Privacy Policy

Joint use of Personal Information

We will share and jointly use the Personal Information of our customers/users as follows.

• Personal information: Personal Information listed in Section 3.
• Scope of joint users: Our group companies (Please refer to the following for our group companies)
  https://www.jtbcorp.jp/jp/jtb_group/
• Purpose of Jointly Use: The purposes for jointly use shall be included within the scope of the purpose of use mentioned in Section 3.
• Manager in charge of jointly use under Japanese law: JTB Corp.

Transfer of Personal Information to a third party in a foreign country

In order to arrange travel services provided by transportation/accommodation facilities in the travel for which the customer applies or for the purpose of use as set forth in Section 3, we may, upon informing you of the country or region in which your Personal Information is to be provided, transfer Personal Information to transportation/accommodation facilities, service providers, or other third parties in the country or region above. In this case, it is as follows.

• Country or region to which Personal Information is transferred: We will inform you orally, by pamphlets, brochures, travel terms and conditions documents, notice documents, or websites, e-mails or other electromagnetic means.
• Systems for the protection of Personal Information in the above country or region and measures for the protection of Personal Information to be taken by a third party: Please see [https://www.jtb.co.jp/privacy/]

We may transfer Personal Information to a third party in a foreign country after taking measures such as concluding an agreement with such third party to implement appropriate measures for the protection of Personal Information.

Handling of anonymously processed information

We will take appropriate protective measures to prevent the identification of specific individuals and the restoration of such Personal Information used for production, and will prepare anonymously processed information and provide such information to third parties to the extent permitted by law.

When preparing anonymously processed information, we process the information appropriately according to the following in accordance with the standards stipulated by the Personal Information Protection Law and the Rules of the Personal Information Protection Committee.

• Deleting a description that identifies a specific individual
• Deleting an Individual Identification Code
• Eliminating the sign that connects information with each other
• Deleting unique descriptions, etc.
• Taking other appropriate measures based on the nature of the personal information database, etc.

Items included in anonymously processed information

• Personal Attribute Information of Customers [Gender and Year of Birth of Representatives]
• Information on use of us [Application date (month/year), Stores (prefecture/municipality/type), Travel information (departure date/return date, area, and accommodation facility (name/type), Number of users (by adult, male, female, and child), Product grade, product type, product form, travel purpose, and type of participation]

Provision of anonymously processed information to a third party

Items and methods of provision of information included in anonymously processed information prepared by us and provided to third parties are as follows.

• Items in (2) above
• We will inform the recipients of such information that such data is anonymously processed information and provide such information after stipulating a contract to prevent improper handling of such information as identifying acts.
• To provide anonymously processed information to a third party by a secure electromagnetic manner such as encrypting data files.

Other safety management measures for anonymously processed information

• Clarify the authority and responsibility of the person handling information such as the processing method.
• We have established rules and regulations concerning the handling of such information, such as processing methods, and provide education and supervision to employees who handle such information.

• When we access your information stored on your device for the purpose that is not strictly necessary to provide our services, we obtain your consent. For example, when we collect information through Cookie for such purpose, we ask your consent in advance, and you can withdraw such consent at any time by accessing to the Cookie setting page on our website.
• If you live in France, you have a right to instruct us on the processing of your Personal Information after your death. You can change or revoke such instruction at any time.
• Details of EU data protection authorities is available here and the website of the data protection authority of the UK Information Commissioner’s office is here.
• We have designated the following domestic representative in the European Economic Area and the United Kingdom to process Personal Information:

• Name of the entity: TUMLARE CORPORATION HUNGARY Travel Agent Ltd.
• Address: H-1133 Budapest, Váci út 76.
• E-mail: eurepresentative@jtb-europe.com

For residents of U.S. states excluding California

• We set forth in our Privacy Policy, the categories of personal data we process. The purpose for processing Personal Information, the categories of Personal Information shared, and the categories of third parties with whom Personal Information is shared.
• Consumers in certain states may have the following rights, and you can submit a request to exercise these rights by contacting us as indicated in Section 10 “Contact Information” above.

