【公式】tripla(トリプラ) - AIチャットボットとホテル・旅館公式HP向け予約システム

GDPR Privacy Policy

The protection of your personal data is of great importance to tripla Co., Ltd. (the “Company”, “we”, “our” or “us”). This GDPR Privacy Policy (this “Privacy Policy”) therefore intends to inform you about how the Company, who may act as a data controller or processor, collect and processes your personal data that you submit or disclose to us, in the case where the General Data Protection Regulation (“GDPR”, which you can access from https://eur-lex.europa.eu/eli/reg/2016/679/oj) applies to such collection or processing.

tripla Co., Ltd. routinely collects, uses, stores and transfers a variety of data, including personal data defined in GDPR (“Personal Data”). tripla Co., Ltd. is committed to ensure the privacy of data subjects throughout its global business, and make sure its employees and business partners also take the necessary measures to protect Personal Data.

This Privacy Policy sets out the basis on which any Personal Data we collect from you, or that you provide to us, will be processed by us. This Privacy Policy applies to you in the case where the GDPR applies to such collection or processing and is available on our website and through other channels. In all your dealings with us you must ensure that others you may represent are aware of the content of this Privacy Policy and consent to you on their behalf.

We encourage you to read this Privacy Policy carefully. If you do not wish your Personal Data to be used by us as set out in this Privacy Policy, please do not provide us with your Personal Data. Please note that in such a case, we may not be able to provide you with our services, and your customer experience may be impacted.

 1 Your Personal Data

“Personal Data” we collect may include the information set out in Clause 2.1 below. Your Personal Data is collected when you contact us, make a booking, use our website(s)/apps, link to or from our website(s)/apps, connect with us via social media and any other engagement we or our business partner have with you.

2 Collection and Processing of Your Personal Data

2.1 Personal Data that may be collected by tripla Co., Ltd.

We mainly collect and process the Personal Data you provide us during a precontractual phase. We may collect:

1. full name;
2. e-mail address;
3. residential address;
4. phone number;
5. nationality;
6. marital status;
7. date of birth;
8. gender;
9. order history;
10. IP Address and IP location;
11. ID numbers of your device;
12. referring (exit pages and URLs);
13. number, duration and time of visits (your interaction with our website);
14. search engines, keyphrases and keywords used to find our site;
15. browser type, type of device, screen size, internet service provider and operating system;
16. payment data;
17. purchase information;
18. billing address;
19. credit/Debit card number;
20. expiration date;
21. passport information;
22. travel preference;
23. special needs/disabilities/dietary requirements that you supply us or is supplied to us (including your social preference, activities and any information about other persons you represent such as those on your booking and conversations through our chatbot);
24. other billing information necessary to process transactions; 
25. other Personal Data provided by you in a free text field; and/or
26. messenger account (Eg. Line, Messenger, Whatsapp etc).

2.2 Purposes for Collecting and Processing Personal Data

We collect and process your Personal Data for the purposes set out below:

1. [considering and processing your proposal on or application for our services;]
2. [providing you with our services;]
3. [responding to your queries and requests;]
4. [resolving complaints, and handling requests of and enquiries;]
5. [improving our services and developing new services;]
6. [communication and marketing purposes;]
7. [internal record keeping;]
8. [website functionality;]
9. [fraud detection; and/or]
10. [troubleshooting, analytics].

Further, we disclose your Personal Data to our service providers who act as ‘controller’ or ‘processor’ on our behalf, for the purposes set out below: 

1. [considering and processing your proposal on or application for our services;]
2. [providing you with our services;]
3. [responding to your queries and requests;]
4. [resolving complaints, and handling requests of and enquiries;]
5. [improving our services and developing new services;]
6. [communication and marketing purposes;]
7. [internal record keeping;]
8. [website functionality;]
9. [fraud detection; and/or]
10. [troubleshooting, analytics].

The above are basically based on:

a. Fulfilling the contract with you and legal obligations (Articles 6(1)(b) and (c) of the GDPR: In order for you to travel abroad, it may be mandatory as required by government authorities at the point of departure and/or destination to disclose and process your Personal Data for immigration, border control and/or any other purposes. Also we need to provide airlines/accommodation providers with your name, passport number, contact details, and other related information in accordance with their terms and conditions. If you do not provide us with this Personal Data, we might not be able to offer our services to you.
b. Fulfilling your and our legitimate interests (Article 6(1)(f) of the GDPR): Where it is in both your and our benefit that we further process your Personal Data as part of our business administration, maintaining service quality, customer care, business management, risk assessment/management, security, and operation purposes.
c. Consent: If we process Personal Data for marketing purposes and other similar data processes under Article 6(1)(a) of the GDPR, we will inform you before collecting your data and obtain your consent if we intend to use your Personal Data for such purposes or if we intend to disclose your Personal Data to any third party for such purposes. You can withdraw your consent at any time to prevent such processing by checking the applicable boxes on the forms we used to collect your data.
d. Explicit consent (Article 9(2)(a) of the GDPR): Information such as health or religion may be considered ‘sensitive personal data’ under the GDPR. This Personal Data might include information necessary to arrange bookings and travel plans, including your allergies, disabilities, and other relevant health information. We collect it to provide you with our services, cater to your needs or act in your interest, and we will only collect sensitive Personal Data on the condition that we have your positive consent. You can withdraw your consent at any time by contacting us. However, please note that, if you withdraw your consent, we might not be able to offer our services to you.

