Concerning Protection of Personal Information

Mitsui Fudosan Resort Management Co., Ltd. (hereinafter "the Company") is a member of the Mitsui Fudosan Group.In addition to the resort business, the Mitsui Fudosan Group engages in various other businesses, including the hotel business, the housing and living-related business, the commercial facilities business, the office buildings business, and the logistics business (for details, please refer to the website of Mitsui Fudosan).
For the Company's personal information protection policy, please see below.
Personal Information Protection Policy

Purposes of use

The Company and its group companies (which refers to and hereinafter refers to Mitsui Fudosan Co., Ltd. and the consolidated subsidiaries listed in the Annual Securities Report, etc. of Mitsui Fudosan Co., Ltd. (iIncluding Halekurani Corporation)) will use shared personal information to the extent necessary to achieve the following purposes of use.

1. To provide products and services related to our business

Examples of our business are –
  • hotel management and administration
  • management and administration of restaurants and bars
  • management and administration of spas
  • management of uniquespecial public bath houses
  • the sale of alcoholic beverages, tobacco, revenue stamps, and postage stamps
  • the sale of medical supplies, foodstuffs, furniture and appliances, household goods and sundries, newspapers and magazines
  • real estate transactions, leasing, and management
  • the sale of alcoholic beverages, tobacco, revenue stamps, and postage stamps
  • the sale of souvenirs, foodstuffs, furniture and appliances, household goods and sundries, newspapers and magazines, and acting as agents for such sales
  • dealing in dealing antiques andsecondhand goods or antiques, and the sale of arts and crafts
  • marine transportation
  • management of vessels and, boat rental and repair
  • car rental business, and car park management
  • travel business and travel agency
  • general passenger motor vehicle transport business
  • real estate leasing and management
  • all other businesses incidental to the preceding items.
Examples of purposes of use may include the following
  • accommodation reservations and stay management (including reservations and applications for activities such as golf and skiing; and reservations and applications for relaxation such as spas and massages)
  • ordering, shipping, and payment management for products, and delivery of billing materials
  • sales activities by mail, e-mail, telephone, etc.
  • to manage membership information in the membership organizations operated by the Company
  • to provide services for members
  • to contact customers by mail, email, telephone, etc., and to respond to einquiries in relation to transactions with customers and the provision of services to members
  • to provide security, emergency response, or fraud countermeasures.

2. To introduce products and services* handled by the Company and its group companies and to provide various types of information and special offers in relation to clothing, food, housing, recreation, and work of customers.

Examples include the following purposes of use –
  • to provide information on various seminars, campaigns, and events*
  • to deliver behavioral targeted advertising* (an advertising method that analyzes information such as acquired web browsing history and service usage history to estimate customer attributes and interests, and adjust the content of advertisements) using an ad-serving company
  • to provide discounts or other benefits when using vouchers and services

*These include services based on the analysis of transaction history and other information obtained by the Company or its group companies to estimate customer attributes, interests, etc.
The information, distribution, and provision referred to above will be made by telephone, letter or postcard etc., mail magazine, or direct mail.

3. To develop and improve products and services handled by the Company and its group companies in relation to clothing, food, housing, recreation, and work of customers, and additionally to conduct marketing activities, surveys, and analyses, such as market research, in order to provide better products and services to our customers.

Examples include the following purposes of use –
  • development and improvement of products and services
  • conducting questionnaires
  • customer trend analysis
  • verifying effectiveness of sales promotion activities and formulating sales promotion plans.

4. To provide information to third parties in order to achieve the Purposes of use 1 through 3 above.

Acquisition of information related to individuals

The Company uses data collected by cookies, or advertising IDs (smartphone device identifiers), etc. (hereinafter referred to as "cookies, etc.") from third-party data service providers to obtain web browsing and usage history as well as the results of analysis, which are then linked to each customer’s personal data and used for advertising distribution and other purposes.
In addition, the Company uses data collected by cookies, etc. to obtain web browsing or usage history as well as the results of analysis thereof from the Company's group companies, which are then linked to each customer’s personal data, and used to the extent necessary to achieve the purposes of use described in 1 through 3 in the above "pPurposes of use".

