PRIVACY POLICY

2254 / FILTr inc. (hereafter referred to as “we”) will comply with the Act on the Protection of Personal Information and relevant laws and regulations, and handle personal information properly based on the following policy in order to protect our guests' personal data:

BASIC POLICY

i. Personal data must be collected through legitimate and fair procedures; We will not acquire personal information by unauthorized means.

ii. Personal data shall be used exclusively within the limits of the prescribed purposes. We will not use it for any other purpose.

iii. Personal data shall be handled under security sensitive procedures. Output / input, storage, transportation or transmission shall not be done under any circumstances when such security cannot be guaranteed.

iv. We will not provide any personal information to a third party outside the exact prescribed specifications of the laws, and without consent from the subject individual of the data. When the handling of personal information is delegated to a third party for business-related purposes, or that personal information 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.

v. We acknowledge that an individual has the right to access, correct or discontinue our usage of his/her 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. WHAT IS PERSONAL
INFORMATION?

Personal information is any information about you as an identifiable individual. The personal information that we process includes:

Basic information – such as name, age, gender, passport information and publicly available photograph;

Contact information – such as your home address, zip/postal code, email address and phone number;

Financial information – such as your credit card details, itemized spending and transaction history;

Health information where disclosed and relevant to the provision of services;

Preferences – such as special requests, service issues and other preferences for your stay;

Technical information – such as information about the device you use to interact with us (including the unique device identifier, hardware model, operating system and version, and mobile network information, in the case of our mobile App); and

Correspondence – when you contact us, such as to send an enquiry or make a request, any correspondence or application may be kept and added to your personal information.

2. HOW DO WE USE
YOUR PERSONAL INFORMATION?

We use your personal information for the following purposes:

to enable you to use our website and our mobile App;

to help us identify you and any accounts you hold with us;

to provide superior customer service to you;

to assist us in making your reservation and providing the services you request at any of our properties;

to process transactions through our website (including taking payment for purchases you may make through our website) and to assist in any inquiries about your transaction;

for billing purposes in relation to your stay with us;

to confirm prior transactions and reconcile statements or invoices;

to contact you in relation to matters that arise from your stay with us;

to send you newsletters regarding our properties and to advise you of promotions or to inform you of offers or other information that may be of interest to you (if, where required, you separately provide your consent for us to do so);

to conduct surveys to receive your views on our properties and service delivery (if, where required, you separately provide your consent to this);

to respond to a specific "Information Request" from you about our hotel and deal with any other enquiries, correspondence, concerns or complaints you have raised;

to analyze customer trends and insights; and

to operate our business, including for internal purposes such as auditing, data analysis, statistical and research purposes and troubleshooting to help us improve our services.

when it is necessary for legal request, the establishment of the legal procedure, the use or defense

Conforming to local legislation.

For other purposes of use expressed at the time when peronal information is acquired.

Occasionally we will combine information from a number of Guests to better understand trends and your expectations. When this occurs, all identifiers are removed and the aggregate, anonymized information cannot be linked to any specific individual.

3. HOW IS PERSONAL
INFORMATION COLLECTED?

We collect your personal information while monitoring our technology tools and services, including comment cards and email communications sent to and from us.
Otherwise, we gather information when you provide it to us, or interact with us directly, for example:

when you make a reservation online, by calling or contacting us directly; and

during your stay at our hotel, including information provided during check-in.

We also receive information about you from other sources, such as our business partners and publicly available sources. We combine information that we have about you from various sources, including the information that you have provided to us.
We may collect your photograph from publically available sources so that we can recognize you in order to provide you with superior customer service.

We may also collect information from you through the use of cookies, when you visit our website. Cookies and other similar tracers are packets of data used by servers to send status information to a user's browser and return status information to the original server through this same browser.
The status information can be a session identifier, a language, an expiration date, a response field or other types of information.
During their validity period, cookies are used to store status information when a browser accesses various pages of a website or when the browser returns to this website at a later point.

How to control cookies?

You can control and/or delete cookies as you wish. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.

4. HOW DO WE MANAGE ACQUIRED
PERSONAL INFORMATION?

We will appropriately manage personal information and take suitable safety measures, such as reasonable technical measures to prevent unauthorized access to personal information and the loss, damage, alteration or leakage of personal information, and will make efforts to continuously correct and improve these measures. Additionally, we will make efforts to keep the retained personal information accurate and up-to-date within the scope necessary to achieve the purpose of use, and suitably supervise personnel handling such personal information.

5. RESTRICTION ON
THIRD PARTY PROVISION

Personal information acquired by the guests will not be provided to third parties without the prior consent of the guest, except in cases stipulated by laws and regulations.

6. EXCEPTION OF
THIRD PARTY PROVISION

(1) Entrustment:
For the purposes set out in Clause 2 of this Charter, we may entrust the whole or part of its business involved in handling personal information after taking safety control measures for the contractor.

(2) Shared use :
For the purposes set out in Clause 2 of this Charter, we share a portion of your personal data, as follows. The personnel who is in charge of protecting personal information will control such data responsibly.

(i) Items of personal data subject to shared use
Name (including reading), address, telephone number, sex, date of birth, e-mail address, and other information necessary in order to provide our guests with optimal services.

(ii) Scope of parties to share use

(iii) Purpose of use by parties to share use
・Provision of accommodations, parties, restaurant services, etc.
・Provision of reservation services for accommodations
・Provision of Internet reservation service
・Cleaning guest rooms
・Provision of transportation service
・Provision of experience service or workshop
・Response to inquiries
・Provision of other services related to the above

(iv) Party responsible for the control of relevant personal data
2254 / FILTr inc.

7. DISCLOSURE, CORRECTION,
DELETION, USE SUSPENSION

If you request the notification of purpose of use, disclosure, correction, deletion, or the halting of use of personal information acquired by us, we will respect your wish and respond such request in a reasonable period of time and within the scope stipulated by laws and regulations upon confirming that the requesting party is the person himself/herself. However, such request may be refused if the request violates laws and regulations, such request is likely to cause harm to the life, body or property of a third party, such request is likely to cause a significant disruption in the proper conduct of the business of our hotel and company, the requested personal information does not exist, or the requesting party's identity cannot be confirmed.

8. INQUIRIES AND
CONTACT INFORMATION

2254 / FILTr inc.

2-254 Miyagawasuji, Higashiyama ward, Kyoto, Japan 6050801+81-(0)75-285-3012
info@filtr.co.jp

9. UPDATES

We may modify this Charter from time to time, in accordance with revision or repeal of laws and regulations, and any other grounds. Consequently, we recommend that you consult it regularly, particularly when making a reservation at our hotel.

Enacted on 1 August 2019
2254 / FILTr inc.

Copyright © 2019 FILTr inc. All Rights Reserved.