Privacy Policy for JAPANiCAN

Part 1 General Terms and Conditions

JTB Corp. which has its registered offices at 2-3-11 Higashi-Shinagawa, Shinagawa-ku, Tokyo, Japan offers travel and destination management services and other related services worldwide.

This Privacy Policy for JAPANiCAN sets forth the manner in which JTB Corp. (“JTB Corp.”, “we”, “us”, “our”) handles and safeguards your personal information in connection with our JAPANiCAN services in accordance with the Act on the Protection of Personal Information of Japan, the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (“Individual Numbers Act”) and our internal policies regarding the protection of personal information.

Please use our JAPANiCAN services after you have carefully read and understood this Privacy Policy for JAPANiCAN.

For Residents of Member states of the European Economic Area (EEA):

Please see and read carefully the special and supplemental provisions in Part 2 below for EEA residents under the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”) ( click here ) in addition to this general terms and conditions .

For Residents of the States of California, United States:
Please see and read carefully the special and supplemental provisions in Part 3 below for California residents under the California Consumer Privacy Act (“CCPA”) (click here) in addition to this general terms and conditions.

1 Category of Information We Collect and Purposes of Processing

JTB Corp. collects directly and indirectly, retains as searchable personal data files and uses your personal information in connection with our JAPANiCAN services as follows:

(1) For Membership Services

We collect and use and process your information necessary for JAPANiCAN membership services (including incentive programs) such as name, phone number, e-mail address, nationality, account ID, password and IP address for the following purposes:

  • Making our membership services and other related services arrangements
  • Considering, entering into or performing contracts or other relationship
  • Responding to your queries or requirements
  • Maintaining our relations with you or re-establishing our relationships

(2) For Travel And Accommodation Related Services For Which You Enter Into An Arrangement Agreement With JTB Corp.

We collect and use and process your information necessary for JAPANiCAN travel and accommodation related services under our JAPANiCAN services for which you enter into an arrangement agreement with JTB Corp. such as your name, phone number, e-mail address, nationality, account ID, password and IP address for the following purposes:

  • Making accommodation or hotel arrangements
  • Making transportation arrangements
  • Making restaurant arrangements or other food arrangements
  • Making other related services arrangements
  • Considering, entering into or performing contracts or other relationship
  • Responding to your queries or requirements
  • Maintaining our relations with you or re-establishing our relationships

Please note that in the case where you enter into an accommodation agreement or an another service agreement directly with an accommodation or an another service provider through JAPANiCAN site, such accommodation or another service provider directly collect and process your data through JAPANiCAN site, and the terms and conditions and the privacy policy of such accommodation or another service provider should be applied.

(3) For Service Improvement, Research and Development, Customer Relation Management, Promotion and Advertisement and Safety Use

We also collect and use and process above your information for the following purposes:

  • Satisfaction surveys that you would complete, maintaining and improving the site, tailoring the user experience, and for internal training
  • Conducting surveys or provide you with information about our services on our site or on other websites you may visit
  • Advertising, Promoting or Marketing/ Providing information regarding our or other person’s products, services
  • Considering, entering into or performing contracts or other relationship
  • Responding to your queries or requirements
  • Maintaining our relations with you or re-establishing our relationships
  • Preventing and mitigating fraudulent or illegal activities or protecting the legal rights of JTB Group and/or the rights of third parties, including but not limited to the prevention, identification and investigation of scams, cyber-attacks, and other potentially illegal or fraudulent activities.
  • Exercising a right or obligation conferred or imposed by law, including responding to request and legal demands.

If you need to get in touch with our customer support team, or reach out to us through other means (such as through social media, or communicating with your accommodation through us), we will collect information from you there too.

Where you submit reviews regarding your accommodation or other ancillary services available on our website through us, we will collect information from you included in your reviews, including your name and country of residence.

You can decide to participate in our promotions, and doing this will also mean providing us with personal data. In addition to that, you can provide us with feedback or ask for help with using the Sites or our various communications platforms.

Where you are making a booking with other guests whose details you provide to us as part of your reservation, or if you make a booking on behalf of someone else, it is your responsibility to ensure that the person or people you have provided personal information about are aware that you have done so, and have understood and accepted how JTB Corp. uses their information (as described in this Privacy Policy).

