Processing of EU Personal Data
In order to strictly protect customers' information (hereinafter referred to as "EU personal data"),
Kinki Nippon Tourist Co.,Ltd. (hereinafter referred to as "this company") is implementing thefollowing measures.

1.

Measures for protecting customers' EU personal data

(1) This company will manage customers’ EU personal data appropriately.
(2) This company has a security manager for each department that manages customer's EU
personal data, and the manager properly manages the customer's EU personal data.
(3) The data this company acquires from customers is the customer's EU personal data which
is necessary for providing the services such as customer's name, e-mail address, telephone
number, address. This company may ask other questions for the purpose of providing
customers with the desired services; however, this will be offered by the customer
arbitrarily except for the minimum necessary items.
(4) <For inquiries and consultation >Depending on the contents of inquiry and consultation (hereinafter referred to as"consultation"), this company may notify third parties of EU personal data of customers inadvance with consent. For example, if the contents of inquiries are not handled by thiscompany, it is a case to confirm with the group company which handles this matter.
(5) <For application>
Depending on the type of service, this company may notify third parties of EU personal
data of customers; for example, when notifying the customer's name and other informationneeded for shipping and accommodation agencies.
(6) In order to strictly store customers' EU personal data, this company has establishedinternal rules and has been conducting education for employees and audit related to theprotection of EU personal data on the regular basis.
(7) In the case where customers wish to inquire or modify their own EU personal data, thiscompany will respond within a reasonable range after confirming the customers'identification.
(8) On this company's website, this company may use "cookie" to provide better service, but
this company does not acquire any data to identify individuals by this. "Cookie" is afunction to store on the computer of the person who viewed the website. Although it ispossible to refuse receipt according to the settings of the browser, some of the servicesmay not be available by this.

(9) This company will comply with the laws and regulations applicable to customer's EU
personal data, and this company will review and improve these efforts as necessary. In
connection with the occurrence of incidents, this company may cooperate in thepublication of EU personal data due to the provision of data at the time of police
investigation and requests from relevant organizations.

2.

The purpose of processing EU personal data acquired from customers< For inquiries and consultation >This company will use EU personal data provided during inquiries and consultation forcontacting with customers. In addition, in the content of customer's inquiries andconsultation, this company may use it within the necessary range for contact andconfirmation with the related organizations.
<For application>
For EU personal data provided at the time of travel application, in addition to using it forcontacting customers, this company will use it within the range necessary for thearrangement and receipt of services provided by transportation and accommodation
organizations on customer's travel.
In addition, this company may use customer's EU personal data at this company anddealers in order to develop better travel products and inform customers about theinformation on travel products, as well as the damage insurance of each company which isentrusted by each insurance company, and to provide incidental and related services.
Providing EU personal data is essential for fulfillment of the contract, and if customers
cannot provide EU personal data on their own judgment, provision of service to customers
and so forth may be interfered and it may cause damage or loss.

3.

For the conditions of handling of EU personal data
This company shall deal with EU personal data only if this company obtains consent fromthe customer and in any one of the following cases.
(1) When handling is necessary for the performance of the contract where the customer
is a party concerned (e.g., in the case where to notify customer’s information suchas address to the hotel to arrange a hotel designated by customer).
Or when handling is necessary according to customer's request before the contract isconcluded.
(2) When handling is necessary to comply with the legal obligation that this company shallabide by (When following information disclosure orders based on laws from government
agencies, etc.).
(3) When handling is necessary to protect the serious interests of customers or otherindividuals (e.g., in the event that the life of customer or accompanying person falls into

a serious crisis due to an accident during the trip, provide customer’s or accompanying
person’s data to relevant organizations such as police and hospitals).
(4) When it is deemed appropriate to investigate, prevent, or take measures against illegal acts
or suspicious acts.

4.

For the special categories of EU personal data
In order to carry out various procedures concerning customers' travels, and to manage theitinerary for participation in special tours (extreme tour such as Antarctica, and climbingtours), in principle, this company shall obtain consent from the customer in advance, andacquire, use, relocate customers’ special categories of EU personal data (health condition,physical characteristics, etc.) within the necessary scope of purpose. The EU personal data
shall not be processed other than for this purpose.

5.

For international transfer of EU personal data
EU personal data may be stored in servers after they are transferred to the groupcompanies and outsourcing contractors, etc. in Japan. This company shall manage
customer's EU personal data appropriately.

6.

For safety management measures
In order to properly manage the EU personal data of customers, and prevent from leakage,loss or damage of EU personal data and so forth, this company shall implement technicaland physical / organizational / personal safety management measures for them.

