INFINI TRAVEL INFORMATION, INC. (hereinafter referred to as the “INFINI”) will endeavor to protect your personal information based on the following privacy policy.

Personal Information Protection Policy

INFINI believes that it is our social responsibility to protect the personal information of our users and our employees in providing GDS services in the Japan travel market and in providing information services related to international GDS. We are dedicated to building and operating an effective personal information protection management system, maintaining our policy standards, and always strive to find new ways to improve it.

(1) INFINI will acquire, use, and provide appropriate personal information limited to the necessary range. In addition, we will not handle personal information beyond the scope necessary to achieve the specified purpose of use (use outside purpose) and will take measures to realize it.
(2) INFINI will comply with laws and regulations regarding the handling of personal information, guidelines set by the country, and other norms.
(3) INFINI will endeavor to prevent and correct unauthorized access to personal information, leakage, loss, or damage to personal information.
(4) INFINI will respond appropriately and promptly to complaints and consultations regarding personal information.
(5) INFINI will continuously improve the personal information protection management system.

Enactment date: September 14, 2015
Revision date: April 1, 2018
INFINI TRAVEL INFORMATION, INC.
Chairman, President & CEO. Seiichi Takahashi

Handling of Personal Information-Part 1

1. Scope of application

This privacy policy is applied when you use INFINI GDS services, products, and INFINI websites.

2. The purpose of collecting personal information

When INFINI asks you to provide us with personal information, we will specify the purpose of utilizing the personal information in advance. The information provided by you will be used within the scope of the stated purpose of use, and will not be used for any purpose other than that stated. In addition, we will not use it in a method that has the possibility of fomenting or prompting unlawful or unfair act, even within the scope of the purpose.

INFINI handles acquired personal information as follows:

(1) Provision of GDS services in the domestic travel market
(2) Information service services related to international GDS
(3) Personal information of the product applicant: contact with the applicant, usage status management, etc.
(4) Personal information of trainees/courses/certificates: Contact with trainees, management of attendance status, acquisition of questionnaire after attendance
(5) Personal information of participants in seminars/events: contact with participants, acquisition of questionnaires, etc.
(6) Personal information of the applicant for promotional campaign (and delivery a product)
(7) Personal information of an inquirer: for responses to inquiries
(8) E-mail address of e-mail magazine applicants: For the provision of various information
(9) Personal information of our employees: For personnel management, payroll, welfare, labor management education/training, etc.
(10) Personal information of applicants for employment: For communication regarding approval/disapproval of recruitment, and interviews
*Other than the above, personal information will be used for the purpose described in [8. Joint use]

3. EU-Specific Notice

These terms apply to personal information collected by INFINI through the services if you are an EU resident. Where INFINI collects information directly from you through its services, such personal information is controlled by INFINI TRAVEL INFORMATION, INC., which is headquartered in Tokyo, Japan at Sumitomo-Fudosan Shin-Akasaka Building, 4-2-6 Akasaka, Minato-ku, Tokyo. The legal basis for the processing of your data includes the purposes set forth above. In some cases, INFINI may additionally process your information based on your consent.

Your personal information will not be stored for longer than necessary for the purposes for which they are collected, or in accordance with applicable law.

Subject to applicable law, you have (i) the right to access and request personal information controlled by INFINI, (ii) the right to request the transmission of the personal information you have provided to us to you or another company, (iii) the right to object to uses or disclosures of your personal information, (iv) the right to withdraw your consent in relation to our processing of your personal information based on your consent (however, such withdrawal of consent will not affect the lawfulness of processing based on consent before such withdrawal), (v) the right to request deletion of your personal information and (vi) the right to request that INFINI restrict processing of your personal information.