Every customer is free to determine what personal information he/she wishes to furnish to us. However, we may be unable to provide you with our services if your decision not to furnish us with any personal information or to furnish us with only a limited amount of information renders us unable to contact you or to take the steps necessary to arrange for the delivery of the corresponding our services.

When you use our JAPANiCAN services or access the related sites, we collect and use cookie related information, IP address and your device information for service improvement, research and development, customer relation management and promotion and advertisement (including but not limited to tailoring your experience on the Site, providing you with high-quality and relevant content (including interest based advertising), and developing and improving our products and services).

In addition, your personal data may be converted into statistical or aggregated data which cannot be used to identify you and then used to produce statistical research and reports. This aggregated data may be shared and used in the ways described above.

2 Transfer of Personal Information to Third Parties

  1. To the extent required in order to arrange for the delivery of our services and to the extent required in order to secure insurance to cover our contractual liability as well as any expenses that may arise in the event of any contingency, JTB Corp. transfers the customer information (such as name, telephone number, e-mail address, passport number and credit card number) to the relevant transportation carriers, lodging operators, insurance carriers and other service providers.
  2. In order to facilitate shopping and other customer activity at the travel destination, JTB Corp. may furnish personal data (such as customer name, passport number, flight information) in its possession to gift shops.
  3. In order to prepare for contingencies during travel, including but not limited to illness and accidents, JTB Corp. may request personal information relating to customer emergency contacts during travel. JTB Corp. will use said personal information when JTB Corp. deems it necessary to do so in order to communicate with a customer’s emergency contacts in the event of illness or other unanticipated occurrence during travel. The customer is responsible for obtaining consent from his/her emergency contacts regarding the furnishing of the relevant personal information to JTB Corp., etc.
  4. In order to prevent and mitigate fraudulent or illegal activities or to protect the legal rights of JTB Group and/or the rights of third parties, JTB Corp. may provide customers information such as name, phone number, email address, credit card related information to the authorities, investigation agencies, business alliance entities, etc.
  5. Where required or permitted by an applicable law or regulation – such as to protect ourselves against liability, to respond to subpoenas, judicial processes, legitimate requests, warrants or equivalent by law enforcement officials or authorities, to investigate fraud or other wrongdoing or as otherwise required or necessary in order to comply with applicable law, protect our legitimate interests or to the purchasers in connection with any sale, assignment, or other transfer of all or a part of our business or company. We may also, in compliance with applicable law, disclose your information to enforce or apply the terms and conditions applicable to our services or to protect the rights, property, or safety of JTB Corp, our users, or others.
  6. Business Reorganization – such as part of any sale, assignment or other transfer of our business, or transition of service to another provider. We will ask for your consent if required by applicable law.

3 The Shared Use of Personal Information

In order to contact customers, simplify future travel product bookings and facilitate the arrangement and management of your travel needs and for other following purposes, JTB Corp. shares the minimum required amount of personal data (customer name, telephone number, e-mail address, etc.) with the JTB Group companies identified below. Each of these JTB Group companies is responsible for complying with all applicable laws when using any such data to provide information to customers regarding corporate offerings, to simplify the travel booking process, to disseminate information regarding events and/or to deliver products purchased by the customer.

  • JTB OKINAWA Corp.
  • JTB Media Retailing Corp.
  • JTB Grand Tours&Services.INC.
  • JTB BUSINESS INNOVATORS Corp.
  • JTB Global Marketing&Travel Inc.
  • JTB GLOBAL ASSISTANCE,INC.
  • JTB GAIAREC Inc.
  • JTB Benefit Service, inc.
  • JTB TRADING Inc.
  • Travel Plaza International, Inc.
  • JTB Communication Design, Inc.
  • JTB Business Travel Solutions, Inc.

4 Outsourcing

We may also disclose your personal information to certain outsourcing third party service providers, including those located outside of Japan, where necessary to carry out our business operations.

Please be assured that we will only disclose your personal information in compliance with applicable law, and with the appropriate management and supervision of the relevant third parties.

