EFFECTIVE DATE: 1, July, 2023
Kenedix Property Design, Inc. provides hotels and serviced offices to individual persons who require temporary and long-term accommodation and/or office space as well as employees of companies and other organizations.
At Kenedix Property Design, Inc. (“we,” “us,” “our”), we take the privacy rights of California consumers under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, (“CCPA”) seriously. This California Consumer Privacy Policy Addendum (“California Addendum”) applies if (i) you are a resident of the State of California of the United States, and (ii) information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household subject to the CCPA (“California Personal Information”) about you is collected by or shared with us. For such residents, the provisions of this California Addendum supplement our privacy policy available at /privacypolicy/index_en.html (“Privacy Policy”) and prevail over any conflicting provisions therein.
Information on the categories of personal information we collect and whether we sell or share personal information is contained in I. 1. ‘Categories of California Personal Information’ , I. 5. ‘Disclosure of California Personal Information’, and I. 6. ‘Sale or Sharing of California Personal Information’ below. Information on the length of time we intend to retain personal information is contained in I. 2. ‘Retention Period’ below, and information on your rights is contained in III. ‘Your Rights Regarding California Personal Information’ below.
We reserve the right to update this California Addendum from time to time at our discretion. When we make changes to this California Addendum, we will post the updated notice on our website and update the effective date of this California Addendum. It is your responsibility to regularly review this California Addendum. Without limiting the generality of the foregoing, if we make a material change to this California Addendum, we will provide appropriate notice to you, as required under applicable law, such as by posting a prominent notice on our website.
Consumers with disabilities may access this California Addendum by using a standard screen reader or contacting us using the methods identified in V. ‘Contact for More Information’ hereinbelow.
I. California Personal Information
1. Categories of California Personal Information
We collect, and in the past 12 months, we have collected, the following categories of California Personal Information:
･Identifiers: Identifiers such as first and last name, postal address (temporary and/or permanent), place of residence, date of birth, online identifier, email address, passport number, copies of government ID’s including driver’s licenses and driver’s license numbers.
･Personal Information Described in Cal. Civ. Code § 1798.80(e): Personal information described in Section 1798.80(e) of the California Civil Code such as physical characteristics or description, telephone number, passport number, copies of government ID’s including driver’s licenses and driver’s license numbers, or employment information. Bank account number if necessary for refunding.
･Characteristics of Protected Classifications: Protected classifications under California or federal law such as age, nationality, citizenship, or marital status. Medical condition, physical or mental disability, gender, pregnancy or childbirth and related medical conditions may be obtained voluntarily from your side such as yourself, your employers, your or your employers’ engaged booking agents if necessary for service requirements or considerations.
･Commercial Information: Commercial or transactions information such as records of services purchased, obtained or considered, transaction history, dates of check-in and check-out, accompanied members and their information (if any), and other information necessary to provide the services, process payments, and refunds including accommodation requirements and emergency contact information.
･Internet Information: Internet or other electronic network activity information such as browsing history.
･Geolocation data: Physical location or movements.
･Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information: Sensory information such as audio, electronic, visual, or similar information, including call recordings from customer service interactions.
･Professional or Employment-Related Information: Professional or employment-related information such as employer, job title, income, length of employment, and other statements will be obtained, if necessary for credit check for serviced office leasing contracts. Job title occasionally will be obtained in case of booking of accommodation by employer.
･Inferences drawn from other California Personal Information: Profiles reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
･Sensitive personal information: Social Security Number, driver’s license or state identification card number, or passport number, precise geolocation, and California Personal Information collected and analyzed concerning your health.
California Personal Information does not include (i) publicly available information, including information that is lawfully obtained from federal, state, or local government records, information that we have a reasonable basis to believe is lawfully made available to the general public by the consumer or from widely distributed media, or information made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience, (ii) lawfully obtained, truthful information that is a matter of public concern, (iii) deidentified or aggregate consumer information, and (iv) certain personal information excluded from the CCPA requirements.
2. Retention Period
We will periodically review California Personal Information held by us to ensure that such information is accurate and up to date. We will also retain California Personal Information only for so long as it is necessary to carry out the processing purposes described in this California Addendum. We also retain information for related business purposes, security, legal compliance, and disputes and claims handling, consistent with our corporate retention policy and as permitted by applicable law.
3. Categories of Sources of California Personal Information
We obtain California Personal Information from a variety of sources. We may obtain, and within the past 12 months, we have obtained, California Personal Information from the following sources:
･Directly from California residents like yourself.
･From California resident’s employer or booking agent.
･Indirectly from access devices used by California residents (such as observations on California resident’s interaction with our website using cookies).
4. Our Use of California Personal Information.
For each of the categories of California Personal Information, we use the California Personal Information we collect for purposes explained below:
･Perform our services and fulfill or meet the reason you provided the information to us. For example, we may use your California Personal Information to provide our services, arrange necessary accommodations, respond to your inquiries, make proposals, and enter into lease agreements.
