Privacy Policy
Last Updated: June 20, 2024
Keio Plaza Hotel Co., Ltd. (“KPH”, “we”, or “us”), as a member of the Keio Group aiming
to become “the Top Brand in Trust”, considers the protection of personal information an
important social responsibility. We carry out appropriate procedures when we handle
personal information by placing our relationship of trust with our customers first andforemost. We have therefore set out our privacy policy (“Policy”) as stated hereinafter forprotecting personal information.
In accordance with this Policy, our executives and employees endeavor to handle
personal information properly.
If you are a resident of the European Economic Area (EEA), please see Appendix 1 foradditional information regarding our use of your personal information.
1. Compliance with Laws and Regulations, Etc.
(1) We will comply with the “Act on the Protection of Personal Information” (“APPI”)
and relevant laws and regulations, governmental and ministerial ordinances,
guidelines and other standards (collectively, “Laws, etc.”).
(2) We will set forth our internal rules regarding the protection and handling of
personal information, and review and continuously improve such internal rules, asnecessary.
2. Definition of Personal Information“Personal Information” as used in this Policy is information concerning a living
individual and means information that corresponds to either of:①

information that can identify a specific individual from the name, date of birth andother descriptions contained in such information (including information that canbe easily compared with other information and can identify a specific individual
thereby); or②

information containing an individual identification code.

3. Acquisition of Personal Information
We collect Personal Information from the following sources in conducting business
related to our facilities, services and products by lawful and fair methods.
① Direct acquisition from an individual: by telephone, letter (including electromagnetic records), business cards, verbally, through the internet, etc.
② Acquisition from persons with proper authorization to provide information for1

an individual: an individual applying on behalf of another, a party introducedby as second party, travel agents, business partners and agents selling retailpackaged plans.
③ Acquisition from published material or public sources: internet, newspapers,
telephone directories, books and other publications, etc.
4. Personal Information We Collect
We handle Personal Information which includes the following:① Name, gender, date of birth, address, telephone number, e-mail address, date of
marriage, business information (company name, address, telephone number,department, position), family information (names, genders, relationships,
birthdays)② Information obtained during a stay, including purchased goods and services, thecontent of special requests, findings about service preferences such as room
preferences.
③ Hotel member information, online user account information④ Information provided in the course of participating in a questionnaire survey,
promotional offer, etc.
⑤ Information collected through the use of surveillance cameras, card keys,
security system, etc.
⑥ Contact information and other related information from corporations dealing
with us, employees of agents and outside contractors, or other individuals(travel agency employees, meeting planners, event planners, etc.)
5. Purpose of Use of Personal Information
When we collect Personal Information from customers, we shall clarify the purpose of its
use and use the information within the scope indicated below. For any use of theinformation beyond the indicated scope, we will do so only after obtaining the consent of
the customer, with the exception of statutory exceptions.
(1) Personal Information of customers① Registration of customer information according to laws and regulations② Sending our Sending our information about various benefits, product plans andevents, and distribution by email or other electronic means.
③ Management of member information in each membership and for the use ofservices, etc. offered to members.
④ For persons who provided opinions on questionnaires, etc., to contact them byletter, telephone or e-mail.
⑤ To contact regarding guidance, confirmation, etc., to ship products, forpayments/settlements of charges, or similar matters.

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⑥ For inquiries, confirmations, requests, etc. concerning our services when thecustomer makes purchases or reservations, etc.
⑦ Other uses related to our overall provision of services.
※ When sending newsletters, etc. of the Keio Plaza Hotel chain, there may beinstances where leaflets and other materials concerning products and services ofeach Keio Group company may be enclosed therewith, however, the customer’s
Personal Information will not have been provided to such other companies.
In addition, there may be instances where we analyze information regarding thecustomer’s access and purchase histories, etc. on the website, and use such information
for the following purposes:① Use for advertising for new products and services of the Keio Plaza Hotel chain
according to the customer’s interests and preferences; and② Use for usage trend investigations, new product development, and customer
satisfaction surveys.
(2) Personal Information of business partners① Carrying out meetings, etc. with business partners② Providing information and communicating with business partners③ Executing services entrusted by business partners④ Services in connection with each of the above(3) Personal Information of employees, officers and other Keio members① Calculation and payment of wages② Security management for the Keio members③ Personnel management concerning Keio members④ Services in connection with each of the above(4) Personal Information of applicants for employment① Our hiring activities and personnel and security management after hiring, andservices in connection therewith.
6. Provision to Third Parties
Unless otherwise permitted by the laws and regulations, we will not provide Personal
Information to third parties without obtaining the individual’s consent.
7. Entrustment
We may entrust services to a third party, in whole or in part, for the services of sending
information regarding products and services to customers and for the analysis and3transactions, etc. of the provision and purchase histories of products and services andother information. In such instance, we will conduct necessary and proper supervision of
the entrustee.
8. Provision to Overseas Third Parties(1) Unless otherwise permitted by the laws and regulations, we will not provide
Personal Information of the customer to overseas third parties without obtaining
the customer’s consent.
(2) Since we are a member of “Preferred Hotels and Resorts” (head office location: USA,preferredhotels.com) (“PHR”), we are entrusted and conduct services concerning
the provision of services in connection with point services, etc. for PHR members
based on the collaboration agreement with PHR, through the cloud services, etc.
described in Article 11(7). Please confirm the privacy policy and terms of use
provided by PHR for the handling of personal information by PHR.

