01.Management of personal information

To keep Personal Information accurate and up-to-date, and prevent Personal Information from unauthorised access, loss, damage, falsification, leakage, etc, Hiramatsu has adopted data security measures and practise rigorous personal information management, including measures to maintain our security management systems. Hiramatsu ensures that our employees are trained in personal information protection, etc and takes appropriate remedial action in the event that any incident arises.

02.Use and sharing of personal information

Hiramatsu identifies the purposes for which personal information is to be used within the scope of our business activities, and collect, use and share personal information only to the extent necessary to achieve those purposes, and in a fair and appropriate manner. Hiramatsu also takes measures to prevent the use of personal information for any other purpose.

03.Compliance with laws, regulations and other rules, and policy reviews

Hiramatsu complies with Japanese laws and regulations and other rules applicable to the personal information Hiramatsu holds, and reviews and improves the content of this policy as appropriate.

04.Enquiries

Hiramatsu has established a Enquiries to handle complaints and enquiries regarding the handling of personal information, etc, which responds to complaints and inquiries in good faith.

05.Continuous improvement

For the purpose of implementing this policy, Hiramatsu has established internal regulations on personal information protection and appointed a personal information protection manager. Hiramatsu ensures that our directors and employees and all third parties to whom Hiramatsu outsources work are familiar with the appropriate handling of personal information, and Hiramatsu periodically reviews and strives for continuous improvement of our personal information protection management system, monitoring its implementation in a timely manner, etc.

Amended: 1 May 2022
Hisashi Endo, President and CEO

01.Name of business handling personal information

Hiramatsu Inc.

02.Personal information protection manager

Hideki Kitajima, General Manager of Corporate Division

03.Purpose of use of personal information

The categories and purposes of use of personal information are as follows:

①Customer information is used:

1. a For business purposes in connection with the use of our hotels and restaurants;
2. b To deliver goods that customers have purchased;
3. c To send customers our hotels, restaurants, menus, events, new businesses, etc;
4. d For marketing, product development, service improvement and new service development;
5. e To send customers materials relating to the company and its businesses;
6. f To manage the Hiramatsu members points programme;
7. g To send customers information, announcements and advertisements that they may find useful; and
8. h To reply to enquiries

②Business partner information is used:

1. a For business communication, contract performance, business negotiation and other purposes; and
2. b To manage business partner information

③Mémoire de Hiramatsu member information is used:

1. a To operate the Mémoire de Hiramatsu scheme;
2. b To send members information, announcements and advertisements that they may find useful; and
3. c To reply to members’ enquiries

④Shareholder information is used:

1. a To exercise rights and perform duties in accordance with the Companies Act;
2. b For shareholder management purposes, such as keeping records in accordance with laws and regulations;
3. c To send shareholders investor relations materials;
4. d To send shareholders information on shareholder benefits;
5. e To send shareholders information, announcements and advertisements that they may find useful; and
6. f To reply to shareholders’ enquiries

⑤Job applicant information is used:

1. a To contact and provide information to job applicants;
2. b For pre-employment screening purposes; and
3. c For other purposes relating to recruitment activities

⑥Employee information is used:

1. a For work-related communication with employees;
2. b To pay employee remuneration (salary, allowances, etc);
3. c To deduct withholding tax and pay income tax, local tax, social insurance premiums, etc;
4. d For personnel and labour management purposes;
5. e For health and security management purposes;
6. f For the provision of employee benefits; and
7. g To send employees information and announcements that may find useful

⑦Specific Individual information is used:

1. For purposes specified in the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (Act No. 27 of 2013)

⑧Information on persons who have made enquiries is used:

1. To respond to, confirm and record enquiries and complaints

⑨ Information on persons or their representatives who have submitted disclosure requests, etc is used:

1. To respond to disclosure requests, etc

04.Scope of information sharing

Hiramatsu shares information on Mémoire de Hiramatsu members as follows:

①Entities with which information will be shared

1. Hiramatsu Research Laboratory
   5-15-13 Minami-Azabu, Minato-ku, Tokyo

②Purpose of use

1. Provision of benefits to Mémoire de Hiramatsu members

③Scope of personal information

1. a Customer’s name;
2. b Customer’s address, telephone number, email address, etc; and
3. c Customer’s Mémoire de Hiramatsu membership number

④Name, address, name of representative, etc of company responsible for management of personal information

1. Hiramatsu is responsible for the personal information shared.
   Our address, and the name and contact details of our personal information protection manager are as follows:
   Company address; and
   Hiramatsu Inc., 4-17-3 Ebisu, Shibuya-ku, Tokyo 150-0013 Japan
   Personal information protection manager:
   Hideki Kitajima, General Manager of Corporate Division
   Contact details;
   See below

05.Sharing personal information with third parties

Hiramatsu does not share personal information with third parties except in the following circumstances:

06.Voluntary nature of personal information provision

Personal information is provided on a voluntary basis, but if the personal information is not provided, the person concerned may not be able to use our services, or Hiramatsu may not be able to respond to their enquiries or consider them for employment.

07.Security management methods

Hiramatsu implements security measures necessary and appropriate to the management of personal information to prevent leakage, loss, damage , etc. As necessary and appropriate, Hiramatsu also supervises employees and contractors (including subcontractors) handling personal information. Measures for the secure management of personal information are specified in our Personal Information Protection Regulations , set out elsewhere.

08.Outsourcing of personal information handling to foreign contractors

Not applicable

09.Disclosure of personal information

If Hiramatsu is asked to disclose personal information under the provisions of the Act on the Protection of Personal Information, Hiramatsu firstly verifies that the request has been made by the person concerned (or their representative), then discloses the information without delay (when no such personal information exists, Hiramatsu notifies the person making the request). However, Hiramatsu does not disclose personal information unless required to do so under the provisions of the Act on the Protection of Personal Information or other laws and regulations. To make a disclosure request, please contact the Enquiries (see below for details). Hiramatsu will then send you a Disclosure Application Form by post or email. Please complete this form and return it along with the necessary documentation.

10.Amendment, cessation of use, etc of personal information

11.Amendment of this policy

Hiramatsu updates and continuously improves our methods for handling personal information in a appropriate manner, and amends our policy on the handling of personal information as necessary.

12.Data collected automatically when you use our website, etc

For the purpose of targeted advertising (advertising according to customer needs and interests) of our services by ourselves or by third-party advertising serving companies, or for the purpose of analysing other data regarding our business, Hiramatsu may collect and use or share the following information:

①Log and website use data

1. When you use our services, Hiramatsu may collect your IP address, the date and time of your request, and data on your actions our website.

②Cookies and anonymous ID

1. Hiramatsu may use cookies or similar technologies to identify devices using our services. Hiramatsu will not use cookie data to identify individual users. Hiramatsu will retain any log data, etc collected only for as long as necessary to fulfil the purposes for which it was collected.

Enquiries

Hiramatsu Inc., 4-17-3 Ebisu, Shibuya-ku, Tokyo 150-0013 Japan