Article 1 Basic Policy on Handling of Personal Information

SKYTREK, Inc. (hereinafter referred to as the "Company") recognizes the importance of personal information and strives to appropriately handle and protect personal information based on the following policy.

Article 2 Compliance with Laws and Regulations

The Company shall comply with applicable privacy laws and regulations, including laws and regulations concerning the handling of personal information, guidelines established by the government, the EU General Data Protection Regulation (GDPR), and related national enabling laws in respective countries.

Article 3 Personal Information

"Personal Information" refers to information about an individual that can identify a specific individual, such as name, address, date of birth, age, gender, telephone number, family structure, email address, ID, IP address, place of employment, department, work address, work telephone number, etc. (including information that can be easily collated with other information to thereby identify a specific individual).

Article 4 Method and Purpose of Acquisition of Personal Information

The Company acquires personal information of users by appropriate and fair methods for the following purposes and uses it strictly within the scope of these purposes:
  • (1) Provision of aircraft charter services and travel planning/arrangement services provided by the Company (hereinafter referred to as "Company Services") (including necessary provision of information to partner operating companies and business partners)
  • (2) Sending promotional materials, email newsletters, and sales announcements by the Company and the joint users specified in Article 7 (hereinafter referred to as the "Company Group")
  • (3) Marketing activities, research, study, development, and improvement of services/products by the Company Group
  • (4) Responding to inquiries or requests, and properly and smoothly fulfilling transactions with users and other relevant parties
  • (5) Creation of statistical data (data from which individual users cannot be identified)

When acquiring personal information of users for purposes other than those listed above, the purpose will be specified in advance, and use will be limited to the scope of that purpose.

Article 5 Personal Information Management Measures

The Company establishes a personal information management system to maintain the accuracy of personal information and strive to prevent loss, damage, alteration, unauthorized access, and leakage.
The Company promotes education and awareness activities for officers and employees, providing necessary and appropriate supervision to ensure the safe management of personal information.
The Company may entrust part or all of its operations to a third party and provide personal information to the subcontractor within the necessary scope. In such cases, the Company will provide necessary and appropriate supervision to ensure that personal information is handled safely by the subcontractor.

Article 6 Provision of Personal Information to Third Parties

The Company will not disclose or provide acquired personal information of users to third parties, except in the following cases:
  • When user consent has been obtained
  • When disclosure or provision of personal information is required based on laws and regulations
  • When necessary for the protection of human life, body, or property, and it is difficult to obtain user consent
  • When it is necessary to cooperate with national agencies, local governments, or entities entrusted by them in executing affairs prescribed by laws and regulations, and obtaining user consent risks hindering the execution of such affairs
  • When disclosing or providing information processed into a state where individual users cannot be identified, such as statistical data

Article 7 Joint Use

The Company jointly uses personal information of users as follows:
Purpose of Joint Use
In accordance with the purpose of use of personal information specified in Article 4.
Personal Information Jointly Used
User's name, date of birth, gender, address, telephone number, FAX number, email address, workplace information (company name, department, title, address, phone/FAX number, contact person), flight ticket, reservation/boarding information, etc.
Scope of Joint Users
Parent company and partners having a capital relationship with the Company (hereinafter referred to as "Jointly Using Companies").
The names of the entities jointly using the information are posted on the Company's website. If there are changes to the entities jointly using the information, notice will be given or posted on the Company's website.
Person Responsible for Management of Personal Information
SKYTREK, Inc.

Article 8 Retention Period

The Company retains personal information of users for a certain period after the end of the provision of Company Services and for the period necessary to fulfill obligations under laws and regulations.

Article 9 Use of Cookies and Other Technologies

When users use Company Services or view pages, the Company automatically acquires information such as advertisements, pages, apps viewed by the user, and user operating environments using user cookie information, Apple's Advertising Identifier (IDFA), Google's Advertising ID (AAID), etc. (hereinafter referred to as "Cookies, etc."), and records it on Company servers. This information is not intended to identify individuals and is used to improve services and optimize advertisement distribution. Please see below for purpose and method of use:
(1) Saving Basic Settings
To provide a more comfortable service environment, Company Services use Cookies, etc. to save display settings customized by the user.
(2) Understanding Usage Status and Considering Service Improvements
As a reference for providing services better suited to user interests and needs, Google Analytics provided by Google is used to understand and analyze the usage status of Company Services. Google Analytics analyzes the usage status of Company Services using Cookies, etc. The method of collection and use of access information by Google is governed by the Google Analytics Terms of Service and Google's Privacy Policy.

Users can set whether to allow the use of Cookies, etc. However, if the use of Cookies, etc. is prohibited, some settings and services within the service that require Cookies, etc. may not be available.

Article 10 Inquiries Regarding Personal Information

Inquiries regarding the Company's handling of personal information should be directed to the following:

SKYTREK, Inc.
6-13-5 Akasaka, Minato-ku, Tokyo 107-0052, Japan
info@skytrek.co.jp

Residents in EU member states subject to the EU General Data Protection Regulation (GDPR) exercising their rights under GDPR should contact the inquiry point listed above. If not processed appropriately, a complaint may be lodged with a supervisory authority.

Article 11 Procedure for Changes to Privacy Policy

The Company may change the above policy as necessary due to revisions to laws and regulations, review of operational status regarding the handling of personal information, etc. In such cases, the revised Privacy Policy will be posted on the Company's website.

Supplementary Provisions

Enacted on September 20, 2018