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Handling of Personal Information

Handling of Personal Information

Handling of personal information

Mitsui Fudosan Resort Management Co., Ltd. (hereinafter "the Company") is a member of the Mitsui Fudosan Group. In addition to the resort business, the Mitsui Fudosan Group engages in various other businesses, including the hotel business, the housing and living-related business, the commercial facilities business, the office buildings business, and the logistics business (for details, please refer to the website of Mitsui Fudosan ）.
For the Company's personal information protection policy, please see below.

Personal information protection policy

Purposes of use

The Company and its group companies (which refers to and hereinafter refers to Mitsui Fudosan Co., Ltd. and the consolidated subsidiaries listed in the Annual Securities Report, etc. of Mitsui Fudosan Co., Ltd. (including Halekurani Corporation) will use shared personal information to the extent necessary to achieve the following purposes of use.

1. To provide products and services related to our business

Examples of our business are

- hotel management and administration
- management and administration of restaurants and bars
- management and administration of spas
- management of special public bath houses
- the sale of alcoholic beverages, tobacco, revenue stamps, and postage stamps
- the sale of medical supplies, foodstuffs, furniture and appliances, household goods and sundries, newspapers and magazines
- real estate transactions, leasing, and management
- the sale of alcoholic beverages, tobacco, revenue stamps, and postage stamps
- the sale of souvenirs, foodstuffs, furniture and appliances, household goods and sundries, newspapers and magazines, and acting as agents for such sales
- dealing in secondhand goods or antiques, and the sale of arts and crafts
- marine transportation
- management of vessels, boat rental and repair
- car rental business, and car park management
- travel business and travel agency
- general passenger motor vehicle transport business
- real estate leasing and management
- all other businesses incidental to the preceding items.

Examples of purposes of use may include the following

- accommodation reservations and stay management (including reservations and applications for activities such as golf and skiing; reservations and applications for relaxation such as spas and massages)
- ordering, shipping, and payment management for products, and delivery of billing materials
- sales activities by mail, e-mail, telephone, etc.
- to manage membership information in the membership organizations operated by the Company
- to provide services for members
- to contact customers by mail, email, telephone, etc., and to respond to inquiries in relation to transactions with customers and the provision of services to members
- to provide security, emergency response, or fraud countermeasures.

2.To introduce products and services* handled by the Company and its group companies and to provide various types of information and special offers in relation to clothing, food, housing, recreation, and work of customers.

Examples include the following purposes of use

- to provide information on various seminars, campaigns, and events*
- to deliver behavioral targeted advertising* (an advertising method that analyzes information such as acquired web browsing history and service usage history to estimate customer attributes and interests, and adjust the content of advertisements) using an ad-serving company
- to provide discounts or other benefits when using vouchers and services
* These include services based on the analysis of transaction history and other information obtained by the Company or its group companies to estimate customer attributes, interests, etc.
letter or postcard etc., mail magazine, or direct mail.

3.To develop and improve products and services handled by the Company and its group companies in relation to clothing, food, housing, recreation, and work of customers, and additionally to conduct marketing activities, surveys, and analyses, such as market research, in order to provide better products and services to our customers.

Examples include the following purposes of use

- development and improvement of products and services
- conducting questionnaires
- customer trend analysis
- verifying effectiveness of sales promotion activities and formulating sales promotion plans.

4.To provide information to third parties in order to achieve the Purposes of use 1 through 3 above.

Acquisition of information related to individuals

The Company uses data collected by cookies, or advertising IDs (smartphone device identifiers), etc. (hereinafter referred to as "cookies, etc.") from third-party data service providers to obtain web browsing and usage history as well as the results of analysis, which are then linked to each customer’s personal data and used for advertising distribution and other purposes.
In addition, the Company uses data collected by cookies, etc. to obtain web browsing or usage history as well as the results of analysis thereof from the Company's group companies, which are then linked to each customer’s personal data, and used to the extent necessary to achieve the purposes of use described in 1 through 3 in the above "Purposes of use".

