PRIVACY POLICY

The company, as a member of the JTB Group, has a management philosophy of promoting international exchanges and achieving a peaceful and environmentally friendly society by improving the attractiveness of Japan, as well as by promoting positive values and inspiring people around the world.

Under this philosophy and basic policy, we try to provide the highest quality products and services in the MICE*2 businesses, such as those for enterprises and events, SITs*3, and package tours for foreigners. We do this by utilizing the solution techniques that we have developed as DMC*1 of Japan, to achieve the number-one ranking in customer satisfaction; and by undertaking open and fair corporate activities, to gain the trust of our customers, business partners and society. We also endeavor to raise our corporate value through ceaseless business innovation. Gaining our customers' trust requires protection of their personal information and that of others connected with our Company. So, we execute the following:

1. We will create a personal information protection management system that conforms to the JIS Q 15001 standard, and which all the directors and employees shall strictly observe.
2. The handling of personal information such as its collection, use and provision, shall be based on the above-mentioned personal information protection management system, and we will only collect information necessary for our business and by legitimate means, and will use and provide the information only for legitimate purposes. Furthermore, if the necessity arises for handling in a way that exceeds the range of the specific purposes of use, we will notify the person concerned of the purpose of use in order to obtain prior acknowledgement from him/her, after obtaining an approval from the personal information protection manager in-house. We will never use the information for any other purposes than those mentioned above. The specific personal information that has been obtained shall be used and provided only for the purposes stipulated by the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure. The personal information protection manager shall create a procedure for storing and administering personal information and shall appoint a person to manage its administration, and shall not allow anybody except the administrative manager to handle Social Security and Tax Number information. The personal information shall not be used for any other purposes than the above-mentioned legitimate purposes.
3. For all the personal information handled in the Company, we shall execute reasonable prevention and correction measures regarding organization and technology against an unauthorized access, loss, destruction, falsification and leakage, etc.
4. For complaints and inquiries concerning the personal information handling, we will respond quickly and appropriately..
5. We will observe the regulations concerning the protection of personal information and the proper handling of specific personal information, the guidelines provided by the government, social norms, and public order and morals.
6. We will regularly audit the personal information protection management system, and continuously improve it.

*1 DMC: Abbreviation of Destination Management Company
*2 MICE: Abbreviation of Meetings, Incentives, Conferences and Exhibitions
*3 SIT: Abbreviation of Special Interest Tour

In accordance with the Act on the Protection of Personal Information, the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures
(hereinafter referred to as the “Individual Numbers Act”) and JTB Global Marketing & Travel Inc.’s policies regarding the protection of personal information, we handle and protect personal information as follows.

(1)We acquire personal information directly or indirectly in connection with the provision or performance of products or services such as travel related products
or services or in connection with the receipt of opinions from customers or other contact with customers, and retain a portion of such information as personal data.

(2)We acquire personal information from job applicants and retain it as personal data.

(3)We acquire personal information from our business partners (in the case of corporate business partners, its officers and employees) and retain it as personal data.

(4)We acquire and retain personal data, such as personal numbers (My Number), relating to our employees and their relatives, as well as individuals with whom we have a continuous contractual relationship in which we prepare payment records, etc. Such personal information will be acquired, managed, used, and provided in accordance with laws, regulations, and our internal regulations, as well as labor, employment management, welfare, health management, and remuneration payment (including tax).

(1) We use your personal information for the following purposes.

• Arrangement of travel services provided by transportation, accommodation facilities, etc. (as described in the contract document with respect to major
  transportation and accommodation facilities) and procedures for receipt of such services, procedures for payment of travel expenses, and provide of other travel services in the course of travel for which the customer has applied.
• For the supply of other products and services of us or our business partners.
• To respond to customer opinions, requests, inquiries, etc., including inquiries about products or services and preparation of contracts.
• For registration, management, and guidance on various membership programs, etc.
• For after-sales service relating to products or services.
• For the purpose of conducting questionnaires and other activities such as requests for the provision of opinions and impressions.
• To develop, improve or reform products or services (*1)
• For the selection, provision, and operation of privileges, prizes, point programs, etc. of us or our business partners.
• To provide information on or distribute advertisements for products, services, various campaigns, events, and other sales promotion activities of us or our
  business partners (*2)
• For the preparation of statistical materials.
• For the maintenance and operation of products, services,
  networks, systems, etc., and prevention of disabilities, defects, incidents, etc., of products, services, networks, systems, etc., and response in the event of such accidents.
• In order to create an environment in which customers can use products or services safety, such as monitoring, preventing, analyzing, and taking countermeasures on or against illegal, fraudulent or any other improper acts
• For use to the extent permitted by law.
• To provide personal information to a third party in order to achieve each of the above-mentioned purpose of use.