We will process your data for as long as it is necessary to fulfill our service to you and comply with the applicable fiscal, tax, securities and commercial law regulations on retention of business and financial documentation.

2.3 Processing Personal Data related to Children

Our services are not intended for and may not permissibly be used by individuals under the age of thirteen (13). We do not knowingly collect personal data from persons under 13 or allow them to register. If it comes to our attention that we have collected or processed personal data from such a person, we may delete this information without notice. If you have reason to believe that this has occurred, please contact our Data Protection Team at: [email protected].

2.4 Links to other websites

We may propose hypertext links from our websites to third-party websites or Internet sources. We do not control and cannot be held liable for third parties’ privacy practices and content. Please read carefully their privacy policies to find out how they collect and process your personal data.

2.5 Transfer of your Personal Data

When we process your personal data, we will store it on our systems located in Japan or Singapore depending on type of our service. 

Your data will be processed by staff in a member of the same company group as tripla Co., Ltd. located outside the EEA who work for us or for one of our suppliers (e.g., travel agencies, travel guides, transportation services). Such staff may be engaged in, among other things, the provision of support services.

Service providers
For the purpose of providing you with our services, including your booking of restaurant, activity, flight, hotel, security, incident/accident management etc., we may disclose and process your personal data outside of the EEA countries. In order for you to travel abroad, it may be mandatory as required by government authorities at the point of departure and/or destination to disclose and process your data for immigration, border control and/or any other purposes. Also we need to provide airlines/accommodation providers with your name, passport number, contact detail, etc. in accordance with their terms and conditions.

To achieve the purposes described above, it may be necessary to disclose your Personal Data to the following Recipients in certain cases. We may disclose and transfer your Personal Data to third parties, including to our contractors or service providers who provide services which are integrated into our services or perform functions on our behalf. The actual Recipients depend on the services you have signed up for. Personal Data may be disclosed by being transferred, disseminated, or provided by other means to the entities including but not limited to:

Legal compliance and security
It may be necessary for us – by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence – to disclose your Personal Data. We may also disclose your Personal Data if we determine that, due to purposes of national security, law enforcement, or other issues of public importance, the disclosure is necessary or appropriate.

We may also disclose your Personal Data if we determine in good faith that disclosure is reasonably necessary to protect our rights and pursue available remedies, enforce our terms and conditions, investigate fraud, or protect our operations or users.

2.6 Safeguards to Protect your Personal Data

Where we share your Personal Data with a data processor, we will put the appropriate legal framework in place in order to cover such transfer and processing (Articles 26, 28 and 29 of GDPR). When we process and/or share your Personal Data in Japan, the basis will be the Adequacy decision. Furthermore, where we transfer your data from Japan to any other entity outside the EEA than Japan, such as Singapore, the Philippines, Indonesia, Thailand, South Korea, Taiwan and the United States, we will put appropriate legal frameworks in place, notably Standard Contractual Clauses, adopted by the EU Commission (Article 46 (2)(c) of GDPR), controller-to-controller (2004/915/EC) and controller-to-processor (2010/87/EU) Standard Contract Clauses approved by the European Commission, in order to cover such transfers (Articles 44 ff. GDPR), or we will share your Personal Data based on rules of the GDPR.

2.7 Collection of Personal Data from sources other than the data subject himself or herself (Art 14 GDPR)

If we process your Personal Data we usually collect Personal Data from you, and it is usually you who provides us with this Personal Data. Nevertheless, in individual cases, we may also obtain Personal Data from other sources. These other sources are publicly available, such as information we obtain from the Internet.

This Processing is based on our Legitimate Interest in a complete set of Personal Data required for professional communication, Contract Performance, our business relationships and the application process, depending on the relationship we have with you.

3. Our Records of Data Processes

We handle records of all processing of Personal Data in accordance with the obligations established by the GDPR (Article 30), both where we might act as a controller or as a processor. In these records, we reflect all the information necessary in order to comply with the GDPR and cooperate with the supervisory authorities as required (Article 31).

4. Security Measures

We process your Personal Data in a manner that ensures their appropriate security, including protection against unauthorised or unlawful processing, accidental loss, destruction or damage. We use appropriate technical or organisational measures to achieve this level of protection (Article 25(1) and 32 GDPR).

5. Retention of Personal Data

We will retain your Personal Data for as long as it is necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Specifically:

1. Personal Data collected for purposes related to Contract Performance shall be retained until such contract has been fully performed.
2. We may be allowed to retain Personal Data for a longer period whenever you have given consent to such processing (e.g. subscription to our newsletter), as long as such consent is not withdrawn. 
3. Furthermore, we may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. 
4. All Personal Data necessary for tax purposes, especially contracts, invoices and other bookkeeping documents as well as relevant correspondence in relation to our contractual relationship we store for a period of 5years.