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9. Joint Use
We will jointly use the customer’s Personal Information as follows:(1) Personal data that will be jointly used
① ①, ② and ③ of “Personal Information We Collect” in Article 4 of this Policy.
② Information on business cards, including names, addresses, telephone numbers,
e-mail addresses, departments, and job titles.
(2) Scope of joint users and purposes of use① Scope and purpose of joint use of personal data in(1)①
Purpose of Use
Accommodations,

・Providing decorations, flower

foods andarrangements, costumes,

beverages,

beauty services, MCs,

banquets, etc.

staging, writings,

Sharers
Use with providers of said
products and services

photographs, gifts, and otherproducts and services
・Providing packaged plansincluding medical checkups,
esthetic services, and otherproducts and services
In-house facilities,
etc.

・Payments and providing
services such as theUse with providers of said
services

swimming pool, massages,
tenants, and other services
Management of・Providing membership data

Use with the Keio Plaza Hoteleach member

and registration

chain (Keio Plaza Hotelgroup, etc.

management, point services,

Sapporo) and service providers

and other services

that provide such services

Other uses

・Providing services other than
the above according tocustomer requests

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Use with business partners
and providers of said services

② Scope and purpose of joint use of personal data in(1)②
Purpose of Use

Scope of joint users

・ To notify, communicate, and share

Keio

Group

companies

(For

more

information related to the "Purposes

information on each company, please visitof Use of Personal Information" as

the following website.)

described in Article 5(2) of this policy.

https://www.keio.co.jp/group/index.html

・To introduce and provide information
on products and services handled by
Keio Group companies(3) Parties responsible for the management of shared personal data
① Party responsible for management of joint use of personal data in(1)①2-2-1 Nishi-Shinjuku, Shinjuku-Ku, Tokyo
Keio Plaza Hotel Co., Ltd.
Personal Information Protection Officer: Nobuhiko Yamakawa, Managing Director② Party responsible for management of joint use of personal data in(1)②Keio Corporation(Please check https://www.keio.co.jp/company/corporate/summary/index.html for
address and name of representative.)
10. Request for Disclosure, etc. of Retained Personal Data
When there is a claim for disclosure of such retained personal data from the individual
or an agent thereof, we will respond thereto within a reasonable period (in principle, 2weeks; however, 30 days is expected if the response requires time such as if there aremany cases or if there is a difficult claim) and to the extent necessary, except in thefollowing instances. Further, if we will not make such disclosure or there is no suchretained personal data, we will respond to that effect.
① if there is the likelihood of harming the life, body, property or other rights andinterests of the individual or a third party;② if there is the likelihood of causing significant interference with the proper
execution of our services; or③ if it will violate a law or regulation.
In addition, we will investigate and respond in accordance with the laws and regulations
when there is a claim for revision, addition or deletion, or a claim for suspension of use
or removal or suspension of third party provision in relation to such retained personal
data from the individual or an agent thereof.
For details on procedures concerning these requests (necessary documents, reception
method, identity verification method, fees, etc.), please contact the Inquiry Desk for6Personal Information Protection.
11. Security Management Measures(1) Enactment of basic policyThis Policy is provided to secure the proper handling of Personal Informationand to give notification of the inquiry desk for questions and complaint
processing.