Right to know and access
The tight to confirm whether we are processing Personal Information and to access such information. Residents in certain states may also obtain a list of third parties with whom we have shared personal data.

Right to correct
The right to correct inaccurate Personal Information we hold about you.

Right to delete
The right to delete the Personal Information provided by you or obtained about you.

Right to access and data portability
The right to obtain a copy of the Personal Information previously collected by us and, to extent feasible, in a readily usable format to allow data portability.

Right to appeal
If for any reason you would like to appeal a decision made by us relating to your request to exercise privacy rights, you have the right to submit an appeal to us. Please include your full name, the basis for your appeal and any other additional information to consider.

Consumers in certain states may also have the following rights:

Right to Opt-out of Targeted Advertising and Sales
Some state laws may set forth the right to opt-out of advertising and analytics practices that may be considered “Targeted Advertising” or “Sale/Selling” of Personal Information under the applicable state law. To exercise the above right, please ensure that you may send an e-mail to request for opt-out to “private@jtb.com”, and you may also submit a request at: the Contact in Section 10.

Right to Opt-out of Automated Decision Making and Profiling
While some state laws may set forth the right to opt-out of the automated decision making and profiling in furtherance of decisions that produce legal or similarly significant effects, JTB does not engage in such activities.

For residents of California

California Consumer Rights

Request to Know
Request information regarding what Personal Information we collect, use, disclose and sell, including the right to request that we provide you with the categories and specific pieces of Personal Information we have collected about you.

Request to Correct
Request correction of inaccurate Personal Information that we maintain about you.

Request to Delete
Request deletion of Personal Information that we maintain about you.

“Do Not Sell or Share My Personal Information”
Request to opt-out of the “sale” of your Personal Information or the “sharing” of your Personal Information to a third party for cross-contextual behavioral advertising (i.e., targeted advertising).

“Limit the Use and Disclosure of Sensitive Personal Information”
A consumer has the right to limit the use of the consumer’s sensitive personal information to certain purposes such as the purpose which is necessary to perform the services or provide the goods reasonably expected by on average consumer who requests such goods or services. JTB does not offer this right because we do use and disclose sensitive personal information only for such purposes.

Verifying Request
When making the above request, please provide us with enough information to allow us to verify you are the data subject of the Personal Information that we collected, or their authorized representative. You must also describe your request with enough detail so that we can understand, evaluate and respond to it.
When you exercise your Right to Know, Right to Delete, and /or Right to Correct, we may ask you to provide us with additional information to verify your identity and process your request. If we obtain such additional information, we may not be able to process the request.

Agent
If you are an authorized representative submitting a request on a consumer’s behalf, please complete the applicable request per the instructions below. We will follow up to request a signed, written permission signed by the individual who is the subject of the request. The written permission must state your full legal name, the full legal name of the individual who is the subject of the request, and a clear description of the permission granted. Alternatively, you may submit a copy of a power of attorney under applicable state law. Please keep in mind that if we do not receive adequate proof that you are authorized representative, we may deny the request.

Exercising Your Rights - Request to Know, Correct and/or Delete
Please submit your request at: private@jtb.com by e-mail.

Data Retention
We retain Personal Information for as long as it is necessary for the purposes outlined in this California Privacy Notice. However, we will keep the data for so long as is reasonably necessary if we are required to retain information by law.

Non-Discrimination
California consumers have the right to not receive discriminatory treatment for exercising CCPA rights. We will not discriminate against you for exercising your CCPA rights.

Notice of Financial Incentive
Under California regulations, if offer certain loyalty or similar program(s) directly or reasonably related to the collection, retention or deletion of your Personal Information, such program may be considered a “financial incentive”. In such case, we will be required to make additional disclosures to you, which we will provide when you agree to participate.

Personal Information We Collect and Purposes for Collection
The Personal Information we collect about you will depend upon you use services. Accordingly, we may not collect all of the below information. In addition to the below, we may collect and use additional type of information and will do so after providing notice to you and obtaining consent to the extent such notice and consent is required by applicable law.
We may have used Personal Information for the business or commercial purposes described in the following Table 1.

