Rules on Handling of Personal Information

Chapter 1 GENERAL INTRODUCTION PROVISIONS

1. SALE OF GOODS

Resorttrust, Inc. ("Company") shall apply this policy to goods and accessories that Company sells or trades directly or through other arrangements such as concession sales ("Goods").

Chapter 2 HANDLING OF PERSONAL INFORMATION

2. HANDLING OF PERSONAL INFORMATION IN CONNECTION WITH SALE OF GOODS

1. Company will collect, use, provide and register Personal Information (as defined in section 3. In this policy, unless otherwise provided, Personal Information excludes individual numbers and specific Personal Information) about customers and guests including membership applicants, members and guests who use Company’s facilities ("Members") which Company duly obtained to provide services to the Members by way of sale of Goods.
2. Company seeks to use reasonable measures to handle Personal Information about Members properly and to protect the privacy of Members and Company will strictly manage Personal Information to keep it accurate and confidential.
3. Company may outsource all or part of the handling of Personal Information set out in section 3 to the extent necessary to achieve the purpose of use as set out in section 4. In this case, Company will enter into an agreement with the engaged service provider and guide and manage the service provider to ensure that the service provider will seek to use reasonable measures to handle Personal Information about Members properly and protect the privacy of Members.
4. Company will sufficiently supervise its employees who handle Personal Information and train its employees to ensure that they will strictly manage Personal Information to keep Personal Information accurate and confidential.
5. Members will enter into any agreement with Company only when they have agreed to the terms of this policy in terms of the handling of their own Personal Information.

3. COLLECTION, RETENTION AND USE OF PERSONAL INFORMATION

Members hereby agree that Company collects, retains and uses the following Personal Information about them ("Personal Information") for the provision of special offers and services to them or for marketing activities on the condition that Company takes reasonable measures to protect Personal Information.

1. ①Any and all information which Members provided to Company by filling out any forms, applications, agreements or membership application check sheets including name, gender, birth date, family relationships, residential address, telephone number, email address, employer details, family details, the status of residence, salary, survey responses (including any amendments to them of which Company is informed by notice from Members after the execution of the agreement; hereinafter the same);
2. ②The date of order for Goods, whether a sales agreement has been entered into, the date of the sales agreement, membership number, the price of membership, the details of real property owned, the terms of agreement such as service charges and the records of transactions;
3. ③Billing history for service charges and payment history;
4. ④Details of use of Company’s facilities and use of internet;
5. ⑤Any information available from official documents issued by public authorities such as a resident registration certificate which Company collects in a lawful and proper way from Members, other businesses or public authorities;
6. ⑥Any information publicly available from official gazettes, telephone directories and residence maps; and
7. ⑦Any other information Company uses for the provision of special offers and services to Members or for marketing activities.

4. DETAILS OF PURPOSE OF USE OF PERSONAL INFORMATION

Company uses Personal Information about Members for the following purposes:

1. ①To issue membership cards in connection with agreements between Company and Members, to manage Members and provide Goods and services to Members;
2. ②To market Company’s Goods and services in any way such as by delivering marketing materials from Company and by sending emails from it;
3. ③To carry out marketing activities and develop Goods to enhance satisfaction of Members;
4. ④To market Goods and services of the Joint Users (as defined in section 5) in any way such as by delivering marketing materials from Company and by sending emails from it; and
5. ⑤To carry out any business which is related to any of the above and to carry out procedures required by law.

5. JOINT USERS OF PERSONAL INFORMATION

Company will jointly use Personal Information as defined in section 3 for the purposes set out in section 4 under joint use agreements between Company and its subsidiaries and affiliates which are listed on its financial statements ("Joint Users"). For the purpose of the joint use, Company will be the person who is responsible for the management of Personal Information.
Note: "Company’s subsidiaries and affiliates which are listed on its financial statements" are publicly available on Company’s websites (https://www.resorttrust.co.jp/).

6. ACCESS, CORRECTION AND DELETION OF PERSONAL INFORMATION

1. Members have a right to request access to Personal Information about themselves from Company or any of the Joint Users set out in section 5. A request for access shall be made to the information centre as specified at the end of this rules.
2. When requesting access to Personal Information pursuant to section 6.1, Members will follow the procedures set by the person to which the request is made including providing identity documents (such as a driving license and passport) to prove their identity. Members will bear charges for the procedures.
3. If any registered details are turned out to be inaccurate or incorrect as a result of an access request, Company will promptly correct or delete such details. Any request for correction or deletion shall be made to the information centre as specified at the end of these rules.

7. CONSEQUENCES OF NOT AGREEING TO THESE RULES

If Members do not wish to provide some required information (which is shown as required on application forms or other documents) to Company or Members do not accept all or part of the terms of these rules, Members may not be able to receive the services specified by Company.

8. REQUEST FOR SUSPENSION OF PROVISION OR USE OF PERSONAL INFORMATION

Notwithstanding that Company uses or provides Personal Information within the consent granted under these rules, if any Member makes a request for suspension, Company will suspend the use of their Personal Information and suspend the provision of their Personal Information by Company to the Joint Users pursuant to section 5. However, Company will continue to provide the Joint Users with any information about the membership of the Member and Company will reserve the right to enclose any documents with magazines for members or invoices. If the use of Personal Information is suspended, the Member may not be able to receive the services specified by Company.

