IN-OUTBOUND SENDAI MATSUSHIMA INC. PRIVACY POLICYOBJECTIVE

In-Outbound Sendai Matsushima Inc. (‘we’ ‘us’ or ‘our’) acknowledges the importance ofpersonal information and firmly believes it is our social obligation to protect thisinformation. We are committed to the appropriate collection, use and management ofpersonal information in strict adherence with relevant legislation as well as our company

regulations.

SCOPE OF USEThis Privacy Policy demonstrates the principles our company will adhere to in the handlingof our customer’s personal information, or equivalent information, when conducting ourservices.

COLLECTION OF PERSONAL INFORMATIONThe collection of personal information will only be conducted for clearly indicated purposes,
and only within the scope necessary for the fulfillment of specified purpose of use.

Our company receives the following information from customers:

1. Information collected in the event of making reservations, applications and otherpreparations relating to travel:

Customer’s name, address, phone number, fax number, email address, occupation,

passport information, date of birth, gender, emergency/other contact details, credit
card information and other necessary information.

The name, address, phone number, fax number, email address, occupation,

passport information, date of birth, gender, emergency/other contact details, credit

card information and other necessary information of other travelers/accompanying

members (‘other travelers’) provided by a customer when making reservations etc.
on behalf of other travelers, or as a representative or responsible member of anaffiliated group.

2. Other information collected in connection with use of our company’s services:

Information provided by customers as part of any other services not relating totravel.

Information relating to transaction records between customers and our company.
Information relating to postage of pamphlets etc. from our company.

3. Information automatically collected when accessing our webpage; including IP address,
information relating to unique identifiers of mobile devices, browser type and version,

as well as information relating to browsed pages and length of browsing.
USE OF PERSONAL INFORMATION

Personal information provided by customers will be used in the services provided by ourcompany within the scope of the purposes outlined below. Personal information will not becollected or used for any other purpose without customer consent.

1. The arrangement, provision or receipt of travel or other services provided by ourcompany or business partners.

2. Communication of product and service campaigns of our company or cooperating
enterprises, other advertising and marketing activities.

3. Communication via digital magazine, direct mailing services etc.
4. Management of customer inquiries.

5. Surveys conducted following provision of services, after-sales services following

completion or cancellation of transaction, all inquiries, management of service usage

records.

6. Creation of statistic materials, market research and development or research of otherservices.

7. Ensuring smooth dealings between our company and customers.
DISCLOSURE OF PERSONAL INFORMATION TO A THIRD PARTY

Our company will not disclose personal information to a third party without the priorconsent of the user, except in adherence to the law or in the cases determined below:

1. When necessary to protect human life, physical safety or property and it is difficult toobtain consent from the relevant party.

2. When necessary for improving public health or promoting healthy upbringing ofchildren and it is difficult to obtain consent from the relevant party.

3. When necessary to cooperate with a government organization, local public body or part
commissioned by such an organization or agency for the execution of legally prescribedmatters, and obtaining consent from the relevant party would hinder or risk impeding
said implementation of issues.

4. When content, usage history or profile information is displayed within our services
based on conditions determined by our company.

5. Provision of information as a result of the succession of business due to a merger,
company split, transfer of business or otherwise.

6. When the user is a minor and disclosure is requested by parental authority or legal

guardian, or when the user is an adult ward and disclosure is requested by a Guardian

of Adult.

7. When disclosure is judged necessary by our company to solve dissent between users orwith a third party.

8. When the information is used for the improvement of service quality or in thedeliberation, examination, research or analysis of new services.

9. When disclosure is necessary for the arrangement of tour products administered by ourcompany, travel related insurance procedures, financial procedures relating tosettlement of travel expenses, and other cases when disclosure is judged necessary tocarry out our services within the necessary scope of purpose.

10. Other cases when disclosure becomes necessary for the appropriate administration ofour services.

CONSIGNMENT OF PERSONAL INFORMATION

In order to run our affairs smoothly and provide the best level of service to our customers,

the handling of personal information may be consigned to a subcontracting partner within

the scope necessary for fulfillment of the purpose of use. In such cases, a system for theappropriate management of information will be created through careful and thoroughconsideration of the eligibility of the subcontractor, along with a duty of confidentiality

stipulated in the relevant contract.
CUSTOMER INQUIRIES

Customers may request the disclosure or details of purpose of use of their personal data

(personal information subject to disclosure), as well as the correction, amendment, deletion,suspension of use, or suspension of access by a third party to the contents of thisinformation. Relevant procedures will be explained following enquiry to the below contact
details. Necessary corrective measures will be undertaken swiftly and in adherence torelevant legislation and company regulations.

Contact details: Protection of personal information management

Inoutbound Sendai Matsushima Inc.

Address: Nippou Koutoudai Nishi Bldg. 7F, 3-11-5 Kokubuncho, Aoba-Ku,Sendai, Miyagi 980-0803 Japan

TEL：+81-22-302-7390

Email： info@inoutbound.co.jp