1. Basic policy

Hotel Granvia Osaka Co., Ltd (hereinafter referred to as “The Company”) has established this privacy policy and organizational system for the handling of the personal information of all stakeholders (customers, job applicants, external business partners of The Company, etc.) who are related to the business of The Company or use the corporate website of The Company (hereinafter referred to as “The Website”) and strives for the appropriate protection of personal information.

(1) Acquisition of personal information

The Company may acquire the following personal information for the purpose of providing the services and business operations of The Company. The Company acquires personal information within the scope of its intended purposes of use and clearly explains the purposes of use, scope of utilization, and inquiries office of The Company, etc.

(2) Prohibition on the use of personal information beyond the intended purposes and the provision of personal information to third parties

The Company uses personal information within the scope of its intended purposes of use, appoints a Personal Information Protection Manager, and has established the organizational system for the protection of personal information. The Company deals with personal information adequately and does not provide or disclose personal information to third parties without the consent of Persons Concerned or request by laws and regulations.

(3) Assigning of personal information

If The Company entrusts all or part of personal information to a person, The Company prohibits such entrusted persons from leaking or providing personal information to third parties by contract and supervises such entrusted persons appropriately.

(4) The rights of Persons Concerned

The specific individuals identified by personal information (hereinafter referred to as “Person(s) Concerned”) have the right to withdraw their consent to the use of their personal information at any time even if they had previously consented to the intended purposes. In addition, Persons Concerned have the right to request that The Company ceases utilization of, discloses, etc. the retained personal information pursuant to the provisions of applicable laws and regulations.

(5) Procedures for requesting cessation of utilization, disclosure, etc. of personal information

In case that Persons Concerned request that The Company ceases utilization of, discloses, etc. the retained personal information, they shall contact the inquiries office specified by The Company. The Company shall respond as soon as reasonably possible.

(6) Observance of laws and regulations

The Company observes applicable laws, regulations and standards, provides in-house education, informs employees of this privacy policy, and strives for the improvement of understandings of employees on the handling of the retained personal information.

(7) Maintenance and improvement of the system for the protection of personal information

The Company will continuously evaluate and review this privacy policy and the systems for the protection of personal information. The Company will maintain and improve the actions for the protection of the retained personal information.

(8) Handling personal information by link destinations

The Company shall bear no responsibility with regard to the handling of personal information by other entities or individuals linked to The Website.

(9) Management of personal information

• If any part of the acquired personal information is to be managed in the database of an overseas third party service provider contracting with The Members’ Organization, The Members’ Organization shall take security management measures based on the understanding of the relevant country’s systems for personal information protection.
• The Company shall define the retention period for personal information within the scope of its intended purposes of use, and after the retention period, delete the relevant personal information without delay, unless otherwise required by laws and regulations.

2. Definition of personal information

The term “personal information” in this privacy policy means information related to a living individual that can identify a specific individual by name, date of birth, or other description contained therein. (This includes “personal information” as defined by Article 2(1) of the Act on the Protection of Personal Information.)

3. Acquisition and purposes of use of personal information

The Company acquires and uses the following personal information for the following intended purposes. The Company does not use personal information beyond the scope of the intended purposes of use without the consent of the Persons Concerned.

(1) Personal information of customers

1 Personal information acquired

Name, age, gender, date of birth, occupation, address, telephone number, email address, nationality, passport number, and other information necessary for the following purposes of use.

2 Purposes of use

<1> For performing work required to provide services and products in The Company business (accommodation, restaurants, shops, banquets, wedding receptions, catering, etc.).

<2> For providing services and products such as on-line booking reservations and sales, and other related businesses.

<3> For handling inquiries and requests, etc.

<4> For providing necessary information on the products, services, events, and other related business activities of The Company.

<5> For providing information on the products, services, and events of The Company to the customers who have consented to sending by direct mail, email, LINE, etc.

<6> For offering prizes or campaigns.

<7> For grasping and analyzing state of usage of the products, services, and events of The Company to improve their quality.

<8> For exercising rights and performing duties based on laws and regulations and the provisions of terms and conditions for accommodation.

<9> For other purposes of use indicated at the time of acquisition of personal information.

(2) Personal information of job applicants

1 Personal information acquired

Name, age, gender, date of birth, address, telephone number, email address, and other information necessary for the following purposes of use.

2 Purposes of use

<1> For performing work required for recruitment activities, the procedures and contracts of employment, and other required work.

<2> For handling inquiries and requests, etc.

<3> For other purposes of use indicated at the time of acquisition of personal information.

