GDPR Privacy Policy

The protection of your personal data is of great importance to ActiValues, Inc.(“ActiValues”). This Privacy Policy therefore intends to inform you about how the ActiValues, whose entities may act as data controllers or processors, collect and processes your personal data(“Personal Data”) that you submit or disclose to us, in the case where the General Data Protection Regulation (“GDPR”) applies to such collection or processing.

ActiValues routinely collects, uses, stores and transfers a variety of data, including Personal Data. ActiValues is committed to ensure the privacy of Personal Data throughout its global business, and make sure its employees and business partners also take the necessary measures to protect Personal Data.

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

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

1. Personal Data

This refers to a combination of personal data such as your name, address, telephone number, email address, travel preference and special needs/disabilities/dietary requirements that you supply us or is supplied to us, including your social preference, activities and any information about other persons you represent such as those on your booking and conversations through our chatbot and/or other services. Your personal data is collected when you contact us, make a booking, use our website(s)/apps, link to or from our website(s)/apps, connect with us via social media and any other engagement we or our business partner have with you.

2. Processing of your Personal Data

Data processes

We may collect and process your Personal Data for the purposes set out below and disclose your Personal Data to the ActiValues for business purposes and also to our service providers who act as ‘controller’ or ‘processor’ on our behalf.

These purposes include

a. Fulfilling the contract with you and legal obligations (Articles 6(1)(b) and (c) of the GDPR):

To confirm a person’s identity (including biometric identification) when we provide you with services of making room reservations for accommodation, seat reservations for transportation, and purchasing goods. We need to provide service providers with your name, passport number, contact details, and other related information in accordance with their terms and conditions. If you do not provide us with this Personal Data, we might not be able to offer our services to you.

b. Fulfilling your and our legitimate interests (Article 6(1)(f) of the GDPR):

Where it is in both your and our benefit that we further process your Personal Data as part of our business administration, maintaining service quality, customer care, business management, risk assessment/management, security, and operation purposes.

c. Consent:

For marketing purposes and other similar data processes that may require your authorization for their processing (Article 6(1)(a) of the GDPR). We will usually inform you before collecting your data if we intend to use your data for such purposes or if we intend to disclose your Personal Data to any third party for such purposes.

d. Explicit consent (Article 9(2)(a) of the GDPR):

Information such as health or religion may be considered ‘sensitive personal data’ under the GDPR. This Personal Data might include information necessary to arrange bookings and travel plans, including your allergies, disabilities, and other relevant health information. We collect it to provide you with our services, cater to your needs or act in your interest, and we are only prepared to accept sensitive Personal Data on the condition that we have your positive consent.

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

Links to other websites

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

Data transfers

There are cases when ActiValues may transfer personal data to countries outside of the EEA. This includes transfer to third parties (to conduct data processing) such as entities of the cloud service vendors, and service management companies. In these cases, third parties are supervised to ensure that they provide an appropriate level of protection in accordance with the GDPR when handling personal data.

Service providers

For the purpose of providing you with our services, including reservation services of accommodations, tourist attractions, restaurant, transportation, etc., we may disclose and process your Personal Data outside of the EEA countries.

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.

By using the ActiValues’s services you agree to the following:

a. In the event that countries outside of the EEA do not have adequate Personal Data protection laws, the same level of protection established by the GDPR cannot be guaranteed.

b. To achieve the ActiValues’s use objectives, Personal Data may be transferred to third parties (to conduct data processing), such as cloud service vendors, and service management companies located in countries outside of the EEA. “

3. Our Records of Data Processes

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

4. Security Measures

We process your Personal Data in a manner that ensures their appropriate security, including protection against unauthorized or unlawful processing, accidental loss, destruction or damage. We use appropriate technical or organizational 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.

5. Notification of Data Breaches to the Competent Supervisory Authorities

In case of breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized 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).

6. 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 organizational 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).

7. Your Rights

You have the following rights:

Access to personal data: You have the right to be provided full information about your Personal Data that we hold.

Data correction: You have the right to require that we correct any incorrect information we hold about you.

Data deletion: You may also have the right to ask that we delete your personal data. Please note that certain conditions may apply to the exercise of this right.

Restriction on processing of personal data: You may have the right to ask that we restrict the use of your personal data. Please note that certain conditions may 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.

To exercise your rights, make any complaints, or if you require further information about how your personal data is used by us, you can contact us

8. 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.

9. Contact

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


1-30-14 Yoyogi, Shibuya-ku, Tokyo 151-0053 Japan


10. About Cookie

a. ActiValues may use cookies in order to provide information that is easily accessible by, and valuable to users. Cookies allow data to be temporarily saved on a computer or other devices used by a customer when using our services. Using cookies enables us to acquire and save in ActiValues’s server the customers’ activity history on ActiValues’ services (including, but not limited to, Chatbots, accommodation reservation system, and FAQ system), and unidentifiable attribute information such as travel preference, conversation records, language setting, and location information.

If you prefer not to allow us to collect your information, you can block cookies by modifying your internet browser preferences, but as a result some or all of the website services may become unusable. Please contact your software manufacturer for instructions on how to change your browser settings.

b. ActiValues uses advertisement delivery services provided by third parties. In providing advertisement delivery services, such third parties may collect and use the information of users’ access history to the ActiValues’s website or activity history by using cookies.

Cookies and other information acquired by such third parties will be handled in accordance with the ActiValues’s privacy policy.

Users may discontinue advertisement delivery performed by such third parties using cookies by accessing an opt-out page on the third party’s website.