Effective Date: 26 November 2024
All divisions and organisations in Far East Orchard Limited, including the Far East Hospitality division (hereinafter referred to as “Company”, “we”, “our”, or “us”), responds to your confidence in us and complies with the Act on the Protection of Personal Information(Act No. 57 of 2003)(hereinafter referred to as the "APPI"), its enforcement order, its enforcement regulations, guidelines of the Personal Information Protection Commission and other norms (hereinafter collectively referred to as the “APPI Regulations”), and to ensure the appropriate use and management of personal information, the Company will implement and maintain the following personal information protection policy.
The meanings of terms used in this policy shall be in accordance with the definitions in the APPI, unless stated otherwise herein.
1. General Overview
We handle personal information properly in accordance with the APPI Regulations.
2. Appropriate Management
We will keep personal information accurate and up-to-date to the best of our knowledge, delete it without undue delay when it is no longer needed, and strive to prevent the loss, destruction, alteration, leakage, or unauthorized access to personal information, and otherwise manage it securely.
In order to implement this privacy policy, we have established internal rules and systems for the handling of personal information and anonymized information and will maintain and improve them to ensure that all of our employees (directors, employees, contract employees, temporary employees, etc.), contractors, and other related parties are fully aware of and appropriately comply with these rules and systems.
3. Explicit Statement of Purpose of Use
(1) When we obtain personal information, we will do so by legal and fair means, and we will clearly state the purpose of use of personal information and other necessary matters at the time of acquisition or announce such matters on our website, etc.
(2) When acquiring personal information indirectly, we will notify necessary information such as the purpose of use of personal information on our website, etc.
4. Compliance with the Purpose of Use
(1) We will use personal information within the scope of the purpose of use under appropriate procedures.
(2) If we intend to use personal information beyond the scope of the purpose of use, we will notify the relevant individual in advance and confirm his/her consent.
5. Provision to Third Parties
We may provide personal data to third parties such as business partners through procedures provided by or in compliance with the APPI Regulations.
6. Joint Use
When we share personal data with third parties, we will disclose the information about such joint use appropriately in accordance with the APPI Regulations.
7. International Transfers
When we transfer personal data outside of Japan, we will either obtain prior consent by the relevant individual or take appropriate measures to ensure that the personal data is protected by the recipient in the same manner as in Japan.
8. Supervision of Contractors
When we outsource the handling of personal data, we will select an appropriate contractor to ensure safe management and will enter into a contract with the contractor regarding the handling of personal data and appropriately supervise the contractor.
9. Disclosure, Correction, etc. of Retained Personal Data
We will promptly respond to requests for disclosure, correction, suspension of use, etc. of the personal data we have retained, after confirming the identity of the individual making the request.
10. Handling of Anonymized Information
(1) In principle, we do not handle anonymized personal information. However, if the opportunity to create or provide anonymized information arises, we will notify the necessary information required by the APPI Regulations on our website, etc.
(2) We will take security control measures for anonymized information as stipulated in our internal rules.
Handling of Personal Information
We will handle provided personal information and retained personal data as follows.
I. Subject of Personal Information
We handle the personal information of the following people (hereinafter referred to as “you”, “your”):
II. Purpose of Use
We use personal information for the following purposes:
(1) To provide services to customers, such as the sale of goods to customers, implementation of membership programs, and in-building calls;
(2) To send information from the hotel regarding the above, to provide information on accommodation, special offers, product information, etc.;
(3) To develop and improve our services and products by conducting surveys regarding our hotel;
(4) To conclude contracts with our business partners including venders and to fulfill such contracts;
(5) To appropriately and smoothly carry out hotel management and sales operations;
(6) To conduct marketing activities such as market research, to verify the effectiveness of sales promotion activities, and to formulate sales promotion plans in order to provide better services and products to customers;
(7) To introduce products and services related to the hotel's business purposes;
(8) To exercise the rights and fulfill the obligations of shareholders and the Company, to provide shareholders with preferential services and information on events, etc., and to manage shares and shareholders;
(9) For our employment selection for job applicants; and
(10) To improve the website, to enhance the convenience of using the website, and to display customized website content and advertisements.
III. Sensitive Information
We may handle sensitive information about you, including biodata and health-related information. In such cases, we will handle it with particular care and will not obtain it or provide it to third parties without your consent.
IV. Your Rights
1. With respect to your personal information, you may request the following:
(1) Disclosure of personal data retained by the Company (including data portability request);
(2) Notification of the purpose of use of retained personal data;
(3) Correction, addition, deletion, etc., of retained personal data when the content of such data is factually incorrect;
(4) Suspension of use or deletion of retained personal data on the grounds that it has been handled in violation of the APPI or that it has been obtained in violation of the APPI; and/or
(5) Cessation of provision of retained personal data to a third party on the grounds that such data is provided to a third party in violation of the APPI.
We will respond to your requests above in the manner described in paragraph 3 below. We will not respond to your request in the following cases:
(1) When the requested information items do not fall under the category of retained personal data;
(2) When you cannot verify your identity;
(3) When a request is made by a proxy and the authority of representation cannot be verified; and/or
(4) In other cases as provided by laws and regulations.
In some cases, a fee may be charged depending on the details of the request. If you have any questions, please contact the disclosure contact listed in the next paragraph 2.