You may exercise these rights free of charge unless the request is unfounded, excessive, or otherwise unreasonable, for instance, because it is repetitive. In some situations, INFINI may refuse to act or may impose limitations on your rights, as permitted by law. Before INFINI can provide you with any information or correct any inaccuracies, INFINI may ask you to verify your identity and/or provide other details to help us respond to your request. For the exercise of your rights, please contact INFINI’s Representative and/or Personal information protection manager.

4. INFINI corporate website (English)- Specific Notice

These terms apply to personal information collected by INFINI through this website (refers to the website of the https://en.infini-trvl.co.jp domain) is operated by INFINI TRAVEL INFORMATION, INC.. (hereinafter referred to as “INFINI”). Please use the after agreeing to the following terms and conditions.

This website is also linked to other websites operated by INFINI. Please note that when using this website, you must also agree to the terms of use posted therein.

About the use of cookies (1*) and IP addresses (2*)

This website uses cookies to distinguish you from other users of our website. This helps us provide you with a good experience when you browse our website and also allows us to improve it. We may use cookies and IP addresses for the following purposes:

-To identify and resolve the cause of a server failure or problem
-To improve the content of websites, emails, etc.
-To customize the content of websites, emails, etc. for individual users
-To use the browsing history and questionnaire results of the person for marketing activities in the membership service where personal information is registered in advance
-To compile statistics in a manner that does not lead to the identification of an individual to improve the management of the website

Depending on your browser, you can change the setting to disable the cookie function, but as a result, you may not be able to use all or part of the services on this website.

About using Google Analytics

This website may use Google Analytics to understand its usage. Google Analytics uses first-party cookies to collect information about your visit to this website without personal identification. The Google Analytics Services Terms of Service and Google Privacy Policy stipulate how to collect and use access information. For more information on Google Analytics, please see http://www.google.com/analytics
(Google Analytics ™ is a trademark of Google Inc.)

About maintaining security

We implement thorough security measures in the physical and systematic security measures of data centers, hardware and software configurations, and overall operations by specialized staff.

About style sheets

This website uses CSS (Cascading Style Sheets) technology to build pages. Please enable CSS to display the page correctly.

About SSL (Secure Sockets Layer) / TLS (Transport Layer Security)

When customers provide personal information through this website, SSL (Secure Sockets Layer) / TLS (Transport Layer Security) encryption or equivalent security is used to prevent monitoring by third parties during communication. However, depending on your computer environment, you may not be able to use these technologies in rare cases. In that case, please note that you may not be able to display the corresponding page or enter information.

If you are connected to the Internet via a firewall, such as a corporate LAN connection, you may not be able to use SSL/TLS communication depending on the settings. In that case, please check with your network administrator.

Copyright / Trademark

The text, illustrations, logos, photographs, videos, software, and all other information posted on this website are copyrighted by us or a third party.

Unless permitted by copyright law, such as personal use, this information cannot be used (including duplication, modification, distribution, public transmission, etc.) without the prior permission of the copyright holder.

In addition, the names of our products or services posted on this website are trademarks or registered trademarks of INFINI.

Disclaimer

Although we take great care in posting information on this website, we do not guarantee the accuracy or completeness of this information.

We may change the information posted on this website without prior notice. INFINI and its affiliated companies are not liable for any direct or indirect loss caused by the use of the information or contents contained in this website by the customer.

About the links to this website

In principle, links to this website are free, whether for-profit or non-profit. However, please refrain from setting links that fall under or may fall under any of the following:

In principle, links to this website are free, whether for-profit or non-profit. However, please refrain from setting links that fall under or may fall under any of the following:
-Homepages that contain content that is intended to slander INFINI or other companies (persons) or other organizations, or to damage their credibility
-Homepages that infringe or may infringe intellectual property rights such as copyrights, trademark rights, property, privacy, portrait rights, and other rights of INFINI or other companies (persons) and other organizations
-Homepages that may be misleading to third parties due to unclear content such as this website being expanded within the frame (always switch the screen completely to this website or a new browser Please set the link so that a window will open and this website will be displayed)
-In addition to the above items, websites that may violate laws, regulations, regulations, or public order and morals, or interfere with the operation of our website
-It is not permitted to link using registered trademarks such as logos and marks owned by INFINI without permission. –We do not allow links that mislead users about the source of the information.