5 Inquiries, Disclosure, Deletion and Correction of Personal Information

Any individual seeking the disclosure, deletion, removal, correction, suspension of use and/or the suspension of the furnishing to third parties of any personal data held by JTB Corp. should contact our Customer Relations Office (contact information provided below) to receive instructions regarding the required procedures for doing so. Note that we are unable to accommodate requests in connection with supplementary information developed by JTB Corp. or when accommodating any such request may significantly impact the proper implementation of the business activities of JTB Corp. In all other cases, we shall promptly take the necessary steps in accordance with applicable laws, regulations and our internal policies. In addition, if we are unable to accommodate your request, in whole or in part, we shall provide you with an explanation as to why we are unable to do so. The contact information for our Customer Relations Office is provided below.

  1. For inquiries and/or complaints regarding our handling of personal information and/or the disclosure, deletion or removal of personal data (personal Information received from customers and reduced to digital format)

JTB Corp. Customer Relations Office
2-3-11 Higashi-Shinagawa
Shinagawa-ku, Tokyo

For inquiries and complaints,
To view procedures related to disclosure and deletion,
Forms required for the disclosure and/or deletion of personal information received from customers and reduced to digital format can be obtained at the offices of any of the companies identified in Section 4 above. However, requests are taken by our Customer Relations Office by mail only.

  1. To correct, suspend the use of or suspend the furnishing of personal data to third parties, please contact the office at which you booked your travel. (Please refer to your written confirmation and/or contract for the relevant contact information).

6 The Handling of Specific Personal Information

  1. JTB Corp. shall limit the use of Individual Numbers to the intended purposes set forth in the Individual Numbers Act.
  2. JTB Corp. shall not furnish Individual Numbers to any third-parties other than as provided in the Individual Numbers Act.
  3. JTB Corp. shall promptly delete and/or remove Individual Numbers upon completion of any Individual Number Administrative Procedures as set forth under the Individual Numbers Act.

7 Breaches involving Personal Information

In the unlikely event of any breach of personal information or similar such event, JTB Corp. shall immediately contact the affected customers. JTB Corp. shall immediately institute responsive measures and, as necessary, may temporarily suspend the operations of its IT systems and/or promptly disclose the relevant factual information via the company’s website, etc.

8 Updates to Privacy Policy

On occasion, JTB Corp. may revise this Privacy Policy to reflect changes in the law, our information collection and use practices, the features of our site, or advances in technology. If we make revisions that change the way we collect or use your information, those changes will be posted in this Privacy Policy and the effective date will be noted at the beginning of this Privacy Policy. Therefore, you should review this Privacy Policy periodically so that you are up to date on our most current policies and practices. JTB Corp. will also prominently post such material changes prior to implementing the change, and ask for your consent if required by law.

JTB Corp. Privacy Officer:
Senior Manager of Legal Affairs
Legal Affairs Department
JTB Corp.
JTB Building, 11th Floor
2-3-11 Higashi-Shinagawa, Shinagawa-ku, Tokyo

Part 2 Special Provisions for Residents of Member states of the European Economic Area

The provisions below are the special and supplemental provisions under the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”) for Residents of Member states of the European Economic Area. These special and supplemental provisions apply to you in the case where the GDPR applies to our collection or processing of your data and is available on our website and through other channels. Please read carefully these special and supplemental provisions in addition to the General Terms and Conditions (Part 1) before you commence use of our JAPANiCAN services.

1. Legal basis:

Under the GDPR, our collection and processing of your data under Section 1 of Part 1 is based on our and/or your legitimate interests such as provision of our JAPANiCAN services

In addition, your personal data may be converted into statistical or aggregated data which cannot be used to identify you and then used to produce statistical research and reports. This aggregated data may be shared and used in the ways described above.

JTB processes your personal data in its interest as well as your interest, so JTB provides and you receive the travel related services that you have requested and other related services specified in the above.

Where GDPR requires us to ask you to give us your consent to collect and use certain types of personal information such as personal data that GDPR considers as special categories, we will seek separate explicit consent from you prior to obtaining that data.

In all your dealings with us you must ensure that others you may represent are aware of the content of our Privacy Policy and consent to you on their behalf.

We will process your data for as long as possible in order to fulfil our service to you and comply with the applicable fiscal, tax, securities and commercial law regulations on retention of business and financial documentation.

