As of July 1, 2022

Privacy Policy
Oriental Hotel Okinawa Resort & Spa (hereafter the Hotel or "we") and the Group Hotels consisting ofthe hotels operated by Hotel Management Japan Co., Ltd. ("HMJ") or its subsidiaries, including Hilton
Narita, International Garden Hotel Narita, Oriental Hotel Tokyo Bay, Holiday Inn Osaka Namba, Namba
Oriental Hotel, Kobe Meriken Park Oriental Hotel, Oriental Hotel Hiroshima, Oriental Hotel Fukuoka
Hakata Station, Hotel Oriental Express Osaka Shinsaibashi, Hilton Tokyo Odaiba, Okinawa Harbor View
Hotel, Oriental Hotel Kyoto Rokujo, Oriental Hotel Universal City, Hotel Oriental Express Fukuoka
Nakasu Kawabata, Hotel Oriental Express Fukuoka Tenjin, Hotel Oriental Express Tokyo Kamata, Hotel
Oriental Express Nagoya Sakae, and Oriental Suites Airport Osaka Rinku, collectively 18 Group Hotels,as well as HMJ and its subsidiaries KK Narita Kosuge Operations, KK NaritaYoshikura Operations, OW
Hotel Operations KK, KK Hotel Centraza, KK Lagoon Resort Nago, KK Hotel Oriental Express, KKTokyo Humania Enterprise, KK Kyoto Horikawa Operations, KK Osaka Sakurajima Operations, KKFukuoka Tenya Machi Operations, KK Fukuoka Tenjin Operations, KK Anoma Operations, and KK OsakaRinku Operations recognize that personal information is important and strive to protect privacy,
complying with the Act on the Protection of Personal Information and other applicable laws andregulations, applicable guidelines, etc. as well as the EU General Data Protection Regulation (GDPR)(collectively, the Laws).
We may collect information on our individual guests and personal information on individuals related toour corporate or group guests in the course of providing various services.
Collecting such personal information is important to provide our guests with the highest level of services,
but at the same time we fully recognize that we are expected to properly handle such personal information.
This Policy states what personal information we collect, for what purposes we use personal information,with which third parties we share personal data, and what safeguards we take to protect personal data.

1. When We Collect Personal Information (Sources of PersonalInformation)
We collect your personal information mainly through the interactions listed below. The personal
information provided by you is necessary for us to provide our services to you. Certain services may
not be available to you if your personal information is not provided to us.
(1) Guest registration card to be submitted by you;
(2) Application form for wedding/banquet;(3) Application form for use of our accessory facilities;(4) Application form for our membership program and other similar documents;(5) Records made at the time of your visit or telephone call to the Hotel; and(6) Booking information through certain websites.

2.

Personal Information We Collect and Purposes of Its Use

We use the personal information collected from you for the purposes shown in the below table.
Personal Information
1Name,address,

Purposes of Use

telephonenumber, e-mail address and(1) For contacting you by mail, telephone, e-mail, facsimile
or other means in connection with the use of the Hotelother contact information(2) For providing you with information on products and/or2

Attribute information such as
age,

dateofbirth,

services provided by the Hotel or Group Hotels

sex,

occupation, job position, title,(3) For facilitating business operations within the Hotel suchand main duties, etc.

as the administration of your usage of the Hotel (including

Information on your usage

and the provision of your personal information to service

history, hobbies, etc.

providers in association with the entrustment of certain

the provision of your personal information to third parties
3services to them, with your consent set forth in Section 3)(4) For facilitating business operations between certain
Group Hotels or within all the Group Hotels(5) For conducting analyses in order to improve the Hotel’sor Group Hotels’ services and products(6) For providing you with information on the Hotel’s orGroup Hotels’ services and/or products(7) For other purposes similar to or closely related to any ofthe above purposes

If you are receiving our services through our website, the information listed in the below table isalso used for the following purposes.

1Personal Information

Purposes of UseYour cookies (A cookie is a(1) For ensuring security

small

text

filecontaining

information designated by a
website and temporarily placedon your personal computer via
a web browser.)(2) For facilitating your use of our website

2Your access logs (Examples:(1) For analyzing your use of services of the Hotel, as wellwhich pages of our website

as the value, performance etc. of the Hotelyou have accessed, how often
you have accessed our website,(2)etc.)advertisements on your deviceFordisplaying

ourlistings

and/ortargeted(3) For improving our services and the convenience ofvisitors to our website

Even if the relationship between you and the Hotel terminates due to your withdrawal from ourmembership program or for any other reasons, we continue to handle your personal information inaccordance with this Policy as long as we retain your personal information subject to the provisions ofSection 5.
We strive to keep the personal data held by us accurate and updated. If there are any changes to yourpersonal information, please inform us of such changes promptly.

3.

Provision of Your Personal Data to Third Parties
We do not provide your personal data to any third party unless we have obtained your consent. If
we entrust the handling of your personal data to a third party to the extent necessary to achieve thepurposes of use of your personal data, we instruct the third party to properly control your personal
data and also properly supervise the third party.
Please note, however, that we may provide your personal data to a third party in order to cooperate
in responding to a request for disclosure of such personal data that has been made based on legal
grounds by a person who is duly authorized by judicial or administrative authorities, or otherwise
as permitted by the Laws.

