the legality of the previous processing).
- Right to object to the processing of your personal data
- The right to require the portability of your personal data (i.e., the right to obtain personal data provided to the Company in a structured, commonly used, machine-readable form and/or the right to require the transmission of such personal data to a third party in compliance with your own confidentiality obligations)
- Exercise of Customer's Rights
In order to exercise the above rights, customers can send requests by e-mail to the Company along with a customer's identity certificate or passport scans/copies for identity verification. The Company will comply with applicable laws.
Please tell us if you are dissatisfied with your personal data processing methods by our hotels. We will investigate our customers' concerns at the Company.
You also have the right to file a complaint with a competent data protection authority.
Ⅶ: Updating this policy
This policy is subject to revision. Future changes or additions to the processing of the customer's personal data described in this policy will be notified to the customer by the appropriate means (depending on the means by which the Companynormally contacts the customer).
Social Media Policy
Nomura Real Estate Hotels Co., Ltd. (below, the Company) are defined as follows when the Company are permanently or temporarily opening and using an official our hotel’s Account (hereinafter referred to as "Official Account") at social media (such as Facebook, Twitter, YouTube, media formed by users disseminating information on the Internet) by theCompany. The matters set forth herein shall apply to all users of our hotel’s official accounts and accompanying services (the "Users").
Ⅰ Operational guidelines
- The Company will carefully disseminate information based on the understanding that information disseminated through social media is disclosed to an unspecified number of people and that once disseminated information cannot be completely removed.
- The Company will take a proactive stance and take responsible actions in response to comments made by users.
- In principle, the Company will not reply to the content sent by the users. However, depending on the content, the Company will respond on the official account or directly to the users when it deems it necessary.
Ⅱ: Purpose of Use
The aim is to share information with customers and revitalize business activities through the dissemination of sales promotion information and information on various episodes at the Company.
Ⅲ: Information disseminated from the Company
The content disseminated by the Company in its official account is limited to promotional information related to the Company, such as products, services, events and promotions, historical episodes, and general matters related to sales promotion, such as local stories and events. For official announcements of company information, financial information, etc., we will disseminate information through the "Company Information Page" and news releases on the Company Website.
Ⅳ: Prohibitions on the communication of the Company and users
In addition to prohibiting the dissemination of the following prohibited items on the official account, the Company will remove the dissemination content at the discretion of the Company if there is a communication that falls under the prohibited items from the users.
- Breaches of human rights and privacy of users or the Company workers
- Content of infringing or defrauding the rights and property of the Company, users or third parties
- In addition, the content deemed inappropriate for the Company to be listed
- The Company may suspend or cancel operations on the official account or change information without notice.
- The Company shall not be liable for any damages arising from the use or unavailability on the Official Account for any reason whatsoever and for any damages arising from the interruption or discontinuation of operations or changes in information.
Ⅵ: Agreed Jurisdiction
The Tokyo District Court shall assume exclusive jurisdiction for the first instance over any and all disputes arising in connection with the use of social media.
Ⅶ: The Company Official Social Media Account
For inquiries regarding social media use and official accounts of our hotels, please contact our hotels.
Requests from customers when using the official social media of the Nomura Real Estate Hotels Co., Ltd.
About remarks and content of posts
- The dissemination of information on official accounts in social media does not necessarily guarantee the official announcements and views of Nomura Real Estate Hotels Co., Ltd. (below, the Company) Please refer to the Company's website.
- If there is a call that falls under the following prohibitions, the details of the call will be removed at the discretion of the Company.
- Breaches of human rights and privacy of users or the Company workers
- Content of infringing or defrauding the rights and property of the Company, other users or third parties
- In addition, the content deemed inappropriate for the Company to be listed
Response to replies and inquiries
In principle, we will not respond to inquiries and replies via social media.
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