Processing of Personal Data of Customers in EU

In order to strictly protect customers' information (hereinafter referred to as "EU personal data"),
KNT-CT Global Travel Co., Ltd. (hereinafter referred to as "this company") is implementing thefollowing measures.

1. 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 the arrangement
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 and dealers
in order to develop better travel products and inform customers about the information on
travel products, as well as the damage insurance of each company which is entrusted 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.

2. For the conditions of handling of EU personal dataThis 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 thecustomer is a party concerned (e.g., in the case where to notify customer’s informationsuch as 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.

3. 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.

4. For international transfer of EU personal data
EU personal data may be stored in servers after they are transferred to the group companies
and outsourcing contractors, etc. in Japan. Japan has not been determined to be adequacy ondata protection from the European Commission, however this company shall manage
customer's EU personal data appropriately.

5. 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 technical andphysical / organizational / personal safety management measures for them.

6. Joint Use of EU Personal Data
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 personal data and inquiry contact clearly.

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

Kinki Nippon Tourist Corporate Business Co., Ltd.

KNT-CT WEB Travel Co., Ltd.

Kinki Nippon Tourist Hokkaido Co., Ltd.

Kinki Nippon Tourist Tohoku Co., Ltd.

Kinki Nippon Tourist Kanto Co., Ltd.

Kinki Nippon Tourist Metropolitan Co., Ltd.

Kinki Nippon Tourist Kansai Co., Ltd

Kinki Nippon Tourist Chubu Co., Ltd.

Kinki Nippon Tourist Kyushu Co., LtdKinki Nippon Tourist Chugokushikoku Co., Ltd

Kinki Nippon Tourist Okinawa Inc.

Kinki Nippon Tourist Kanagawa Co., Ltd

Tourist Experts Inc.

Tourist Service Hokkaido Co., Ltd.

KNT Business Create Co., Ltd.

United Tours Co., Ltd.

and other Group CompaniesEvent & Convention House, Inc.

7. International transfer of EU personal data
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.

8. Customer's EU personal data will be kept for 2 years and then properly erased and discarded
9. 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 etc. 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 thatcomputer is readable, and the right to relocate (shift) the EU personal data to themanagement 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 shall not perform profiling.

If customers are dissatisfied with the processing of EU personal data of this company,
customers may make a complaint to the supervisory authority of EEA member country, or
the inquiry desk of this company.
In addition, customers have the right to withdraw their consent at any time, andwithdrawing the consent shall not affect the legitimacy of processing and transferring ofEU personal data before withdrawing.

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

Director in charge of general affairs and public relations department
KNT-CT Holdings Co., Ltd.
1-7-8, Higashikanda, Chiyoda-ku, Tokyo, Japan 101-8641
Phone number: +81-3-6891-6840
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 Administration Department
KNT-CT Global Travel Co., Ltd.
2-6-1, Nishi-Shinjuku, Shinjuku-ku, Tokyo Japan 163-0236
Phone number: +81-3-6863-1011
Reception hours: 9: 15 ~ 18: 00(excluding weekends, holidays and from 29 Dec. to 3 Jan.)E-mail: gt-somu@or.knt.co.jp