Air Travel Tokushima Co. (hereinafter referred to as the "Company") has established the following privacy policy (hereinafter referred to as "this Policy") regarding the handling of user’s information, including personal information, for the services provided by the Company (hereinafter referred to as "this Service").

1. User information to be collected and method of collection

• In this Policy, "User Information" shall mean information pertaining to the identification of the user, action history on communication services, and other information generated or accumulated in connection with the user or their terminals, which is collected by the Company in accordance with this Policy. The user information we collect in this Service is categorized as follows, depending on the method of collection.
• (1) Information provided by the user
• The information the user provides in order to use this Service or through the use of this Service is as follows
• ・Information related to your profile, such as name, date of birth, gender, occupation, etc.
• ・Contact information such as e-mail address, telephone number, address, etc.
• ・Credit card information, bank account information, electronic money information, and other payment methods
• ・Still image information including the user's portrait
• ・Information entered or transmitted by the user through input forms or other methods determined by the Company
• (2) Information provided by other services when the user permits linkage with such other services in the use of this Service.
• If the user allows the Company to link the user’s use of this Service with other services, such as social networking services, the Company will collect the following information from such external services based on what the user agreed to when the user gave the Company the user’s permission to do so.
• ・IDs used by the user on the external service
• ・Other information that the user has authorized to be disclosed to the linked party according to the privacy settings of the external service in question.
• (3) Information the Company collects when the user uses the Service
• The Company collects information about how the user accesses and uses this Service. This may include the following information.
• ・Referrer
• ・IP address
• ・Server access log information
• ・Cookies, ADIDs, IDFAs, and other identifiers
• ・Location information

2. Purpose of use

• The specific purposes of use of the user information related to the provision of this Service are as follows.
• (1) To provide, maintain, administer, protect, promote, explain, develop, and improve, including the acceptance of registration, identification, user authentication, recording of user setting, and payment and settlement calculation of usage fees regarding this Services
• (2) To measure the user traffic and behavior
• (3) To deliver and display advertisements and measure their effectiveness
• (4) To conduct surveys related to this Service
• (5) To conduct drawings for campaigns, etc., and to send products, etc., and to contact applicants in connection with such drawings and sending of products, etc.
• (6) To prepare statistical data and marketing materials such as usage history of this Service
• (7) To provide information, contact, and respond to inquiries regarding this Service
• (8) To respond to any violation of the Company's terms and conditions, policies, etc. related to this Service
• (9) To notify you of changes to the Company's terms and conditions, policies, etc. of Service, etc.

3. Methods of notification, publication, obtaining consent, and requesting cessation of use

• The Company shall establish and publicly announce this Policy and post it or link to it in a place where the user can easily refer to it. The user may request that the collection or use of all or part of user’s information be discontinued by making the prescribed settings on this Service. In such a case, the Company will promptly suspend the use of the information in accordance with the Company's regulations. In addition, since the collection or use of user information items is a prerequisite for this Service in some cases, the Company will stop collecting or using such information only when the user withdraws from this Service in accordance with the Company's prescribed method. When the user withdraws from this Service, the collection of the user information will cease. The collected user information will be retained as statistical data processed in such a way that individuals cannot be identified.

4. Cookies, Information collection modules

• 4-1. Most browsers allow the user to manage cookie settings by modifying browser settings. This allows the user to set browser to one of the following
• (1) Automatically accept or reject all cookies
• (2) Automatically accept or reject first-party and third-party cookies
• (3) Notify the user before a cookie is placed on the terminal device so that the user has an opportunity to accept or reject it
• If the user consents to the use of cookies by this Service and later wishes to discontinue, the user may at any time delete the cookies placed and change the browser settings to block all or part of the cookies thereafter through the browser settings. Please refer to the browser's "help" feature for instructions on how to change the user’s settings.
• 4-2. This Service may use the following information collection modules.
• In conjunction with this, data on access to and use of this Service may be sent to the following information collection module providers (including cases where data is stored outside of Japan) for analysis to improve this Service. This information collection module collects information on the use of this Service in a form that does not identify specific individuals. Such information is not used to identify the user.
• (1) Name
• Google Analytics
• https://marketingplatform.google.com/about/analytics
• (2) Provider
• Google, LLC
• (3) Privacy policy of provider
• https://policies.google.com/privacy

5. Third party provision

• The Company will not provide personal information among the user information to any third party (including persons located outside Japan) without obtaining the prior consent of the user. However, this does not apply to the following cases where there is a need to provide such information to a third party (including persons located outside Japan).
• (1) When the Company has the consent of the user
• (2) When the Company outsources all or part of the handling of personal information within the scope necessary to achieve the purpose of use
• (3) When disclosing or providing statistical data or other information in a form that does not allow identification of the user
• (4) When personal information is provided as a result of the succession of business due to merger or other reasons
• (5) When personal information is provided to a business partner or information collection module provider in accordance with the provisions of Section 4.
• (6) When it is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and obtaining the consent of the user may impede the execution of such affairs
• (7) When permitted by the Act on the Protection of Personal Information (hereinafter referred to as the "Personal Information Protection Act") and other laws and regulations

6. Credit card information related to payment services

• The Company outsources credit card payment services to payment processing companies. In such cases, the Company may provide personal information to these subcontractors to the extent necessary.
• The Company will appropriately supervise these subcontractors by concluding contracts with them regarding the handling of personal information. Credit card information (credit card number, expiration date, and security code) entered through the Company’s system is retained by the payment processing companies, and the Company does not retain any credit card information.