(3) Personal information of external business partners of The Company

1 Personal information acquired

Business card information and other information regarding external business partners of The Company necessary for the following purposes of use.

2 Purposes of use

<1> For concluding and performing contracts with external business partners of The Company and other required work.

<2> For handling inquiries and requests, etc.

<3> For other purposes of use indicated at the time of acquisition of personal information.

(4) Personal information of members of the JR Hotel Members organization.

1 Personal information acquired

Member number, password, name, age, gender, date of birth, address, telephone number, email address, employer information, history of providing and use of points, and other information necessary for the following purposes of use.

2 Purposes of use

<1> For performing work required within the scope of the purposes of use set forth in 3 (1) 2 of this privacy policy.

<2> For performing work required for the operation of the JR Hotel Members organization (hereinafter referred to as “The Members’ Organization”) by The Company.

<3> For providing important information such as changes to the Membership Agreement, Terms of Service, or benefits of The Members’ Organization.

<4> For other purposes of use indicated at the time of acquisition of personal information.

3 Other agreements of The Members’ Organization

Membership Agreement of the JR Hotel Members Organization
Terms of Service of the JR Hotel Members Organization

4. Handling of personal information and safety protection

(1) We assign a manager on each business that handles personal information.

(2) We take security measures to prevent unauthorized access to personal information, loss, destruction, falsification, or leakage of personal information.

(3) We establish rules and manuals regarding the handling of personal information, then widely disseminate them throughout the company and group companies, and provide guidance and supervision.

(4) We will properly select the outsourcing company and provide guidance and supervision to conduct appropriate management in the same way as we do in our company, when we outsource the processing of personal information to a third party.

(5) Physical security management measures

• We take access control measures in areas where personal data is handled.
• We take measures to prevent theft or loss of devices, electronic media, documents, etc. used to handle or that may contain personal data, as well as measures to prevent the relevant individual from being identified easily from the personal data contained therein in case such devices, electronic media, etc. are carried around within or outside an office.

(6) Technical security management measures

• We take access control measures to limit the scope of the persons handling personal information and the personal information database to be handled.
• We have introduced systems to protect information systems for handling personal data from external unauthorized access or illegal software, as well as measures against information leakage etc. that are necessary for communication containing personal data.

5. Sharing of personal information

The Company may share personal information within the scope of its intended purposes of use as follows. When users of personal information to be shared with have established policies for personal information, their policies shall be applied for their use.

(1) Sharing of personal information related to The Company business (accommodation, restaurants, shops, banquets, wedding receptions, catering, etc.)

1 Scope of sharing users

• Member companies of The Members’ Organization ^(*1), the JR Hotel Group ^(*2), and JR-West Hotels ^(*3).
  *1 Shown in Article 1 of the Terms of Service of the JR Hotel Members Organization
  *2 Including JR Hokkaido Hotels Co., Ltd., JR Shikoku Hotels Co., Ltd., and JR Kyushu Huis Ten Bosch Hotel Co., Ltd., in addition to *1
  *3 Included in *1
• JR West Via Inn Co., Ltd.

2 Purposes of sharing use

For providing services and products of The Company business (accommodation, restaurants, shops, banquets, wedding receptions, catering, etc.), services and products such as on-line booking reservations and sales, and other related businesses.

3 Categories of sharing Information

Member number, password, name, age, gender, date of birth, address, telephone number, email address, employer information, history of providing and use of points, and other information necessary for the above purposes of sharing use.

4 Name of person responsible

Hotel Granvia Osaka Co., Ltd

(2) Sharing use of personal information related to the provision of services and products in all tenant shops in the hotels that The Company operates

1 Scope of sharing users

All tenant shops in the hotels that The Company operates.

2 Purposes of sharing use

For providing services and products of The Company business (accommodation, restaurants, shops, banquets, wedding receptions, etc. ) and other related businesses.

3 Categories of sharing information

Name, age, gender, date of birth, address, telephone number, email address, and other information necessary in the scope of above purposes of sharing use.

4 Name of person responsible

Hotel Granvia Osaka Co., Ltd

6. Provision of personal information to third parties

The Company does not provide personal information to third parties without obtaining the consent of the Persons Concerned in advance, except in cases set forth in the following categories.