About links to external websites

This website may contain links to websites of third parties other than INFINI. The contents are managed by each company and are not under the control of INFINI. We are not liable for the content of such third-party websites or for any damages caused by using them.

About change of contents

INFINI shall be able to change the contents of this agreement as appropriate. In that case, it will be announced by updating this page.

Enactment date: 2020/9/17

Revision date: 2022/3/1

5. About change of purpose of use of personal information

When changing the purpose of use of personal information, we　will update our privacy policy to reflect the change in the purpose of use on our website in advance and operate according to the new purpose of use.

6. Acquisition of personal information

In order to achieve the purpose of use stipulated in the preceding two paragraphs, we will acquire the personal information of all of you shown below by appropriate and fair means.

(Example) Name, address, telephone number, e-mail address, place of employment, transaction details, inquiry details, any and all information contained in documents provided by applicants to INFINI, such as resumes of recruitment applicants for employment, etc.

 7.Disclosure of personal information to third parties

Personal information provided by you will not be disclosed or provided to a third party without your consent. If it is provided by shared use or outsourcing, it does not correspond to disclosure or provision to a third party. However, it may be disclosed or provided in the following cases.
1) When required by laws and regulations
2) When it is necessary to protect a human life, body or fortune, and it is difficult to obtain a principal’s consent
3) When it is necessary for a central government organization or a local government to cooperate in carrying out public affairs, and when there is a possibility that obtaining a principal’s consent would interfere with the performance of the said affairs.
4) When disclosing or providing statistical data (information that cannot identify the person)
5) When providing due to business succession due to merger, company split, business transfer or other reasons

 8. Joint use

INFINI may jointly utilize your personal information within the following scope and for the following purposes. Personal information provided by business partners and stored in GDS will not be jointly utilized.

The scope of a jointly utilized person	ANA Group Companies (https://www.ana.co.jp/group/en/companies/)
The utilization purpose for the utilizing person	(1) For provision of air transportation services, travel services including tours and hotels, and other products/services handled by INFINI or companies that jointly utilize personal data (2) For sending of direct mail and information on products/services, and distribution of questionnaire(s) to users, etc. by the INFINI or companies that jointly utilize personal data (3) For sales analysis, other research/studies, and development of new products/services, etc. by INFINI or companies that jointly utilize personal data (4) For delivery and transfer of data when we receive inquiries, application for use or other offers from users regarding products/services provided by INFINI or companies that jointly utilize personal data (5) For appropriate and smooth fulfillment of other transactions with users by INFINI or companies that jointly utilize personal data (6) For business management/internal management by the ANA Group
The categories of the jointly utilized personal data	Name, address, telephone number, e-mail address, place of employment, transaction details, inquiry details, any and all information contained in documents provided by applicants to INFINI, such as resumes of recruitment applicants for employment, etc.
The name or appellation and address, and the name of its representative of a person responsible for controlling the said personal data	ANA Holdings Inc. Tokyo Shiodome City Center, 1-5-2 Higashi-Shimbashi, Minato-ku, Tokyo, 105-7140 Koji Shibata, President and Representative Director

9. Business assignment

In providing products and services to users, INFINI may entrust a part of its business operations to third parties to which personal information may also be disclosed to the extent required to achieve the purpose of the entrustment. In these cases, INFINI will implement appropriate measures in managing and supervising such third parties to safeguard the handling of users’ personal information, including establishing agreements on the handling of such personal information.

