Rules for Protecting Personal Information

We will handle all User Personal Information in accordance with the provisions set forth in our Rules for Protecting Personal Information. For more information on our Rules for Protecting Personal Information, please see here.

Personal Information

The term “Personal Information” will have the meaning defined in Article 2(1) of the Personal Information Protection Law for information, etc., that can identify a particular individual.

Personal Information Protection Manager

The following person shall be responsible for managing any and all Personal Information regarding Users:

Applicable Information

We will be responsible for handling and managing any and all Personal Information supplied by Users to us on or through the websites for providing the Service (“http://www.travelko.com,” and their respective mirror sites and sub-domains, hereinafter collectively called the “Site”) in accordance with this Privacy Policy.
Notwithstanding the foregoing, we shall have no responsibility whatsoever in any of the following events:

• If the User independently discloses and/or makes known the User’s Personal Information on and/or through any external website having a link to the Site;
• If the User’s Personal Information is disclosed or made known due to the act of any third person who has obtained the User’s password, email address and/or member ID; or
• If the User independently discloses and/or makes known the User’s Personal Information in any manner other than using a function or feature of the Service.

Purpose of Utilization of Personal Information Provided

We hereby agree that we will use the User’s Personal Information for the following purposes, and, without obtaining the User’s prior consent or except pursuant to laws or regulations, we will not use it for any other purpose.

However, please note that we may change or modify any of the following purposes within the scope of, and only to the extent reasonably related to, any of the aforementioned original purposes; provided, however, that such change or modification will be announced on the Site in advance.

Relating to Inquiries or Applications, etc., about or for Travel, etc.:

• To disclose to any tour company, etc., information voluntarily disclosed by the User in carrying out inquiries, making applications or performing similar acts relating to travel, etc.
• To contact the User if there are any problems between the User and a tour company, etc.

Relating to Registered Information:

• To distribute e-mail newsletters to interested Users and to respond to questions relating to e-mail newsletters that have been distributed
• To publish on the Site, etc., comments, suggestions for improvement, evaluations of posted information and other feedback (“Feedback”) voluntarily provided by Users
• To analyze the provided information about attributes such as sex, age, place of residence and feedback, and to use it to study how to improve the Service

Relating to Inquiries to Travelko:

• To respond to User inquiries or opinions

Relating to Inquiries or Applications, etc., about or for Correspondent Blogs:

• To contact Users who have made applications for use
• To contact Users, or to make information (i.e., posted information) publicly available

Other:

• To accept applications in the course of various marketing campaigns, to contact winners and to deliver prizes
• To provide the Service by using the history of viewing and purchasing travel products, etc. and actions or the location information of Users
• To recognize and analyze usage status such as the history of viewing and purchasing travel products, etc. and actions or the location information of Users and to develop the Service using that information
• To compile statistical information

• Note: If a User has concluded a travel contract and/or accommodation contract with a tour company, etc., then the provisions stipulated in the privacy policy established by the tour company, etc. shall apply.

Measures for Securing Personal Information

We will take appropriate and reasonable security measures to prevent any illegal access to any Personal Information or any loss, destruction, alteration or disclosure of any Personal Information, which security measures shall be reviewed and revised continuously. We use encrypted communication technology based on SSL (Secure Socket Layer) on the Site for secure exchange of User Personal Information.
For details about the measures that constitute our system for handling Personal Information, please see here.

Provision of Personal Information to Third Parties

We may provide tour companies, etc. with User Personal Information to the extent necessary for answering User applications and/or inquiries for, or about, travel, etc., or other transactions involving such tour companies, etc.

We shall not provide to any third party any User Personal Information without prior User consent except in the aforementioned cases; however, we may provide User Personal Information to a third party without obtaining User consent in any of the following cases:

• Pursuant to laws and/or regulations;
• If it is necessary to provide the Personal Information in order to protect the life, person and/or property of an individual and it is difficult to obtain the User’s consent;
• If it is specifically necessary to provide the Personal Information for improving public health or promoting the sound growth of children and it is difficult to obtain the User’s consent;
• If it is necessary to provide the Personal Information for cooperating with a state organ, a local government, or a person entrusted by any of these with carrying out any task prescribed by laws and regulations, and if obtaining the User’s consent might impede the execution of such task;
• If the provision of the Personal Information is required by any applicable law and/or regulation, or if the provision of Personal Information to a third party is on a voluntary basis but such third party has a basis for receiving such Personal Information pursuant to applicable laws and regulations; or
• If we determine that the relevant User will cause, or is likely to cause, any harm to us or any third party.