4.

The Basis for Processing Your Personal Information
We process your personal information based on one or more of the items listed below:(1) You have given your consent to the processing of your personal data for one or more specificpurpose set forth in Section 2;(2) Processing of your personal data is necessary for the performance of a contract between you andthe Hotel, or in order to take steps at your request prior to entering into a contract;(3) Processing of your personal data is necessary for compliance with a legal obligation that the Hotelis subject to;(4) Processing of your personal data is necessary in order to protect your vital interests or those of athird party;(5) Processing of your personal data is permitted for the performance of a task carried out in the public
interest or in the exercise of official authority vested in the Hotel; and(6) Processing of your personal data is necessary for the purpose of the legitimate interests (which arelisted below) pursued by the Hotel or a third party, except where such interests are overridden by yourfundamental rights and freedoms:a.

Our business operations;b.

Improving our services and developing new services;c.

Researching and analyzing your usage of the Hotel;d.

Ensuring the safety of our guests, employees, and officers of the Hotel;e.

Direct marketing to you;f.

Making legal claims, insurance claims, or other similar claims by us or a third party;g.

Increasing vital public interests by us or a third party;h.

Providing public authorities with information relating to a criminal offence or threat to publicsecurity.
As it is necessary to provide services to guests, we process personal information of guests that has
been collected within the EEA after transferring such personal information from the EEA to Japanin accordance with Article 49, Paragraph 1 (b) of the GDPR.

5.

Retaining and Erasing Your Personal Information
We retain your personal information under our control only for the period required for achieving thepurposes of its use and erase it within a reasonable period of time after the retaining period has
elapsed.

6.

Rights of Guests
You have the following rights if you satisfy certain requirements under the Law. (Please refer to Section 9
regarding the methods for exercising the rights or contacting us.)
(1) You have the right to request us to explain about your information held by us and how we use suchinformation;(2) You have the right to obtain a copy of your personal data held by us upon payment of a fee set byus;(3) You have the right to have us correct your personal data held by us if such data is incorrect;(4) You may request us to erase your personal data under our control, and we will erase your personal
data in accordance with your request. However, we may retain your personal data under certain
circumstances permitted by the Law;
(5) You have the right to receive your personal data and transfer it to another controller;(6) You have the right to object to any use of your personal data. However, even if you raise anobjection, we may continue to process your personal data to the extent permitted by the Law;
(7) You have the right to request us to restrict our processing of your personal data. Specifically,
you have the right to object to use of your personal data for direct marketing purposes;(8) You may lodge a complaint with the supervisory authorities; and(9) You may withdraw your consent to us regarding use of your personal data.

7.

Safeguards for Personal DataWe have adopted the highest standards on information security in order to protect your privacy andthe confidentiality of your personal data. We only allow authorized employees or agents to accessyour personal data. In addition, we impose strict confidentiality obligations on service providers
that we use. We are taking physical, electronic, and procedural safeguards to prevent loss, misuse,damage, falsification and leakage of, and unauthorized access to, your personal data.
The other features of our information security program include:(1) Using specialized technologies such as Firewall;(2) Testing the safety and operability of products and services that will be used on the internet
before actually using them, and closely examining the generally known vulnerabilities oftechnologies on a constant basis;(3) Conducting internal and external audits of services that are provided through our website or
the internet;(4) Striving to identify vulnerabilities or possible threats of hacking by monitoring theinfrastructure of our systems;(5) Controlling access to various websites and systems by verifying the identity and authority ofpersons; and(6) Training our employees and addressing new risks and development of technology in order
to always keep our security measures updated.

8.

About This Policy
This Policy is subject to change to reflect our actual collection and use of your personal information.
The policy after such changes becomes effective at the time when the changed policy is publishedon our website. The latest revision of this Policy was made on July 1, 2022.

9.

Contact Us
You may request us to disclose your personal data held by us. When requesting such disclosure, youneed to submit an identification document to us in order to prevent the leakage of your personal data
to any person other than you. We handle such requests for disclosure in accordance with the Law.
If we receive your request made in accordance with Laws to correct, add, or delete the content ofyour personal data held by us, or to stop using, erase, or suspend the provisions to a third party ofyour personal data held by us, we handle such requests in accordance with the Law.
If you wish to request the disclosure, correction, etc. of your personal data held by us, or if you needdetailed information on our Privacy Policy or the protection of personal information, please contact
us below. (If you wish to request the disclosure, correction, etc. of your personal data held by us,please download the application form below on our website, complete it, and send it to the contact
below by mail.)Please note that the Hotel may charge you expenses actually incurred in association with theprocedure for disclosure of your personal data held by us.

Contact for inquiries regarding the protection of personal information:
Personal Information Control Manager
Oriental Hotel Okinawa Resort & Spa, General Affairs & Personnel Dept.
1490-1 Kise, Nago-City, Okinawa 905-0026 Japan
info@okinawa.oriental-hotels.com

Download of Application Form (PDF: 88 KB)
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