Provision to Third Parties

  • 1. In addition to cases in which the Company is required by law, the Company will provide personal data of customers to third parties, such as the Company's group companies, tenants and subcontractors of the Company's hotels, as well as providers of point exchange items (gifts) to the extent necessary to achieve the purposes of use described in "pPurposes of use" above.
  • 2. 1. The information provided includes the name, address, telephone number, and other items necessary to achieve the purpose of each use, but will be limited to the minimum necessary items.

    Examples of personal data to be provided –
    • items registered or submitted in connection with the MGH Rewards Club operated by the Company
    • the history of points used, etc.
    Third parties that are provided with personal data (examples) –
    • our group companies
    • tenants and subcontractors of hotels operated by the Company, as well as providers of point exchange items (gifts).
  • 3. When providing information to a third party in writing, by mail, telephone, fax, e-mail, or electronic media, etc., the Company shall deliver the information with due consideration of security control, and when providing electronic data, the Company shall ensure that encryption and other necessary measures are taken as part of the delivery process.
  • 4. The company will cease providing youra customer’s personal information to third parties at the request of athe relevant customer, in accordance with the provisions of the Personal Information Protection Law. The customer should contact the "Mitsui Fudosan HotelResort Management Co., Ltd. Customer Service Center" to make such a request. Please be aware that the customer may not be able to receive some or all of the Company’s services due to the cessation.

Joint Use

The Company shares personal data of customers as follows:

  • 1. Items of personal data to be shared –
    name, address, date of birth, telephone number, e-mail address, information on transaction history, etc.

    Examples of personal data to be shared –
    • items registered or submitted in connection with the hotels operated by the Company
    • points usage history/li>
    • service provision history, etc.
    • history of business negotiations and discussions, etc.
  • 2. The extent of joint users –
    Our group companies
  • 3. Purposes of use by joint users –
    Same as purposes of use 1 through 3 listed in "Purposes of use" above
  • 4. Party responsible for joint use –
    Mitsui Fudosan Resort Management Co., Ltd. (Mr. SUDO Wataru, President and CEO, Head office: 3-2-1 Nihonbashi-Muromachi, Chuo-ku, Tokyo 103-0023, Japan; President and CEO: Mr. SUDO Wataru, President and CEO,)
    In order to provide services to customers in an integrated manner as the Mitsui Fudosan Group, the Company will jointly use the personal data of customers acquired by our group companies and endeavor to keep it up-to-date and accurate at all times.

Measures Taken for Security Management

The Company will comply with relevant laws, regulations, and guidelines, and take necessary and appropriate measures to prevent leakage, loss, or damage of the personal data that it handles and to otherwise manage personal data in a secure manner (hereinafter referred to as "Security Management Measures"). The Company will take the following measures.

Formulating Basic Policy

The Company has established a basic policy to ensure the proper handling of personal data. (Please click here for the basic policy.)

Establishing rules in handling personal data

The Company has established internal rules governing how personal data is handled, who is responsible and in charge, and their duties.

Organizational security management measures

Each division and department of the Company has an "Information Security Manager" who is responsible for the handling of personal information, and who is responsible for evaluating and improving security management measures by reporting on the handling of personal information on an annual basis.
In addition, the Company has a system in place to ensure that employees (including contract employees and temporary staff) comply with internal regulations concerning security management measures, and to report and inform the person in charge if they become aware of any fact or indication that an employee is in violation of the law or internal regulations.

Human security management measures

The Company provides its employees with education and training on the proper handling of personal information.

Physical and technical security management measures

The Company controls the entry and exit of employees to areas where personal data is handled, and secures and locks equipment or devices that hold personal data.
In addition, the Company controls access to personal data and to information systems that handle personal data, takes countermeasures against malicious software, and monitors information systems.
For example: prohibiting the storage of personal data on local disks, periodical change of authentication passwords, obtaining and analyzing operation histories.

Understanding the External Environment

When storing customer’s personal data on servers located in foreign countries, the Company implements security measures to ensure an understanding of the systems in place for the protection of personal information in each country. For further information, please contact the following office.

HOTEL THE MITSUI KYOTO, Kyoto Business HQ, Mitsui Fudosan Resort Management Co., Ltd.
284 Nijoaburanokoji-cho, Aburano-koji St. Nijo-sagaru, Nakagyo-ku, Kyoto 604-0051
TEL: 075-468-3100(the main phone number)
FAX: 075-468-8998

Consultation and complaints regarding handling of personal information

In accordance with the provisions of the Personal Information Protection Law, for details on the disclosure, correction, addition, deletion, cessation of usage, or erasure of personal information, and on necessary measures to ensure the continuous implementation of appropriate measures (hereinafter collectively referred to as "disclosure, etc."), please contact the following office.