2. Retention periods

We keep your personal data as long as there is a statutory or legal requirement to do so or in order to provide the aforementioned services to you. For accounting or auditing purposes we may retain your personal data for a period of time after our direct business dealings have ended.

3. Data storage and transfer

Furthermore, we may share your personal data with JTB group companies as well as with other companies which may be located within or outside the EEA and provide travel and business process services related to the provision of the services indicated above (including cases under Section 2 and 3 of Part 1), for example: airlines, hotels, accommodations, transportations, restaurants, tour operators, travel agencies, other service providers (including service providers for JTB). Where a company is located outside the EEA, we will arrange adequate safeguards such as Binding Corporate Rules or Standard Contact Clause arrangement or transfer your personal data based on appropriate legal basis.

JTB Group

When we process your personal data, we will store it on our systems located within EEA, Japan or other countries. In the event of a merger, reorganization, acquisition, joint venture, assignment, spin-off, transfer, or sale or disposition of all or any portion of our business, including in connection with any bankruptcy or similar proceedings, we may transfer any and all personal data to the relevant third party.

Your data may also be processed by staff operating outside the EEA who works for us or for one of our suppliers (e.g., 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 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.

  • 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.

  • Safeguards to protect your personal data

Where we share your 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). Furthermore, where we transfer your data from EEA to any entity outside the EEA, we will put appropriate legal frameworks in place, notably Binding Corporate Rules (Article 47 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 data based on rules of the GDPR.

By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, in particular, by adopting Binding Corporate Rules (for transfers among certain JTB companies) and Standard Contract Clauses (for transfers among certain JTB companies and with third-parties) where possible.

  • Booking on behalf of someone else

Where you are making a booking with other guests whose details you provide to us as part of your reservation, or if you make a booking on behalf of someone else, it is your responsibility to ensure that the person or people you have provided personal information about are aware that you have done so, and have understood and accepted how JTB Corp. uses their information (as described in this Privacy Notice).

4. Children

Our products and services are intended for adult customers. However, we may knowingly collect and process personal data on children under sixteen (16). On these occasions, we will take account of this event when processing the personal data of children and implementing the legal basis for such processing. For example, where the processing of personal data of children is based on their consent such as the processing of his/her sensitive personal data, we will seek the consent of parents, tutors, or other adults holding parental responsibility over children, if required under the GDPR.

5. Links to other sites

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.

6. 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).

7. 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).
We will retain your personal information 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.

8. 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).

9. 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).

10. Your Rights

As a customer you have a number of rights as follows:

  • 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 the Binding Corporate Rules or of any Standard Contract Clauses that we use if we transfer your personal data outside the EEA 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: private@jtb.com.

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.

11. 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 JTB Data Protection Team at private@jtb.com .

You can also contact the JTB 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 JTB 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 local 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.

12. Changes to our Privacy Policy

We may revise or update this Privacy Policy from time to time. Any changes we may make to our Privacy Policy in the future will be posted on this webpage. 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.

13. Contact

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

JTB Data Protection Team
JTB Group Headquarters
JTB Corp.
17F 2-3-11 Higashi Shinagawa
Shinagawa-ku, Tokyo
JAPAN
Email: private@jtb.com

14. About Cookie

JTB uses cookie information to provide better services, secure security, analyze and distribute appropriate advertisements to customers. 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.

Google LLChttp://www.google.co.jp/policies/technologies/ads/
Google Analytic Opt-outhttps://tools.google.com/dlpage/gaoptout?hl=ja
Yahoo Japan Corporationhttp://btoptout.yahoo.co.jp/optout/preferences.html
MicroAd,Inc.http://send.microad.jp/w3c/
MicroAd,Inc (SmartPhone)http://www.microad.jp/smart/optout.html
Criteo SAhttp://www.criteo.com/jp/privacy/
Platform ID,Inc.http://www.xrost.ne.jp/contents/policy/privacy.html
KYOCERA Communication Systems Co.,Ltd.http://www.kccs.co.jp/policy/optout.html
Facebook, Inc.https://www.facebook.com/help/cookies/update
CyberAgent, Inc.https://www.dynalyst.jp/legal/policy/optout.html
FreakOut, inc.http://js.fout.jp/info/privacy.html
AMoAd, Inc.http://www.amoad.com/guideline/#optout
LINE Corporationhttp://terms.line.me/line_rules/?lang=ja
Twitter, Inc.https://support.twitter.com/articles/20170346?lang=ja#