Entrustment to External Operators of the Handling of Personal Information

To the extent necessary to achieve the purposes of utilization of the Personal Information, we may entrust all or part of the handling of Personal Information to external operators. If such entrustment occurs, then it will be determined whether the entrusted party meets certain standards regarding protection against improper access to Personal Information; the loss, corruption, alteration or disclosure of Personal Information; and the proper handling of Personal Information; and if these conditions are satisfied then we and the entrusted party will execute a non-disclosure agreement. In such a case, we shall undertake periodic assessment of the entrusted party and shall exercise necessary and appropriate supervision over the entrusted party.

Handling of Anonymously Processed information, Pseudonymously Processed Information and Statistical Information

We may use User Personal Information to create and use Anonymously Processed Information, Pseudonymously Processed Information or Statistical Information. In such cases, it will be created and used in accordance with the appropriate procedures and in compliance with the Personal Information Protection Act and other relevant laws and regulations. In addition, in a manner analogous to Personal Information, appropriate security control measures and measures for the supervision of contractors will be taken.

Voluntariness of Providing Personal Information, and Effects on Users Who Do Not Provide Personal Information

User provision of Personal Information to us will be voluntary, except for information whose provision is deemed to be essential; however, if a User does not provide us with Personal Information necessary for us to provide the Services on the Site, then the User may be unable to use all or part of the Services.

Assurance of the Accuracy of Personal Information

We shall endeavor properly to handle User Personal Information within the scope necessary for the achievement of the purpose of utilization of the Personal Information; however, a User will be responsible for keeping the User’s Personal Information accurate and up-to-date.

Procedures for Responding to Requests for Disclosure, Correction and Discontinuance of Utilization of Personal Information

Pursuant to Article 37(1) of the Personal Information Protection Act, Users can request the disclosure, etc. of their Personal Information or of records of its disclosure to a third party. Upon receiving a request from a User for the disclosure, etc. of such User’s Personal Information, we, after confirming the identity of the User, will meet the request to a reasonable extent. To make a request for disclosure, etc., please contact the “Contact for Handling Personal Information, Travelko Office” identified below.

Questions About Personal Information

For questions relating to Personal Information, please contact the following help desk:

We may use Personal Information obtained in connection with User inquiries for the purpose of responding to such inquiries.

In order to respond to inquiries, we may confirm the identity of a User using information that allows us to identify a specific User. In principle we will respond via the requested response method, but if considerable expense is required or other difficulties are involved, then we may respond in writing.

Modification of this Privacy Policy

We may modify this Privacy Policy at any time when we deem it necessary. If we modify the Privacy Policy, then we will post the modified Privacy Policy on the Site. Users who use the Site after such modifications will be deemed to have accepted them, so please check and confirm the Site periodically.

Cookies and Other Tracking Technology

We may obtain information through the use of cookies, pixels, tags, and other tracking technology (collectively, “Cookies”) on the Site and on sites operated by cooperating travel agencies, etc.

This Paragraph will govern such information obtained through Cookies that is not Personal Information.

We may use information obtained through Cookies for the following purposes:

• To provide services and features to Users who have requested them
• To distribute content (including advertisements) conforming to User preferences and geographic locations
• To confirm the status of requests for travel, questions, and other transactions that Users have had with travel agencies, etc.
• To correspond with Users regarding the Site
• To compile statistical information
• Otherwise to make improvements to the Site and to User experiences and services

If, in connection with the above-mentioned use, there is any receipt or provision of person-related information to which Article 31(1) of the Personal Information Protection Act applies, then the information will be provided or received in accordance with appropriate procedures and in compliance with the Personal Information Protection Act and other relevant laws and regulations. Confirmation of User transition via Cookies is a foundation of the maintenance of services on the Site. Accordingly, if a User refuses to accept Cookies, then it may not be possible to provide services through the Site.

Subcontracting the Saving of Cookies to Third Parties

The Site may save and refer to Cookies by using the following third-party services:

1. Google Analytics, Google AdWords and Firebase

• Provider: Google LLC
• Manner of collection and use of cookies: as stated in the Google Analytics Terms of Service, the document entitled “How Google Uses Information from Sites or Apps that Use Our Services” and the Google Privacy Policy.
• Method of deactivating the collection of cookies: Google Analytics Opt-out Browser Add-on

2. Advertising distributed by Yahoo Japan Corporation

• Provider: Yahoo Japan Corporation
• Manner of collection and use of cookies: as stated in “Yahoo! Japan Privacy Center” and “Use of Personal Data in Advertisements Distributed by Yahoo! Japan” .
• Method of deactivating the collection of cookies: as stated in “Use of Personal Data in Advertisements Distributed by Yahoo! Japan” .

Last Update: April 4, 2022