JOT INTERNATIONAL (hereinafter called “JOT”) will handle your personal information with the utmost care in order to respect the privacy of our users and to protect their personal information. Here, we would like to explain how JOT handles our customer information.

1. JOT’s Personal Information Protection Policy

1.Compliance

JOT complies with applicable laws, ordinances, regulations, and guidelines pertaining to personal information protection. JOT’s relevant internal rules keep all personnel informed about these matters, and JOT handles our customer personal information appropriately.

2.Acquisition and use of personal information

JOT will request our customers to provide us with their personal information when the customer uses JOT’s services. In this case, JOT, in principle, will first obtain consent from the customer and then acquire the customer’s personal information from the customer directly. When acquiring personal information, JOT specifies, informs, or has publicized the purposes of use, and handles the personal information of our customers in accordance with those purposes of use.

3.Appropriate administration of personal information

JOT has developed and continues to review its internal rules and relevant guidelines in order to prevent data leakage, loss, falsification, etc. of the personal information of our customers, takes necessary countermeasures, and implements the appropriate administrative actions.

4.Customer consultation window

At our customer’s request, JOT permits the disclosure, correction, elimination, or cessation of use of personal information in our custody, and will respond in good faith to your requests.

2. Purposes for acquiring or using personal information

JOT may ask customers to submit their personal information in order to provide them with services, including reservations of accommodations, dining, and other activities. For smoother operations, some operations may be outsourced and the personal information of our customers may be provided to contractors to the extent necessary. In this case, JOT enters into a contract with the outsourcing company regarding the handling of personal information and its appropriate administration. JOT uses the personal information that is submitted by our customers for the following purposes:

• 1.When JOT needs to contact a customer in order to confirm a reservation or other matters.
• 2.When JOT conducts an analysis in order to improve our services and products.
• 3.When JOT informs customers of new services, new products, the opening or closing of restaurants, etc.
• 4.When JOT responds to inquiries, etc. from customers.
• 5.When JOT separately indicates the purpose of use.

3. Disclosure or offer of personal information to third parties

JOT will neither disclose nor offer the personal information of our customers to third parties, unless submitting the personal information to our outsourcing company as stated in Item 2. Purposes for acquiring or using personal information, or, in the following cases:

• 1.When the customer permits;
• 2.When the personal information is accumulated as statistical data of JOT’s services and disclosed or offered in the condition that individual customers cannot be identified; or
• 3.When the personal information is disclosed or offered in accordance with legal requirements (including personal information protection laws) and relevant guidelines.

JOT INTERNATIONAL (hereinafter called “JOT”) will handle your personal information with the utmost care in order to respect your privacy and to protect your personal information.
In this Privacy Policy (“the Privacy Policy”), we would like to explain how JOT handles your personal information subject to EU General Data Protection Regulation No 2016/679 (“GDPR”).

1. JOT’s basic policy for personal information subject to GDPR

1. JOT complies with GDPR, other applicable laws, guidelines, and its relevant internal rules pertaining to your personal information. JOT keeps all employees informed about these matters and handles your personal information appropriately.

2. JOT may request you to provide us with your personal information when you use JOT’s service.
When acquiring your personal information, JOT specifies, informs, or has publicized the purposes of processing, and handles your personal information in accordance with those purposes. Furthermore, as part of a contractual relationship between you and JOT, you are required to provide your personal information which is required to establish and perform a contract.
Without such personal information, JOT will generally not be able to conclude a contract with you, or to execute the same, and might not be able to provide you with the requested services.

3. JOT has developed and continues to review its internal rules and relevant guidelines in order to prevent data leakage, loss, falsification, etc. of your personal information,takes necessary countermeasures, and implements the appropriate administrative actions.
Furthermore, JOT will keep your personal information as long as it is necessary for JOT to comply with its legal obligations or to achieve the purposes mentioned below.

4. JOT will not make decisions only on automated means such as profiling of personal information.

2. Purposes for acquiring and using personal information

JOT may ask you to submit your personal information in order to provide you with services, including reservations of accommodations, dining, marine activity, and other activities.
JOT processes your personal information based on one of the legal basis provided for in GDPR (Article 6 and 7). In addition, JOT processes your sensitive personal information, for example, concerning your religious requirements, health condition, or food allergy, in accordance with the special rules provided for in GDPR(Article 9 and 10).

JOT may collect and process your personal information for the following purpose, based on the necessity for the performance of a contract between you and JOT (Article 6.1 (b) GDPR):

・to manage your reservation.

JOT may collect and process your personal information for the following purposes, based on obtaining your express prior consent (Article 6.1 (a) GDPR):

・to conduct analysis in order to improve JOT’s services and products; and

・to inform you of new services, new products, the opening or closing restaurants, etc.

JOT may also collect and process your personal information for the following purpose,which is required so that JOT can pursue its legitimate interest and provide you with adequate services and products:

・to respond to inquiries, etc.

You may withdraw your consent at any time.
The withdrawal of consent will not affect the lawfulness of processing personal information based on consent before the withdrawal.
You may withdraw your consent by contacting JOT (contact details are provided in “5.Contact”).

3. Disclosure or offer of personal information to third parties

JOT will neither disclose nor offer your personal information to third parties, unless falling into the following cases:

1. When obtaining consent from you;

2. When the personal information is accumulated as statistical data of JOT’s services and disclosed or offered in the condition that individual customers cannot be identified; or

3. When the personal information is disclosed or offered in accordance with legal requirements (including GDPR and other applicable laws) and relevant guidelines.

Furthermore, where we share your personal information with any entity outside the European Economic Area, JOT will put the appropriate legal framework (notably,Standard Contractual Clauses) in place in order to cover such transfers (Articles 44 ff. GDPR).

4. Your rights

You have the following rights regarding personal information collected and processed by JOT.

・Access to personal information: You have the right to obtain from JOT confirmation as to whether or not personal information concerning you are being processed, and,where that is the case, access to the personal information and certain related information(Article 15 GDPR).

・Rectification or erasure of personal information: You have the right to obtain from JOT the rectification of inaccurate personal information concerning you without undue delay, and to complete any incomplete personal information (Article 15 GDPR).
You may also have the right to obtain from JOT the erasure of personal information concerning you without undue delay, when certain legal conditions apply (Article 17 GDPR).

・Restriction on processing of personal information: You may have the right to obtain from JOT the restriction of processing of personal information, when certain legal conditions apply (Article 18 GDPR).

・Object to processing of personal information: You may have the right to object, on grounds relating to your particular situation, at any time to processing of personal information concerning you, when certain legal conditions apply (Article 21 GDPR).

・Data portability of personal information: You may have the right to receive your personal information in a structured, commonly used and machine-readable format,and have the right to transmit those information to another controller without our hindrance, when certain conditions apply (Article 20 GDPR).

In case you exercise such rights stated above, please see contact details provided in “5.Contact”.
You may also lodge a complaint with a country, territory, international organization, or supervisory authorities regarding the processing of your personal information by JOT, in accordance with GDPR and other applicable laws.

5. Contact

For any questions or requests relating to the Privacy Policy, please contact JOT (contact details are as follows).

JOT INTERNATIONAL
YYYCLUB iE RESORT
1965 Higashimae, Ie-son, Kunigami-gun, Okinawa
905-0502 JAPAN
TEL: 0980-49-5011