Part 3   Special Provisions for Residents of States of California, United States

January 1, 2020

The provisions below are the special and supplemental provisions under the California Consumer Privacy Act (“CCPA”) for Residents of States of California, United States. These special and supplemental provisions apply to you in the case where the CCPA applies to our collection or processing of your data and is available on our website and through other channels.  Please read carefully these special and supplemental provisions in addition to the General Terms and Conditions (Part 1) before you commence use of our JAPANiCAN services.

1. Categories and Purposes of Your Collected Personal Information

The categories of personal information which we have collected within the preceding 12 months, and the business or commercial purposes for which such personal information was collected are specified in Section 1 of the General Terms and Conditions (Part 1).

2. Sources of Personal Information

Under JAPANiCAN services, we collect your personal information from you (data subject) or a person who provide your personal information on behalf of you (including but not limited to your parents or guardians).

3. Disclosure of Personal Information

We have disclosed your Personal Information specified in Section 1 of Part 1 to third parties for our operational business purposes specified in Section 2, 3 and 4 of Part 1 and Section  of this Part 3 within the preceding 12 months, and We have disclosed these categories of personal information to the parties specified in Section 2, 3 and 4 of Part 1 and Section  of this Part 3.

4. Do not Sell My Personal Information

Under the CCPA, California residents have the right to opt-out of the “sale” of their personal information. CCPA defines “sale” broadly to include any transfers or disclosures to other businesses or third parties for monetary or other valuable consideration (hereinafter referred as “CCPA-defined transfers”). While we do not obtain financial compensation for your personal information, we may share it with third-parties for service improvement, research and development, customer relation management and promotion and advertisement (including but not limited to tailoring your experience on the Site, providing you with high-quality and relevant content (including interest based advertising), and developing and improving our products and services)

To exercise this right, please visit our “Do Not Sell My Personal Information” page from the following link.

            https://www.japanican.com/ccpa.html

5. Your Rights and Requests

If you are a California resident, you have the following rights under the CCPA:

I.          Request to disclose to you the following information covering the 12 months preceding your request:

(I)        The categories of Personal Information we collected about you;

(II)       The categories of sources from which we collected such Personal Information;

(III)      The business or commercial purpose(s) for collecting such Personal Information about you;

(IV)      The categories of third parties with whom we shared such Personal Information; and

(V)       The specific pieces of Personal Information we have collected about you.

II.         Request to delete Personal Information we collected from you

III.        Non-Discrimination for the exercise of the rights under the CCPA

To make a request for the disclosure or deletion described I. and II. above, please contact us by using the following means:

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: providing your email and phone verification, known customer information, and/or account sign-up authentication or other information (including but not limited to passport related information and social security related information) needed to verify your identity depending on the sensitivity of personal information in question.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

If you use an authorized agent to submit a request to know or a request to delete described I. and II. above, you may specify your agent by providing the authorized agent written permission to do so. In addition, we will request sufficient information that allows us to reasonably verify your agent is the person about whom you assign.

We use good faith efforts to respond to a verifiable consumer request within forty-five (45) days after its receipt. If we need more time (up to 90 days), we will inform you of the reason and the needed extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. For data portability requests, we will select a commercially reasonable format to provide your Personal Information that is commonly useable and should allow you to transmit the information from one entity to another entity without hindrance, but we do not guarantee that all formats are useable in all media. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

6. Changes to this Privacy Policy

We may change this Privacy Policy from time to time.  The “Date last updated” mentioned at the top of this page states when this Privacy Policy was last updated and any changes will become effective upon our posting the revised Privacy Policy.

Where required by CCPA or other applicable law, we will request your consent to any such changes.  We will provide the revised Privacy Policy by email or by posting notice of the changes on our website or through any relevant services.

7. About Cookie

About Cookie, please see Section 14 of Part 2.

8. Contact Us

If you have any questions or concerns regarding this Privacy Policy or our privacy practices, please contact us at private@jtb.com