7. Joint Use of EU Personal Data
EU personal data received from customers will be jointly used only for the following
purposes.
<For inquiries and consultation >Among EU personal data provided by customers for inquiries and consultation, thiscompany will jointly use items within the minimum range necessary for contacting andresponding to customers such as name, telephone number and address, with the groupcompanies listed below.
<For application>
This company may use EU personal data this company holds jointly with the groupcompanies for the purpose of product development, promotion such as product guidance,and contact or response to customer and so forth.
Regarding joint use of EU personal data with group companies, this company will define
the scope of responsibility for handling EU personal data and inquiry contact clearly.

EU personal data used jointly by the group companies
Address, Name, Phone number, Age, Date of birth, Sex, Item purchase history, E-mailaddress, and Passport numberGroup companies
KNT-CT Holdings Co., Ltd.

Kinki Nippon Tourist Blue Planet Co., Ltd.

Club Tourism International Inc.

Kinki Nippon Tourist Okinawa Inc.

Tourist Experts Inc.

United Tours Co., Ltd.

KBC Co., Ltd.

Event & Convention House, Inc.

SANKI Travel Service Co., Ltd.

8.

and other Group Companies

EU personal data provided by customers will be transferred only for the following
purposes.
<For inquiries and consultation >In order to respond to customer inquiries and consultation, this company may transfer
customers’ EU personal data to transportation and accommodation organizations(including organizations overseas) within the range necessary.
<For application>
This company will transfer customers’ EU personal data to transportation andaccommodation organizations (including organizations overseas) within the range
necessary.
In addition, for the convenience of customers' shopping at the travel destination, etc., thiscompany will transfer the customer's EU personal data to the organizations such as theduty free shop of the destination. In this case, this company will relocate EU personal data
related to customer's name, and passport number sent by electronic method, etc.
This company shall transfer customer's EU personal data to group companies andoutsourcing contractors, etc. that have subcontracted. This company shall request proper
handling of the transferred EU personal data to the corresponding outsourcing contractor,
and this company also shall properly manage it accordingly.

9.

Customer's EU personal data will be kept for 2 years and then properly erased anddiscarded.

10.

For the customer's rights
Customers have the following rights regarding EU personal data concerning themselves.
(1)

Right to know customer's EU personal data and relevant information(2)

Right to correct the incorrect EU personal data concerning customers without

undue delay(3)

Right to eliminate EU personal data on customers without undue delay(4)

Right to restrict handling of EU personal data concerning customers(5)

Right to receive EU personal data provided by customers in a general format
that computer is readable, and the right to relocate (shift) the EU personal datato the management of other organizations without disturbing(6)

Right to object to public interest or handling for the interests of this company or
third parties and handling for direct marketing for EU personal data of thecustomers(7)

Right to not undergo assessment / decisions that have serious impact including
legal effects on individuals through automatic processing such as profiling etc.
*This company does not perform profiling.

11.

Liability
Use of this website is at customers' own responsibility.
With respect to all damages caused by the use of various information acquired fromthis website and other web pages with links to this website, Kinki Nippon TouristCo.,Ltd. assumes no responsibility.

12. Governing law
This homepage is under the control of Kinki Nippon Tourist Co.,Ltd. This homepage
can be accessed from all countries of the world with different laws; however, both thecustomer who accessed this homepage and Kinki Nippon Tourist Co.,Ltd., agree to bebound by the laws of Japan concerning the use of this website regardless of thedifference in legal principle.
Also, Kinki Nippon Tourist Co.,Ltd. will not describe or display anything such aswhether the content of this homepage is appropriate in the customer's environment onthis page. Access to this homepage is based on the customer's free will and thecustomer shall be responsible for the use of this page.

13. Data Protection Officer
As a group data protection officer (DPO), this company and group companies haveappointed director in charge of general affairs department of KNT-CT Holdings Co., Ltd.
The contact information of the data protection officer is as follows.

Director in charge of general affairs department
KNT-CT Holdings Co., Ltd.
2-6-1, Nishi-Shinjuku, Shinjuku-ku, Tokyo, Japan 163-0239
Phone number: +81-3-5325-8513
E-mail: privacysomu@or.knt.co.jp

For inquiries regarding this matter, please contact the inquiry desk below.
＜Inquiry Desk＞
EU Personal Data Management Officer
General Manager of General Affairs Department
Kinki Nippon Tourist Co.,Ltd.
Shinjuku-Sumitomo Bldg, 36F
2-6-1, Nishi-Shinjuku, Shinjuku-ku, Tokyo Japan 163-0236
Reception hours: 10：00-17：00(excluding weekends, holidays and from 29 Dec. to 3 Jan.)E-mail: knt-kanri-somu@or.knt.co.jp