(2) Maintenance of rules regarding the handling of Personal Information
Enactment of personal information protection regulations with respect to thehandling method, responsible persons, and their duties, etc. regarding theacquisition, usage, storage, provision, deletion, disposition, etc. of Personal
Information(3) Organizational security management measuresEstablishment of the responsible person for the handling of Personal
Information (personal information protection officer)

Clarification of the employees handling Personal Information and the scope of
the Personal Information that such employees will handle



Maintenance of the reporting and communication system to the personal
information protection officer in the event a fact of a breach of a law or internal
rule or an indication thereof becomes knownPeriodically conduct self-inspections and audits of the handling status of
Personal Information(4) Personal security management measuresPeriodically conduct training and educational activities of employees withrespect to points to consider regarding the handling of Personal Information

Statementofmatters

concerning

confidentiality

regarding

Personal

Information in the work rules(5) Physical security management measuresManage the entry and exit of employees and execute measures to prevent
unauthorized persons form accessing Personal Information in the information
system room, which manages data including Personal Information

Permit the use of or properly restrict external storage devices, and periodicallyconfirm the usage status thereofTake measures to prevent thefts or losses of equipment, electronic media anddocuments that handle Personal Information(6) Technical security management measures
Execute access controls and limit the scope of persons in charge and Personal
Information that is handledIntroduce mechanisms to protect the information system handling Personal

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Information from outside unauthorized access or unauthorized software(7) Understanding the external environment
With respect to the handling of certain Personal Information※1, cloud services of acompany that has established servers in the U.S.A.※2 is used, and security
management measures are implemented upon understanding the system for theprotection of personal information in the U.S.A. (In the U.S.A., while the APPI exists
in some states, there is no comprehensive APPI as federal law, and the system of thecompany managing such system is such that the personal information of thecustomer cannot be handled. In addition, if claims for disclosure or claims for
suspension of use, etc. are made by customers, there is a system in place to lawfully
respond thereto.)※1 Handling in the foreign language accommodation reservation system and themember management system of “Preferred Hotel and Resorts” of which we are amember of.
※2 There are descriptions on the home pages, etc. of the Personal Information
Protection Commission and other administrative agencies regarding the system forpersonal information protection in the U.S.A.; please confirm such home pages, etc.
Personal Information Protection Commission Home Page
https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/#gaikoku


If personal information will be handled overseas other than as the above, takesecurity management measures upon understanding the system for theprotection of personal information in such country.

12. Audits
We conduct periodical audits on the implementation of this Policy and improve ourprocedures.
13. Website
Our website pays the utmost attention to handling and protection of Personal
Information in accordance with this Policy so that all users may use the website
comfortably and safely. However, we are not responsible for the security of users’
Personal Information on third-party websites linked to our website.
We encourage customers to check the privacy policies of websites that you visit before
submitting Personal Information.
① Cookies
Our website uses cookies for some services to ensure that we can provide thebest service.
Cookies are a type of data sent by website servers to a user’s computer. The
cookies used on our website are for the purpose of providing proper information,

8and do not contain any data that can be used to identify the user. Customers
can disable cookies by changing the browser settings, but this may result in an
inability to access some or all of the services provided on our website.
② Access log
This website records the information of a person accessing it in the form of anaccess log. The access log includes the domain name and IP address of theaccessing person, the type of browser used, and the date and time of access, butdoes not contain information that can identify a specific individual. Access logs
are used for statistical analysis for website maintenance and usage, and for noother purposes.
14. Pseudonymized Information(1) We will create pseudonymized information that is processed so that the individual
cannot be identified unless it is compared with other information and will analyze
such information to the extent of the purpose of use set forth in article 5 of this Policy.
Furthermore, if a purpose of use set forth in article 5 of this Policy is changed, we
will publicize the changed purpose of use on our homepage, etc.
(2) When creating the pseudonymized information, we will process the Personal
Information pursuant to the standards set forth in the APPI, the Personal
Information Protection Committee Rules and other laws and regulations.
(3) When pseudonymized information is created, or when pseudonymized informationand deletion information, etc. regarding such pseudonymized information is
acquired, we will take measures for the security management of the deletion
information, etc. pursuant to the standards set forth in the Personal Information
Protection Committee Rules as measures necessary for preventing the leakage ofdeletion information, etc.
15. Anonymized information(1) When creating the anonymized information, we will process the Personal
Information pursuant to the standards set forth in the APPI, the Personal
Information Protection Committee Rules and other laws and regulations.
(2) When anonymized information is created, we will take measures for the security
management to prevent the leakage of descriptions, etc. and the individual
identification code deleted from the Personal Information used for creating theanonymized information, and information concerning the processing method
conducted pursuant to the provisions of the preceding paragraph (limited to
information that enables the restoration of such Personal Information by using suchinformation).
(3) When creating the anonymized information, we will publicize the items of9

