MOL Sunflower Privacy Policy
Revised October 1, 2023

We, MOL Sunflower Ltd. (1-18-13 Sotokanda, Chiyoda-ku, Tokyo;
Representative Director and President, Chief Executive Officer Hirotoshi
Ushioku) (hereinafter, “we”, “us” or “our”), are implementing the following
initiatives based on the "Act on the Protection of Personal Information" toensure your information that we handle is strictly protected.
Purpose of use of personal information
We will use your personal information for the following purposes:•

For the reservation and sale of boarding tickets, various boarding
procedures, and provision of on-board services;•

For the operation of member services, such as internet reservation
membership, web membership, and "Sunflower Members (limited to Kansai⇔ Kyushu route)";•For guidance, communication, provision and management of our services,
products, events and promotions;•

To conduct surveys regarding our services, products, events andpromotions;•

For guidance, communication, provision and management of the services,
products, events and promotions of our partner companies, etc.;•

To receive orders for and sell other products and services;•

To respond to your inquiries, requests, etc.;•

To improve our services and develop new services through market research,data analysis, etc.;•

For the management of complimentary tickets for Mitsui O.S.K. Lines
shareholders; and•For emergency response and operations incidental thereto.

If we will acquire your personal information for a purpose other than the above,
we will do so within the minimum scope necessary after clearly indicating the
purpose of use and items of personal information to be acquired.

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Contents of personal information to be acquired
We will acquire the following items of personal information through appropriate
and fair means, such as the Internet, telephone, postal mail and face-to-facecommunication.
•

Your name, date of birth, age, gender, address, postal code, telephone
number, FAX number, e-mail address, and work information (company
name, department, title, address, telephone number, FAX number);•Voyage number, date, place of embarkation/disembarkation, class, purposeof travel, and details of use of discount system;•

Name, date of birth, age, gender, contact information, etc. of allaccompanying passengers;•

Passenger car and motorcycle license plate numbers;•

Credit card information (card type, card number, cardholder name and dateof birth, expiration date, place of employment, etc.);•

Information related to support, etc. required at the time ofboarding/disembarkation and on board;•

Physical information and information about illnesses related to boarding(optional); and•Information contained in communications between you and our company,
and the contents of your inquiries, opinions and questionnaire responses.

Disclosure/provision to third parties
We will never disclose or provide your personal information to third parties
except under the following circumstances:•

When you have provided your consent;•

When we have been demanded to do so based on laws and ordinances;•

When we need to do so in order to cooperate with the official affairs ofnational or local public entities, etc., and obtaining your consent is likely tohinder the performance of those affairs;•

In an emergency involving risk to life, etc. when obtaining your consent
would be difficult;•Disclosure to our contractors, etc. in the case that we have concluded anagreement in advance to prevent them from using your personal
information for any purpose other than the services that we have entrusted
to them;2•When necessary for the settlement of payments for the purchase ofboarding tickets, products, etc. (to confirm the validity of the bank accountor the validity of the credit card); or•

In the case of business succession through merger, company split-up,transfer of business or otherwise.

Protection and management of personal information
We will appoint a personal information protection manager and endeavor to
manage your personal information appropriately.We properly manage yourpersonal information and take the utmost care to prevent leakage, loss anddamage, etc.
We have internal regulations and in-house management systems in place forthe protection and proper handling of personal information, and we provide theappropriate education to our staff. We have established a retention period for
personal information depending on its purpose of use and we discard
information in an appropriate manner when that period has elapsed. We will
provide some of your personal information (transaction ID, name, address,
telephone number, e-mail address, shipping address, details and the price ofyour order, credit card number and expiration date) to the external companies
to whom we outsource operations required for the settlement of payments forour products and services and related information system management.
We respect your rights as the subject of personal information, and will promptly
respond to any request that you make for the disclosure, correction, cessationof use, erasure, etc. of the contents of your personal information.
We take measures such as concluding non-disclosure agreements andprohibiting subcontracting, etc. to ensure that these external companies use
your personal information only for operations required for the settlement of
payments for our products and services and manage your personal information
appropriately to prevent leakage.
Joint use of personal information
We may jointly use your items of personal information in our possession
together with Mitsui O.S.K. Lines, Ltd., our group companies, and, whennecessary, with our affiliates, for operations related to the "Purpose of use of
personal information" stipulated above. The items of personal information
subject to such joint use are as follows:3•Your name, date of birth, age, gender, address, postal code, telephone
number, FAX number, e-mail address, and work information (company
name, department, title, address, telephone number, FAX number);•Name, date of birth, age, gender, contact information, etc. of allaccompanying passengers;•

