privacy policy

Chapter 1: Privacy Policy

1. Purpose of setting a privacy policy

We set the Privacy Policy in order to protect and secure our customer’s personal information and to offer our customer a continuous sense of safeness and trustworthiness.

2. Scope of application

The Privacy Policy will apply when customers use ANA Business Jet’s services and products.

3. Purpose of using personal information

3.1 Purpose

ANA Business Jet utilizes personal information obtained from customers for the following purposes:

Notification of services and products
Guidance, provision, and management of other services
Guidance, operation, management and information provision for various events and campaigns
Implementation of questionnaires concerning service and products, etc.
Development of new services and products
Response to inquiries and requests
Service provisions for ANA Mileage Club members

3.2 Handling of credit card information

The credit card information ANA Business Jet obtained will be used for credit card settlement only and will be saved until the completion of settlement. At the time of receiving credit card information, we will clarify the credit card company to which the information is provided.

3.3 Disclosure and provision of information to a third party

ANA Business Jet will not disclose or provide personal customer information to any third parties except under the following circumstances. Note that provision of information to business entrusted companies is not deemed to constitute disclosure or provision to third parties.

Customer consent has been obtained.
Disclosure or provision is required in accordance with laws or regulations.
Disclosure is required to protect human life, health, or property in cases where obtaining customer consent is difficult.
Disclosure is required to cooperate with the public affairs of national or local governments, and when obtaining customer consent is likely to hinder the administration of public affairs.
Disclosure or provision of information is done as statistical data, in a format that does not disclose the customer's identity.
Data is shared based on “3.5 Data sharing.”

3.4 Data sharing

ANA Business Jet will share customers’ personal information it holds, such as the name, address, phone number, email address, itinerary, among the ANA group companies mentioned below, to contact our customers.
The ANA group companies may use the shared data to provide information on each group company, its products, and the details of its events or to deliver purchased products.

3.5 Business entrustment

ANA Business Jet may entrust part of its business operations to third parties to which personal information may also be disclosed to the extent necessary. In these cases, ANA Business Jet will implement all appropriate measures in supervising such third parties, including establishing agreements on the handling of such personal information with them.

4. Transfer to outside of Japan

If ANA Business Jet provides customers’ personal information to third party business operators outside of Japan, including business entrusted companies and data sharing partners, it will take necessary and appropriate measures in keeping with laws and regulations.

5. Implementation of safety measures

ANA Business Jet implements information security measures to ensure the accuracy and safety of customers’ personal information. It saves such personal information in an environment that general users cannot access, so that unauthorized access to personal information and the loss, destruction, alteration, leak, etc, of such information are completely prevented. In addition, when it is decided that an improvement of our information security measures is required in light of results of internal audits, actual cases of security incidents at other companies, or requests by customers, ANA Business Jet will promptly correct the measures.

6. Compliance with laws and regulations and other rules

ANA Business Jet will comply with laws and regulations related to the handling of personal information, guidelines presented by the supervisory authorities (such as the Ministry of Land, Infrastructure, Transport and Tourism), and other rules.

7. Disclosure, correction, deletion, addition, discontinuance, and erasure

Any customer request submitted in the manner specified for 1) the disclosure, 2) the correction, deletion, or addition, or 3) the discontinuance and erasure of personal information held by ANA shall be handled as follows, within a reasonable timeframe, after such requests are determined to be authentic.
A customer request may be rejected partially or entirely if compliance with such request would endanger the life, health, or property of the customer or a third party; seriously impact ANA's business operations; or result in a violation of laws or regulations.

7.1 Appropriate acknowledgement will be made of receipt of disclosure requests.

7.2 Correction, deletion, or addition shall be undertaken as necessary after due review of requests.

7.3 Discontinuance and erasure shall be undertaken by appropriate methods. However, we remind customers that such requests may impede the provision of services to the customer, despite our best intentions.

8. Submission of request for disclosure, etc. and inquiries

For requests in the preceding paragraph concerning personal information of customers subject to disclosure, as specified by ANA Business Jet, and inquiries such as complaints and consultation relating to personal information, refer to the following:

8.1 Contact point

For requests for disclosure etc. (notification of purpose of use, disclosure, correction, deletion, addition, discontinuance, erasure, or discontinuance of the provision to a third party of customers’ personal information held by ANA Business Jet), please send the specified application form after filling in all of the required items, together with the required documents, by postal mail to the address below.

