PRIVACY
POLICY

This English version is provided for reference only. In the event of any discrepancy, the Japanese version shall prevail.

Green Hospitality Management Co., Ltd. (hereinafter referred to as "the Company") and the Company's group companies that operate the hotels listed at the end of this document (hereinafter collectively referred to as "the Hotels") (hereinafter collectively referred to as "we" or "us") are committed to complying with laws and other standards relating to the protection of personal information, and to properly managing and protecting personal information in connection with the provision of services at the Hotels (hereinafter referred to as "the Services").

Furthermore, "Customers, etc." refers to guests, persons making reservations, website users, and others who use the services of this Hotel.

1 . Acquisition of Personal Information

The Company will clearly state the purpose of use and acquire personal information by appropriate means within the scope necessary to achieve that purpose.
In addition to receiving personal information directly from Customers, etc., the Company may receive personal information of Customers, etc., who have given their consent, from companies such as travel agencies that have concluded contracts with the Company.

2 . Purpose of Use of Personal Information

Information acquired from Customers, etc. will be used for the following purposes.

1. To accept registrations, conduct screenings, and perform identity verification/authentication related to this Service
2. For the operation of member organizations (membership/withdrawal procedures, management of member information, provision of member services and point services, etc.)
3. To provide this Service, products, and information to Customers, etc.
4. To contact Customers, etc. for reservation confirmation, etc.
5. To provide information to Customers, etc. regarding the services and products of the Company and the Company's group companies via email, direct mail, or other methods
6. To perform analysis for the improvement and enhancement of service and product quality
7. To conduct sales guidance and surveys related to the Company's business
8. For the shipment of prizes associated with surveys, etc.
9. To request compliance with the terms and conditions of use of the Company's website
10. To ensure the safety of customers using the Company's website and the Company's services
11. For other purposes of use clearly stated at the time of personal information acquisition

3 . Joint Use

The Companies may jointly use held personal information within the scope of the above purposes of use.
Personal information to be jointly used will be managed responsibly by the personal information protection managers of the Companies.

1. Items of Personal Information to be Jointly Used
   Address, name, company name, phone number, email address, and other information provided by customers when using this Service
2. Scope of Joint Users
   Green House Co., Ltd. and its group companies (Please refer to the [List of Hotel Business Group Companies] for group companies.)
3. Purpose of Use
   Within the scope of the purposes of use described in "2. Purpose of Use of Personal Information" above
4. Person Responsible for Management of Personal Information
   Green Hospitality Management Co., Ltd.
   3-20-2 Nishi-Shinjuku, Shinjuku-ku, Tokyo Representative Director: Jun Ochiai

4 . Disclosure and Provision of Personal Information to Third Parties

The Company will not disclose or provide your personal information to third parties except in any of the following cases.
Furthermore, cases of joint use, business succession, and provision to contractors do not constitute disclosure or provision to third parties.

① When the customer has given consent
② When disclosure or provision is required by law
③ When necessary to protect a person's life, body, or property, and obtaining the customer's consent is difficult
④ When particularly necessary for improving public health or promoting the sound development of children, and obtaining the customer's consent is difficult
⑤ When it is necessary to cooperate with a national agency, local government, or an entity entrusted by them in executing affairs prescribed by law, and obtaining the customer's consent could impede the execution of such affairs

5 . Outsourcing of Operations

The Company may provide personal information to contractors (including companies, organizations, and sole proprietors with whom the Company has a partnership or contractual relationship necessary for providing this Service; the same shall apply hereinafter) within the scope necessary to achieve the purpose of use. In such cases, we will exercise appropriate supervision, including the conclusion of contracts regarding the handling of such information with these contractors.

6 . Handling of Personal Information

For the safety of personal information, we take reasonable security measures from both management/operational and systemic perspectives to prevent unauthorized access, loss, destruction, falsification, and leakage.
The transmission of personal information between customers and the Hotel's website via the Internet employs SSL (Secure Sockets Layer) encrypted communication.
As part of information collection on the Hotel's website, we collect access records (access logs) to the Hotel, but these will not be used for purposes other than statistical processing related to the operation of the Hotel's website and investigation of causes such as unauthorized access.

7 . Handling of Cookies

The Company's official website may use cookies and similar technologies (pixel tags, local storage, etc.) for the purpose of providing optimal services to customers, improving website convenience, analyzing access status, and optimizing advertisement delivery. Customers can restrict or refuse the receipt of cookies through their browser settings; however, in such cases, some functions of the Company's official website may not be available.

The Company uses services provided by the following third parties, and in the process, browsing information and other data may be transmitted to said third parties through cookies and other identifiers.

・Google Analytics (Provider: Google LLC): Analysis of website usage status
For the handling of data in Google Analytics, please refer to the company's site.
"How Google uses information from sites or apps that use our services"
https://www.google.com/intl/en/policies/privacy/partners/

8 . Provision to Third Parties in Foreign Countries

The Company may provide your personal information to a third party in a foreign country only in the following cases. In such cases, we will take measures in accordance with Article 28 of the Act on the Protection of Personal Information and other laws and regulations.

・When operators of cloud services, PMS/reservation management systems, CRM, email delivery services, etc., used by the Company are located outside Japan
・When it is necessary to share reservation information with overseas group facilities or jointly operated facilities
・When necessary for transactions with overseas travel agencies, OTAs, payment service providers, etc.

When providing personal information to a third party in a foreign country, we will, in principle, provide information regarding the personal information protection system in that country and the measures taken by said third party when obtaining the individual's consent. However, this shall not apply in any of the following cases.

・When the country of the recipient is designated by the Personal Information Protection Commission as having a protection system equivalent to that of Japan (currently EU member states and the UK)
・When the third party recipient has established a system that conforms to the standards set by the Personal Information Protection Commission rules
・When based on laws and regulations or otherwise falling under any of the items of Article 27, Paragraph 1 of the Act on the Protection of Personal Information

9 . Personal Information on Linked Sites

To provide our guests with more useful information and services, this hotel website may include links to websites operated by other companies or organizations.
Please note that we assume no responsibility for the collection or handling of personal information on any linked third-party websites.

10 . Disclosure, Correction, Deletion, Suspension of Use, Erasure, etc.

When a request for disclosure (including records of provision to third parties), correction, deletion, addition, suspension of use, erasure, etc., is received from the customer themselves regarding personal data held by the Company in the prescribed manner, we will respond within a reasonable period and within the scope prescribed by laws and regulations after confirming that the requester is the individual in question.
However, we may refuse all or part of the request if there is a risk of harming the life, health, or property of the individual or a third party, if it would significantly hinder the implementation of the Hotel's business, or if it would violate other laws and regulations.

11 . Contact Office

For the above requests under item 10 regarding your personal data we hold, as well as other inquiries about personal information, please contact the following desk.

Green Hospitality Management Co., Ltd.
"Personal Information Complaints and Consultation Desk"
19F Tokyo Opera City Tower, 3-20-2 Nishi-Shinjuku, Shinjuku-ku, Tokyo
163-1419
TEL: 03-3379-1193

12 . Changes to Privacy Policy

The Company will appropriately review the operations regarding the handling of information entrusted by Customers, etc., and may change this policy as necessary.
In the event of a change, the revised policy will be published on this website.
The revised privacy policy shall take effect from the time it is posted on this website.

Applicable Hotels: Hotel GrandBach Tokyo Ginza, Hotel GrandBach Kyoto Select, Hotel GrandBach Atami Crescendo, Hotel GrandBach Sendai