INSTRUCTION & SUMMARY

Shinmonzen K.K hereafter “The Shinmonzen”, a company registered in Kyoto, Japan has prepared this data protection privacy notice (“the Notice”) to describe its practices regarding the collection, use, storage, transfer and other processing of individually identifiable information about you (“Personal Data”) when you contact us, use our services or interact with our websites, such as www.theshinmonzen.com, Shinmonzen K.K is the controller responsible for the processing of Personal Data described in this Notice.

We are updating this privacy notice to reflect changes we have made as part of our ongoing commitment to be transparent about how we use your data and keep it safe. We have included changes to address the new standards introduced by the European data protection law, known as the General Data Protection Regulation (GDPR), and the new Data Protection Act 2018.

1. How we collect your personal data

   In order to provide our highly personalised service we are required to collect and process your personal information in the following ways:
   • You may volunteer this information when speaking to our staff and/or agents acting on our behalf.
   • You provide information to us when you stay or use our guest services at one of our hotels.
   • When you provide information to us when you dine at one of our restaurants.
   • By visiting our websites or corresponding with us by email or post.
   • When you provide your contact details to our marketing department requesting relevant and useful information about our service through submission forms, by telephone or e-mail.
   • When you apply for a position at The Shinmonzen.
   • When you place an order online or on our premises.
   To ensure that you are provided with a first-class service, telephone calls may be monitored or recorded for quality control and training purposes.

2. The types of personal data we collect

   The personal data we routinely collect includes: title, full name, role, organisation name, telephone, e-mail address, address.
   
   If you are applying for a position at The Shinmonzen, we will collect your CV which will include: title, full name, education details, work experience, telephone, e-mail address, address, right to work.
   With regard to each of your visits to our website we may also automatically collect the following information:
   • Some limited technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), methods used to browse away from the page.

3. How we use your personal data

   We will use your personal information so that we can provide you with a first class service, and in particular to:
   • Confirm your hotel reservations
   • Send you emails that are related to your hotel stay, spa, restaurant or bar reservation and your car booking as appropriate
   • Respond to your customer service inquiries or requests
   • To confirm, update and improve customer records
   • Identify and inform you of services that may be of interest
   • Analyse and develop a relationship with you
   • To fulfil your orders placed on premises or online
   This section explains how and why we process your personal data, as well as the legal basis on which we carry out this processing.
   Communications: sending communications related to The Shinmonzen, keeping a record of your relationship with The Shinmonzen, including ensuring we know how you prefer to be contacted.
   • The legal basis for such processing is your consent;
   Information and services: providing you with information and access to services that you have requested from us or which we feel may be of interest to you, where you have consented to be contacted for such purposes.
   • The legal basis for such processing is for the performance of a contract or agreement, yet you may opt-out for some communications;
   Enquiries: providing you with information about our services that you have requested from us where we identify you as a prospect.
   • The legal basis for such processing is our legitimate interests;
   Job applications: processing applications for a position at The Shinmonzen
   • The legal basis for such processing is your consent;

4. Confidentiality and security

   Unfortunately, the transmission of information via the internet is not completely secure.
   However, by making purchases via our online booking engine, you are protected by Secure Socket Layer (SSL) technology, utilised by most popular browsers, including Google Chrome, Mozilla Firefox and Internet Explorer. This ensures, through encryption, the personal information you enter, including your name, address and credit card information is converted into code being dispatched over the Internet.
   The Shinmonzen will store your data safely and, therefore, The Shinmonzen maintains appropriate technical and organisational measures to protect against unauthorised or unlawful processing of Personal Data and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage to your Personal Data. To try to prevent unauthorised access, maintain data accuracy and ensure the correct use of information The Shinmonzen maintains physical, electronic, standard security practices, including encryption, passwords and physical security measures, and managerial procedures to protect the security and confidentiality of Personal Data. Only a limited number of persons within our organisation are authorised to access, delete or modify your data. These measures are aimed at ensuring the on-going integrity and confidentiality of Personal Data. The Shinmonzen evaluates these measures on a regular basis to ensure the security of processing.
   The Shinmonzen employees or any of The Shinmonzen’s contractual partners who have access to your data in order to provide The Shinmonzen are contractually obliged to keep such information in confidence and may not use these data for any other purpose than performing their contractual missions for The Shinmonzen.

5. Sharing your personal information with anyone else?

   The Shinmonzen won’t transfer personal data about you to third parties for the purpose of providing or facilitating third-party advertising to you. We won’t sell personal data about you to a third-party.
   We may transfer your personal data with trusted third parties in some circumstances, including:
   • Our group companies
   • Where sharing is required to fulfil the contract between us
   • Where you have consented to us sharing your personal data with other parties involved in the service we provide to you
   • Any successors in title to our business
   • Companies to whom we transfer or may transfer our rights and duties under our agreement with you
   • To a service provider or partner who meets our data protection standard
   • Where disclosure is required or permitted by law (for example to government bodies and law enforcement agencies
   The Shinmonzen requires all third parties to comply strictly with its instructions, The Shinmonzen requires that they do not use your personal data for their own business purposes, and only use your personal data for reasons associated with the services we provide for you.

6. Direct marketing

   We may use your personal data to send you direct marketing communications about our hotels, experiences or our related services. This will be in the form of telephone, email and post.
   Where we require explicit opt-in consent for direct marketing in accordance with the Privacy and Electronic Communications Regulations we will ask for your consent. You have a right to stop receiving direct marketing at any time – you can do this by following the opt-out links in electronic communications (such as emails).

7. Data retention

   The Shinmonzen will only retain your personal information for as long as we feel that we have a relationship with you and will only use it for clear and explicit purposes, this may also include satisfying any legal, accounting or reporting requirements. Where your information is no longer required, we will ensure it is disposed of in a safe manner.

8. Cookies

   Our website uses cookies or similar technologies to collect information about your access to the website. Cookies are pieces of information that include a unique reference code that a website transfers to your device to store and sometimes track information about you.
   A few of the cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the site and will last longer.

9. Updating your personal profile and preferences

   You can update or change your preferences for the way in which you would like us to communicate with you - including how you receive news updates from us, or details of our latest offers by following the unsubscribe instructions in the correspondence we send to you.

10. Changes to this privacy notice

    The Shinmonzen may periodically update this Notice. This may be in relation to changes in the law, best practice, changes in our services or treatment of your personal data. Where necessary, we will notify you of these changes. We will always display when the Notice was last amended on the website.

11. Your rights under GDPR

    You have the right to withdraw your consent to the processing of your Personal Data at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
    To the extent required by applicable law and subject to legal limitations, you have the right:
    • Your right of access – You have the right to ask us for copies of your personal data.
    • Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
    • Your right of erasure – You have the right to ask us to erase your personal data in certain circumstances.
    • Your right to restriction of processing – You have the right to ask us to restrict processing of your information in certain circumstances.
    • Your right to object to processing – You have the right to object to processing of your personal data in certain circumstances.
    • Your right to data portability – You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
    All the above requests will be forwarded on should there be a third party involved in the processing of your personal data.
    If you are concerned that any of the information we hold about you is incorrect, out of date, or may be used inappropriately, please contact us with your concerns and we will take appropriate steps to amend our records.

12. Contact us

    In you have any questions in connection with your Personal Data or you want to exercise your rights, you can contact our Data Protection Officer.