Personal Information Protection Policy (Privacy Policy)

1. Collection of Personal Information

The Company collects personal information by lawful and fair means. In connection with the use of the Hotel, the Company primarily collects the following information.

(1) Name, address, phone number, email address, date of birth, nationality, and passport number; image data of identification documents (driver's license, passport, My Number Card (front side), etc.) obtained from the Guest via the self check-in machine or other means; and a facial image of the Guest captured via the self check-in machine or other means for the purpose of identity verification

(2) Information relating to accommodation reservations, usage history, and payment (including credit card information)

(3) Footage from security cameras installed within the Hotel, and access control data from smart locks and similar systems

(4) Information recorded in a parental consent form obtained in connection with the stay of a person under 18 years of age, and image data of the identification document of the person with parental authority attached to such consent form

(5) Other information provided by the Guest based on the Guest's own consent (such as requests concerning the stay)

(6) Voice data and records of dialogue (questions, requests, etc.) obtained in connection with the Guest's use of AI concierge services (such as Aiello)

2. Purpose of Use of Personal Information

The Company uses the personal information it collects within the scope of the following purposes, and will not use it for any other purpose except with the Guest's consent or as otherwise permitted by law.

(1) Performance of the Accommodation Contract and provision of services associated with the stay

(2) Confirmation of accommodation reservations, responding to inquiries, and contacting the Guest in the event of an emergency

(3) Preparation, management, and retention of the guest register pursuant to the Hotel Business Act

(4) Safety management of facilities and equipment at the Hotel, crime prevention, and the detection, investigation, and prevention of fraudulent use (such as fictitious reservations, resale, and unauthorized use of credit cards)

(5) Statistical analysis to improve the Company's services, develop new products and services, and enhance customer satisfaction. In conducting such analysis, the Company may use AI tools provided by external operators as a subcontractor referred to in Item 4 below. In such cases, the Company shall ensure, under the relevant outsourcing agreement, that the provider of such AI tools does not divert the input data for the general-purpose training of its own models.

(6) Sending of emails and other communications regarding events, campaigns, surveys, and other notices from the Company, and the delivery of advertisements incidental thereto (only to Guests who wish to receive them)

3. Provision of Personal Data to Third Parties

The Company will not provide personal data to third parties except in any of the following cases.

(1) Where the Guest has given prior consent (including consent to the provision of personal data to the relevant credit card company or other third party involved in payment, for the purpose of preventing and detecting unauthorized use of credit cards, chargebacks, and other fraudulent acts, where the Guest pays the accommodation charges by credit card or through another third party)

(2) Where required under applicable laws and regulations (the Hotel Business Act, the Code of Criminal Procedure, etc.)

(3) Where necessary for the protection of a person's life, body, or property, and it is difficult to obtain the consent of the person concerned

(4) Where particularly necessary for improving public health or promoting the sound development of children, and it is difficult to obtain the consent of the person concerned (such as providing information to a public health center in connection with infectious disease countermeasures)

(5) Where cooperation with a national or local government agency, or a person entrusted by such agency, is necessary for the performance of duties prescribed by law (such as an inquiry from the police in connection with a criminal investigation)

4. Outsourcing of Personal Data (Including Provision to Third Parties Located Overseas)

The Company may outsource the handling of personal data to external operators to the extent necessary to achieve its purposes of use. In doing so, the Company shall handle such data appropriately as follows.

(1) The Company may outsource the handling of personal data to external operators, including the accommodation reservation system (PMS), the self check-in system, payment agency companies, cleaning and facility management companies, and the providers of the AI tools referred to in Item 2(5) above. In such cases, the Company shall exercise appropriate supervision over such subcontractors.

(2) Where a subcontractor referred to in the preceding item (including a cloud server provider or a system development or maintenance operator) is located overseas, the Company may, to achieve its purposes of use, provide the Guest's personal data to, and have it handled by, such third party located overseas. In such cases, the Company shall implement appropriate safety management measures and supervision in accordance with applicable laws and regulations. In addition, where the Guest makes an inquiry concerning the personal information protection system of the relevant foreign country, the Company shall provide the necessary information in accordance with applicable laws and regulations.

5. Safety Management Measures

The Company shall take necessary and appropriate organizational, personnel, physical, and technical safety management measures to prevent the leakage, loss, or damage of personal information and to otherwise ensure the safety management of personal information.

6. Use of Cookies and Similar Technologies, and Use of Access Analysis Tools

The Company uses cookies and similar technologies as follows in operating its website, improving user convenience, and conducting marketing and other activities.

(1) The website operated by the Company (hereinafter the "Company Website") may use cookies and similar technologies for the purposes of improving convenience for Guests, analyzing the usage status of the site, and delivering advertisements optimized to Guests' interests (such as behavioral targeting advertisements).

(2) The Company Website uses access analysis tools and advertisement delivery services provided by third parties, such as Google Analytics, in order to understand and analyze the usage status of the site. Through this, the respective providers may collect browsing history, device information, and other data of Guests on the Company Website. Where such information is cross-referenced with other information held by the provider and thereby identifies an individual, the Company shall carry out the necessary confirmation and response in accordance with the Personal Information Protection Act.

(3) Guests may refuse to accept cookies, or delete stored cookies, by changing their own browser settings. Please note, however, that if cookies are disabled, some services on the Company Website, such as the reservation function, may not operate properly. Guests who wish to opt out of advertisement delivery, etc. using cookies placed by third parties should follow the procedures set out on the opt-out page provided by the relevant third party.

(4) In connection with the preceding two items, the Company publishes, pursuant to the Telecommunications Business Act (regulations concerning external transmission), the following outline of information transmitted regarding Guests' device information, etc. from the Company Website to external operators.

Recipient operator: Google LLC (service provided: Google Analytics)

Information transmitted: IP address, cookie identifiers, URLs and date/time of pages viewed, information concerning the device and browser, etc.

Purpose of use: Measurement and analysis of the usage status of the Company Website (access analysis)

*In addition to the above, where information is transmitted to an external operator for purposes such as advertisement delivery, the recipient, the information transmitted, and the purpose of use shall be added to this Item.

Guests may stop such transmissions by refusing or deleting cookies through their browser settings, or by using the opt-out means provided by each external operator (such as the Google Analytics Opt-out Add-on).

7. Retention Period of Personal Data

The Company retains personal data only for the period necessary to achieve the purpose of use. For information for which a retention period is prescribed by the Hotel Business Act or other applicable laws and regulations (such as the guest register), the Company shall comply with such prescribed period; for all other information, the Company shall erase or dispose of it within a reasonable period after the purpose of use has been achieved.

8. Disclosure, Correction, Suspension of Use, etc. of Retained Personal Data

Guests who wish to request the disclosure, correction, addition, deletion, suspension of use, or erasure of their own retained personal information should contact the inquiry desk set forth in Item 9 below. After conducting identity verification, the Company will respond within a reasonable period in accordance with applicable laws and regulations.

9. Inquiry Desk

For inquiries concerning this Policy, and for consultations regarding the handling of personal information, please contact the following desk.

[Inquiry Desk]

Company name: NEW CLASSIC JAPAN Co., Ltd.

Address: 5F TTN Sakaisuji-Honmachi Building, 1-7-2 Kawaramachi, Chuo-ku, Osaka-shi, Osaka 541-0048, Japan

Department in charge: Personal Information Inquiry Desk

Email address: hotel_privacy@nc-japan.co.jp