･Process your requests, purchases, transactions, and payments and prevent transactional fraud. For example, we may use your California Personal Information to verify your identity and perform payment processing, and deposit refund, also perform credit check in connection with your serviced office leasing agreement.
･Support checking-in, checking-out, moving-in, moving-out and damage recovery processes.
･Arrange services and facilities such as concierge and emergency assistance.
･Provide optional services available at serviced offices such as meeting room arrangements, mailing, and rental equipment services.
･Provide service updates and other service-related information.
･Manage renewal, amendments, or termination of reservations or contracts.
･Support the handling of feedback, complaints and disputes.
･Detect or prevent security incidents or other illegal activity and prosecuting the responsible parties.
･Maintain the safety, security, and integrity of our services, website and other technology assets, and business.
･For legal compliance and to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
･Analyze and monitor our website use, personalize your experience with us, and improve our website and services.
The business purposes for which we may use California Personal Information include:
i. Helping to ensure security and integrity;
ii. Debugging to identify and repair errors that impair existing intended functionality;
iii. Short-term, transient uses, including nonpersonalized advertising;
iv. Performing services on our behalf , including maintaining or servicing accounts, providing customer service, processing or fulfilling transactions, verifying identity information, processing payments, and other services;
v. Undertaking internal research for technological development and demonstration;
vi. Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us; and
vii. Other operational purposes, purposes for which we provide you additional notice, purposes disclosed elsewhere in this California Addendum, or for purposes compatible with the context in which the personal information was collected.
5. Disclosure of California Personal Information
a. Disclosure of California Personal Information for Business Purposes
We may disclose, and within the last 12 months, we have disclosed, the following categories of California Personal Information to the following categories of recipients for business purposes. When we disclose California Personal Information for business purposes, we enter a contract that describes the purpose and requires the recipient to both keep that California Personal Information confidential and not use it for any purpose except performing the contract.
･Identifiers:
･For operational service providers such as building management companies or security companies for our operating properties, necessary information such as first name and last name of accommodation guest will be disclosed. E-mail address and date of birth of approved employee for entering serviced office during the non-business hours will be disclosed in addition to first name and last name.
･IT system maintenance providers.
･Government entities to meet our legal obligations.
･Other legal professional service providers such as lawyers to the extent necessary to meet our legal obligations or respond to court order.
･Personal Information Described in Cal. Civ. Code § 1798.80(e):
･For operational service providers such as building management companies or security companies for our operating properties, necessary information such as business card and telephone of approved employee for entering serviced office during the non-business hours will be disclosed.
･IT system maintenance providers.
･Government entities to meet our legal obligations.
･Other legal professional service providers such as lawyers to the extent necessary to meet our legal obligations or respond to court order.
･Characteristics of Protected Classifications:
･For operational service providers such as building management companies or security companies for our operating properties, necessary information such as physical or mental disability of accommodation guest will be disclosed in case for emergency evacuation.
･IT system maintenance providers.
･Government entities to meet our legal obligations.
･Commercial Information:
･For operational service providers such as building management companies or security companies for our operating properties, necessary information such as dates of check-in and check-out, name(s) of accompanied guest(s) of accommodation guest will be disclosed.
･IT system maintenance providers.
･Government entities to meet our legal obligations.
･Other legal professional service providers such as lawyers to the extent necessary to meet our legal obligations or respond to court order.
･Internet Information:
･Service providers such as IT system maintenance providers, data analytics providers, and marketing subscription management vendors.
･Government entities to meet our legal obligations.
･Geolocation data:
･Service providers such as IT system maintenance providers, data analytics providers, and marketing and subscription management vendors.
･Government entities to meet our legal obligations.
･Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information:
･Operational service providers such as building management companies, security companies.
･IT system maintenance providers.
･Government entities to meet our legal obligations.
･Professional or Employment-Related Information:
･IT system maintenance providers.
･Government entities to meet our legal obligations.
･Inferences drawn from other California Personal Information:
･Service providers such as IT system maintenance providers, data analytics providers, and marketing and subscription management vendors.
･Government entities to meet our legal obligations.
･Sensitive Personal Information:
･For operational service providers such as building management companies or security companies for our operating properties, necessary information such as physical or mental disability of accommodation guest will be disclosed in case for emergency evacuation.
･Government entities to meet our legal obligations.
b. Use or Disclosure of Sensitive Personal Information
We do not use or disclose sensitive personal information for purposes that, under applicable law, require us to offer consumers a right to limit the use or disclosure of sensitive personal information.
6. Sale or Sharing of California Personal Information
We do not sell or share California Personal Information, including California Personal Information of California consumers we know to be under the age of 16. Within the last 12 months and within the meaning of the CCPA, we have not sold or shared California Personal Information.
