Rakuten Travel Privacy Policy

1. What This Policy Covers
2. The Information We Collect
3. Use of Your Information
4. Retention
5. Disclosure of Information about You
6. Personal Referable Information
7. Your Rights and Choices
8. Updating Your Information
9. Information Security
10. International Transfers
11. Changes to this Privacy Policy
12. Contact Us

1. What This Policy Covers

Rakuten Travel (hereinafter, the "Services") is operated by Rakuten Travel Singapore Pte. Ltd. and provides travel services to customers together with Rakuten Group, Inc. and Rakuten Travel Services, Inc. (hereinafter collectively referred to using "us", "we", and "our").
Here are our details:
Rakuten Travel Singapore Pte. Ltd. (Singapore), a Singapore company with its registered address at 138 Market Street, #32-01, Capita Green, Singapore 048946. (Director Yoshiyuki Takano, Bek Jeremy, Munekatsu Ota)
Rakuten Group, Inc. (Japan) See details in this page
Rakuten Travel Service, Inc. (Japan), a Japanese company with its registered address at rakuten crimson house, 1-14-1 tamagawa, setagaya-ku, tokyo 158-009. (Director Yoshiyuki Takano)

When you make use of the Services, we collect, use, and store your information. This Privacy Policy (hereinafter referred to as this "Policy") was established by us as a means to explain our reasons for, and methods of, acquiring your personal information when providing you with the Services, as well as to deepen your understanding of the rights you hold with regards to your personal information.

2. The Information We Collect

For the purposes stated in Section 3 (“Use and Retention of Your Information”), we collect information about you as described in this Section 2. This includes information that you give us directly, information about your use of the Services, and information received from third parties.

Please note that we provide the Services as a corporate entity of Rakuten Group, Inc. and its affiliated companies (hereinafter collectively referred to as the "Rakuten Group"). When using the Services, you will be required to log in with your Rakuten ID, the universal ID program provided by the Rakuten Group. Personal information connected to your Rakuten ID is shared with us in accordance with the provisions set forth in the Rakuten ID Privacy Policy, and we handle this information for the express purpose of providing the Services.

2-1. Your log-in information

Identifiers: Your name and email address

2-2. Information related to your use of the Services

Identifiers, protected characteristics, commercial information, Internet or other electronic network activity information:

• Personal information provided by you, including your gender, age, date of birth, phone number, and address
• Information relating to your use of reward points, coupons, cashbacks and other incentives provided to you as part of the loyalty program when using Rakuten Group services (“the Membership Service”)
• Information relating to your use of the Services (including activities such as page viewing and comment posting), or to the transactions you make using the Services, such as purchases or subscriptions (including the payment methods you use)

2-3. Payment information and information used for personal identification

Financial, medical, or health insurance information:

• Information relating to payment settlements, such as credit card information, bank account information, and e-money related account information
• Documents that we are required by applicable law to collect in order to authenticate your identity (such as your driver’s license, health insurance certificate or certificate of residence), and the information included therein
• Health information as required to accommodate your travel arrangements; as well as information on your travel insurance, including medical travel insurance

2-4. Device information and information obtained using Cookie Technologies

Internet or other electronic network activity information, geolocation data:

When you use the Membership Service or the Services, interact with any content or advertising related to such services, or validate any cookies, web beacons, unique identifiers and other related technologies (collectively, the “Cookie Technologies”) that we employ, we automatically collect certain information about you and the device you are using.

Such information may include:

• Device ID or other information that allows us to identify the device you are using;
• Operating system and internet connection related information;
• Geo-location information;
• Referring URL;
• IP Address;
• URLs viewed and time stamp of time viewed
• Server log information other than the above
• Information related to products and services displayed and searched

In this service, we will use Cookie Technologies to acquire the user's site browsing history etc. as outlined in Rakuten Travel's cookie policy.

2-5. Information we collect from other sources

Identifiers, protected characteristics, commercial information, internet or other electronic network activity information:

During your use of the Membership Service and the Services, we may request, collect and store your information from publicly available sources and third parties, such as your credit score information and information necessary for fraud prevention and detection, as may be necessary from time to time and as permitted under applicable law. In addition, based on your separate consent, we may receive other personal information about you from third party sources.