10. Transfer of information outside of Japan

INFINI may transfer your personal information outside of Japan. The country or region to which your personal information is transferred may not have the same personal information protection system as Japan.
When providing your personal information to a third party such as a business operator outside Japan, including outsourced companies and joint utilization companies, we will provide it based on your consent, except in the following cases:

1) When a third party is in a country stipulated by law as a country that has the same level of personal information protection system as Japan
2) When a third party has established the necessary system to continuously take measures equivalent to the measures that Japanese personal information handling business operators should take.
In the case of (2), the INFINI will take necessary and appropriate measures to ensure the continuous implementation of equivalent measures by a third party.

11. Management of personal information

In receiving users’ personal information, INFINI will manage such information according to the strictest standards and take necessary safety management measures to prevent the leakage, loss, or alterations. INFINI ensures that the board members and employees are properly trained regarding appropriate handling to safeguard the security of information identifying individual users, and the retention period of personal information is set according to the purpose of use, and when the purpose of use has been achieved, the personal information is disposed of in an appropriate manner.

When you provide personal information on this website, we will use encryption technology such as SSL (Security Sockets Layer) to ensure the security of information transmission.

12. Disclosure / Correction / Deletion of Personal Information

INFINI will respond in good faith if INFINI receives a request from a user, submitted in the manner specified, for the information of a utilization purpose, disclosure, correction, deletion, addition, utilization cease, erasure, cease of a third party provision, disclosure of a third party provision record, or information provision concerning the personal information protection measures (Details of security control measures and measures taken to provide the personal information to third parties outside of Japan) (“disclosure, etc.”) with regard to the user’s personal information stored in a database held by INFINI. Please contact us at the contact information below. The request will be handled according to the laws and regulations as follows, within a reasonable timeframe and scope, in writing or by providing electromagnetic records or by other means, after confirming that the request was submitted by the user themselves.

If the person or agent involved in the entrusted business makes a direct request to the INFINI, the person in charge of the entrusted INFINI will be contacted and the entrusted INFINI will handle the request.

Your request may not be handled as requested in case there is significant hinderance to our regular operation, or may be in breach with the regulations and laws, or interferes the security management of personal information.

13. About Disclosure and related procedures

The method for submitting requests for disclosure or notification of purpose of use of personal information (“requests for disclosure, etc.”) received by INFINI from users and contact information are as follows:

1) Download the “Application for Disclosure of Personal Information”
（Click URL below）
https://en.infini-trvl.co.jp/wordpress/wp-content/uploads/2020/09/Request-Forms-for-Disclosure-of-Personal-Information-1.pdf
2) We will verify your identity based on the personal information owned by us.
3) In case of inquiries from an agent, we will confirm that you are an agent with a power of attorney or a seal certificate.
4) Inquiries are accepted by mail to the following contact information using the “Application for Disclosure of Personal Information”.
5) If you wish to notify or disclose the purpose of use of the personal information, please pay a fee of 1,100 yen per case by postage stamp.
6) Personal information received from the “Application for Disclosure of Personal Information,” will be used for contacting all inquiries. It will not be used for any other purpose.

14. Regarding inquiries and the personal information protection manager

For Disclosure of personal information, complaints / consultation
INFINI TRAVEL INFORMATION, INC. Personal information inquiries
Sumitomo Fudosan Shin-Akasaka Building, 6th floor, 4-2-6 Akasaka, Minato-ku, Tokyo 107-0052
Telephone 03-6229-8500 FAX 03-5570-9577
Email address cp@infini-trvl.co.jp
Personal Information Protection Manager for the INFINI is:
Masahiko Dan

15. Changes of privacy policy

The INFINI’s privacy policy may be modified due to changes in laws and regulations. If we change our privacy policy, we will post it on the INFINI website (https://en.infini-trvl.co.jp/)

When using the website:

1. Limitation of liability

Use of this website is at your own risk

2. About links to external sites

This privacy policy does not apply to the handling of various information on the websites of businesses other than our company linked from this website. We encourage you to review each link’s own privacy statement.