2. Contact Information to Exercise Your Rights
E-mail: DPO@fareastorchard.com.sg
3. Procedure
Please send the following required documents by e-mail or postal mail to the contact listed in the previous paragraph.
When you make a request
(1) Personal Information Disclosure Request Form
Please provide your address, name, e-mail address and phone number, and details of the request including type of the personal information and reason for request.
(2) Documents verifying your identity
Please enclose a copy of your driver’s license, passport, MyNumber card, residence card or health insurance card.
When a proxy makes a request
If the person making the request for disclosure, etc. is your representative or authorized agent, please enclose the following documents in addition to the documents listed in (1) and (2) above.
In the case of a representative
(1) Documents to confirm that the applicant has representation
A copy of the family register, or in the case of a person with parental authority, a copy of the health insurance card with dependents’ names filled in is also acceptable.
(2) Documents to verify the identity of the legal representative
A copy of a document such as a driver’s license, passport, MyNumber card or residence card with a photograph that verifies the representative’s name and current address.
In the case of an authorized agent
(1) Letter of proxy
The letter of proxy should include the signatures and seals of both you and the agent, their addresses and telephone numbers, and the details of the authorization.
(2) Your seal registration certificate (issued within the last 3 months)
(3) Documents to verify the identity of the authorized agent
A copy of a document such as a driver’s license, passport, MyNumber card or residence card with a photograph that verifies the agent's name and current address.
V. Provision to Third Parties
We will not provide your personal data to any third party without obtaining your prior consent, except as provided for in the APPI. However, in accordance with the APPI Regulations, our group companies (joint use) and our business partners (outsourcing) may be provided with your personal data.
If a third party who calls or comes to the hotel identifies the guest’s name and requests to make a phone call from the front desk or transfer his/her the call, the call will be made or transferred only if the name and room number match. If you do not wish to receive such calls, please notify the front desk staff at the time of reservation or check-in.
VI. Joint Use
We will share your personal data as follows.
Items of personal data for joint use: Name, gender, date of birth, nationality, passport number, address, e-mail address, telephone number, biodata, health-related information, account information, your preferences.
Joint users: Far East Organization stable of companies and Far East Orchard Limited
For more information, www.fareast.com and https://fareastorchard.com.sg/
Purpose of joint use: Implementation of membership programs (provision of services to members) and other purposes of use described in Section II above.
The person responsible for data management regarding joint use:
Data protection officer of Far East Orchard Limited: DPO@fareastorchard.com.sg
VII. International Transfer
We may transfer your personal data to Singapore, Malaysia, Australia, EU and UK for the joint use described in Section VI and for the collective management of personal data within the group. Of these countries, the EU and UK have been certified by the Personal Information Protection Commission of Japan as having systems for the protection of personal information at the same level as those in Japan. The personal data protection status in Singapore, Malaysia and Australia, the countries to which the data will be transferred, are summarized as follows:
Singapore
https://www.ppc.go.jp/enforcement/infoprovision/laws/offshore_report_singapore/
Malaysia
https://www.ppc.go.jp/enforcement/infoprovision/laws/offshore_report_malaysia/
Australia
https://www.ppc.go.jp/enforcement/infoprovision/laws/offshore_report_australia/
VIII. Contact
Please contact the following for questions, concerns, or complaints regarding our handling of your personal information.
E-mail: DPO@fareastorchard.com.sg
Cookies and Access Logs
1. Cookies
Some parts of this website send and receive information called cookies for the purpose of providing services to customers.
We use cookies primarily:
(1) To customize content delivery and display information, such as advertisements and e-mails, for various input aids and individual customer use in services and e-mails for members, such as websites and smartphone applications.
(2) To be used as statistical data in a manner that does not identify individuals.
*Cookies are used only for the purpose of providing services to customers and analyzing usage, and will not be used for any other purpose.
In addition, cookie information may be stored and referred to via a third party based on the outsourcing of the delivery of advertisements to the third party. If you do not wish to provide such information, you can set your browser not to use cookies, but if you do so, you may not be able to use some of the services on the website.
What is a Cookie?
Cookie is information exchanged between the web server and your browser for the efficient operation of the Internet and may be stored on your information terminal.
Cookies may be used to obtain non-personally identifiable attribute information, device information, user activity history within the website (accessed URLs, contents, order of reference, etc.), and location information based on the user's consent or application when using a smartphone or other device. However, personal information such as e-mail addresses and names will not be obtained through cookies.
In order to provide more customized services, such as member services and e-mail distribution, we may associate this information with information that identifies you.
2. Access Logs
This website records information on your computer when you access it as an access log.
We will use the access log mainly:
(1) To locate and resolve the cause of a problem with the web server;
(2) To improve the website and user satisfaction;
(3) To use the information on the usage of the website as statistical data in a manner that does not identify individuals; and/or
(4) To customize the delivery of advertisements, e-mails, and other content and display information on the website, services for members, e-mail delivery, and other services.
What is an access log?
It is the information such as the domain name or IP address of the user when accessing the site, the file accessed, the OS and browser type used, and the time of access. In addition, we may customize this information by using your previous activity history and other information when associating it with information that identifies you. Once the information becomes identifiable personal information, it will be managed in accordance with the privacy policy of the hotel's website.