Passenger car and motorcycle license plate numbers;•

Credit card information (card type, card number, cardholder name and dateof birth, expiration date, place of employment, etc.);•

Information related to support, etc. required at the time ofboarding/disembarkation and on board;•

Physical information and information about illnesses related to boarding(optional); and•Information contained in communications between you and our company,
and the contents of your inquiries and opinions.

About pseudonymized information
We will create pseudonymized information that is processed so that it cannot
identify you personally unless compared with other information, and analyze
and use such pseudonymized information for the purposes stipulated under"Purpose of use of personal information". We will take measures to ensure thesecurity of pseudonymized information in compliance with our internal
regulations. We may jointly use pseudonymized information with Mitsui O.S.K.
Lines, Ltd. and our affiliates as necessary.
•Blue Highway Service, Ltd.

•

SUNFLOWER TRAVEL LIMITED•

Sunflower Agency Co., Ltd.

•

Beppu Port Service Co., Ltd.

•

Sunflower Marine Service K.K.

•

Mitsui O.S.K. Lines, Ltd.

Our company is the entity responsible for the management of jointly usedpersonal information, so please direct any inquiries to our personal information
consultation service listed under I) below.
Requests regarding the handling of personal information
If you have submitted a request in our prescribed manner to: 1. Disclose; 2.
Correct, delete or make additions to; 3. Cease using, etc.; or 4. Notify you of4the purpose of use (hereinafter, "Disclosure, etc.") of your personal data in ourpossession, then we will respond to that request as follows within a reasonable
period of time and to the extent appropriate and possible in accordance withlaws and ordinances after first confirming your identity.
Please note that a 500 yen (incl. tax) administrative fee will be charged foreach request to disclose the content of your personal information in ourpossession and to notify you of the purpose of use of your personal information.
Disclosure of multiple reservations and boarding information is handled as one
request for disclosure per reservation/voyage. "I)

Inquiries about the protection of personal information
Personal information consultation service[Tokyo metropolitan area ⇔ Hokkaido route]Passenger Division personal information officer
TEL: 03-6866-7307 (Monday to Friday, 9:00 a.m. to 5:00 p.m. Excluding
public holidays and New Year holidays) Address: Akihabara Dai Building
11F, 1-18-13 Sotokanda, Chiyoda-ku, Tokyo 101-0021[Kansai ⇔ Kyushu route]Passenger Division personal information officer
TEL: 06-7634-8932 FAX: 06-7634-8935 (Monday to Friday, 9:00 a.m. to
5:00 p.m. Excluding public holidays and New Year holidays)
Address: ATC Building O's Bld. North Bld. 6F 605, 2-1-10 Nankokita,
Suminoe-ku, Osaka 559-0034

II) Procedures for requesting Disclosure, etc.
To request Disclosure, etc., please fill in the following request form (A) andsend the request form, documentation to verify your identity or the identityof your agent (B), and the 500 yen administrative fee for each request (ifrequired) in a registered letter for sending money addressed to thepersonal information consultation service listed above.
A) Prescribed request form
To make a request for Disclosure, etc., please download and print a request
form and fill in the necessary information. Request form (Click to open theform).
B) Identity verification documentation
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(When you are making a request yourself) Please enclose copies of two
documents from among those listed below
Driver's license
My Number Card
Basic Resident Registration Card
Certified copy of Family Register (Address, name, and other necessary
matters only)
Certificate of residence (Address, name, and other necessary matters only)
Insurance card for various insurances
Long-term Care Insurance card
Pension handbook
Pension certificate
Passport(When making a request via an agent)
Letter of attorney from you to your agent
Certificate of seal-impression for the seal you used to stamp the letter ofattorney (issued within 3 months from the date of issuance of the letter ofattorney)
Copies of two documents from among those listed under “B) Identity
verification documentation” above for the agentIII) Points to note when requesting Disclosure, etc.
Please be sure to use our prescribed request form and fill in all the necessary
information (including affixing your seal). We cannot accept your request if you
have not used the prescribed form or if you have not filled in all the necessary
information on the form.
Please obtain all the identity verification documentation required to make arequest for Disclosure, etc. at your own expense.
You are responsible for paying the postage costs to send the request form andother documentation to our company. When sending documentation by postal
mail, please use a method that allows confirmation of delivery such as
simplified registered mail.
We will promptly shred and dispose of the identity verification documentation,etc. you have submitted along with your request for Disclosure, etc. after
procedures have been completed.
The fee charged for a request to disclose the content of your personal6

