1. Controller information

Controller: TOMOTOMO LLC

Representative: Tomoko Yanata

Address: 575-4 Amamizushima, Matsunoyama, Tokamachi, Niigata 942-1424, Japan

Email: info@amamizushima.com

Lodging business: Private Lodging Business Act, Notification No. M150062846 (Governor of Niigata).

2. Information we collect

[Reservation & stay]

Name, address, nationality, phone, email, reservation details, dates, party size, payment information, enquiry content, guest information provided by OTAs such as Booking.com and Airbnb, ID documents (at check-in).

[Site usage]

IP address, User-Agent, referrer, cookie / localStorage identifiers, access logs, language preference, screen size, time zone, time on site.

3. Purposes of use

• Processing and managing reservations

• Identity verification

• Provision of lodging services

• Check-in and check-out

• Responding to enquiries

• Emergency contact

• Statutory creation and retention of the guest register

• Fraud prevention

• Security

• Site improvement (only where consent is given)

4. Legal bases under GDPR / UK GDPR

• Reservation management: performance of a contract (GDPR Art. 6(1)(b))

• Enquiry handling: pre-contractual steps / legitimate interests (Art. 6(1)(b) / (f))

• Guest register: legal obligation (Art. 6(1)(c)) — Japan Private Lodging Business Act

• Security logs: legitimate interests (Art. 6(1)(f))

• Analytics: consent (Art. 6(1)(a))

• Language preference storage: legitimate interests (Art. 6(1)(f))

5. Cookies and localStorage

This site uses:

• amami_lang: language preference (set on user action, 6 months)

• amami_consent: consent state (12 months)

• amami_sid: analytics session ID (only after consent, browser session)

Users in the EU / UK are shown a consent banner on first visit. Consent can be withdrawn at any time via the “Cookie settings” link.

6. Third parties and processors

• Cloudflare Inc. (United States): hosting, analytics storage (data processing agreement in place)

• Booking.com B.V. (Netherlands): reservation management

• Airbnb Ireland UC (Ireland): reservation management

• PayPal Pte. Ltd. (Singapore): payment processing

Other than the above, we do not share your data with third parties without your consent, except where required by law or to protect a person’s life or safety.

7. International transfers

The processors listed above may process data outside Japan (in the United States, Netherlands, Ireland, Singapore, etc.). Transfers from the EU / UK are covered by GDPR Article 46 Standard Contractual Clauses (SCCs) or equivalent safeguards.

8. Retention periods

• Guest register: 3 years (statutory under the Private Lodging Business Act)

• Reservation, billing and incident records: 7 years

• Enquiry content: 3 years

• Analytics data: 13 months

• Security logs (IP, etc.): 90 days

• Consent logs: 24 months

Data is deleted promptly once the retention period has elapsed.

9. Your rights

For data subjects under GDPR / UK GDPR:

• Right of access (Art. 15)

• Right to rectification (Art. 16)

• Right to erasure / “right to be forgotten” (Art. 17)

• Right to restriction of processing (Art. 18)

• Right to data portability (Art. 20)

• Right to object (Art. 21)

• Right to withdraw consent (Art. 7(3))

• Right to lodge a complaint with a supervisory authority (Art. 77)

For users in Japan (Act on the Protection of Personal Information):

• Right of disclosure

• Right of correction, addition, or deletion

• Right to demand suspension of use

• Complaints: Personal Information Protection Commission (https://www.ppc.go.jp/)

For users in Hong Kong (PDPO):

• Data access request

• Data correction request

To exercise these rights, please email info@amamizushima.com.

10. Security

We use HTTPS encryption in transit, minimised storage, restricted administrator access, log management, and regular security reviews.

11. Contact and complaints

Enquiries, rights requests and complaints:

TOMOTOMO LLC

575-4 Amamizushima, Matsunoyama, Tokamachi, Niigata 942-1424, Japan

Email: info@amamizushima.com

Phone: +81-90-3231-8088

We may update this policy without prior notice. Material changes will be announced on this page.

12. Notation under the Specified Commercial Transactions Act (Japan)

[Seller] TOMOTOMO LLC

[Representative] Tomoko Yanata

[Address] 575-4 Amamizushima, Matsunoyama, Tokamachi, Niigata 942-1434, Japan

[Phone] +81-90-3231-8088 (09:00-20:00 JST)

[Email] info@amamizushima.com

[Service] Whole-house private lodging "Amamizushima Hills" (Private Lodging Business Notification No. M150062846, Governor of Niigata)

[Price] ¥28,000-¥40,000 per night (tax included). Varies by season/day; total tax-included price is shown on the booking quote.

[Other charges] Linen ¥1,500 per guest (not required if you bring your own). Pet fee (heads × nights). No consumption tax surcharge; no payment processing fee.

[Payment methods] Credit card (Visa / Mastercard / American Express / JCB / Diners) via Stripe Checkout.

[Payment timing] Charged immediately upon booking confirmation.

[Service period] From check-in (16:00) on the reserved date to check-out (11:00).

[Cancellation] Up to 3 days before: free. 2 days to 1 day before: 50% of room charge. Same-day, including no-show: 100%.

[Equipment failure] In case of equipment failure rendering the stay impossible (as judged by us), full refund (processed via Stripe for Stripe payments).

[Operating environment] Modern HTTPS browser (Chrome / Safari / Edge / Firefox).

[Other] Under the Private Lodging Business Act, annual operating days are capped at 180. Identification documents must be presented at check-in.