Enactment Date: September 14, 2015
Revision Date: October 1, 2022
INFINI TRAVEL INFORMATION, INC.
Chairman, President & CEO. Seiichi Takahashi

Handling of GDS Personal Information-Part 2

Introduction

This document describes the privacy policy regarding the personal information of travelers managed by our (hereinafter referred to as “GDS personal information”). GDS personal information is part of the personal information provided by the traveler to the travel agency based on the consent of the traveler and will be strictly managed and handled in accordance with applicable laws and regulations.

Personal information protection policy

INFINI will endeavor to protect GDS personal information and the rights of travelers.

 Handling of GDS personal information

1. Scope of application

The scope of application of GDS personal information is as follows:

(1) GDS personal information is provided as part of the travel information (passenger information, guest information, etc.) necessary for travel arrangements performed by INFINI’s GDS, out of the personal information provided by the traveler to the travel agency. The travel companies INFINI provide GDS services to are those located in Japan.

(2) This privacy policy is applied to GDS personal information. It does not apply to personal information managed by third parties such as travel companies, travel suppliers (airlines, hotels, rental cars, etc.), settlement agents, travelers, and personal information disclosed when applying for travel-related products to a third party using GDS personal information.

2. Personal information handled

INFINI handles the following types of personal information as GDS.

(1) Basic personal information such as name and date of birth
(2) Contact information such as telephone number and email address
(3) Individual identification code such as passport information
(4) Credit card number
(5) Travel destination information such as boarding section and accommodation
(6) Special service information such as meals and wheelchairs

The personal information of our customers that INFINI has acquired in the past 12 months is as specified above. All of this personal information was provided as described in “1. Scope of application” in the previous section.

3. Purpose of use GDS personal information

INFINI uses GDS personal information as the GDS for the following purposes.

(1) Travel arrangements made by travel agencies based on travelers’ applications
(2) Ancillary services to travel agencies or travel suppliers
(3) Settlement of work

4. Changes in the purpose of use of personal information of GDS business

When changing the purpose of use of GDS personal information, INFINI will post a privacy policy reflecting the change in the purpose of use on our INFINI website in advance and then use it according to the new purpose of use.

5. Disclosure of GDS personal information to third parties

GDS personal information will be disclosed, provided, and shared with a third party only in the following cases based on the travel application of the traveler and consent to the handling of personal information.

(1) Travel arrangement processing, billing processing, marketing data provision to travel suppliers
(2) Provision of settlement information to settlement agents
(3) In addition, when it is requested by law to provide

The personal information is handled by a contractor (including cloud service providers) who operates, maintains or develops the system. The contractor performs safety management based on the contract.

6. Selling GDS personal information to third parties

(1) INFINI does not sell GDS personal information to third parties.
(2) INFINI may sell the information obtained by anonymously processing GDS personal information to a third party. For details on anonymous processing, see “2. Anonymous processing of personal information” below.

Management of GDS personal information

INFINI will take appropriate security measures to prevent loss, damage, and leakage of information for GDS personal information.

1. Security

INFINI will use SSL, highly secure networks, data encryption, etc., and strive to ensure safety for GDS personal information.

2. Anonymous processing of GDS personal information

The anonymous processing of GDS personal information is handled as follows:

(1) In order to improve services and expand the aviation/travel industry, INFINI anonymously processes data related to airline seat reservations for travelers and provides such data periodically to airlines requesting it as a part of our marketing data products
(2) Personal information included in the data provided to third parties
Anonymously processed data includes:
[Travel agencies’ information (no individual name)], [boarding date], [boarding airline], [boarding sector], [boarding class]
(3) Provision method of the anonymously processed data
INFINI provides anonymously processed data to third parties by the following method:
-Send as data
Security measures [file password], [data encryption], [communication encryption] is taken
-Downloading from website
Login ID/Password is provided only to limited persons at the third parties
(4) Handling of anonymous processed data
As with personal information, INFINI will take security measures for the data after anonymous processing in accordance with the personal information protection management system, or in accordance with laws and guidelines.