2-6. Sensitive information

Unless necessary for the purpose of providing you with the service in question or for another legally permissible reason, during your use of the Services or the Membership Service, we do not intentionally collect or use information of yours that may be considered sensitive, such as information relating to your race, religion, social status, medical or criminal history, or whether you were a victim of a crime (together, “Sensitive Information”). In the event that you voluntarily give your Sensitive Information to us and with your express consent, we will treat such information as information related to your use of the Services (2-2) and process it in accordance with this Policy.

2-7. Inferences regarding preferences or other characteristics

We may infer your preferences or other characteristics from the information we collected above.

3. Use of Your Information

We use your personal information to provide you with the single log-in function as part of Rakuten ID, the Services and the Membership Service, and advertising and marketing content in accordance with your interests and preferences; to conduct research and development, to respond to customer inquiries, and to prevent and mitigate fraudulent or illegal activities.

3-1. Use of Your Information

Specifically, we may use your information for the purposes listed below:

3-1-1. To provide you with the Services:

• To enable your use of the Membership Service and the Services
• To provide you with the necessary support during your travels
• For the provision of personalized services, content, and information related to the Membership Service and the Services
• For the provision of incentive programs relating to the Membership Service, such as reward points, coupons and cashback rewards

3-1-2. To provide you with advertisements, promotion and marketing content:

• To display or send to you advertising content, such as direct mail or email newsletters, with your consent, or as otherwise permitted under applicable law
• For the display, introduction, or advertisement of products and services offered by us, other Rakuten Group companies and our third party partners on our websites or on other advertising media that we manage or operate
  ※We may analyse the information we collected above in “2. The Information We Collect” (including but not limited to the profile information and information related to your use of the Services) using artificial intelligence. This analysis may include your past or current information, and it may also be conducted by combining your information with other individuals’ information (personal, aggregated or inferences). We may infer your preferences, purchase trends, profile and credibility, and provide you with marketing contents and display advertising based on such analysis and inferences.

3-1-3. To undertake service improvement, research and development:

• To improve existing services and conduct R&D for the development of new services
  ※we may conduct analysis for service improvement and R&D activities using your information collected in Section 2 (“The Information We Collect” (profile information and information related to your use of the Membership Service and the Services)).

3-1-4. To respond appropriately to customer inquiries:

• So that we may respond appropriately to customer inquiries, complaints, or requests in relation to our services and advertisements
• After your use of Membership Service or Services, to provide you with aftercare by appropriately responding to your inquiries related to the relevant Services

3-1-5. To prevent and mitigate fraudulent or illegal activities:

• For the prevention, identification and investigation of scams, cyber-attacks, and other potentially illegal or fraudulent activities, or in relation to any other activities necessary to protect the legal rights of the Rakuten Group and/or the rights of third parties ※we may conduct analysis on your credibility etc. using your information collected in Section 2 (“The Information We Collect” (information related to your use of the Membership Service and the Services)), and provide the results of such analysis or inferences to third parties.

3-1-6. To respond to the occurrence of an emergency situation:

• To ensure your safety in the event of an emergency situation such as a natural disaster, armed conflict, riot, etc.

3-1-7. To provide your personal information to third parties:

• To provide your personal information to third parties in accordance with Section 5 (“Disclosure of Information about You”)

4. Retention of Your Information

We will keep your personal information necessary to fulfil our contractual obligations for as long as we have a relationship with you, and for a period of 10 years thereafter.

We will only retain your personal information after this time if we are required to do so to comply with the applicable laws, or if there are outstanding claims or complaints that will reasonably require your personal information to be retained.

5. Disclosure of Information about You

5-1. Disclosure within the Rakuten Group

In order for the Rakuten Group to develop and provide you with ever more unique and attractive services, it is essential that the Rakuten Group companies are able to share information with one another.