II. Cookies & Analytics.
1. Cookies
Our website uses cookies for essential functionality and site analytics purposes. Cookies are files sent by web servers to web browsers and stored by web browsers. The information is then sent back to the server each time the browser requests a page from the server. This enables a web server to identify and track web browsers. On our website, we track general visitors’ information, including the IP address of your access device and other browser information. These details are used to provide essential functionality of our website, personalize your experience, and for site analysis, including analysis of visitation and clicking behavior on our website. This helps us improve our website usability. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our website, you may not be able to take advantage of all available features.
2. Google Analytics
To assess the web traffic to our website and how effective our online campaigns are, we use Google Analytics. We restrict Google’s use of our information by enabling the Restricted Data Processing configuration provided by Google.
For more information regarding how Google collects and uses your information, please visit: https://policies.google.com/technologies/partner-sites. Google also provides you choices on how your information is collected by Google Analytics by offering you an opt-out browser add-on which can be located at: https://tools.google.com/dlpage/gaoptout?hl=en.
3. HubSpot
We use HubSpot to analyze who are visiting our website. HubSpot is a tool that helps provide our marketing and sales team with lead generation. They deliver reports on the information such as IP addresses related to the individuals who visited our website, for how long the individuals stayed on our website, and how many visits the individuals had.
HubSpot also allows us to collect information from you when you subscribe to our online mailing list form. We use HubSpot as a mailing list tool, so that we can store your name, email address, company and phone number. Subscribers can opt-out and unsubscribe any time by following instructions available on our email communication.
For more information regarding how Hubspot collects and uses your information as our service provider, please visit https://legal.hubspot.com/privacy-policy
III. Your Rights Regarding California Personal Information.
California residents have certain rights with respect to the California Personal Information collected by businesses. If you are a California resident, you may exercise the following rights regarding your California Personal Information, subject to certain exceptions and limitations:
･The right to know the categories of California Personal Information we collect about you, the categories of sources from which we collected your California Personal Information, our purposes for collecting, selling or sharing your California Personal Information, the categories of your California Personal Information that we have disclosed for a business purpose, and the categories of third parties with which we disclosed that particular category of California Personal Information. You also have the right to request a copy of specific pieces of your California Personal Information.
･The right to delete the California Personal Information we have collected from you. Please note if you have requested a service that requires the use of your California Personal Information, we may not be able to provide that service if you choose to delete your California Personal Information.
･The right to correct inaccurate California Personal Information about you.
･The right to opt out of a sale or sharing of your California Personal Information. Please note that we do not sell or share your California Personal Information, and therefore, we do not offer support for opt-out of a sale and a sharing, including by use of opt-out preference signals such as Global Privacy Control.
To exercise any of the above rights, please contact us using the following information:
･E-mail: p-policy@kenedix-pm.com
･California Privacy Rights Request Form
Verification Process and Required Information. Note that we may request additional information from you to verify your identity or understand the scope of your request, as permitted or required under applicable law. Although you will not be required to create an account with us to submit a request or have it fulfilled, we ask you to provide certain California Personal Information as part of our verification process, including your name, email address and phone number and your employer’s name.
Authorized Agent. You may designate an authorized agent to make a CCPA request on your behalf by submitting the written power of attorney or by providing the agent with written permission to act on your behalf. As permitted by law, we may require verification of the agent’s authorization or require you to verify your own identity in response to a request even if you choose to use an agent.
Please note that we may not be able to respond to your request or provide you with your California Personal Information if we cannot verify your identity or authority to make the request and confirm the California Personal Information that relates to you.
In addition to the above rights, you also have the right not to receive discriminatory treatment
for the exercise of the privacy rights conferred by the CCPA. We will not discriminate against you for exercising any of your CCPA rights. Please note that we currently do not provide any financial incentive program.
Other California Privacy Rights. Under California’s “Shine the Light” law (Civil Code Section § 1798.83), you, as a California resident, may ask us to provide a list of what personal information (if any) we disclosed to third parties for their direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Please note that we do not disclose your personal information to third parties for their direct marketing purposes.
IV. California Do Not Track Disclosure.
As of the Effective Date listed below, there is no commonly accepted response for “Do Not Track” signals initiated by browsers. Therefore, we do not respond to such signals or to other mechanisms that provide the ability to exercise choice regarding the collection of personally identifiable information regarding your online activities over time and across third-party web sites or online services.
V. Contact for More Information.
For questions or concerns about our Privacy Policy, this California Addendum or our data practices, please contact us by using the information below.
･E-mail: p-policy@kenedix-pm.com
･Web Form (Japanese): https://webform.kenedix-pm.com/webapp/form/20851_zveb_6/index.do
･Tel: +813-3502-7000
Available from 10:00 am to 5:00 pm (Japan standard time)
(except Saturdays, Sundays, local national holidays, and the year-end and New Year holidays)
･Physical address:1-2-9 Nishi-Shinbashi, Minato-ku, Tokyo, 105-0003, JAPAN