Provision to Third Parties

1. In addition to cases in which the Company is required by law, the Company will provide personal data of customers to third parties, such as the Company's group companies, tenants and subcontractors of the Company's hotels, as well as providers of point exchange items (gifts) to the extent necessary to achieve the purposes of use described in "Purposes of use" above.
2. The information provided includes the name, address, telephone number, and other items necessary to achieve the purpose of each use, but will be limited to the minimum necessary items.
Examples of personal data to be provided
- - items registered or submitted in connection with the MGH Rewards Club operated by the Company
- - the history of points used, etc.
  Third parties that are provided with personal data (examples)
- - our group companies
- - tenants and subcontractors of hotels operated by the Company, as well as providers of point exchange items (gifts).
3. When providing information to a third party in writing, by mail, telephone, fax, e-mail, or electronic media, etc., the Company shall deliver the information with due consideration of security control, and when providing electronic data, the Company shall ensure that encryption and other necessary measures are taken as part of the delivery process.
4. The company will cease providing a customer’s personal information to third parties at the request of the relevant customer, in accordance with the provisions of the Personal Information Protection Law. The customer should contact the "Mitsui Fudosan Resort Management Co., Ltd. Customer Service Center" to make such a request. Please be aware that the customer may not be able to receive some or all of the Company’s services due to the cessation.

Joint Use

The Company shares personal data of customers as follows:

（1）Items of personal data to be shared
name, address, date of birth, telephone number, e-mail address, information on transaction history, etc.
Examples of personal data to be shared
- ・items registered or submitted in connection with the hotels operated by the Company
- ・points usage history
- ・service provision history, etc.
- ・history of business negotiations and discussions, etc.
（2）The extent of joint users
Our group companies
（3）Purposes of use by joint users
Same as purposes of use 1 through 3 listed in "Purposes of use" above
（4）Party responsible for joint use
Mitsui Fudosan Resort Management Co., Ltd. (Head office: 3-2-1 Nihonbashi-Muromachi, Chuo-ku, Tokyo 103-0023, Japan; President and CEO: Mr. SUDO Wataru) n order to provide services to customers in an integrated manner as the Mitsui Fudosan Group, the Company will jointly use the personal data of customers acquired by our group companies and endeavor to keep it up-to-date and accurate at all times.

Measures Taken for Security Management

The Company will comply with relevant laws, regulations, and guidelines, and take necessary and appropriate measures to prevent leakage, loss, or damage of the personal data that it handles and to otherwise manage personal data in a secure manner (hereinafter referred to as "Security Management Measures"). The Company will take the following measures.

Formulating Basic Policy

The Company has established a basic policy to ensure the proper handling of personal data. (Please click here for the basic policy.)

Establishing rules in handling personal data

The Company has established internal rules governing how personal data is handled, who is responsible and in charge, and their duties.

Organizational security management measures

Each division and department of the Company has an "Information Security Manager" who is responsible for the handling of personal information, and who is responsible for evaluating and improving security management measures by reporting on the handling of personal information on an annual basis.
In addition, the Company has a system in place to ensure that employees (including contract employees and temporary staff) comply with internal regulations concerning security management measures, and to report and inform the person in charge if they become aware of any fact or indication that an employee is in violation of the law or internal regulations.

Human security management measures

The Company provides its employees with education and training on the proper handling of personal information.

Physical and technical security management measures

The Company controls the entry and exit of employees to areas where personal data is handled, and secures and locks equipment or devices that hold personal data.
In addition, the Company controls access to personal data and to information systems that handle personal data, takes countermeasures against malicious software, and monitors information systems.
For example: prohibiting the storage of personal data on local disks, periodical change of authentication passwords, obtaining and analyzing operation histories.

Understanding the External Environment

When storing customer’s personal data on servers located in foreign countries, the Company implements security measures to ensure an understanding of the systems in place for the protection of personal information in each country. For further information, please contact the following office.

Halekulani Okinawa, Mitsui Fudosan Resort Management Co., Ltd.: 1967-1 Nakama, Onna-Village, Kunigami-gun Okinawa 904-0401, Japan
TEL: +81-98-953-8600 (the main phone number)
FAX: +81-98-953-8601

Consultation and complaints regarding handling of personal information

In accordance with the provisions of the Personal Information Protection Law, for details on the disclosure, correction, addition, deletion, cessation of usage, or erasure of personal information, and on necessary measures to ensure the continuous implementation of appropriate measures (hereinafter collectively referred to as "disclosure, etc."), please contact the following office.

Halekulani Okinawa, Mitsui Fudosan Resort Management Co., Ltd.: 1967-1 Nakama, Onna-Village, Kunigami-gun Okinawa 904-0401, Japan
TEL: +81-98-953-8600 (the main phone number)
FAX: +81-98-953-8601

For specific procedures for disclosure, etc., please refer to the Procedures for Disclosure of Personal Information.

Procedures for Disclosure of Personal Information

(1) Request for Disclosure, etc.
Requests for disclosure, etc. must be made with the required documents by mail to the address below. Please kindly write "Request for Disclosure of Personal Information enclosed" in red ink on the envelope.

Halekulani Okinawa, Mitsui Fudosan Resort Management Co., Ltd.