7. Disclosure of personal information

• When the user requests disclosure of his/her personal information in accordance with the provisions of the Personal Information Protection Act, the Company will confirm that the request is made by the user himself/herself and disclose the information to the user without delay. If such personal information does not exist, the Company will notify the user to that effect. However, this does not apply to cases in which the Company is not obligated to disclose the information under the Personal Information Protection Act or other laws and regulations. Please note that a fee (1,000 yen per case) will be charged by bank transfer for the disclosure of personal information.

8. Correction and suspension of use of personal information

• 8-1. In the following cases, the Company will conduct the necessary investigation without delay after confirming that the request is made by the user himself/herself, and based on the results, the Company will correct the content of the personal information or suspend its use, and notify the user to that effect.
• (1) When the correction of the content of personal information is requested in accordance with the provisions of Personal Information Protection Act on the grounds that the personal information is untrue.
• (2) When a request is made to suspend the use of personal information in accordance with the provisions of Personal Information Protection Act on the grounds that the information has been used for purposes beyond the scope of the purposes of use publicly announced in advance or that the information has been collected through deception or other wrongful means. If the Company decides not to correct or suspend the use of the personal information, the Company will notify the user to that effect.
• 8-2. If the user requests deletion of the user's personal information and the Company deems it necessary to comply with the request, the Company will confirm that the request is made by the user himself/herself, delete the personal information, and notify the user to that effect.
• 8-3. The provisions of 8-1 and 8-2 do not apply to cases in which the Company is not obligated to make corrections, etc. or suspend use, etc. under the Personal Information Protection Act and other laws and regulations.

9. Contact for Inquiries

• Please direct any comments, questions, complaints, or other inquiries regarding the handling of user information to the following contact point.
• Address
• 1-47-3 Saiwai-cho, Tokushima City, Tokushima Prefecture, Japan
• Company name
• Air Travel Tokushima Co.
• Person in charge of handling personal information
• Masaichi Saka
• Contact (e-mail address)
• aitripper@air-travel.jp

10. Procedures for changing this Policy

• The Company reserves the right to change this policy as necessary. However, in the event that the Company modifies this Policy that requires the consent of the user under the law, the modified Policy shall apply only to the user who has consented to the modification in the manner prescribed by the Company. In the event of any modification of this Policy, the Company shall publicize the effective date and content of the modified Policy and notify the user by displaying the modified Policy on the Company’s website or by any other appropriate means.

• This additional provision applies to the handling of personal information of users residing in the European Economic Area (EEA) in accordance with the EU General Data Protection Regulation (GDPR).

1. Handling of personal information

• The Company shall handle user's personal information in the following cases.
• ・When it is necessary to handle personal information in order to fulfill a contract to provide this Service to the user.
• ・When the handling of personal information is necessary for the pursuit of legitimate interests of the Company or a third party, such as improvement of this Service, promotion of the use of this Service, or provision of such information to a third party
• The Company shall handle user’s personal information in the following cases after weighing the necessity of handling personal information against the user's rights and interests.
• ・When it is necessary to handle personal information in order to comply with the Company’s legal obligations, such as to fulfill the obligation to preserve personal information.
• ・When the Company has obtained the prior explicit consent of the user
• The user has the right to withdraw consent at any time by notifying the " Contact for Inquiries " below. However, the legality of the handling of personal information based on the consent before withdrawal will not be affected by the withdrawal of consent.
• Contact for Inquiries
• Address
• 1-47-3 Saiwai-cho, Tokushima City, Tokushima Prefecture, Japan
• Company name
• Air Travel Tokushima Co.
• Person in charge of handling personal information
• Masaichi Saka
• Contact (e-mail address)
• aitripper@air-travel.jp
• The Company does not make decisions based solely on automated information processing that would have legal or similarly significant effects.

2. Transfer of personal information to a third country

• The Company transfers users' personal information to Japan based on the European Commission's sufficiency certification.

3. Retention period of personal information

• The Company retains users' personal information for the period necessary to achieve the purpose for which it is used. The specific period of retention will be determined in consideration of the purpose of use, nature, and legal and business necessity of the personal information.

4. User rights

• The user has the following rights with respect to the personal information that the Company collects and handles.
• ・The right to obtain information on the handling of personal information
• ・The right to access personal information
• ・The right to correction or deletion of personal information
• ・The right to restrict the handling of personal information
• ・The right to object to the handling of personal information
• ・The right to the portability of personal information
• ・The right not to be subject to automated decision-making
• To exercise any of the above rights, please contact the " Contact for Inquiries" above.
• The user may object to the handling of the personal information to the Personal Data Protection Supervisory Agency of the Member State in which the user resides, workplaces or where the GDPR violation occurred.