Chapter 3 HANDLING OF INDIVIDUAL NUMBERS AND SPECIFIC PERSONAL INFORMATION

9. HANDLING OF INDIVIDUAL NUMBERS AND SPECIFIC PERSONAL INFORMATION IN RELATION TO SALE OF GOODS

1. Company will handle the individual numbers and specific personal information (as defined in sections 2(5) and 2(8) of the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (the "Numbers Act")) of Members which Company duly obtained to the extent necessary for the purposes set out in section 11.
2. Company seeks to use reasonable measures to handle individual numbers and specific personal information of Members properly and to protect the privacy of Members and Company will strictly manage individual numbers and specific personal information to keep it accurate and confidential.
3. Company may outsource all or part of the handling of individual numbers and specific personal information of Members to the extent necessary to achieve the purpose of use as set out in section 11. In this case, Company will enter into an agreement with the engaged service provider and guide and manage the service provider to ensure that the service provider will seek to use reasonable measures to handle individual numbers and specific personal information of Members properly and protect the privacy of Members.
4. Company will sufficiently supervise its employees who handle individual numbers and specific personal information and train its employees to ensure that they will strictly manage individual numbers and specific personal information to keep Personal Information accurate and confidential.
5. Members will enter into any agreement with Company only when they have agreed to the terms of this rules in terms of the handling of their own individual numbers and specific personal information.

10. COLLECTION, RETENTION AND USE OF INDIVIDUAL NUMBERS AND SPECIFIC PERSONAL INFORMATION

1. Company will collect the individual numbers and specific personal information of the Members in a propter and lawful way.
2. Company will not collect or retain any individual numbers or specific personal information beyond the purposes set out in section 11.
3. Company will not handle any individual numbers or specific personal information of Members unless it is necessary for the purposes set out in section 11. Company will not use any individual numbers or specific personal information of Members beyond the purposes set out in section 11 even with the consent of the Members.
4. Notwithstanding sections 10(2) and 10(3), in the following circumstance, Company is permitted to handle the individual numbers and specific personal information of Members beyond the purposes set out in section 11.
   • The handling is necessary to protect the life, body or assets of a natural person and the natural person has granted consent to it or it is difficult to obtain consent from the natural person.

11. THE PURPOSE OF USE OF INDIVIDUAL NUMBERS AND SPECIFIC PERSONAL INFORMATION

Company will use individual numbers and specific personal information obtained from Members to the extent necessary to carry out the following tasks:

1. ①Preparation of tax related documents concerning fees, charges, down payments, prize money;
2. ②Preparation of tax related documents concerning rent for real property;
3. ③Preparation of tax related documents concerning purchase prices of real property; and
4. ④Preparation of tax related documents concerning broker fees for sale or lease of real property.

12. RESTRICTION OF PROVISION OF INDIVIDUAL NUMBERS AND SPECIFIC PERSONAL INFORMATION

Except for the cases listed in subparagraphs of section 19 of the Numbers Act, Company will not provide any third party with the individual numbers and specific personal information of Members.

13. ACCESS, CORRECTION, DELETION AND DISPOSAL OF INDIVIDUAL NUMBERS AND SPECIFIC PERSONAL INFORMATION

1. Members have a right to request access to individual numbers or specific personal information about themselves from Company. A request for access shall be made to the information centre as specified at the end of these rules.
2. When requesting access to individual numbers or specific personal information pursuant to section 13.1, Members will follow the procedures set by the person to which the request is made including providing identity documents (such as an individual number card, a notification card, a driving license, a passport) to prove their identity. Members will bear charges for the procedures.
3. If any registered details are turned out to be inaccurate or incorrect as a result of an access request, Company will promptly correct or delete such details. Any request for correction or deletion shall be made to the information centre as specified at the end of these rules.
4. Company will delete or dispose of the individual numbers of Members as soon as possible when it becomes unnecessary for Company to carry out any of the tasks set out in section 11 and statutory retention periods have lapsed. However, Company will be permitted to retain any Personal Information of Members other than such individual numbers if all the references to such individual numbers have been masked making them unrecoverable or have been deleted.
5. Company will keep the records of deletion or disposal where Company deletes or disposes of individual numbers of Members pursuant to section 13.4.

14. CONSEQUENCES OF NOT AGREEING TO THESE RULES

If Members do not wish to provide some required information including their individual number or specific personal information (which is shown as required on application forms or other documents) to Company or Members do not accept all or part of the terms of these rules, Members may not be able to receive the services specified by Company.

15. REQUEST FOR SUSPENSION OF PROVISION OR USE OF INDIVIDUAL NUMBERS AND SPECIFIC PERSONAL INFORMATION

Notwithstanding that Company uses Personal Information within the purposes set out in section 11, if any Member makes a request for suspension, Company will suspend the use of their Personal Information. If the use of Personal Information is suspended, the Member may not be able to receive the services specified by Company.

Chapter 4 MISCELLANEOUS

16. CHANGES TO THESE RULES

If Company changes these rules, Company will notify the Members by posting the 　changes on magazines for members or Company’s websites or by sending mails. The version of these rules provided on Company’s websites shall be deemed to be the most updated version.