Privacy Policy

Club Tourism Co., Ltd.
NBF Toyosu Canal Front, 5-6-52 Toyosu, Koto-ku Kyoto 135-0061
President and CEO: Hiroshi Sakai

We will acquire Personal Information through legal and fair means that take into consideration the nature and scale of our business, and will use the information appropriately. When acquiring Personal Information, we will specify the purpose of use and, if necessary, obtain explicit consent before acquiring the information. In addition, we will develop an internal management system and take safety measures to ensure that Personal Information is not used beyond the scope of the purpose of use, except when we have the consent of the individual or when permitted by law.

We will manage Personal Information with strict confidentiality and will not disclose or provide data to third parties except when consent is obtained from the individual or when required by law.
In addition, in order to prevent the leakage, loss, or damage of Personal Information, we will take safety measures and corrective actions based on our internal regulations, such as the "Personal Information Protection Regulations" and the "Specific Personal Information Handling Regulations." The main details of these measures are as follows:

(1) Formulation of basic guidelines
・In order to ensure the proper handling of personal data, we have formulated this policy regarding "compliance with laws and regulations," "matters related to safe management measures for Personal Information," "handling complaints and inquiries," etc.

(2) Establishment of rules regarding the handling of personal data
We have established rules for the handling of personal data by formulating "Personal Information Protection Rules" and "Specific Personal Information Handling Regulations" that stipulate handling methods, responsible persons/staff and their duties for each stage, such as acquisition, use, storage, provision, deletion/disposal, etc.

(3)Organizational safety management measures
We have established an organizational structure to take safety control measures, such as appointing an administrative manager for the handling of personal data. We have also clarified the employees who handle personal data, their roles, and the scope of personal data that they handle. We have also established a system for reporting to the administrative manager in the event that we become aware of any facts or signs of violations of Personal Information Protection Act or Personal Information Protection Regulations.
We regularly inspect the status of handling of personal data ourselves and also have other departments and departments audit our status.

(4) Personnel safety measures
- We provide regular training to employees on important points regarding the handling of personal data.
- Matters concerning confidentiality of personal data are stated in the company regulations.

(5) Physical safety control measures
- We manage the entry and exit of employees to areas where personal data is managed, and take measures to prevent unauthorized persons from viewing personal data in areas where it is handled.
We manage devices, electronic media, documents, etc. that handle personal data to prevent theft or loss, and take measures to prevent leakage, etc. when transporting such devices, electronic media, etc.

(6) Technical safety control measures
・We limit the information systems and devices that can handle Personal Information databases, etc., and also limit the employees who can use those systems and devices. We have introduced a mechanism to protect information systems and devices that handle personal data from unauthorized access from outside or unauthorized software.

(7) Understanding the external environment
-In light of the fact that Personal Information protection systems in some countries are regulated lower than Japan's Personal Information Protection Act, we have concluded service outsourcing agreements with entrusted businesses such as land operators that require them to comply with the Eight Principles of the OECD Privacy Guidelines.

We will comply with applicable laws, regulations, national guidelines Other standards regarding Personal Information held by our company and will manage it appropriately.

We have established a system and procedures for receiving and responding to inquiries and complaints regarding Personal Information held by us, and will respond promptly. The contact point for inquiries and complaints regarding the handling of personal data held by our company is as follows.

個人情報に関するお問合わせ窓口
クラブツーリズム株式会社 お客様相談センター
住所：〒135-0061　東京都江東区豊洲5丁目6-52 NBF豊洲キャナルフロント
TEL： 03-4335-6263
受付時間： 9：30～17：00
（土、日、祝日、振替休日、12／30～1／3 は休業）

We will continually improve our management system and mechanisms for protecting Personal Information.

(1) We directly or indirectly obtain personal information provided to us by customers through applications or inquiries made by telephone, post, facsimile, the Internet Other means of communication, travel application forms, participation confirmations, questionnaires, product purchase applications and other such information, as well as Personal Information Personal Information such as browsing history on our website, purchasing history and behavioral history when using apps provided by our company, and we retain a portion of such information as personal data.

(2) We hold Personal Information of job applicants and employees working for our company as personal data.

(3) We retain Personal Information captured by security cameras installed in our offices as recorded video data.

(4) As we are not compliant with the EU General Data Protection Regulation (GDPR), we do not hold personal data of EEA residents.

