1. Purpose of Use of Personal Information and the Legal Basis for Use
(Guests’ Personal Information)
Palace Hotel Group (hereinafter referred to as “PHG”) will use guests’ personal information, based on consent of the guests or where the use is necessary for the performance of a contract for the following purposes:
・ For responding to various inquiries and requests for various information on hotel services or properties
・ For acceptance of reservations for hotel and provision of hotel services
・ For acceptance of reservations for food and beverage outlets and provision of these services
・ For acceptance of reservations for weddings, banquets, functions or other services or products and provision of these services
・ For acceptance of reservations for spa treatments, personal training or other services or products and provision of spa and fitness services
・ For delivery services of email newsletters
・ For responding to applications for our campaigns or answers to our surveys
・ For statistical operations such as understanding your past usage history and performing statistical processing for the purpose of improving our services
・ For improving our services in other areas
・ For conducting marketing activities that involve behavioral targeting ads through advertising distributors such as Google, Yahoo and Meta (hereinafter referred to as “Providers”)

(Business Partners’ Personal Information)
PHG will use business partners’ personal information, based on consent of the data subject or where the use is necessary for the performance of a contract for the following purposes:
・ For provision of our services for guests
・ For the performance of a contract between business partners and PHG
・ For responding to various inquiries from business partners
・ For informing business partners about the guidance of our products or services

2. Sharing Personal Information with or Disclosing Personal Information to Third Parties
We will never share or disclose your personal information with third parties except for the following:
・ We will disclose the information for the purposes of use stated in the above 1 of this Policy only to subcontractors who have signed a confidentiality agreement with PHG
・ We have your consent to disclose your personal information
・ We receive legal requests from such public institutions, including courts or other law enforcement agencies

We have outsourced some system operations, including the management and storage of personal information to a United States company, and have concluded a contract with that company regarding strict information security management. (The Personal Information Protection Commission in Japan reports that the United States is one of the countries that has a certain level of personal information protection.)

3. Use of Hashed Personal Data and Sharing with Third Parties
When placing advertisements using Providers, PHG may provide third-party advertising distributors with guests’ data such as email addresses, phone numbers, and other contact information after they are hashed (a method of converting information to a secure, irreversible code) to maintain user privacy. To gain advertising insights, this first-party data may be matched with the user information of Providers to deliver advertisements that are more optimized to guests based on the results.
Furthermore, this website may obtain information about advertisements that guests clicked before visiting this site (such as the date, time, and referring website where the advertisement was placed) from third-party tracking tools to measure the effectiveness of ad campaigns and match it with information provided in guests’ inquiries, reservations, purchases, etc.

4. Storage Period of Personal Information
We will promptly delete personal information in the event that the storage period stipulated by laws has expired or when it is no longer necessary to use the information for the purposes described in the above 1.

5. Establishing and Maintaining Compliance Program
PHG is committed to establishing a compliance program that obligates its directors and employees including temporary staff and other workers (hereinafter referred to as “employees”) to be aware of the importance of protecting personal information, and to ensure that personal information is protected and used appropriately. Furthermore, PHG will maintain this program and strive for continuous improvement.

6. Appointment and Authorization of Personal Information Administrator
PHG appoints a Personal Information Administration Officer for each hotel who is in charge of PHG’s personal information protection. The authority of such Officer is to be clearly defined in the corporate organization and the Officer is to receive organizational support so that he or she may be able to properly manage the responsibility of personal information protection.

7. Establishing In-House Rules & Regulations
PHG establishes in-house rules and regulations to protect the privacy of personal information and establishes a clear policy for handling personal information. PHG notifies all employees that leaking of information and similar acts shall be subject to severe penalties.

8. Information Security Measures
PHG is determined to take necessary measures both for maintaining accurate and secure personal information and for preventing improper access, loss, destruction, falsification and/or leakage of personal information.

9. Reviewing and Improving of Outsourcing System
PHG continues to review and improve its outsourcing arrangements to ensure the protection of personal information. When signing contracts with outsourcing agents, PHG thoroughly reviews its outsourcing agents’ qualification and capability to protect personal information.

10. Compliance with Laws and Regulations
PHG will comply with applicable laws, regulations, guidelines and standards concerning the protection of personal information.

11. Intensified Education of the Employees
PHG educates its employees on the protection of personal information so that they fully understand the importance of information security and can carry out their duties with sufficient knowledge.

12. Reviewing and Improving of Internal Auditing Function
PHG continues to review and improve its internal auditing function by introducing an organizational mechanism to review whether the systems and procedures for protecting personal information are properly operated or not.

13. Disclosure of Retained Personal Data
If you or your attorney request us to disclose the retained personal data, PHG will respond to such requests without delay except as otherwise provided under the following cases:
・ Cases in which the disclosure is likely to harm the life, body, property or other rights and interests of the individual or a third party
・ Cases in which the disclosure is likely to interfere with the proper execution of our businesses
・ Cases in which the disclosure violates laws and regulations

Furthermore, PHG will investigate and respond to the following requests from individuals or their attorneys regarding retained personal data:
・ You or your attorney request us to correct, add or delete such personal data because the contents are contrary to fact
・ You or your attorney request us to disuse, erase or suspend the provision to a third party because such personal data is handled in violation of the law, such personal data is no longer necessary to use, or there is a risk that your rights and interests will be harmed
・ You or your attorney lodge complaints, objections, etc.

You can withdraw your consent to the use of personal information at any time.

If you have any inquiries, please contact us at the following:

Personal Information Administration Officer
Palace Hotel Co., Ltd.
1-1-1 Marunouchi, Chiyoda-ku, Tokyo, 100-0005, Japan
e-business@palacehotel.jp

In addition, you may file a complaint with the Personal Information Protection Committee and other supervisory authorities regarding the use of personal information.

June 2026
Palace Hotel Co., Ltd.