3. Use of cookies (*1) and IP address (*2)

Our GDS web-based solutions may use cookies and IP addresses. Since the usage method differs depending on the solution, details of the policy will be described on each website.
*1 A “cookie” is identification information that the server sends to your browser and is retained on the browser side for efficient operation of the INFINI website.
*2 “IP address” is a number that can identify the computer accessing the server. It is not possible to identify the computer user.

4. Use of Google Analytics (*3)

Our GDS web-based solutions may use Google Analytics. Since the usage method differs depending on the solution, details of the policy will be described on each site.

*3 For details on Google Analytics, refer to the next page. (Google Analytics™ is a trademark of Google Inc.)

http://www.google.com/analytics

5. Retention period of GDS personal information

GDS personal information will be retained for a period necessary for the travel agency to carry out operations related to travel arrangements and ticket refunds and will be deleted thereafter.

6. Changes to the privacy policy

This privacy policy may be modified due to changes in laws and regulations. If we change our privacy policy, we will post it on the INFINI website

Individual rights under privacy protection laws

Travelers have certain rights under the law, such as access to personal information and deletion.

1. Restrictions on handling personal information in GDS

Please note that since GDS personal information is a part of the traveler’s travel information, there are conditions such as cancellation of the trip for withdrawing consent, erasing, correcting personal information, and restricting handling.

In addition, the travel company that the traveler applied for travel to and the travel supplier that is planning to use it also store the personal information of the traveler. INFINI can only handle GDS personal information stored in our GDS, so the linked system will not operate properly and will hinder travelers’ travel and business operations. To prevent these, first contact the travel agency that made the travel request.

2. Procedures for personal rights

The procedures for travelers regarding “disclosure of personal information”, “data portability”, “opposition”, “disclosure of a third-party provision record”, and “information provision concerning the personal information protection measures” are as follows:

(1) Download “GDS Personal Data Disclosure Application Form”.

Download the application form here: https://en.infini-trvl.co.jp/wordpress/wp-content/uploads/2020/09/Request-Forms-for-Disclosure-of-Personal-InformationGDS.pdf

(2) Please fill in the required information, attach the required documents, and send it to the personal information inquiry window described below by mail or by using the INFINI website form described in “About INFINI information” below. Please be aware that if there are omissions in the application form, INFINI may not be able to respond to your request and may not be able to specify personal information.

(3) INFINI will verify the identity of the traveler based on the documents sent.

(4) When inquiring from an agent, INFINI will confirm that you are an agent with a power of attorney or seal certification.

(5) Based on the “Application form for GDS personal data disclosure, etc.”, INFINI will identify the personal information managed by our GDS and will respond as appropriate and as possible. In some cases, INFINI may contact you to confirm details.

(6) In addition to the above, the personal information obtained from the “GDS Personal Data Disclosure Application Form” will be used for contacting the traveler or the agent, and will not be used for any other purpose.

(7) In principle, INFINI will not change the service provided to travelers who have made various requests.

3. Appeal

A traveler can lodge a complaint regarding the personal information processing of the traveler to the supervisory authority having jurisdiction over the place of residence of the traveler.

About INFINI information

1. GDS personal information inquiry contact point

INFINI TRAVEL INFORMATION, INC. Personal information inquiries:

Sumitomo Fudosan Shin-Akasaka Building, 6th floor, 4-2-6 Akasaka, Minato-ku, Tokyo 107-0052
Telephone 03-6229-8500
FAX 03-5570-9577
Email address cp@infini-trvl.co.jp

2. Personal information protection manager

Personal information protection administrator: Masahiko Dan

Enactment Date: September 14, 2015
Revision Date: October 1, 2022
INFINI TRAVEL INFORMATION, INC.
Chairman, President & CEO. Seiichi Takahashi