1. Basic Policy

ANA NEO, Inc. (hereinafter, “we”, “our” or “us”) will handle personal information in compliance with the "Act on the Protection of Personal Information" of Japan (hereinafter, "the Personal Information Protection Act") and other personal information and privacy protection laws, and relevant cabinet orders, ministerial ordinances and guidelines, etc. of Japan.

2. Acquisition of Personal Information

We will acquire personal information by appropriate means and within the scope necessary after first specifying the purpose of use of such information.

3. Purpose of Use of Personal Information

We will use personal information only within the scope of the following purposes of use and the purposes of use separately notified or announced, except when permitted by law. And we will not use customers’ personal information in a way that may encourage or induce illegal or improper conduct, even within the scope of its purpose of use.

• To provide information about our services/products, and to provide and manage such services/products;
• To develop new services/products;
• To respond to inquiries and requests, etc.; and
• (4) For all other operations incidental or related to the purposes listed in items (1) through (3) above.
  *In addition to the above purposes, personal information will be utilized for the purposes described in “6. Personal Information Data Sharing” below.

4. Personal Information to be Acquired

• Information acquired in connection with use of our services and products
  Name, e-mail address, payment information, ANA Mileage Club membership number, etc.
• IT system data including details of usage of our website
  Information about how the customer has used our website, services and products, including cookies and website activity logs, etc.
• Contents of inquiries and opinions
  Information contained in communications with the customer, and the contents of customer inquiries, requests and opinions (including their causes and solutions), etc.

We will never acquire and use information of a sensitive nature to the customer (hereinafter, "Sensitive Information”), such as information on race, creed, social standing, medical history, criminal record, and history of having been a victim of crime, etc., unless stipulated by laws and regulations or with the consent of the customer.

5. Disclosure to Third Parties

We will not disclose or provide customers’ personal information to any third parties except under the following circumstances. Note that provision of information to data sharing partners and business entrusted companies is not deemed to constitute disclosure or provision to third parties.

• With the content of the customer;
• Disclosure or provision is required within the scope allowed by laws or regulations;
• Disclosure is required to protect human life, health or property, and it is difficult to obtain the consent of the customer;
• Disclosure is required to cooperate with the public affairs of national or local governments, etc., and obtaining the consent of the customer is likely to hinder the administration of such public affairs;
• Disclosure or provision of information as statistical data (in a format whereby the customer cannot be identified); or
• Provision of information as a result of the succession of business due to a merger, company split, transfer of business or otherwise.

6. Personal Information Data Sharing

We may share customers’ personal information within the following scope and for the following purposes.

Scope of data sharing partners	ANA Group companies
Purpose of use by the user	For provision of air transportation services, travel services including tours and hotels, and other products/services handled by ANA NEO or our data sharing partners; For sending of direct mail and information on products/services, and distribution of questionnaire(s) to customers, etc. by ANA NEO or our data sharing partners; For sales analysis, other research/studies, and development of new products/services, etc. by ANA NEO or our data sharing partners; For delivery and transfer of data to the company in charge when inquiries, applications for use or other offers regarding products/services provided by ANA NEO or our data sharing partners have been received from customers; For appropriate and smooth fulfillment of other transactions with customers by ANA NEO or our data sharing partners; and For business management/internal management by the ANA Group.
Items of personal information to be shared	Name, e-mail address, payment information, ANA Mileage Club membership number, etc., information about how the customer has used our website, services and products, including cookies and website activity logs, etc., information contained in communications with the customer, and the contents of customer inquiries, requests and opinions, etc.
Name, address and representative of the party responsible for management of personal information	ANA Holdings Inc. Shiodome City Center, 1-5-2 Higashi-Shimbashi Minato-ku, Tokyo, Japan 105-7140 Koji Shibata, President & Chief Executive Officer

7. Handling of Entrustment

We may entrust the handling of personal information to third parties. In this case, we will thoroughly examine the third party's eligibility as a contractor and take measures to supervise the contractor as necessary and appropriate such as by establishing matters relating to the duty of confidentiality in the contract concluded with the contractor.

8. Transfer to Outside of Japan

If we provide customers’ personal information to third parties such as business operators outside of Japan, including entrusted companies and our data sharing partners, we will do so based on the customer’s consent, except in either of the following cases.

• The third party is located in a country specified by laws and regulations as one that has a personal information protection system equivalent to Japan’s; or
• The third party has a system in place where it can continuously take measures corresponding to those that business operators handling personal information in Japan should take.

In the case of (2) above, we will take necessary and appropriate measures to ensure that the third party takes the corresponding measures on an ongoing basis.

9. Management of Personal Information

We ensure that our employees carefully manage customers' personal information to the strictest standards, and we take necessary security
management measures to prevent the leakage, loss, alteration of, or unauthorized access to personal information. And we will establish an appropriate retention period for personal information in accordance with its purpose of use, and will dispose of the information in question by appropriate methods after its purpose of use has been achieved.

10. Requests about the Handling of Personal Information

• If we have received a request from a customer for disclosure, correction, deletion, addition, discontinuance of use, erasure, or provision of information concerning personal information protection measures (the contents of our security management measures and measures taken when customer information is provided to third parties outside of Japan) (hereinafter collectively referred to as request for "Disclosure, etc.") with regard to the personal information of the customer that we retain, then we will promptly handle that request according to the laws and regulations within a reasonable timeframe and scope, after confirming that the request was submitted by the customer themselves or their agent.
• We may not be able to fulfill customers’ requests if compliance with such requests would seriously hinder our normal business operations, or may be in violation of laws and regulations, or may hinder the security management of personal information.
• Please direct requests for Disclosure, etc. and inquiries toinfo@ana-neo.com

11. Modification of the Privacy Policy

We may make modifications to this Privacy Policy. If modifications are made, details will be posted on our website(https://www.ana-neo.com/en/), so please confirm the revised contents.

Established May 14, 2021
Revised April 1, 2022