This Policy explains the type of personal information (including specific personal information, which refers to personal numbers and personal information that contains such personal numbers) that Accordia Golf Co., Ltd., its Group companiesand Accordia Golf Asset Godo Kaisha, a company that undertakes their business management operations, (“the Accordia Group, etc.”) will handle.This Policy is commonly adopted by the Accordia Group, etc. and the term, “Accordia Golf,” as described below means each company of the Accordia Group, etc.
Accordia Golf is committed to protecting your privacy.
Accordia Golf recognizes the importance of the proper handling of personal information of any person who provides it with personal information (the “Personal Information Holder”). As such, Accordia Golf abide by laws and regulations, guidelines and other standards for protecting personal information and has established its own rules, which it makes known to all executives, employees (including part-time workers; the “Executives and Employees”) and other related persons, to protect personal information.
Obtain of Personal Information
Accordia Golf will acquire personal information through legal and fair means. Accordia Golf acquires personal information mainly through 1) Accordia Golf Point Card application forms, 2) records of customer visits to golf courses operated by Accordia Golf, 3) reservation information through the website, 4) documents necessary for proceeding with internal operations, and 5) other documents and materials.The acquisition of specific personal information will be conducted upon notifying or announcing its use and through the use of a special letterhead, etc.
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
- Personal numbers (to be acquired using a special letterhead, etc.)
While Accordia Golf makes every effort to keep personal information updated and accurate, please contact Accordia Golf if there are any changes to your personal information.
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.
Accordia Golf will handle personal information in the manner set forth in this policy even after the Personal Information Holder withdraws from golf clubs of Accordia Golf Courses or otherwise terminates their relationship with Accordia Golf, as long as it possesses such personal information.To use personal information on behalf other companies within the scope of the nominated purposes.
Shared Use of Personal information
Personal information may be shared within the Accordia Group, etc. for the purposes as described in “Purposes for which Personal Information May Be Used” to provide efficient and reliable services and increase the product and service options available to customers. The items of personal information that are 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. As for specific personal information, etc., Accordia Golf will not share it within the Accordia Group, etc.
Provision of Personal Information to Third Parties
Except for the cases when exceptional application is allowed by laws, without obtaining customers’ consent in advance, Accordia Golf will not disclose personal information to third parties other than those mentioned in this Policy. As for specific personal information, it will not be disclosed to third parties unless this is carried out in accordance with laws and regulations, regardless of the customer’s consent. Accordia Golf will not sell personal information to third parties.
Outsourcing Management of Personal Information
If Accordia Golf outsources the handling of part or all of personal information, it will carry out rigid examinations in accordance with laws and regulations, etc., ensure that the outsourcing service providers comply with confidentiality obligations, and carry out the necessary and appropriate supervision of the outsourcing service providers.
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 Employees and agents on a need-to-know basis. As explained under “Outsourcing Management of Personal Information,” 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 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 website of the Accordia Group, etc. 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 the website of the Accordia Group, etc., or frequency of access) for the purpose of analyzing the use, value, or performance of its services.
- The website of the Accordia Group, etc. 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.
Accordia Golf will continuously revise and strive to improve its internal systems and initiatives for the protection of personal information
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 website of the Accordia Group, etc. The current version is effective as of October 11, 2016.
The Personal Information Holder may request disclosure of personal information 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 applies when the Personal Information Holder requests the correction, addition, or deletion of personal information possessed by Accordia Golf pursuant to laws and regulations, etc. Please see below when making requests or inquiries about the disclosure, correction, etc. of the personal information in the possession of Accordia Golf.