information concerning an individual contained in such anonymized information on
our homepage, etc.
16. Revisions of the Policy
Important revisions to this Policy will be announced on our website. We may revise thisPolicy without notice, however, so please confirm the latest version on our website.
Please note that we shall bear no responsibility for any trouble caused by failure toconfirm the Policy in advance.
17. Inquiry Desk for Personal Information Protection
Membership Office
Keio Plaza Hotel Co., Ltd.
2-2-1 Nishi-Shinjuku, Shinjuku-Ku, Tokyo, 160-8330, Japan
Tel: +81-3-3344-0111
E-mail: member-rlt@keioplaza.co.jp
Hours: Weekdays 10:00 A.M. ~ 5:30 P.M. / except Wednesday, weekends, national

holidays and the New Year holidays※Reservation confirmations of our accommodation, food and beverage, banquet andother business facilities are handled by the inquiry desk of business facility.
2-2-1 Nishi-Shinjuku, Shinjuku-Ku, Tokyo
Keio Plaza Hotel Co., Ltd.
Katsuyoshi Wakabayashi, President and CEO

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Appendix 1

Additional Provisions Applicable to Processing of Personal Information of EEA
Residents
For individuals residing in the EEA, this Appendix outlines certain additional
information that KPH is obligated to provide to you, as well as certain rights you havewith respect to the processing of your personal information, based on the General Data
Protection Regulation (GDPR). This Appendix will control to the extent it conflicts withany provision in the main body of this Policy.
1. Processing of Personal Information
The purposes, the categories and the sources of personal information that we handle,
and the provision of the customer’s personal information to third parties are set out inarticles 3 through 9 of the Policy.
2. Legal Basis
We process customer’s personal information based on the customer’s consent in principle.
The processing of personal information in the absence of the customer’s consent shall bebased on the necessity for the performance of the contract with the customer, thenecessity to take steps at the request of the customer prior to entering into a contract,
the necessity for the purposes of the legitimate interests pursued by us or a third party,or the necessity for compliance with a legal obligation to which we are subject. The
legitimate interests pursued by us or a third party include an increase in operating
income from marketing and improvement of services, and improvement of theconvenience, security, etc. of our website.
3. Transfer of Personal Information to a Third Country.
For the purposes of fulfilling the contract with the customer, or for taking procedures
according to the customer’s request prior to entering into a contract, personal
information acquired outside Japan will be transferred to Japan. We handle thecustomer’s personal information with appropriate security and confidentiality measures.
4. Retention Period
We retain personal information for the period necessary to accomplish its purpose ofprocessing. Following the retention period, we eliminate or anonymize such personal
information in a secure way within a reasonable period of time.
5. Customer’s Rights
You have the following rights with respect to us based on Laws, etc. A customer may

11exercise these rights by contacting the Inquiry Desk for Personal Information stated inarticle 17 of the Policy. In the event that you exercise these rights, we will respond ingood faith, barring statutory exceptions, after confirming that the requesting person is
the person in question.
① The right of access
The right to obtain confirmation as to whether or not personal information
concerning you is being processed, and where that is the case, access to thepersonal information and the accompanying information② The right to rectification
The right to obtain the rectification of inaccurate personal information
concerning you③ The right to erasure
The right to obtain the erasure of personal information concerning you in
certain cases④ The right to restriction of processing
The right to obtain restriction of processing in certain cases⑤ The right to object to processing
The right to object the processing of personal information based on the purposesof the legitimate interests pursued by us or third parties.
⑥ The right to data portability
The right to receive the personal information concerning you, which you haveprovided to us, in a structured, commonly used and machine-readable format
and have the right to transmit those data to another controller without
hindrance from us.
6. Withdrawal of Consent
You can withdraw consent on the processing of your personal information at any time.
Withdrawing consent does not affect the lawfulness of the processing based on consent
before the withdrawal. You can withdraw consent by contacting the Inquiry Desk for
Personal Information stated in article 17 of the Policy.
7. Lodging a Complaint with an Authority
Customers have the right to lodge a complaint on the processing of their personal
information with the protection authority having jurisdiction over their residence.
8. Personal Information Necessary for Accommodations
We require the following information to provide accommodation services to ourcustomers. In particular, the laws of Japan require that we keep the information on the
hotel register for three years. Should you be unable to provide the required information,12

we may not be able to provide you with accommodation services.
① Basic information (name, telephone number, etc.)② Hotel register items (name, address, occupation, nationality, passport number,sex, age, etc.)
9. Personal Information from Children
A guardian’s consent or permission must be obtained in the event that a customer under
the age of 16 uses our service and consents to the Policy.
10. Automated Individual Decision-Making, including profiling
We do not make decisions based solely on automated processing, including profiling.

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