Privacy Policy

This is a reference translation. In the event of any discrepancy, the Japanese text shall prevail.
Fund Develop Co., Ltd. (hereinafter “we” or “the Company”), as an operator engaged in the hotel business, recognizes—under the principle that we should set a standard for the appropriate handling of personal information—the importance of handling personal information appropriately. We have therefore established this Privacy Protection Policy, which our officers and employees observe as one, so as to devote our full efforts to the protection of personal information and of the rights and interests of individuals.

Privacy Protection Policy

Purpose of Use of Personal Information

When we acquire personal information, we specify the purpose of use as far as possible and acquire personal information only to the extent necessary to achieve that purpose. We use personal information only within the scope of the purpose of use. In addition, we have established and implement procedures to take the measures necessary to prevent use beyond that purpose.

Security Measures for Personal Information

We manage the personal information we hold accurately and in an up-to-date state, within the scope necessary for the purpose of use, and we take reasonable security measures against risks such as the leakage, loss, or damage of personal information, striving for both prevention and correction.

Compliance with Laws and Regulations

We comply with laws and regulations concerning the handling of personal information, guidelines established by the government, and other norms.

Complaints and Inquiries Regarding the Handling of Personal Information

If you have any complaints or inquiries regarding our handling of personal information, we will respond to them upon your contacting the desk below. Fund Develop Co., Ltd., Person in charge — Postal contact: 〒151-0053 東京都渋谷区代々木2-21-11 ベルテ代々木Ⅱ501号室 Email: info@ten-hotels.jp

Continuous Improvement

We have established a personal information protection management system, which we review periodically and improve on an ongoing basis.

Handling of Personal Information

[ Purposes of Use ]

The personal information we acquire is used within the scope of the following purposes. Should a purpose of use arise that is not included within the scope below, we will use the information only after obtaining the consent of the individual as to the purpose of use in the case of direct acquisition, or after publicly announcing the purpose of use in the case of acquisition by other means.

  1. 1

    Personal information relating to the hotel business

    To receive and manage reservations for lodging, dining, banquets, and the like at our operated facilities and to provide goods and services; to compile and analyze information for the planning and improvement of goods and services; to provide information on goods, services, campaigns, questionnaires, and the like offered by our operated facilities by means of invitations, email, and so on; to manage member information within the membership organizations of our operated facilities and to provide services to members; and to carry out the following marketing activities at our operated facilities.

    • ⅰ. Advertising and provision of information on goods, services, campaigns, and the like via invitations, email, and so on (*1, *2)
    • ⅱ. Delivery of behavioral targeting advertisements using advertising distributors such as Google and Yahoo (*1, *2)
    • ⅲ. Analysis of attribute information, behavioral history, and the like acquired by us in order to understand customers’ interests and preferences (*3, *4)
    • ⅳ. Other matters equivalent to ⅰ through ⅲ
    • *1 We analyze information such as website browsing history and purchase history acquired from customers and others in order to provide services, deliver advertisements, and the like.
    • *2 We may use information such as the interests, preferences, and browsing history of customers and others acquired from third parties other than us by linking it with the personal information of customers and others that we already hold. In such cases, we obtain the prior consent of the customers and others and use the information within the scope of the purposes of use set out above.
    • *3 Our website uses cookies so that customers and others can use it more conveniently. For details on the handling of cookies, please see “7. Cookies and Other Similar Related Technologies.”
    • *4 Our website uses Google Analytics, a service of Google LLC, in order to understand how customers and others visit our website. When Google Analytics is used on our website, Google collects, records, and analyzes the visit history of customers and others to our site based on cookies issued by us.

    We receive the analysis results from Google and thereby understand how customers and others visit our website. The information of customers and others collected, recorded, and analyzed by Google Analytics does not contain any information that identifies a specific individual. Such information is managed by Google in accordance with its privacy policy.
    <Google Analytics Terms of Service> https://marketingplatform.google.com/about/analytics/terms/jp/
    <Google Privacy Policy> https://policies.google.com/privacy
    <Google Analytics Opt-out Add-on> https://tools.google.com/dlpage/gaoptout
    To send questionnaires for the further improvement of our services; for purposes of use separately indicated or announced to customers and others; and for record-keeping.

  2. 2

    Personal information relating to business partners

    For sales activities and the management of business partner information.

  3. 3

    Personal information relating to employees and retirees

    For employment and personnel management.

  4. 4

    Personal information of job applicants

    For screening and for communications regarding hiring decisions.

Retention Period of Personal Information

We retain customers’ personal information for the period necessary to fulfill the purposes described in this Policy.

