Privacy Policy

1. 1.
   We will establish company rules governing privacy in order to enact this declaration. We will educate our entire staff, including directors, regular employees, temporary employees, as well as other concerned parties, concerning the details and enforcement of these rules and regulations and request their compliance.
2. 2.
   We will establish company regulations for the secure administration of personal data in order to avoid loss, damage, tampering and theft of personal data. We will also set up necessary security systems to prevent illegal access and any possible invasion by computer viruses.
3. 3.
   Our fundamental principles governing privacy protection are as follows.

   1. （1）
      Personal data must be collected through honest, legally sound procedures; unauthorized data collection is prohibited.
   2. （2）
      Personal data shall be used exclusively within the limits of the prescribed purposes. Usage for any other purpose is prohibited. Personal data must be handled under security sensitive procedures. Output/input, storage, transportation or transmission shall not be permitted under any circumstances when such security cannot be guaranteed.
   3. （3）
      Providing any personal data to a third party outside the exact prescribed specifications of the laws, and without consent from the subject individual of the data is prohibited. When the handling of personal data is delegated to a third party for business-related purposes, or that personal data is to be shared with a third party, a contract with the third party concerned will be put into effect to assure compliance with all legal procedures.
   4. （4）
      We acknowledge that an individual has the right to access, correct or discontinue our usage of their personal data or other rights stipulated in each applicable jurisdictional law. We will comply with any such request in full accordance with the laws and regulations.
   5. （5）
      We acknowledge that an individual has the right to access, correct or discontinue our usage of his personal information or other rights stipulated in each applicable jurisdictional law. We will comply with any such request in full accordance with the laws and regulations.

1. 1.
   Formulation of Privacy Policy
   In order to ensure the proper processing of personal data, we have formulated this Privacy Policy, which covers compliance with relevant laws and guidelines, as well as contact points for inquiries and complaints.
2. 2.
   Establishing Rules for Processing Personal Data
   We have established rules for the protection of personal data that specify how personal data is processed, who is responsible and what their duties are, etc. for each stage of the process, including collection, use, storage, disclosure, deletion, and disposal.
3. 3.
   Organizational Security Control Measures
   In addition to appointing a person in charge of handling personal data, we have clearly defined the scope of personal data handled by employees and the employees who handle such data, and have established a reporting and communication system for the person in charge in the event that any fact or indication of a violation of the laws or personal data protection regulations is identified. In addition, we regularly conduct self-inspections of the status regarding the status of handling personal data, and also conduct audits by other departments, etc.
4. 4.
   Personal Security Control Measures
   We have included matters relating to the confidentiality of personal data in our employment rules, and regularly train our employees on the points to consider when handling personal data.
5. 5.
   Physical Security Control Measures
   In the areas where personal data is handled, we implement measures to prevent unauthorized persons from viewing personal data, and to control the entry and exit of employees and restrict the equipment they can bring into the area. We also take measures to prevent the theft or loss of equipment, electronic media, documents, or other items used to handle personal data. In addition, we have taken measures to prevent personal data from being readily identifiable when carrying such items, including in the office.
6. 6.
   Technical Security Control Measures
   By implementing access control, we establish the system to limit the scope of personnel in charge and the personal data database they can access, while protecting the information system that handles personal data from unauthorized access from outside or unauthorized software.
7. 7.
   Understanding the External Environment
   With respect to the countries in which our trustees who are our subsidiaries (Singapore and New York, USA) and partners (Hawaii, USA) are located, we implement security management measures to identify and understand the systems in place for the protection of personal data in those countries.

• （1）
  Member ID;
• （2）
  Name;
• （3）
  Email address;
• （4）
  Postal code;
• （5）
  Address;
• （6）
  Phone number;
• （7）
  FAX number;
• （8）
  Passport number;
• （9）
  Gender;
• （10）
  Age;
• （11）
  Date of birth;
• （12）
  Marital status (married/unmarried);
• （13）
  Wedding anniversary date;
• （14）
  Allergy and food preference information;
• （15）
  Accommodation service informatio n (accommodation booking number, plan name, room type, accommodation period, number of guests, arrival date and time, payment method, booking channel, hotel booked, price, check-in date and time, check-out date and time, restaurant usage status, hotel shop usage status, and newsletter subscription status, etc.)
• （16）
  The display language of email newsletters, the opening status of email newsletters, and the history of vouchers checked, etc.;
• （17）
  Device identifier, and browsing history, etc.;
• （18）
  Inquiry details, guest room order details, and survey response details;
• （19）
  Workplace, workplace address, and job title;
• （20）
  Email address (member ID) and password combination, and nationality;
• （21）
  Usage information for food and beverage services, weddings, banquets and fitness center (order information, upcoming visits, past visit information, total amount spent, average amount spent, previous amount spent, banquet cuisine menu, locker number, reason for joining, shoe storage number, etc.) and for merchandising sales (order information, upcoming visits, past visit information, total amount spent, average amount spent, previous amount spent, etc.);
• （22）
  Information listed in (1) to (6) above regarding the marriage partner and family members;
• （23）
  Name of matchmaker and guests invited to the wedding or banquet;
• （24）
  Name of the referrer of the wedding, banquet or fitness service;
• （25）
  Blood type and shoe size;
• （26）
  Pregnancy status; and
• （27）
  Bank account information and credit card number.