Personal Information Administrator
ANA Business Jet Inc.
Cross Office Uchisaiwaicho, 1-18-6, Nishishinbashi, Minato-ku, Tokyo 105-0003, Japan

For questions in submitting the request for disclosure, etc. or other consultation or inquiries, send the required documents by postal mail to the above address or send an email to the following email address.
Personal Information Administrator of ANA Business Jet: info@anabj.co.jp

8.2 Documents to be submitted for request for disclosure, etc. and fees

In making “a request for disclosure, etc.”, please fill in all the required items in the applicable application form below and send it together with identity verification documents by postal mail. Customer requests for disclosure, etc., may not be acknowledged if any of the required information is missing. For application forms, please download from the link below.

1) Predetermined application form

2) Fees

Applicants are charged a fee of 1,000 JPY for each application for disclosure/the notification of purpose of use.

3) Submission of request for disclosures, etc.

Please fill in the application form at 8.2 1) and send to the address below.

Personal Information Administrator
ANA Business Jet Inc.
Cross Office Uchisaiwaicho, 1-18-6, Nishishinbashi, Minato-ku, Tokyo 105-0003, Japan

9. Modification of the Privacy Policy

ANA Business Jet may make modifications to this Privacy Policy. If modifications are made, details will be posted on our ANA Business Jet website (www.anabj.co.jp), so please be sure to read carefully the contents of any changes that have been made.

Chapter 2. Handling of personal information of EEA residents

Besides Chapter 1, Chapter 2 also shall be applied to the handling of personal information of persons residing in the European Economic Area (hereinafter referred to as “EEA”) based on the REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive “95/46/EC.” In the event that any provisions of this chapter contradict those of chapter 1, the provisions of this chapter shall prevail.

1. Introduction

A guardian’s consent or permission must be obtained in the event that a customer under the age of 16 uses ANA Business Jet’s service and consents to this Privacy Policy. The data subject’s consent to this Privacy Policy must be obtained in the event where a person is applying for service of ANA Business Jet on behalf of the data subject.

2. Request about handling of Personal Information

If ANA Business Jet receives from an EEA resident a request relating to customers’ personal information it holds, besides Chapter 1, Article 8 (Submission of request for disclosure, etc. and inquiries), such request will be handled as follows, within a reasonable timeframe and scope, after confirming that the request was submitted by the customer himself/herself.

2.1 Request for withdrawal of consent

Personal information will be deleted or suspended in accordance with the customer’s request, wherever possible and appropriate, after due review of the request.
However, please note that such requests may prevent customers from being provided with services that they had utilized, or may impede the provision of services in accordance with their wishes.

2.2 Request for data portability

A copy of the personal information held by ANA Business Jet will be provided in accordance with the customer’s request, wherever possible and appropriate, after due review of the request.

2.3 Objection to data processing

The use of personal information will be suspended, wherever possible and appropriate, after due review of the request.

2.4 Making a request

Customers may submit the requests mentioned in the above (1) through (3) by the method provided in Chapter 1, Article 8 (Submission of request for disclosure, etc. and inquiries). Customers may use the following forms for submission.

3. Transfer to outside of EEA

ANA Business Jet may provide the customers’ personal data to third parties, such as its affiliates, and business entrusted companies (Cloud service providers etc.), to implement the purposes of use specified above. Since countries located outside the EEA (including, without limitation, Japan and the U.S., the same shall apply hereafter) are among the locations of third parties to whom ANA Business Jet will disclose the personal data of the customers, the customers shall be deemed as having consented to the following matters by consenting to the Privacy Policy:

3.1 In the case that the country in which the third party is located is outside the EEA, such country does not have the same data protection laws as the EEA, and many of the rights provided in the EEA to the data subjects of the data will not necessarily be provided.
3.2 The customers’ personal data may be provided for the purposes specified above to third parties outside the EEA.

4. Change of purposes of use of personal data

n the case of a change to the purposes of use of personal data, ANA Business Jet will announce the revised Privacy Policy in advance on ANA Business Jet website (www.anabj.co.jp).

5. Lodging a complaint with an authority

Customers have the right to lodge a complaint on the processing of their personal data with the data protection authority having jurisdiction over their residence. Please use the following URL to contact the authority having jurisdiction over your residence: (http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080)

6. The contact information of data protection officer

Data protection officer of ANA Business Jet is Personal Information Administrator, and you can contact him/her at info@anabj.co.jp.

as of 2nd July, 2018