Additional Notice
Under the California “Shine the Light” law, you have the right to receive the following information:

• information identifying any third-party company to which we may have disclosed, within the past year, Personal Information pertaining to you and your family for the company’s direct marketing purposes
• a description of the categories of Personal Information disclosed.

To obtain such information, please email your request to private@jtb.com, and include your name, email address, mailing address or zip code, and a reference to “Your California Privacy Rights”.

[Table 1]

International Transfer

Through your use of our services, your Personal Information will be transferred outside of Canada or state where you live. Please see Section 3 for categories of recipients.

If your Personal Information is transferred to jurisdictions outside of Canada, it may be subject to the laws of those jurisdictions, which may allow access by courts, law enforcement, or government authorities in accordance with their laws.

You may obtain written information regarding our policies and practices with respect to service providers outside Canada, by sending an e-mail to private@jtb.com. You may also contact our JTB PIM Office (e-mail: private@jtb.com) for questions about the collection, use, disclosure, or storage of Personal Information by such service providers.

Profiling

We may use Personal Information for profiling. In such cases, we will inform you of the means to activate or deactivate profiling. You may also deactivate profiling by withdrawing your consent to our use of your data by sending an e-mail to private@jtb.com.

Your Rights

Subject to certain exceptions, you may have the following rights regarding your Personal Information in addition to the rights listed in Section 8:

• Right to Access. Request to confirm the existence of the Personal Information, communicate it to you, and allow you to obtain a copy of it.
• Right to Rectify. Request rectification of inaccurate, outdated or incomplete Personal Information we maintain about you.
• Right to Withdraw Consent. Request to withdraw previously provided consent to the communication or use of the information collected.

Where we collect the Personal Information based on your separate consent to this Privacy Policy, provision of any requested Personal Information is optional. In all other cases, provision of any requested Personal Information is mandatory, and we will not be able to provide services to you without this information.

[Recipients]

• Travel suppliers (airlines, hotels, vacation rental property owners or management companies, car rental services, cruise ship operators, activities or tour providers).
• Duty free shops, souvenir shops
• Accountants, consultants, lawyers and other professional service providers

Pursuant to Article 28-8, Paragraph 1, Item 3 of the Personal Information Protection Act, we entrust the processing of your Personal Information or provide your Personal Information to the following entities outside South Korea. The retention period of your Personal Information at the recipients shall be in accordance with the provisions outlined in Section 5. The transfer of your Personal Information occurs only when necessary and is carried out via the internet.

[Entrusted entities]

Tour operators, accommodation facilities such as hotels, duty free shops, souvenir shops, transportation companies, activity companies, and other entities which are necessary to provide services under the contract with you.
We will inform you the country or region to which your personal information is transferred orally, in our pamphlets, brochures, travel terms and conditions, notice, or website, by e-mail or by other electromagnetic means.

If you wish to refuse the entrustment or provision of your Personal Information to the above entities, please refer to Section 10.

We have designated the following domestic representative for the processing of Personal Information:

• Name of the entity: LOTTE JTB CO., LTD.
• Name of the above entity’s representative: Ko Moonyoung
• Address: 13FL, Central Place, 50, Seosomun-ro, Jung-gu, Seoul, 04505, Korea
• Tell: 82-2-6313-8034
• E-mail: privacy@lottejtb.com

Under Personal Data Protection Law of Indonesia, subject to certain exceptions, you may have the following rights regarding your Personal Information in addition to the rights listed in Section 8:

• Right to Inform/Access. Request to confirm the existence of the Personal Information, communicate it to you, and allow you to obtain a copy of it.
• Right to Rectify. Request rectification of inaccurate Personal Information we maintain about you.
• Right to Withdraw/Restrict Processing. Request to withdraw previously provided consent to process your Personal Information.
• Right not be subject to a decision based solely on automated processing
• Right to obtain clear information regarding identity clarity, basis of legal interest, purpose of requesting and using Personal Information, and accountability of the party requesting Personal Information; and
• Right to sue and receive compensation for violations of Personal Information processing about you.