PRIVACY POLICY

1. Business Operator

• Company name: Tomaruba Co., Ltd.
• Address: 4F Horinoue-cho Building, 105 Horinoue-cho, Nakagyo-ku, Kyoto 604-8117, Japan
• Personal Information Protection Officer: Takahiro Ashino

2.Personal Information Collected

In providing the Services, the Company may collect the following personal information:

• Name, name in kana (furigana), gender, date of birth
• Address, telephone number, email address
• Information relating to reservations and stays (dates of stay, number of guests, plan, requests, etc.)
• Payment information, including credit card details (card numbers and similar data are not retained by the Company but are processed by the payment service provider described below)
• Information required for the guest register under the Hotel Business Act (name, address, contact details, occupation, etc., and, for foreign nationals without a residence in Japan, nationality and passport number)
• Information provided through inquiries, surveys, and similar channels
• Information collected automatically through use of this website (IP address, cookies, browsing history, device and browser information, access logs, etc.)
• Video recordings from security cameras installed on the premises

3. Purposes of Use

The Company uses collected personal information within the scope of the following purposes:

• Accepting reservations, concluding and performing accommodation contracts, and providing accommodation services
• Processing payments, billing, and refunds
• Preparing and retaining the guest register as required by the Hotel Business Act and other laws
• Responding to customer inquiries and requests
• Sending newsletters and information on campaigns and news (distribution will be discontinued upon request)
• Improving the quality of the Services, developing new services, and analyzing usage
• Managing the operation of the facility, and reporting and sharing information regarding operations with the facility’s owner
• Ensuring the safety and security of the facility and its users
• Preventing fraudulent use and otherwise ensuring the proper operation of the Services

4. Provision to Third Parties

The Company does not provide personal information to third parties without the customer’s prior consent, except in the following cases:

• Where required by law (including compliance with lawful requests under the Hotel Business Act or from police or administrative authorities)
• Where necessary to protect a person’s life, physical safety, or property and obtaining the individual’s consent is difficult
• Where the customer has booked through an external booking site (OTA) or similar service, and information is shared with that operator to the extent necessary to fulfill the reservation
• Where business succession occurs due to merger, business transfer, or other cause

5. Outsourcing of Personal Data Handling

The Company may outsource the following operations to external parties to the extent necessary to achieve the purposes of use. In such cases, the Company exercises necessary and appropriate supervision over the contractors.

• Operation of the booking engine and channel manager used to accept and manage reservations (including centralized management of reservation data from OTAs and similar sources)
• Payment processing, including credit card transactions (outsourced to a payment service provider)
• Distribution of newsletters and similar communications
• Cleaning, facility operations, and other services incidental to the provision of the Services

6. Joint Use of Personal Data

For the purpose of managing the operation of the facility, the Company may jointly use customers’ personal data as follows:

• Personal data subject to joint use: name, contact details, information relating to reservations and stays, etc.
• Scope of joint users: the Company and the facility’s owner (CPA Alliance Co., Ltd.)
• Purposes of use by joint users: the purposes set forth in Section 3 (including facility management and operational reporting)
• Party responsible for management of the personal data: Tomaruba Co., Ltd. (contact details as set forth in Section 11)

7.Use of Cookies, Analytics, and Advertising Tools

This website uses cookies and similar technologies to improve usability, analyze usage, and optimize advertising delivery. Specifically, the Company uses Google Analytics to measure site traffic, and advertising tags from Google Ads and Meta (Facebook) for advertising delivery. Information collected through these tools may include data that cannot, on its own, directly identify an individual. Customers may refuse cookies through their browser settings and may opt out of advertising through the settings provided by each company. Note that disabling cookies may limit the availability of some website functions.

8.External Transmission of Information (Telecommunications Business Act)

Through the tools described above, usage information is transmitted from the customer’s device to external operators. The recipients, the information transmitted, and the purposes of use are as follows:

9. Security Measures

The Company takes necessary and appropriate organizational, personnel, physical, and technical measures to prevent the leakage, loss, or damage of personal information and to otherwise ensure its secure management. Information transmitted through this website is encrypted using SSL/TLS.

10.Requests for Disclosure, Correction, Suspension of Use, and Related Matters

Customers may request disclosure, correction, addition, deletion, suspension of use, or cessation of third-party provision of their personal information held by the Company. Upon receiving a request, the Company will verify the identity of the requester and respond in accordance with applicable law. Requests should be directed to the contact point listed below.

11. Contact

For inquiries, complaints, or requests regarding the handling of personal information:

• Tomaruba Co., Ltd. — Personal Information Inquiries
• Telephone: +81 50-5785-7813 (weekdays, 10:00 AM – 7:00 PM JST)
• Email: info@tomaruba.me

12. Governing Law

The interpretation and application of this Policy are governed by the laws of Japan.

13. Revisions to This Policy

The Company may revise this Policy in response to amendments to laws and regulations, changes in business operations, or other circumstances. Revised versions take effect upon posting on this website.