Accordia Golf Privacy Policy
This Policy explains the type of personal information that Accordia Golf Co., Ltd. and its Group companies (“Accordia Golf”) may acquire, for what purposes the information may be used, with which third parties the personal data may be shared, and what safety measures are being implemented to protect the personal data.
Accordia Golf is committed to protecting your privacy.
Accordia Golf may acquire personal information through its business activities. Accordia Golf recognizes the importance of the proper handling of personal information of any person who provides us with personal information (the “Personal Information Holder”). As such, we abide by laws and regulations for protecting personal information and have established our own rules, which we make known to all executives, employees (including part-time workers; the “Executives and Employees”) and other related persons, to protect personal information.
- Sources of Personal Information
- Accordia Golf acquires personal information mainly through 1) Point Card application, 2) records of customer visits to golf courses operated by Accordia Golf, 3) reservation information through the website, and 4) other documents and materials.
- Personal Information Possessed by Accordia Golf
- Personal information that Accordia Golf may ordinarily acquire includes the following:
- Name, address, telephone number, e-mail address, and other contact information
- Age, occupation, position, title, and job responsibilities
- Purposes for which Personal Information May Be Used
- Accordia Golf may use personal information for the following purposes:
- To communicate via mail, telephone, e-mail, or facsimile regarding use of Accordia Golf’s products and services.
- To provide information regarding Accordia Golf’s products and services.
- To provide information and notices to shareholders
- To implement Accordia Golf’s internal operations.
- To use personal information on behalf other companies within the scope of the nominated purposes
- Shared Use of Personal Data
- Personal data may be shared among Accordia Golf and golf courses operated by it or its partners, to provide efficient and reliable services and to increase the product and service options available to customers. The items of personal data shared shall be limited to the scope necessary for the purpose, and Accordia Golf Co., Ltd. shall be entirely responsible for managing the personal information.
- Disclosure of Personal Data to Third Parties
- Accordia Golf will not disclose personal information to third parties other than those mentioned in this Policy. Accordia Golf may disclose personal information to third parties for the purpose of receiving professional advice concerning legal, accounting, or other matters, or to receiving support in improving its services. Companies receiving such information from Accordia Golf will be required to bear the duty of treating received data as confidential and to limit the use of such information to the purposes specified by Accordia Golf.
- Accordia Golf may disclose personal data based on the Personal Information Holder’s instruction, in order to protect the interests of Accordia Golf or the Personal Information Holder, or based on the Personal Information Holder’s consent.
- Finally, Accordia Golf may disclose personal data to the courts, administrative agencies, or other parties with justified privileges to such data based on their requests for information disclosure.
- Accordia Golf will in not sell personal data to third parties.
- Information Security: How Does Accordia Golf Protect Personal Information?
- Accordia Golf employs the highest information security standards to protect the privacy and confidentiality of personal information. Accordia Golf limits access to personal information to the Executives and Employees and agents on a need-to-know basis. As explained under “Disclosure of Personal Data to Third Parties,” service providers used by Accordia Golf are held to a strict duty of confidentiality. Accordia Golf engages in physical, electronic, and procedural preventive measures to prevent the loss, misuse, damage, falsification, or leakage of, and unauthorized access to, personal information. Other characteristics of Accordia Golf’s information security program include the following:
- Use of a specialized technology called a firewall
- Safety and operational testing before the actual provision of products of services on the internet and continuous evaluation of generally known technological weaknesses
- Internal and external audits on services provided through Accordia Golf’s website or the internet
- Monitoring of the system infrastructure and efforts to discover possible sites of unauthorized access by external parties
- Controls on access to websites and internet systems through verification of personal identity and access authority
- Safeguards on the transmission of non-public information through encryption and other means
- Training programs provided to Executives and Employees to ensure an approach to security that remains current with new risks and technological developments
- Privacy and the Internet
- Customers receiving services through the Accordia Golf website should also refer to the following additional information.
- A “cookie” is a small text file composed of encrypted information assigned to the browser of the customer’s computer from a website. Accordia Golf may utilize cookies for administrative purposes, to ensure security or to eliminate the need to repeatedly re-enter user passwords when utilizing the website.
- Accordia Golf may keep access logs (e.g., logs showing which pages customers accessed within Accordia Golf’s website, or frequency of access) for the purpose of analyzing the use, value, or performance of its services.
- The Accordia Golf website includes a bulletin board and similar services. Customers are advised to use these services at their own discretion. Accordia Golf cannot be held responsible for the way personal information is handled on the websites of third parties linked to the Accordia Golf website. Please confirm the privacy protection policies of these third-party websites.
- Policy Revision
- This Policy may be revised to reflect changes in the conditions surrounding the collection or use of personal information. Revised policies become effective immediately upon publication on the Accordia Golf website. The current version is effective as of May 7, 2010.
- Inquiries
- The Personal Information Holder may request disclosure of personal data possessed by Accordia Golf. To prevent information leaks to parties other than the Personal Information Holder to whom the data pertains, the Personal Information Holder will be requested to submit personal identification documents. Information requests shall be handled in accordance with the Personal Information Protection Law and other applicable laws and regulations. The same holds when the Personal Information Holder request the correction, addition, or deletion of personal data possessed by Accordia Golf pursuant to the Personal Information Protection Law. Please see below when requesting or inquiring about disclosure, correction, etc. of the personal data in possession of Accordia Golf.