(※1) We will use Cookie, etc. (including web beacons, UIDs, and other technologies, and hereinafter simply referred to as "Cookie, etc.") and, by or through Cookie, etc., we acquire customer purchase history, service provision history, browsing and other behavior history, information on terminals used, network
information (IP addresses, etc.), analyze these as personal information of customers or information related to customers, and use these information to develop, improve, or reform products or services or advertise or promote or provide information on products or services according to induvial interest, preferences, trends, etc.

(※2) We may acquire information related to individuals other than personal information (including purchase history, location information, browsing and other behavior history, terminal information, and network information (IP address, etc.) obtained through Cookie, etc.) from a third party and use such information to develop, improve, or reform products and services with personal information held by us, as well as to advertise or promote or provide information on products or services in accordance with individual interest, preferences, or trends, etc..

(2) We will use personal information obtained from job applicants within the scope necessary for identification, communication with job applicants, and other recruitment purposes.

(3)We will use personal information about our business partners (in the case of corporate business partners, its officers and employees) for business purposes, such as
communication, contract fulfillment, business negotiations and management of our business partners.

(1) We will provide name, ID, gender, age, address, telephone number, e-mail address, passport information, credit card information, information on emergency contacts, and other necessary personal information by electromagnetic means etc., to facilities for transportation, accommodation facilities, service providers, insurance companies, public offices, etc., to the extent necessary for arrangements for the travel services you have applied for and procedures for receipt of such services, to the extent necessary for the procedures for insurance covering our travel contract responsibilities, expenses in the event of an accident, to the extent necessary for providing information
relating to safety or health or contacting a customer for confirmation of its safety, etc.

(2) We may provide personal data of our customers to souvenir stores or other dealers for the convenience of customers' shopping at our travel destinations. In this case, personal data pertaining to the customer's name, passport information, and the flight name to be boarded will be provided by sending in advance by electromagnetic means, etc.

(3) In case of illness or accident during a trip, we may ask for personal information to whom we may contact. This personal information will be used if we acknowledge that in the event of illness or other illness, we need to contact the contact person. The customer shall obtain the contact's consent to provide us with the personal
information of the contact.

(4) To the extent necessary for the arrangement or provision of the various services that you have applied for, we will provide our business partners, service providers, or public offices with personal information such as your name, ID, gender, age, address, telephone number, e-mail address, and other necessary personal information by
electromagnetic means, etc.

(5) To the extent necessary for responding to customer opinions, requests, and inquiries, including inquiries about products or services, or preparing contracts, we will provide the customer's name, ID, gender, age, address, telephone number, e-mail address, credit card information, and other necessary personal information by
electromagnetic means, etc to the transportation/accommodation facility, service provider, other related organizations and corporations, etc.

(6) We will provide customers' names, IDs, genders, ages, addresses, telephone numbers, e-mail addresses, purchase information, etc., by electromagnetic means, etc. to our business partners for various points or other privilege granting programs, various campaigns, prizes, events or other sales promotion activities implemented by us or our business partners or for providing customers with information on these programs or activities.

(7) In order to prevent or respond to the occurrence of any disability, malfunction, or accident relating to products, services, networks, or systems, we will provide the customer's name, ID, gender, age, address, telephone number, e-mail address, and other necessary personal information to the relevant authorities or parties by
electromagnetic means, etc.

(8) We will provide personal data such as your name, gender, age, address, telephone number or e-mail address, passport information, credit card information, and other personal data by electromagnetic means, etc. to the government, public offices, investigative organizations, and business partners to the extent necessary to provide an
environment in which you can use products or services safely, such as monitoring, preventing, analyzing, and taking countermeasures on or against illegal, fraudulent or any other improper acts.

(9) We will provide the customer's personal data by electromagnetic means, etc., with the consent of the customer or to the extent permitted by law.

We may entrust all or part of the business including handling personal information of customers to a third party for the purpose of arranging travel, managing travel, travel attendance services, intermediary services at airports, travel services such as payment of travel expenses, and other our services, and for the purpose of use as
described in 2 above or for our businesses. In this case, we will select the such third party based on our standards and entrust the personal information after entering into an agreement including confidentiality.

8. Notification of matters regarding held personal data

9.  Handling of Specific Personal Information

10. Amendment of these Regulations