Joint Use of Personal Information

In order to provide customers who use the services of our operated facilities with high value-added services, and to carry out communications, payment operations, and the like necessary to perform such services, we jointly use personal information as follows, under strict management and appropriate security measures.
Parties jointly using the personal information: Crowd Fund Holdings Co., Ltd. (our parent company) and Fund Develop Co., Ltd. (the Company).
Purpose of joint use: As described above (Purpose of Use of Personal Information).
Items of personal information jointly used: the customer’s name, membership number, telephone and fax number, nationality, passport number, address, email address, age, gender, date of birth, information on the history of use of the services of our operated facilities, information provided by customers and others in order to use the services of our operated facilities, and information provided to our reservation sites (including affiliated reservation sites).
Party responsible for managing the jointly used personal information: Fund Develop Co., Ltd.

Provision of Personal Information to Third Parties

Except where any of the following items applies, we will not provide personal information to a third party without obtaining the prior consent of the individual.

  1. (1)
    Where based on laws and regulations.
  2. (2)
    Where it is necessary for the protection of a person’s life, body, or property, and it is difficult to obtain the consent of the individual.
  3. (3)
    Where it is especially necessary for improving public health or promoting the sound development of children, and it is difficult to obtain the consent of the individual.
  4. (4)
    Where it is necessary to cooperate with a national government organ, a local government, or a party entrusted by either of them in performing affairs prescribed by laws and regulations, and obtaining the consent of the individual is likely to impede the performance of such affairs.
  5. (5)
    Where the handling of personal information is entrusted within the scope necessary to achieve the purpose of use; where personal information is provided in connection with the succession of a business due to a merger or other cause; or where the case falls under the joint use provided for in the preceding section.

Provision of Personal Information to Third Parties in Foreign Countries

In connection with the use of analytics and advertising-distribution tools such as Google Analytics and of cloud services, we may provide information such as customers’ browsing history to third parties located in foreign countries (the United States and other countries). For information on the names of the foreign countries to which the information is provided, the systems concerning the protection of personal information in those countries, and the measures for the protection of personal information taken by the recipients, please refer to the information on each country’s system published on the website of the Personal Information Protection Commission and to the privacy policies of the respective service providers. We provide personal information to third parties in foreign countries only after obtaining the prior consent of the individual, or where an exception provided for in Article 28 of the Act on the Protection of Personal Information applies.

Requests Concerning Personal Information

When an individual requests notification of the purpose of use, disclosure, disclosure of records as a provider or recipient in the provision to third parties, correction, addition, or deletion of content, suspension of use, erasure, or suspension of provision to third parties (hereinafter “disclosure, etc.”), we will conduct an internal investigation of the personal information and respond without delay.
* However, depending on the content of the request, we may be unable to comply with the disclosure, etc. In such cases, we will also provide a response regarding the reason.
When making a request for disclosure, etc., please submit your request by post or email in accordance with the procedures below. If there are deficiencies or missing items in the content of the request, we may be unable to accept it.
The personal information we receive by means of the “Personal Information Disclosure Request Form” will be used to respond to your inquiry and for no other purpose.
Please note that, for requests for notification of the purpose of use and requests for disclosure, a fee of 1,000 yen (tax included) will be charged per request. The fee is to be paid by bank transfer to the account designated by us before the request documents are sent. Transfer fees are to be borne by the requester.

When the individual makes the request

When making a request for disclosure, etc., please prepare the following documents and send them by recorded-delivery mail or as email attachments.

  1. ①
    Personal Information Disclosure Request Form: Please fill in specifically the requester’s address, name, and telephone number; the address, name, and telephone number of the person subject to the request; the type, content, and time of submission of the personal information concerned; and the content of the request.
  2. ②
    Identity verification document: A copy of a photo-bearing document that can confirm the individual’s name and current address, such as a driver’s license, passport, or residence card.

When an agent makes the request

If the person making the request for disclosure, etc. is a statutory representative or an agent authorized by the individual, please enclose or attach the following documents in addition to those in the preceding item, as applicable.

● In the case of a statutory representative

  1. ①
    A document confirming the existence of statutory representation authority (a copy of the family register; in the case of a person with parental authority, a copy of a health insurance card listing dependents is also acceptable).
  2. ②
    A document confirming that the person is the statutory representative in question (a copy of a driver’s license, passport, residence card, or the like).

● In the case of an agent by power of attorney

  1. ①
    A power of attorney (bearing the signatures and seals, addresses, and telephone numbers of both the person delegating the request and the agent, together with the content of the delegation).
  2. ②
    The individual’s seal registration certificate (issued within the past three months).
  3. ③
    A document confirming that the person is the authorized agent in question (a copy of a driver’s license, passport, residence card, or the like).