In summary:

6. Notification of Data Breaches to the Competent Supervisory Authorities

In case of breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise processed, we have the mechanisms and policies in place in order to identify it and assess it promptly. Depending on the outcome of our assessment, we will make the requisite notifications to the supervisory authorities and communications to the affected data subjects, which might include you (Articles 33 and 34 GDPR).

7. Processing Likely to Result in High Risk to your Rights and Freedoms

We have mechanisms and policies in place in order to identify data processing activities that may result in high risk to your rights and freedoms (Article 35 of the GDPR). If any such data processing activity is identified, we will assess it internally and either stop it or ensure that the processing is compliant with the GDPR or that appropriate technical and organisational safeguards are in place in order to proceed with it.

In case of doubt, we will contact the competent Data Protection Supervisory Authority in order to obtain their advice and recommendations (Article 36 GDPR).

8. Your Rights

You have the following rights:
Access to Personal Data: You have the right to be provided full information about your Personal Data that we hold.
Data correction: You have the right to require that we correct any incorrect information we hold about you.
Data deletion: You may also have the right to ask that we delete your Personal Data. Please note that certain conditions may apply to the exercise of this right.
Restriction on processing of Personal Data: You may have the right to ask that we restrict the use of your Personal Data. Please note that certain may conditions apply to the exercise of this right.
Object to processing of Personal Data: You may have the right to object to the use of your Personal Data by us. Please note that certain conditions may apply to the exercise of this right.
Portability of Personal Data: You may have the right to receive your Personal Data in a structured and commonly used format. Please note that certain conditions may apply to the exercise of this right.
You also have the right to obtain from us a copy of any Standard Contract Clauses that we use if we transfer your Personal Data outside the Japan and take such arrangement.
To exercise your rights, or if you require further information about how your Personal Data is used by us, you can contact the staff member in charge of your travel or write to us at: [email protected].

Following is the procedure when you want to execute these rights;
1) Upon receiving your request, we will contact you to confirm the request is being handled, and we will indicate the reasonable timeframe for us to respond.
2) Our special team will make an initial assessment of the request to decide whether it is a valid request and whether confirmation of identity is required.
3) If no further action from you is required, we will proceed with the processing of your request.
4) At the end of our assessment and internal procedure, we will provide a confirmation as to our compliance or processing of your request.
5) For any unfounded or excessive (e.g., further repeated) requests, we may charge a reasonable fee based on administrative costs.

9. When you want to complain about your personal data

We have appointed appropriate staff with management support to oversee and ensure compliance with the GDPR.
You can bring complaints in writing by contacting the tripla Data Protection Team at: [email protected].

You can also contact the tripla Data Protection Team members or other employees to complain about the way we handle your Personal Data. The employees to have been confronted with the complaint will inform you about the contract details to file a complaint in accordance with the present procedure or pass the complaint to the tripla Data Protection Team whichever appropriate.

After receiving the complaint, the Data Protection Team will send an acknowledgement of receipt within one week to you. The confirmation may include further questions necessary for the clarification of the issues. The Data Protection Team or Human Resources Department will provide an answer to you as soon as reasonably practicable, but no later than one month upon receiving the complaint. If, due to complexity of the complaint, a substantive response within one month cannot be provided, you will be notified with a reasonable estimate of the timeframe, but not exceeding two months from the notice.

You may also raise the complaint to the relevant Data Protection Authority or lodge a claim with a court of competent jurisdiction

9. Changes to Privacy Policy

We may revise or update this Privacy Policy from time to time. Any changes we may make to this Privacy Policy in the future will be posted on this website. If we make changes which we believe are significant, we will inform you through the website to the extent possible and seek your consent where applicable.

10. Contact

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to:

tripla Data Protection Team
tripla Co., Ltd.
3rd Floor, No.3 Sumitomo Realty Nishi-Shinjuku Building
4-15-3 Nishi-Shinjuku, Shinjuku-ku, Tokyo 160-0023 Japan
Email: [email protected]

11. About Cookies

Like many other websites, we use so-called “cookies” to provide better services, secure security, analyze and distribute appropriate advertisements to customers. Cookies are small text files that are stored on your device (laptop, tablet, smartphone, etc.) when you visit our website. Please find a detailed list of all cookies we use in our Cookie Policy [link to Cookie Policy]. In our Cookie Policy, we inform you furthermore on the processing of your Personal Data when you visit the website.

Third-party companies may distribute advertisements or obtain behavioral information for the purpose of advertising their company. Third-party companies use cookies only for advertisement distribution purposes and acquire information. If you wish to invalidate this function, please disable (opt out) from the site of the corresponding company below.

※ If you change browser, delete cookie, etc., you need to set opt-out and opt-in again.

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改正　2024年9月27日