ACCORDIA GOLF Co.,Ltd.

This Policy provides for matters regarding the personal information (including individual numbers and any personal information that includes an individual number (“Specified Personal Information”)) handled by (i) Accordia Golf Co., Ltd. and its subsidiaries, and (ii) Next Golf Management Corporation and its subsidiaries (collectively, the “Accordia Next Golf Group, etc.”).

This Policy is adopted by all of the companies of the Accordia Next Golf Group, etc., and the terms “we,” “us” and “our” below refer to each company of the Accordia Next Golf Group, etc.

We acknowledge the importance of our duty to properly handle the personal information of any person (“you” and “your”) who provides personal information to us, and we are committed to protecting your personal information by establishing our own internal rules as well as complying with the laws and regulations, guidelines, and other relevant standards regarding personal information protection, and fully educating our officers and employees (“Staff”) and other related persons with respect to those requirements.

We obtain personal information through lawful and fair means. We will obtain personal information from you mainly through (i) application forms for loyalty cards, (ii) records of customer visits to golf facilities, (iii) reservation information provided through our website, (iv) documents necessary for our internal operations, and (v) other documents and materials.

When obtaining Specified Personal Information, we will provide notice or a public announcement of the purpose of use of that information, and ask that you submit it using a special form or the like.

The personal information that we obtain usually includes the following:

• name, address, telephone number, e-mail address, and other contact information;
• age, occupation, position, title, and job responsibilities; and
• individual number (to be obtained using a special form, etc.)

While we endeavor to keep the personal information we hold accurate and updated, please notify us promptly if there are any changes to your personal information.

We will use your personal information only for the following purposes. We will not use your personal information beyond the scope necessary for achieving these purposes of use without obtaining your prior consent.

• 1.To appropriately respond to communications and inquiries regarding the use of golf courses or golf ranges operated by us, such as reservations, changes, cancellations, and the like
• 2.To screen applicants for golf course membership and make appropriate decisions and appropriately handle identity verification
• 3.To appropriately manage your use of golf courses and agreements with you, and to respond to your inquiries and conduct appropriate management as required by laws and regulations after the end of golf play or the termination of your contract
• 4.To keep you informed about us, our group companies and allied companies, and our products and services by post, e-mail, or telephone
• 5.To conduct internal market research to provide better products and services or otherwise increase customer satisfaction
• 6.To perform management activities necessary for our operations

If we need to use your personal information for a purpose not stated above, we will clearly inform you of that purpose and obtain your prior consent.

We will handle your personal information in accordance with this Policy as long as we hold it, even after you withdraw from our golf clubs or otherwise terminate your relationship with us.

If we receive personal information from another company, we will use that information only for that company’s purposes.

• 1.Joint User
  Accordia Next Golf Group, etc.
• 2.Purpose of use by the Joint User
  The Joint User will use the personal information for the following purposes:
  • (i)to manage debtors, assets, risks and other information necessary for the operation of the Accordia Next Golf Group, etc.;
  • (ii)to conduct market research and develop products and services to increase your satisfaction by providing you with better products and services; and
  • (iii)to keep you informed of the products and services of the Accordia Next Golf Group, etc.
• 3.Personal information to be jointly used
  The joint use of personal information will be limited to the information necessary for the above purposes. We will not share Specified Personal Information within the Accordia Next Golf Group, etc.
• 4.Personal information manager
  Accordia Golf Co., Ltd.
  4-12-4 Higashishinagawa, Shinagawa-ku, Tokyo

Except where exceptions are permitted by laws and regulations, etc., we will not provide personal information to any third party not provided for in this Policy without obtaining your prior consent. Specified Personal Information will not be provided to any third party unless otherwise prescribed by laws and regulations, regardless of whether we receive your consent.

We will not sell your personal information to any third party.

We may outsource part of our business (e.g., to a provider of direct mail services or information-processing services that are necessary for our business purposes), in which case we may also outsource all or part of the handling of personal information. When outsourcing part or all of the handling of personal information, we will strictly screen outsourcees in accordance with the provisions of laws and regulations, impose confidentiality obligations on outsourcees, and supervise outsources as necessary and appropriate.

We maintain the highest standards with respect to information security to protect privacy and confidentiality of personal information. We limit access to personal information to authorized Staff and their agents. We impose strict confidentiality obligations on our service providers as provided for in “Outsourcing the Management of Personal Information” above. We take physical, electronic, and systemic preventive measures against the loss, misuse, damage, falsification, unauthorized access, divulgence, etc. of personal information. Other features of our information security program include:

• use of specialized technology such as a firewalls;
• testing of our online products and services for safety and operationality before deployment on the internet and constant tracking of generally known technical vulnerabilities;
• internal and external auditing of services provided through our website or on the internet;
• monitoring of system infrastructure to discover vulnerabilities or points through which unauthorized intrusion is likely to occur;
• control of access to various websites and systems by identity verification and confirmation of permissions;
• protection of transmissions of nonpublic information by encryption or similar means; and
• training of Staff and constant security updates to keep up with new risks and technological developments.

The following additional information applies to services provided through the website of the Accordia Next Golf Group, etc.

• A “cookie” is a small text file composed of encrypted information assigned to your computer’s browser by a website. We may use cookies for administrative purposes to ensure security or to eliminate the need for you to input your password multiple times while using the website.
• We may collect access logs (e.g., logs showing which pages and how often you accessed within the website of the Accordia Next Golf Group, etc.) and use such access logs mainly to analyze the use, value, performance, etc. of our services.
• The website of the Accordia Next Golf Group, etc. includes a user review forum and other user-generated content. Please use such content at your own responsibility. We are not liable for the handling of personal information on any third-party website linked to from our website. Please see the privacy policy, etc. of that third party.

We will continuously revise and endeavor to improve our internal systems and practices for the protection of personal information.

This policy may be amended in accordance with actual circumstances surrounding our obtainment and use of personal information. The amended policy will become effective immediately upon publication on the website of the Accordia Next Golf Group, etc. The current version is effective as of April 1, 2021.