1. 1. The items of the personal data to be jointly used
   Member ID, name, email address, postal code, address, phone number, fax number, passport number, gender, age, date of birth, marital status (married/unmarried), wedding anniversary date, allergy information, accommodation service information, inquiry details, workplace, workplace address, job title, nationality, etc.
2. 2. Scope of the joint users
   1. （1）
      Imperial Hotel America, Ltd.
      1251 Avenue of the Americas, Suite 2375 New York, NY 100
      President Akihiko Iwashita
   2. （2）
      Imperial Hotel Asia Pte. Ltd.
      80 Robinson Road #10-01A Singapore 068898
      Managing Director Akihiko Iwashita
3. 3.
   The purpose of use by the joint users
   For the provision of our services and marketing activities.
4. 4.
   The name of the person responsible for the management of the personal data
   Imperial Hotel, Ltd.
   1-1, UCHISAIWAI-CHO 1-CHOME, CHIYODA-KU
   TOKYO 100-8558, JAPAN
   President and Representative Director Jun Kazama

1. 1.
   To protect personal data, we implement reasonable security measures at both the administrative/operational and system levels to prevent unauthorized access, loss, destruction, alteration, and leakage.
2. 2.
   On our website, we use SSL (Secure Sockets Layer) encryption to securely transmit and receive personal data between our customers and us via the Internet.
3. 3.
   We collect information through “cookies” (a technology that stores browsing history and other data exchanged over the Internet in the customer's browser) and access logs to our website. This data is used solely for statistical processing to improve the operation and services of our website and to investigate the cause of unauthorized access. If you prefer not to to accept cookies, you can disable them by adjusting your Internet browser settings.

• ※
  If you are a representative of one of our business partners, please contact the relevant department of our company.
• ※
  Please contact the respective department for details on the procedures for requesting disclosure (including required documents, submission methods, identification verification, etc.). Please note that a fee of 500 yen (including tax) will be charged for per disclosure request.

Imperial Hotel, Ltd. (hereinafter referred to as the "Hotel") hereby establishes the following policy upon the establishment and utilization, whether permanent or temporary, of the Hotel's official account (hereinafter referred to as the "Official Account") for social media (meaning media where any user is free to transmit and display information via the Internet, with typical examples of social media being Facebook, Twitter, and YouTube) .
In addition, the provisions of this policy shall be applicable to all users of the Hotel's Official Account and any incidental services thereto (hereinafter referred to as the "Users") :

The Hotel's purpose in utilizing social media is to share information with customers and to increlase the Hotel's business activities by transmitting information related to any sales promotions conducted by the Hotel, along with any information concerning other related activities of the Hotel.

Any contents transmitted by the Hotel on the Official Account shall be limited to general information pertaining to sales promotions and any information related to any such promotion, such as information pertaining to any products, services, events, and promotions relating to the Hotel, Hotel history, as well as any information concerning regional and seasonal events as relevant to the Hotel. Formal announcements, such as company information and financial information, shall be displayed on the Hotel's home page or other similar medium.

Neither the Hotel nor the Users shall transmit on the Official Account any information or content described below, and the Hotel shall actively delete, at its sole discretion, any information or contents promulgated by any User that falls into any of the below categories.

Any dispute arising with respect to the utilization of social media shall be subject to the exclusive jurisdiction of the Tokyo District Court as the court of first instance.

Contact details regarding the Hotel's utilization of social media and its Official Account:

Responsible Officer of the homepage
Imperial Hotel, Ltd.
1-1, UCHISAIWAI-CHO 1-CHOME, CHIYODA-KU,
TOKYO 100-8558