1967-1 Nakama, Onna-Village, Kunigami-gun Okinawa 904-0401, Japan
TEL: +81-98-953-8600 (the main phone number)
FAX: +81-98-953-8601
(2) Documents (or forms) to be submitted for disclosure procedures, etc.
To request disclosure, please download the following request form (A), fill in the required items, enclose documents for identification (B), and send it by post to the address in (1) above.
- - (A) The prescribed form from the Company
    Personal Information Disclosure Request Form (PDF)
  - (B) Documents for identification
    One copy of a driver's license, passport (with address) or health insurance card (the symbol or the number, etc., of the insured person being masked in advance; the same requirement applies hereinafter).
- (3) Requests for disclosure by proxy
  If the person making the request for disclosure is a legal representative of a minor or an adult ward or a representative authorized by the customer to make the request for disclosure, please enclose the following documents (either A or B) in addition to the documents listed in 2. above.
  - A. In the case of a legal representative
    One copy of a document confirming the right of legal representation (copy of the family register, or in the case of a person with parental authority, a copy of the insurance card with the dependent’s names filled in is also acceptable)
    One copy of a document to confirm the identity of the legal representative (a copy of the legal representative's driver's license or health insurance card).
    B. In the case of an authorized representative
    One copy of letter of attorney
    One document confirming the identity of the proxy (copy of the proxy's driving license or health insurance card).
- (4) Fees and how they are collected
  In the case of a request for disclosure or notification of purpose of use, a fee of 1,500 yen (including tax) is required for each application. The fee of 1,500 yen in the form of a fixed-sum money order (issued by a post office) must be enclosed with the request documents. No fee is required for requests for correction or suspension of use.
  *Customers are responsible for the cost of postage to the Company and for the fees for obtaining a fixed-sum money order.
  *We will contact and inform the customer if the fee is insufficient or if the fee is not enclosed; if the required payment is not made within the prescribed period, we will assume that the request for disclosure has been withdrawn.
- (5) Method of response to requests for disclosure, etc.
  The response will be mailed to the address for notification given in the Request Form for Disclosure of Stored Personal Data. If the customer requests disclosure in digital form, we will save the data on electronic media and reply by post with the electronic media enclosed.
- (6) "Purpose of use" of personal information obtained in connection with a request for disclosure, etc.
  Personal information obtained in connection with a request for disclosure, etc. shall be handled only to the extent necessary for the request for disclosure, etc.
- (7) On non-disclosure of "Stored Personal Data"
  The following cases will be considered as non-disclosure. Even in the case of non-disclosure, the required fee will still be charged.
  - - when the address on the request form does not match the address on the documents for identification, or when the identity of the applicant cannot be confirmed
  - - when the right of representation cannot be verified for a request by a proxy
  - - cases in which the subject of the request for disclosure does not fall under the category of "Stored Personal Data"
  - - if there is a risk of harm to the life, body, property, or other rights or interests of the person named in the request for disclosure or a third party
  - - if there is a risk of significant hindrance to the proper conduct of the Company’s business
  - - if it would violate other laws and regulations.

Terms of Site Use

This Webpage is operated and controlled by Mitsui Fudosan Resort Management Co., Ltd. (this "Company"). For the use of this Webpage, please read the following terms of use, and consent to all of them before using this Webpage. The personal information acquired by this Company not via this Webpage but through the hotel operation, mail order business or event business and the personal data possessed by this Company will also be subject to the same terms of handling and use purpose as set forth herein. If the separate terms of use are applicable to each service content offered in this Webpage, please also read such separate terms of use, and consent to all of them before using such service content. The commencement of your use of this Webpage shall be deemed as your consent to all of the terms of use as set forth herein. The terms of use for this Webpage and the page of each service content may be amended from time to time as needed. Please read through the terms of use each time of your use.

[Copyright]

The information, designs, layouts, logo marks, characters and trademarks as exhibited on this Webpage shall be subject to the intellectual property right (e.g., copyright), usage right or other right of this Company or the licensors who have granted this Company with the license to use the same. You are permitted to use this Webpage insofar as your use does not infringe any one of such rights. Any unauthorized copy or use of the same is strictly prohibited.

[Information Offered]

This Company properly endeavors to ensure that the variety of information offered through this Webpage will not give any unexpected damages or disadvantages to the guests, and uses the care to exhibit the up-to-date and accurate information on the Webpage. However, nothing herein shall warrant any integrity, accuracy or usefulness of such information. Therefore, this Company shall have no liability for any damages or disadvantages incurred by you as the result of your action in reliance on such information.

[Accident during Browsing]

This Company shall have no liability for any damages or disadvantages incurred by you as the result of your use of this Webpage (e.g., any accident of software or hardware, pollution with computer virus, loss of or damage to the data), or as the result of any dispute between you and another guest or any third party.

