Personal Information Protection Policy Including Specific Personal Information.

As a member of the Hospitality Partners Group whose philosophy is “we bring smiles to people with our hospitality,” we at Hospitality Operations Co., Ltd. (“Our Company”) consider the protection of personal information to be an important social responsibility. When handling personal information, including specific personal information (“Personal Information”), as part of our business activities, we do so while placing the highest priority on building trust with customers. In order to carry out our business activities, we have established the following personal information protection policy.

1. Matters regarding the acquisition, use, provision, disclosure, correction/addition/deletion of contents, cessation of use, deletion, and cessation of provision of Personal Information to a third party.

(1) Personal Information shall be acquired legally and fairly, and shall not be acquired by improper means.

(2) The use of Personal Information will be limited to the stated uses only and shall not be used for any other purpose.

(3) Personal Information will be provided to a third party only in the case where laws and regulations permit, or with the prior consent of the customer.

(4) If a customer requests the disclosure, correction/addition/deletion of contents, cessation of use, deletion, or cessation of provision of collected Personal Information to a third party, we will promptly investigate the legality of the request, and if the request is deemed to be lawful, we will comply with the request within a reasonable amount of time.

(5) Our Company will use Personal Information to conduct sales activities, fulfill contracts, and to provide information and services with respect to the following businesses and operations and other related businesses and operations.

1. To provide information on discounts, plans, and events at hotels affiliated with Our Company.
2. To conduct usage trend surveys, new product development, and customer satisfaction surveys, and collect statistical data for these purposes in such a way that does not identify any specific individuals.
3. To provide loyalty program services associated with hotels affiliated with Our Company.
4. To contact in writing, by phone, or by e-mail in response to comments received in questionnaires, etc.
5. Preparation of withholding tax forms, enrollment in health insurance and welfare pension plans, and other administrative work
6. Administrative work for preparation of payment records related to financial product transactions and insurance transactions
7. Other operations related to the provision of our services

(6) For marketing research and development such as analyzing consumer behavior.

(7) To conduct recruitment screening activities for prospective employees of Our Company.

(8) To contact customers as necessary.

(9) As a general rule, Our Company does not handle anonymized information. However, if a situation necessitates creating or providing such information, we will announce all necessary information on Our Company’s website (“Our Website”) in accordance with all laws and regulations.

2．Measures to Protect Personal Information

(1) Our Company has delegated an employee to be responsible for the handling of Personal Information, and limited the number of people with access to Personal Information to the absolute minimum. In addition, we take the utmost care to prevent unauthorized access to Personal Information, as well as the loss, destruction, falsification, or leakage of Personal Information, and continue to implement all necessary security management measures.

(2) When outsourcing the processing of Personal Information, etc., to a third party, we will select an organization with high Personal Information protection standards regarding the handling of Personal Information and information security measures. In addition, when outsourcing, a contract stipulating all matters related to the handling of Personal Information to ensure information safety will be in place.

3. Other Matters

(1) Our Company will establish internal rules necessary for the protection of Personal Information and take all appropriate security measures.

(2) We will comply with all relevant laws and regulations regarding the handling of Personal Information.

(3) Our Company will share Personal Information pursuant to the following. However, in cases where laws and regulations require the prior consent of the customer, the transfer of Personal Information will occur only after consent has been obtained in accordance with the relevant laws and regulations.

1. Personal Information items to be shared
   Name, address, date of birth, age, gender, telephone number, etc., written on guest registration cards and accommodation application forms, and other information related to accommodations and reservations.
2. Parties with whom we will share Personal Information
   Group companies of the Hospitality Partners Group, as well as companies entrusted with the management of facilities operated by Our Company.
3. Purpose of use:
   1. Joint research and development of product plans and services, etc.
   2. Proposals and announcement of product plans and services to individual customers, etc.
   3. Appropriate operation of the group’s business management operations, including the risk identification and management
4. Party responsible for Personal Information
   Hospitality Operations Co., Ltd.

4. Auditing

Corrections and amendments will be made as necessary to address any issues in the implementation of the contents above.

5．Our Website

While we take the utmost care in handling and protecting Personal Information in accordance with this policy so that users can access our services comfortably and safely, we cannot be held responsible for the security of Personal Information on other websites linked to this site. If you are using an external website which does not outline their Personal Information protection and handling standards, we strongly recommend that you check the security of your Personal Information by checking directly with the person or department in charge of that website.

6．Revisions to the Personal Information Protection Policy

If significant changes are made to this policy, we will notify you on Our Website.

7．Inquiries Concerning Personal Information

Nakoji Building Shinkan 8F, 2-5-16 Kanda Nishikicho, Chiyoda-ku,
Tokyo, 101-0054
K.K. Hospitality Operations
TEL: +81 3-5755-5516
Phone hours: 9:00a.m. – 6:00p.m. (excluding weekends and public holidays)

CEO: Akio Tanaka
This Policy is effective as of April 21, 2006, and has been revised on June 1, 2021.