SEN Inc. (“SEN”, “we”, “us”, “our”) recognizes that your privacy is of utmost importance and shall be respected according to the applicable laws protecting your privacy rights. Therefore, SEN is committed to adhere to the following policy guidelines for all matters related to collection, use, disclosure and sharing of your personal information and personal data (“Personal Information”) when our customers, visitors, and users (“Users“, “you“, or “your“) use our sites, services, products, contents and/or visit our facilities (“Services”).
Article 1 (Definition)
Personal Information is information that can be used to contact or identify you, such as your full name, email address, phone number, payment method and profile picture, as well as information that is linked to such Personal Information.
Article 2 (Data collection and processing)
- To provide our Services, we collect and process non-personal information and Personal Information about our Users. The type of information collected may include (but is not limited to) internet protocol (IP) addresses (which may vary from session to session), MAC address, mobile network information including phone number, device type and hardware model, browser type, operating system type, type of browser, Internet Service Provider (ISP), date/time stamp of Site or Service use, referring/exit pages, and clicked pages.
- You may request to withdraw your consent; however such request may not retroactively affect the Personal Information collected and processed prior to such request. Furthermore, Personal Information of anyone under the age of 16 (sixteen) shall only be collected and processed with parental consent from their parent or guardian (“Parent“).
- As a general rule, SEN shall not collect and process any Personal Information beyond the extend described in the table below. For information, collection and processing of Personal Information collectively describes all manual or automatic activities related to data handling, including but not limited to acquiring, collecting, recording, editing, structuring, saving, revising, restoring, referencing, processing, transferring, organizing, combining, disposing, deleting, physical destruction of such data. Disclosure and sharing shall be restricted to data already publicly available or of common-knowledge.
Table: Information collected and corresponding processing purpose
|General processing purpose||Detailed processing purpose||Processed information|
|To provide, promote and improve our Services||
• To confirm our User’s identify and prevent illegal/wrongful mishandling when booking a room and using our Services
|To notify and correspond with Users||
To notify Users regarding our Services and respond to their inquires
• Email address, contact information
|To contract the handling of Personal Information||
Third parties receiving the information listed in the right column will follow the purposes listed below:
• Name, occupation, other information necessary to provide our Services
|To conduct statistical data analyses||
To facilitate, promote and improve our Services
• Information listed above, in part or in whole
Notwithstanding, SEN may collect and process the Personal Information of a User beyond the extend described in the table above in either of the following conditions and/or circumstances:
- Explicit consent from such User have been received
- Such User’s Personal Information is unavoidably needed to fulfill our contractual obligations towards such User (including but not limited to the provision of our Services).
- When we have a good faith belief it is required by law, such as pursuant to a subpoena or other legal process;
- When the personal interest of our Users needs to be protected,
- In matters of public or general interest (such as public health, sanitation, social security, healthcare services related to necessary medical care or treatment), or to perform tasks dictated to us by public authorities
- In pursuit of justifiable interest for SEN or a third party company.
Article 3 (Changes in processing purpose)
In the event that SEN needs to revise with reasonable intent the processing purposes listed in the precedent article, we shall properly notify and seek our Users’ consent.
Article 4 (Collection of Personal Information)
- SEN will not collect Personal Information in any illegal or improper manner. Collection of Personal Information will be conducted according to what our Users have consented to.
- In the event that SEN needs to collect Personal Information beyond what has been consented for the scope of its Services, we shall properly notify and seek our Users’ consent before collecting any further Personal Information.
Article 5 (Safe data management)
Article 6 (Handling of email addresses)
- To protect our Users against loss, theft, falsification, destruction or illegal outside access of their email address, SEN commits to thoroughly protect it following the same laws, guidelines and methods as for Personal Information.
- To protect our Users’ email address, we will implement measures to restrict employee access and limit it to only authorized administrators.
- SEN may contact all of its users when tan important message needs to be communicated.
Article 7 (Handling of cookies and other technological features)
- Cookies are a small piece of data sent from a website server (HTTP) to the user’s computer via its web browser, while the user is browsing. Cookies are designed to be a reliable mechanism for website to remember stateful information or to record the user’s browsing activity.
- Cookies can discern browser activities, however it cannot discern personal activities.
- Depending on the browser used, cookies can be sometimes deactivated. In such case, Services on our website might become unusable in part or in whole.
Article 8 (External services and links)
Under certain circumstances, SEN may provide Services that involve an external service provider (“External Service Provider”). If our Users purposely use such External Service Provider to access and use our Services, we may need to receive and/or disclose Personal Information with such External Service Provider. (e.g. “Booking.com”)
Article 9 (Disclosure and sharing of Personal Information)
SEN may only disclose and/or share Personal Information to third parties, with User’s consent and in strict respect of applicable laws and guidelines related to personal privacy, under the circumstances listed below:
- When SEN contracts a third party to handle Personal Information in part or in whole to fulfill its Services
- When SEN needs to invoice Users, request or process payments from payment system companies, credit card companies or banks
- When SEN needs to share company and Personal Information in the event of a merger, acquisition, assignment, joint venture or other company change of incorporation, to joint venture partners, assignee company or any relevant third parties.
- When SEN is required to disclose and/or share Personal Information by law to the public authorities such as the police or courts of justice.
Article 10 (Disclosure, correction of Personal Information)
- SEN provides the following rights to all of our Users:
- Access to User’s Personal Information
- Correct, remove User’s Personal Information
- Restrict on data processing
- Oppose data processing
- Data portability (transferability)
- For any request of information disclosure, correction, removal, restriction, portability (etc), we invite our Users to contact SEN with the information listed in the following article.
- We will support such request to a reasonable extend, upon formal verification of the requester’s identity. However, we may not be able to fulfill some of the requests unless obligated by the relevant privacy protection laws.
- Our Users have the right to file objections to the relevant data protection authorities of their country of jurisdiction with regards to data handling and processing.
Article 11 (Contact information)
Please use the following contact information to reach out to us for all matters related to Personal Information such as feedback, questions or claims.
(Office hours are restricted to weekdays 10am to 5pm, Japan time)
Article 12 (Organization)
- At SEN, our data security officer is also responsible for the adequate management of our User’s Personal Information, and its continuous improvement.
- We strongly conform to the applicable laws and policies related to the protection of Personal Information, as well as follow the “Guidelines for personal information protection applicable to businesses with electronic communications” of the Japanese Ministry of Internal Affaires and Communications. Furthermore, we commit to continually improve our protection and management systems for Personal Information according to ongoing societal and environmental changes.
Article 13 (Disclaimer)
SEN bears no responsibility in any of the following cases:
- When our Users disclose their own Personal Information to a third party.
- When our Users suffer any damage related to discriminatory information NOT required by SEN but entered by the Users themselves through our Services.
Article 15 (Other notice)
SEN bears no responsibility with regards to content or Personal Information protection for services outside of SEN’s direct management.
Article 16 (Retention period of Personal Information)
SEN commits to promptly remove and destroy Personal Information that has become irrelevant or unnecessary to the Company’s purposes per Article 2. However, SEN will continue to retain Personal Information in the specific cases listed below:
- For public interest
- For potential research purposes
- For statistical analyses