(1) Cases where The Company provides personal information to third parties

1 Cases where disclosure or provision is requested based on laws and regulations

2 Cases where there is a need to protect a human life, body, or fortune, and when it is difficult to obtain the consent of the Persons Concerned

3 Cases where there is a special need to enhance public hygiene or promote fostering healthy children, and when it is difficult to obtain the consent of the Persons Concerned

4 Cases where there is a need to cooperate in regard to a central government organization or a local government, or a person entrusted by them performing public affairs, and when there is a possibility that obtaining the consent of the Persons Concerned would interfere with the performance of the said public affairs

5 Cases where disclosure or provision to a third party has been requested clearly by the Persons Concerned

(2) Disclaimer regarding provision to third parties

In the following cases, The Company will bear no responsibility whatsoever with regard to the acquisition of personal information by third parties.

1 Cases where personal information is disclosed to an accommodation facility by Persons Concerned (if a Person Concerned discloses personal information of companions at the time of reservation, it is assumed that the consent of those companions is obtained at the responsibility of the Person Concerned)

2 Cases where personal information is disclosed to third parties by Persons Concerned

3 Cases where personal information is provided to or used on external websites linked to The Website by Persons Concerned

4 Cases where third parties obtain information that could identify an individual (password, etc.) for reasons not attributable to The Company

(3) Appropriate management and supervision over entrusted persons

If The Company entrusts the handling of personal information to third parties within the scope of intended purposes of use, The Company shall take appropriate consideration for the selection of entrusted persons, conclude a non-disclosure contract with them, guide them in the proper management of personal information, and exercise appropriate supervision over them.

7. Transfer of personal information outside of the European Economic Area (EEA)

The Company may transfer the personal information of Persons Concerned who reside in the European Economic Area (EEA) to the areas outside of the EEA and use it within the scope of the intended purposes of use. In these cases, The Company shall appropriately and strictly handle the personal information under applicable laws and regulations.
Please see below for the handling of the personal data of persons who are in the EEA.
“Privacy Policy on the Handling of the Personal Data of Persons Who are in the EEA”

8. Rights of Persons Concerned

Persons Concerned have the right to demand actions such as the notification of the purposes of use, disclosure, correction, deletion, cessation of utilization, or ceasing of provision to third parties (hereinafter referred to as ” Cessation of utilization, Disclosure, etc.”) of the retained personal information pursuant to the provisions of applicable laws and regulations. Persons Concerned have the right to withdraw their consent to the use of personal information at any time, even if they had previously consented to the intended purposes.

9. Procedures of Cessation of Utilization, Disclosure, etc.

In case that Persons Concerned request to The Company for Cessation of utilization, Disclosure, etc., The Company shall respect the will of the Persons Concerned, confirm the identification of the Person Concerned, and respond within a reasonable period pursuant to the provisions of applicable laws and regulations.

However, The Company may refuse said request:

• where there is a possibility of violating laws or regulations,
• where there is a possibility of harming a third party’s life, body, fortune, or other rights and interests,
• where there is a possibility of significantly interfering with The Company implementing its business,
• where the said personal information does not exist,
• where The Company cannot confirm the identification of the Persons Concerned,
• or where the Persons Concerned do not pay the prescribed fee.

When Persons Concerned request Utilization cease, Disclosure, etc., please contact the personal information inquiries office below.

(1) Personal information inquiries office

(2) Purpose of use of personal information acquired due to requests for Cessation of utilization, Disclosure, etc.

The Company will use personal information acquired through requests for Cessation of utilization, Disclosure, etc. within the scope of purposes required for the procedures for Cessation of utilization, Disclosure, etc. The Company will appropriately dispose of the documents submitted in the procedures for Cessation of utilization, Disclosure, etc.

10. Protection of the personal information of minors

The Company handles the personal information of minors appropriately in accordance with this privacy policy. When a Persons Concerned is a minor, The Company may require the consent of persons in parental authority to acquire the personal information. If a Person Concerned is less than 13 years of age, The Company shall require the consent of persons in parental authority and give special consideration to the handling of their personal information.

11. Use of cookies

The Website may use cookies to improve the information and services provided and to offer comfortable use of The Website.
For details, please refer to the Cookie policy of The Website.

12. Acquisition of access logs

The Website may acquire access logs to improve the use of The Website and to generate statistical data. The Company does not disclose access logs to third parties unless otherwise required by laws and regulations. If you refuse to send access logs, The Website may not function properly.

13. Revision of this privacy policy

The Company will revise and improve this privacy policy to respond to changes in related laws, regulations, the social environment, etc. The Company will post the revised privacy policy on The Website.

14. Personal information inquiries office

Please contact the personal information inquiries office below when you have any inquiries about this privacy policy.

Updated: December 21, 2022