Contact Desk for Inquiries and Disclosure Requests Regarding Personal Information

Fund Develop Co., Ltd., Person in charge
Postal contact: 〒151-0053 東京都渋谷区代々木2-21-11 ベルテ代々木Ⅱ501号室
Email: info@ten-hotels.jp
Telephone: 03-6381-6545

Personal Information of Minors

Our website is not intended for use by persons under 18 years of age. We do not knowingly collect personal information from persons under 18. Persons under 18 may use our website only with the consent and supervision of a parent or guardian.

Handling of Cookies

Our website may use cookies. In such cases, cookies are used to improve convenience when customers use our website and are not intended to identify customers’ personal information.
You can configure your browser settings to refuse all cookies; however, please understand in advance that doing so may prevent you from using our website comfortably.

Use of Cookie Information by Third-Party Companies

When using cookies, we may use the systems of third-party companies. On our website, in order to analyze users’ access and deliver optimal advertisements, we obtain statistical site-usage information using cookies from third-party companies and deliver advertisements through third-party companies. The cookie information used for access analysis and advertising delivery involving third-party companies does not identify individuals in any way.
On our website, pursuant to Article 27-12 of the Telecommunications Business Act, we may transmit information on users’ devices to external providers. The main information transmitted, the recipients, and the purposes of use of such information are as follows.
・Information transmitted: the URL of the page viewed, the URL of the referring page, IP address, browser type, OS information, screen resolution, language settings, timestamp, and identifiers such as cookie IDs.
・Recipients: Google LLC (United States), Meta Platforms, Inc. (United States), and other analytics and advertising-delivery service providers used by us.
・Purposes of use: analysis of website usage, maintenance and improvement of service quality, and optimal advertising delivery.
If you do not wish for these transmissions, you can complete the procedures from the opt-out pages below.

Use of services for optimizing advertising delivery
Google LLC: http://www.google.co.jp/policies/technologies/ads/
Meta Platforms, Inc.: https://www.facebook.com/policy.php

List of opt-out pages
Google LLC: http://www.google.com/settings/ads
Meta Platforms, Inc.: https://www.facebook.com/settings?tab=privacy

Security Measures for Personal Information

To ensure security when customers transmit personal information while using our website, we protect customers’ personal information using SSL (Secure Socket Layer: a security function that encrypts information for communication over the internet).

For the security management of the personal data we hold, we take the following necessary and appropriate measures.

  1. (1)
    Establishment of a basic policy: To ensure the appropriate handling of personal information, we have established this Policy.
  2. (2)
    Development of rules concerning the handling of personal data: We have established personal information handling regulations covering, for each stage of acquisition, use, storage, provision, deletion, and disposal, the handling methods, the persons responsible and in charge, and their duties.
  3. (3)
    Organizational security control measures: We appoint a person responsible for the handling of personal information, clarify the employees who handle personal information and the scope of the personal data they handle, and maintain a system for reporting to the responsible person when a fact or sign of a violation of the law or the handling regulations is identified.
  4. (4)
    Human security control measures: We provide employees with regular training on points to note regarding the handling of personal information and stipulate matters concerning the confidentiality of personal information in our work rules and in pledges.
  5. (5)
    Physical security control measures: We manage employees’ entry to and exit from areas where personal data is handled and restrict the devices brought in, take measures to prevent the theft or loss of devices, electronic media, and documents that handle personal data, and, when carrying these, implement measures so that the personal data cannot be easily identified.
  6. (6)
    Technical security control measures: We implement access control to limit the persons in charge and the scope of the personal information databases handled, and we have introduced mechanisms to protect personal data from unauthorized external access and malicious software.
  7. (7)
    Understanding of the external environment: When handling personal data in a foreign country, we take the necessary and appropriate measures for security management after understanding the system concerning the protection of personal information in that country.

Supervision of Employees and Contractors

We impose a duty of confidentiality regarding personal information on our employees and provide employee education for the protection of personal information.
When we entrust the management of personal information to a third party (including outside Japan), we conclude a confidentiality agreement after reviewing the contractor’s security regarding the protection of personal information.

Name and Address of the Personal Information Handling Business Operator and Name of Its Representative

Fund Develop Co., Ltd.
Representative Director: 佐藤　慧士
Email: info@ten-hotels.jp
Telephone: 03-6381-6545

Accredited Personal Information Protection Organization

We are not a member of any accredited personal information protection organization as provided for in Article 47, Paragraph 1 of the Act on the Protection of Personal Information.

Established May 12, 2026