[Contact from Guests]

If your email or information request addressed to this Company fails to be delivered to this Company due to any failure or accident on the Internet, this Company shall have no liability for such delivery failure.

[Information Transmitted to Guests]

This Company retains the copyright of any emails or other communication that this Company has transmitted to you. Any unauthorized use of such emails or communication on other webpages or printed publications is strictly prohibited.

[Change to Exhibited Content]

This Webpage may add, change or abolish any information, service content or address with no prior notice to the guests. This Company shall have no liability for any content uploaded by any third party to the bulletin board or otherwise prepared in this Webpage. If this Company should determine that such uploaded content contains any inappropriate content, this Company may delete such content in part or in whole without prior notice.

[Links to this Website]

If you desire to attach a link to the top page of this Webpage, please contact the following contact. However, if the linked webpage contains any content contrary to the public order or morality, any adult content or any content defamatory to this Company or if this Company determines otherwise inappropriate, this Company may reject such linking.

Request for Disclosure and Deletion of Personal Information

This Company will comply with the request from the owner of the personal information or the authorized representative therefor for the disclosure, change, deletion or cease of use of the possessed personal data in the following manner.

[Request for Disclosure]

This Company will disclose your personal information in compliance with the Personal Information Protection Act. For the disclosure of the personal information, please make your request through the following procedures.

Procedures for Disclosure of Personal Information

Party Entitled to Request for Disclosure: The owner of the personal information and the legal or appointed representative therefor are entitled to make the request for disclosure.
Please submit the documentation necessary for the personal identification.
For making the disclosure request by an appointed representative, please submit the letter of authorization in a predetermined form.

Fees: Please pay the fee in the amount of 1,600 JPY (tax included) by enclosing the postal money order with fixed amount.
* Such postal money order is purchasable at post offices.

Reception of Request: Please fill out the Mitsui Fudosan Resort Management Co., Ltd. Personal Information Disclosure Request, and post the completed form to the following reception desk along with the necessary documentation and other required enclosure.

2198-1 Nakama, Onna Village, Kunigami-Gun, Okinawa 904-0401, Japan
Personal Information Desk, Mitsui Fudosan Resort Management Co., Ltd.

* The response shall be sent by post to the address of the owner of the personal information.
* Please kindly note that this Company may not possess your personal data.

Required Documents

Documentation to Be Submitted for Making Disclosure Request

Personal Information Disclosure Request Form
Documentation Required for Personal Identification (see the instruction on the request form)
Fee (Postal Money Order for Fixed Amount of 1,600 JPY)
PDF for Mitsui Fudosan Resort Management Co., Ltd. Personal Information Disclosure Request Form (PDF : 95KB)

Remarks

In the following instances, no disclosure shall be made. If this Company has determined that no disclosure shall be made, you will be notified of such effect along with the reasons therefor. Even in the event of non-disclosure, the predetermined fee will not be refunded unless otherwise excepted.
If the requesting party is not personally identified due to the discrepancy between the address stated in the disclosure request, the address stated in the personal identification document and the address registered in this Company or any other reason;
If the authorization of the representative is not confirmed with respect to a request made by the representative;
If there is any informality contained in the required request form;
If the disclosure request pertains to anything other than the "possessed personal data";
If there is a risk that such request may harm the life, body, property or any other right or interest of the owner or any third party;
If there is a risk that such request may materially obstruct the proper administration of the business of this Company; or If the compliance with such request may result in a violation of any other law.

Request for Correction or Other Action: Mitsui Fudosan Resort Management Co., Ltd. will correct, delete and cease the use or third-party provision of your personal information in compliance with the Personal Information Protection Act.
For the correction of or any other action for the personal information, please make your request through the following procedures.

[Procedures for Correction of or Other Action for Personal Information]

Party Entitled to Request: The owner of the personal information and the legal or appointed representative therefor are entitled to make the request. Please kindly note that the compliance with such request will require the completion of all necessary procedures to confirm the personal identification.

Fees: No fee

Reception of Request: Please directly contact the contact desk of the relevant department of Mitsui Fudosan Resort Management Co., Ltd.

In acquiring your personal information or posting direct mails or other communication, this Company advises you on the relevant department and the contact information thereof. This company may require your submission of the predetermined form. Please kindly note that it may take some time for the confirmation of your information or the completion of the correction or other requested action.

Remarks: Even if your request is submitted, this Company may be barred from complying with your request for a reason that the law requires otherwise or any other relevant reason, in which case you will be notified of such effect along with the reasons therefor.

Handling of Personal Information