HOTEL THE MITSUI KYOTO, Kyoto Business HQ, Mitsui Fudosan Resort Management Co., Ltd.
284 Nijoaburanokoji-cho, Aburano-koji St. Nijo-sagaru, Nakagyo-ku, Kyoto 604-0051
TEL: 075-468-3100(the main phone number)
FAX: 075-468-8998

For specific procedures for disclosure, etc., please refer to the Procedures for Disclosure of Personal Information.

Procedures for Disclosure of Personal Information

1. Request for Disclosure, etc.

Requests for disclosure, etc. must be made with the required documents by mail to the address below. Please kindly write "Request for Disclosure of Personal Information enclosed" in red ink on the envelope.

HOTEL THE MITSUI KYOTO, Kyoto Business HQ, Mitsui Fudosan Resort Management Co., Ltd.
284 Nijoaburanokoji-cho, Aburano-koji St. Nijo-sagaru, Nakagyo-ku, Kyoto 604-0051
TEL: 075-468-3100(the main phone number)
FAX: 075-468-8998

2. Documents (or forms) to be submitted for disclosure procedures, etc.

To request disclosure, please download the following request form (A), fill in the required items, enclose documents for identification (B), and send it by post to the address in (1) above.

  • AThe prescribed form fromby the Company
    Personal Information Disclosure Request Form (PDF)
  • BDocuments for identification
    One copy of a driver's license, passport (with address) or health insurance card (the symbol or the number, etc., of the insured person being masked in advance; same belowthe same requirement applies hereinafter).

3. Requests for disclosure by proxy

If the person making the request for disclosure is a legal representative of a minor or an adult ward or a representative authorized by the customer to make the request for disclosure, please enclose the following documents (either A or B) in addition to the documents listed in 2. above.

  • A.In the case of a legal representative –
    • One copy of a document confirming the right of legal representation (copy of the family register, or in the case of a person with parental authority, a copy of the insurance card with the dependent’s' names filled in is also acceptable)
    • One copy of a document to confirm the identity of the legal representative (a copy of the legal representative's driver's license or health insurance card).
  • B. In the case of an authorized representative –
    • One copy of letter of attorney
    • One document confirming the identity of the proxy (copy of the proxy's driving license or health insurance card).

4. Fees and how they are collected

In the case of a request for disclosure or notification of purpose of use, a fee of 1,500 yen (including tax) is required for each application. The fee of 1,500 yen in the form of a fixed-sum money order (issued by a post office) must be enclosed with the request documents. No fee is required for requests for correction or suspension of use.

*Customers are responsible for the cost of postage to the Company and for the fees for obtaining a fixed-sum money order.
*We will contact and inform the customer iIf the fee is insufficient, or if the fee is not enclosed,; if the required payment is not made within the prescribed period, we will inform the customer of this, but we will assume that the request for disclosure has been withdrawnif payment is not made within the prescribed period, we will assume that no request for disclosure has been made.

5. Method of response to requests for disclosure, etc.

The response will be sent by post mailed to the address for notification given in the Request Form for Disclosure of Stored Personal Data. If the customer wishes to requests disclosure byin digital form electromagnetic record, we will save the data on electronic media and we will reply by post after storing the data on a mediumwith the electronic media enclosed.

6. "Purpose of use" of personal information obtained in connection with a request for disclosure, etc.

Personal information obtained in connection with a request for disclosure, etc. shall be handled only to the extent necessary for the request for disclosure, etc.

7. On non-disclosure of "Stored Personal Data"

The following cases will be considered as non-disclosure. Even in the case of non-disclosure, the required fee will still be charged.

  • when the address on the request form does not match the address on the documents for identification, or when the identity of the applicant cannot be confirmed
  • when the right of representation cannot be verified for a request by a proxy
  • cases in which the subject of the request for disclosure does not fall under the category of "Stored Personal Data"
  • if there is a risk of harm to the life, body, property, or other rights or interests of the person named in the request for disclosure or a third party
  • if there is a risk of significant hindrance to the proper conduct of the Company’s business
  • if it would violate other laws and regulations.

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