JANU TOKYO PRIVACY NOTICE

Aman Group, which includes Aman Group S.a.r.l as well as its affiliates/subsidiaries (i.e., all companies whose shares are held or beneficially owned, in whole or in part, whether directly or indirectly, by Silverlink Resorts Ltd or Grand Moto Ltd) (hereafter collectively, the “Aman Group”, “we”, or “us”), values you as our guest and recognizes that privacy is important to you. We want you to be familiar with how we collect, use and disclose your Personal Data.

This Privacy Notice describes the privacy practices of the Aman Group for Personal Data that we collect in connection to our website, including through the enquiry forms which you complete when submitting inquiry

Your visit or stay as a guest at Janu Tokyo and use our various hospitality services including Spa Centers, Restaurants, Boutiques or other offline interactions you have with us

Collection of Personal Data

“Personal Data” are data that identify you as an individual or relate to an identifiable individual. We collect the following Personal Data:

We may also collect the following information (either based on our legitimate interests or with your consent to the extent required by applicable law):

How We Collect Personal Data

We and our service providers collect Personal Data in a variety of ways, including:

We collect Personal Data to provide the Services to you. If you do not provide the information requested, we may not be able to provide certain Services. If you disclose any Personal Data relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Notice.

Cookies & Similar Technologies

When you use the Online Services, we also collect data typically collected through websites, such as browser and device information, application usage data, information collected through cookies, pixel tags and other similar technologies, and IP addresses. For more detail please see our Cookie Policy.

How We Use Personal Data

We and our service providers use Personal Data for the following purposes:

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

We will provide personalized services based on our legitimate interests, and with your consent to the extent required by applicable law.

We may anonymize Personal Data so that it will no longer be considered Personal Data. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.

We have legitimate interest to anonymize Personal Data.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.

Disclosure of Personal Data

We disclose Personal Data to:

Aman Group affiliates (list here) for the purposes described in this Privacy Notice.

We also use and disclose your Personal Data as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:

To comply with applicable law and regulations.

This may include laws outside your country of residence.

To cooperate with public and government authorities.

To respond to a request or to provide information we believe is necessary or appropriate.

These can include authorities outside your country of residence.

To cooperate with law enforcement.

For example, when we respond to law enforcement requests and orders or provide information we believe is important.

For other legal reasons.

To enforce our terms and conditions; and

To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.

In connection with a sale or business transaction.

We have a legitimate interest in disclosing or transferring your Personal Data to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

By using the Services, you may elect to disclose Personal Data:

On social media platforms, chat, and other services to which you are able to post information and content (including, without limitation, our Social Media Pages).  Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.

Through your social sharing activity.  When you connect your Services account to your social media account, you will share information with your friends associated with your social media account, with other users, and with your social media account provider. By doing so, you authorize us to facilitate this sharing of information, and you understand that the use of shared information will be governed by the social media provider’s privacy policy.

Third Party Services

This Privacy Notice does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Instagram, Google Ads, Yahoo, Baidu, RED, Weibo. Line, Tripadvisor, Trivago, Yandex, Apple, Microsoft, The Hotels Network or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Data you disclose to other organizations through or in connection with our Social Media Pages.

We use third-party advertising companies (such as Meta, Google, Yahoo, Baidu, RED, Weibo. Line, Tripadvisor, Trivago, Yandex,) to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services.

You may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties.  These companies place or recognize a unique cookie on your browser (including through the use of pixel tags).  They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.  If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Notice, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/.

Your choices regarding our use and disclosure of your Personal Data

We give you choices regarding our use and disclosure of your Personal Data for marketing purposes.  You may opt out from: 

Receiving marketing-related emails from us.  If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by sending an email to dataprotection@aman.com or by using the unsubscribed link at the bottom of each marketing email.

Our sharing of your Personal Data with affiliates for their direct marketing purposes.  If you would prefer that we discontinue sharing your Personal Data on a going-forward basis with our affiliates for their direct marketing purposes, you may opt out of this sharing by sending an email to dataprotection@aman.com or by using the unsubscribed link at the bottom of each marketing email.

We will try to comply with your request(s) as soon as reasonably practicable.  Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.

How to exercise your individuals’ rights requests pertaining to your Personal Data

If you would like to request to access, correct, update, suppress, restrict, or delete Personal Data, object to or opt out of the processing of Personal Data, or if you would like to request to receive a copy of your Personal Data for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below.  We will respond to your request consistent with applicable law.

In your request, please make clear what Personal Data you would like to have changed or whether you would like to have your Personal Data suppressed from our database.  For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.  We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Data provided until after the completion of such purchase or promotion). 

Where provided by applicable law, you may also lodge a complaint with the UK data protection authority here or with an EU/EEA data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs.

Retention

We retain Personal Data for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. 

The criteria used to determine our retention periods include: 

The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);

Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or

Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations). 

Security

We seek to use reasonable organizational, technical and administrative measures to protect Personal Data within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section, below.

Sensitive Data

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.

Use of Services by Minors

The Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Data directly from individuals under 16. 

International Transfers

Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.

ADDITIONAL INFORMATION REGARDING THE EEA, the UK and Switzerland: Some countries are recognized by the European Commission, the UK and the Swiss government, respectively, as providing an adequate level of data protection according to EEA/UK/Swiss standards (the full list of these countries for the EEA is available here and for the UK is available here). For transfers from the EEA, the UK, Switzerland to countries not considered adequate by the European Commission, the UK government, and the EU government, respectively, we have put in place adequate measures, such as approved standard contractual to protect your Personal Data. You may obtain a copy of these measures by contacting us in accordance with the “Contacting Us” section below.

Updates to This Privacy Notice

The “LAST UPDATED” legend at the top of this Privacy Notice indicates when this Privacy Notice was last revised. Any changes will become effective when we post the revised Privacy Notice on the Services. 

Contacting Us

Aman Group S.a.r.l and its affiliates in the Aman Group are responsible (data controllers) for the Personal Data we hold about you. The Aman Group is also an independent controller in relation to our resort owners, who have a limited right to use the Personal Data we collect. As the hotel you are booked to stay in may not be owned by the Aman Group, we disclose Data to owners of Aman Group branded properties for the purposes described in this Privacy Notice. Owners have a limited right to use certain Personal Data for their own purposes and therefore qualify as independent data controllers in order to comply with their own legal obligations (including maintaining books & records and other compliance obligation).

Aman Group S.a.r.l is the controller of marketing database and conducts all marketing activities relating to Aman resorts, Aman Club and Aman Residences.

Aman Group’s address is Grabenstrasse 17, 6340 Baar, Switzerland.

Aman’s European Representative is AMANRESORTS MANAGAMENT NV, a company established in the Netherlands , with offices located in Netherlands, address Herikerbergweg 88, 1101CM Amsterdam, registration number 803529363.

You may always contact us at data protection@aman.com  or our EU Representative at  eurepresentative@aman.com with your questions or concerns regarding this Privacy notice or in general about our processing of your Personal Data.