(1) Our company and the contracted travel agency (sales agency) will use Personal Information provided in 1. above to contact customers, and will also use it to the extent necessary for the travel you have applied for, to make arrangements for transportation and Accommodation facilities (major transportation and Accommodation facilities are listed on the final itinerary) and for the procedures for receiving these services, and for souvenir shops, etc. to facilitate shopping at your travel destination. However, Other purposes of use may be announced or notified separately.

(2) Other, the Company:

(3) We will use Personal Information provided by job applicants to our company for identity verification, contact with the applicant, Other purposes necessary for the recruitment and job offer process. However, we may separately announce or notify you of Other uses in addition to the above.

(1) In order to achieve the purpose of the contract with the customer, our company will provide Accommodation information, including address, name, telephone number, gender, age, date of birth, passport number, email address, and flight name, to transportation and accommodation facilities, etc., booking agents, souvenir shops, etc., product suppliers, and external contractors by sending it by electronic means, etc., within the scope of what is necessary. When applying, we will require your Personal Information to the provision of this personal data.

(2) In the cases specified in each item of Article 27, Paragraph 1 of the Act on Personal Information, we will provide Personal Information to the extent necessary without obtaining the customer's consent.

We outsource some of our business operations, and may outsource all or part of the business that handles Personal Information to a third party. In such cases, we will select a contractor that we recognize as handling Personal Information appropriately, and entrust Personal Information to them after signing a non-disclosure agreement, etc.

We will jointly use Personal Information of customers held by our company with the following group companies for the purpose of sales promotion activities such as product development and product proposals, and for contacting and responding to customers.
Personal Information that our group companies may jointly use is as follows:
Address, name, phone number, gender, age, date of birth, passport number, email address, product purchase history, etc.

*Our group companies that share personal information (as of Apr. 1, 2022)
(1) Club Tourism Life Care Service Co., Ltd. (nursing care business, sales of travel, insurance and products, sales of daily life related services, etc.)
(2) Club Tourism Space Tours Co., Ltd. (sales of space travel, etc.)
(3) KNT-CT Holdings Co., Ltd. (holding company)
(4) Kinki Nippon Tourist Tourist Co., Ltd. (sales of travel and insurance, etc.)
(5) Kinki Nippon Tourist Okinawa Co., Ltd. (sales of travel and insurance, etc.)
(6) Kinki Kinki Nippon Tourist Blue Planet Co., Ltd. (sales of travel and insurance, etc.)
(7) Tourist Experts Co., Ltd. (tour conductor dispatch, etc.)
(8) United Tours Co., Ltd. (sales of travel, planning of trips to Taiwan)
(9) KNT Business Create Co., Ltd. (travel procedures, sending itineraries, etc.)
(10) Event and Convention House Co., Ltd. (planning and management of events and conventions)
(11) Other companies in our group

* Name, address, and representative of the company responsible for managing Personal Information in joint use (as of Jun. 26, 2023)
Club Tourism Co., Ltd.
NBF Toyosu Canal Front, 5-6-52 Toyosu, Koto-ku Kyoto 135-0061
President and CEO: Hiroshi Sakai

The measures taken by our company when entrusting the handling of Personal Information to a foreign contractor are as follows:

(1) When providing Personal Information of customers to a foreign contractor (such as a travel agency), the Company will, prior to providing such information, make a contract with the foreign contractor under the condition that the foreign contractor will take appropriate measures to protect Personal Information in compliance with the Eight Principles of the OECD Privacy Guidelines.

(2) Overview of Personal Information protection systems of overseas subcontractors
・Please refer to our website.

(3) Method of confirmation
- The Company will check the implementation status of the measures in (1) above every year by receiving a written report.
With regard to the Personal Information protection system described in (2) above, we will annually verify the information published by government agencies and other organizations of Japan.

(1) If you wish to disclose, correct, delete, or suspend the use of your Personal Information held by our company, or to suspend its provision to third parties, please contact us at the contact point listed below and we will guide you through the necessary procedures.
In such cases, we will take the necessary measures without delay in accordance with the law and our company regulations. If we are unable to meet all or part of your request, we will explain the reasons.
In principle, requests for disclosure must be made in writing by mail, and a fee of 300 yen plus postage (actual cost) will be charged per document.

(2)個人情報に関するお問合わせ窓口
クラブツーリズム株式会社 お客様相談センター
住所：〒135-0061　東京都江東区豊洲 5 丁目 6-52 　NBF 豊洲キャナルフロント
TEL： 03-4335-6263
受付時間： 9：30～17：00
（土、日、祝日、振替休日、12／30～1／3 は休業）

(As of Jun. 26, 2023)

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