information in our possession and to notify you of the purpose of use of yourpersonal information will not be refunded, even in the case we do not have yourpersonal information in our possession or in the case we cannot respond to
your request due to the provisions of laws and ordinances.
When requesting correction, etc. to your personal information, please indicate
specifically “which items of personal information” in our possession are to becorrected and “the contents of the corrections, etc.” We cannot makecorrections, etc. if you do not provide specific instructions.
Please be aware that we may be unable to provide you with services that werepreviously available or services that meet your requests in the case we ceaseusing or erase your personal information at your request.
We may be unable to respond to your request for Disclosure, etc. if doing so
may cause a significant hindrance to our normal business operations, or violate
the provisions of laws and ordinances, or hinder the security management of
personal information.
Application and changes to the Privacy Policy
This privacy policy provides an explanation of our handling of your personal
information. By using our services, you will be regarded as having read andunderstood it. We reserve the right to revise this privacy policy at any time
based on changes to the content of our services and the like.
The handling of information on our website
We may use cookies*1 and other similar technology in order to analyze theusage of our website and to provide you with more personalized member
services, etc.
In addition to using cookies as anonymous information for statistical analysis,
etc. we may also associate cookies with information that identifies you in orderto provide you with more personalized member services, etc.
Scope of application
Our website contains links to other websites that can provide you withinformation about useful products and services. We assume no responsibility inconnection with the collection of your personal information by linked websites.
Please use linked websites at your own discretion.

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Security technology for the protection of personal information
Our website uses SSL (Secure Sockets Layer) encryption technology as a safetymeasure when collecting your personal information. SSL technology can
encrypt data distributed over the Internet and prevent leakage. We are also
striving to ensure the safety of your personal information by installing a firewalland computer anti-virus protection as well as taking other reasonable security
measures to prevent the unauthorized third-party access to, leakage, diversion
and tampering, etc. of your personal information.
Browsing our website
We may use cookies*1, or an individual identification number*2 if you arebrowsing our website on a mobile phone, to allow you to comfortably use ourservices when browsing our website.
You can disable the link with anonymous browsing information through cookies
by disabling cookies and data with similar functionality in your browser settings.
You can also check each company's privacy policy and disable cookies (opt-out)from the following pages. However, please note that doing so may result in you
being unable to use services through our website.
Google opt-out page
Yahoo! opt-out pageUse of other information
We may use advertisements distributed by third parties including Yahoo! andGoogle, and such third parties may acquire and use your cookie informationand your visit/action history on our website, etc. in connection with this.
Your cookie information and your visit/action history on our website, etc.
acquired by such third parties will be handled in accordance with the privacy
policy established by the third party.
This website uses the “Google Analytics” access analysis tool provided by
Google. Google Analytics uses cookies to collect data.
This data is collected anonymously and cannot identify you personally. You canrefuse such collection of data by disabling cookies, so please check yourbrowser settings. For more information about these terms, please visit theGoogle Analytics Terms of Service page or the Google Privacy & Terms page.
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Google Analytics can also be disabled by downloading and installing the Google
Analytics opt-out add-on from the Google Analytics Opt-out Browser Add-on
Download Page and changing your browser's add-on settings.
Explanation of terminology*1 Cookies
Cookies are data sent by the website through your browser and temporarily
saved to your computer which allows the web server to recognize access to thewebsite from a terminal that has previously accessed the same website. We use
cookies only for the purpose of safely managing the transfer of information
during the online reservation screen transition. We do not collect your personal
information.
*2 Individual identification number
The Individual identification number is unique information such as your mobile
phone model and serial number. Personal information such as the name andaddress of the mobile phone subscriber cannot be identified from this number.

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