Handling of Personal Information
Sun Frontier Hotel Management K.K. (here in after referred to as “the Company”) has established the following policies regarding the protection of personal information in order to responsibly protect the personal information of our customers, and will establish an internal system, implement and maintain measures, and continuously improve these measures. Through these activities, we will comply with laws, regulations, and internal rules related to personal information, and live up to the trust of our customers.

1. Compliance with laws and regulations regarding personal information

We will comply with laws and regulations regarding the protection of personal information, and will handle the personal information of our customers and business partners in an appropriate manner.

2. Method of obtaining personal information

When acquiring personal information from customers, we will clearly state the purpose and scope of use of the information, and acquire personal information to the extent necessary through legal and fair means.
In addition, the Company will acquire personal information through the following methods when conducting transactions related to the facilities operated by the Company and the services provided by the Company.
Direct acquisition of personal information from the person in question, such as by telephone, in writing, on business cards, orally, or via the Internet.
Obtaining personal information from a person who has been authorized by the person, such as an applicant for use, an introducer, or a travel agent.

3. Types of personal information

Personal information obtained by the Company includes the name, place of work, home or business address, e-mail address, telephone number, fax number, date of birth, and gender of the person, as well as information to respond to requests regarding rooms, services, etc., and information regarding pre-stay and post-stay locations as required by laws, ordinances, etc.

4. Refusal to provide personal information

If you do not provide your name or otherwise refuse to provide your personal information to us, we may not be able to accept your reservation or provide certain services.

5. Purpose of use of personal information

We will use your personal information only within the scope of the purpose of use, and will not use your personal information for any other purpose or beyond the scope of the purpose.
We will not use personal information for purposes other than those listed below.

• To make reservations and use the facilities operated by the Company, such as hotels and restaurants.
• To provide information on products and services and to respond to orders.
• For statistical aggregation and analysis for the purpose of marketing and service improvement
• To provide various types of information and services regarding membership in the Company’s various membership organizations, etc.
• To provide various types of information and services regarding the above items at other facilities operated by the Company as well.
• To provide better services in response to customer requests, etc.
• To conduct necessary surveys and research, analyze information, and perform other necessary tasks in the operation of the facilities operated by the Company.
• To provide personal information to third parties to the extent necessary to achieve the purposes of use listed in the preceding items.

6. Use of Cookies

“Cookies” are a standard Internet technology that identifies a customer’s computer. The Company may use the information about the pages viewed by the customer, which is collected using cookies, in combination with information that identifies the individual customer, as the customer’s information. This information will be used within the scope described in the “Purpose of Use of Personal Information” section. Depending on the browser you are using, you may be able to change your browser settings to disable the cookie function, but as a result, you may not be able to use all or part of the services on the website.

7. Restriction on Provision to Third Parties and Shared Use

We will not provide or disclose your personal information to any third party without your consent, except in the following cases In accordance with laws and regulations.

• When cooperating with administrative authorities due to special circumstances
• When the Company outsources the handling of personal information to a subcontractor within the scope of legitimate use.
• In addition, the Company will share the personal information it receives for the purpose of providing services closely related to the hotel and the hotel, providing information such as materials and questionnaires, product development, and other related activities.

The scope of those who will be jointly used is only our parent company, Sun Frontier Real Estate K.K., and our group subsidiaries. We will not share the above types of personal information with other businesses beyond the scope of the above purposes of use.
In the event that we provide or share all or part of the personal information entrusted to us with a third party other than those listed above, we will give due consideration to the selection of the party to which we provide or share the information, and request the third party to manage the information appropriately in accordance with the laws and regulations as we do.

8. Supervision of contractors, etc.

When the Group uses customers’ personal information, the Group may entrust personal information to a third party within the scope of legitimate use.
The Group will oblige the third party to manage the personal information strictly at the same level as the Company, and will supervise the third party in a necessary and appropriate manner, and will enter into an agreement with the third party to manage and supervise the confidentiality of the personal information.

9. Safety management of personal information

We will ensure that the personal information of our customers and business partners is accurate, up-to-date, and secure. We will also strictly manage the personal information of our customers and strive to take precautions and safety measures against unauthorized access, loss, destruction, falsification, leakage, etc.

10. Disclosure, correction, suspension of use, and deletion of personal information

We will manage the personal information we have acquired in the most accurate and up-to-date manner possible. Upon request from the person in question, we will take appropriate measures such as disclosure, correction, deletion, and suspension of use in accordance with laws and regulations after confirming the person’s identity.
For these requests, please contact us at the following address. We will guide you through the necessary procedures after you fill out the request form designated by us.

Contact for Personal Information
Name: Sun Frontier Hotel Management K.K.
Address: Toho Hibiya Building 8F, 1-2-2 Yurakucho, Chiyoda-ku, Tokyo 100-0006, Japan
Contact: Phone: 03-6858-5280
Office hours: 9:00 a.m. to 5:00 p.m. (Closed on Saturdays, Sundays, national holidays, and year-end and New Year holidays)

11. Revision and disclosure of this policy

This policy is subject to revision in order to respond to amendments and changes in related laws and regulations, as well as to social needs regarding personal information. In such cases, the Company will publish this policy on this website without delay, and will clearly indicate the date of the last revision of this policy.

12. Contact for inquiries

If you have any questions regarding our company’s personal information, please contact the “Personal Information Inquiry Desk”.

Sun Frontier Hotel Management K.K.
Executive Director Kazuyuki Yanagimura
Enacted: November 18, 2015