Your personal information that we have acquired in accordance with Section 2 (“The Information We Collect”) will be shared by Rakuten Travel Singapore Pte. Ltd. (see details in Section 1 (“What This Policy Covers”) as the person in charge of management for the purposes specified in Section 3 (“Use of Your Information”)

In addition, we may disclose your personal information to other Rakuten Group companies that support Rakuten ID, including those located in countries other than the country you are located in (for details about the countries to which we share personal information, please refer to this page). These companies may access and use your information as set forth in the table below:

5-1-1 Disclosure of service usage information to other Rakuten Group companies when you use multiple Rakuten services

Types of Information

・Your log-in information (identifiers) (2-1);
・Information related to your use of the Services (identifiers, protected characteristics, commercial information, internet or other electronic network activity information) (2-2);
・Payment information and information used for personal identification (financial, medical, or health insurance information) (2-3); and
・Device information and information obtained using Cookie Technologies (internet or other electronic network activity information, geolocation data) (2-4)

Purpose of Use

・To provide you with the services (3-1) including the Rakuten ID program (3-1) as further stated in our Rakuten ID Privacy Policy;
・To respond appropriately to customer inquiries (3-5); and
・For the purposes of use are the provision of the requested service by the Other Rakuten Group Company and any other purpose described in the privacy policy of the Other Rakuten Group Company providing the service.

5-1-2 Disclosure and use of information by Rakuten Group companies that oversee R&D operations

Types of Information

・Your log-in information (identifiers) (2-1);
・Information related to your use of the Services (identifiers, protected characteristics, commercial information, internet or other electronic network activity information) (2-2); and
・Device information and information obtained using Cookie Technologies (internet or other electronic network activity information, geolocation data) (2-4)

Purpose of Use

To undertake service improvement, research and development (3-1-3)

5-2. Access by Hotels and Venues

When you use the Services, we will disclose some of your personal information to the property with which you have effected a transaction, as well as to any other corporate entities that will be providing services subject to said transaction (including entities in countries other than your country of residence; for example, hotels and venues that you reserve your stay; hereinafter collectively referred to as "Hotels and Venues "); this information is disclosed only to the extent necessary to complete said transaction, the scope of which includes the reservation application and usage procedures of the Services, contact and responses to you the customer, and proposals and offers pertinent to the transaction. In this case, the scope of personal information that can be accessed by the Hotels and Venues shall be limited to those listed in Section 2 ("The Information We Collect").

Personal information provided for the purpose of effecting transactions between you and Hotels and Venues is managed by the Hotels and Venues. In addition to completing the transaction you have requested, Hotels and Venues may use your personal information for the purposes of providing you with information via email newsletters after the transaction, analyzing your purchases and use of their services, or for the improvement of their own business operations.

Please exercise caution when disclosing any information to the Hotels and Venues as any information which you disclose directly to the Hotels and Venues will not be governed by this Policy. Any such disclosure will be subject to the privacy notices that they provide.

5-3. Disclosure to Other Third Parties

In addition to the disclosures described above, we may also disclose your personal information to certain trusted third parties, including those located in countries other than where you are located, where necessary to carry out our business operations.

Please be assured that we will only disclose your personal information in compliance with the applicable law, and with the appropriate management and supervision of the relevant third parties.

On occasion, judicial or regulatory authorities may request access to or disclosure of information about you for law enforcement purposes. Such requests typically pertain to criminal investigations or other legal proceedings. Where they are necessary and legitimate, we will respond to such requests in accordance with our internal policies and applicable law.

Additionally, in cases where it is necessary to prevent and mitigate fraudulent or illegal activities (3-1-5), to respond to the occurrence of an emergency situation (3-1-6), or to protect life, body, or property, we may disclose your personal information to another Rakuten Group company or to a third party.

Furthermore, we may share your personal information with any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this Policy.

We will not use or disclose your information in Section 2 (“The Information We Collect”) for purposes not set forth in this Policy or in excess of the minimum necessity in order to achieve the purpose of the disclosure, without informing you and taking any necessary steps in advance as required under applicable law.

5-4. Personal Information Matching Analysis and How We Use it to Display Advertisements

We conduct analysis by matching your personal information and information we got entrusted from third parties (Rakuten Group companies and partners that have concluded contracts with us). For example, we may receive your personal information such as advertising identifier, and by matching it to other personal information including advertising identifiers that we manage, we are able to display advertisements more customized for you. Also, we may conduct matching analysis of your personal information and other personal information we manage, aggregate the result of such analysis in a way it cannot identify individuals, and provide such aggregated results to third parties so that the third parties can use the results for their service improvement and R&D etc.

Furthermore, we may provide your personal information that we manage to third parties (partners that have concluded advertising service agreements with us [※]) in order to display advertising. For instance, we may provide your personal information we manage such as advertising identifiers to third parties, so that the third party may match and analyze its personal information with the information they receive from us and provide you with customized advertising. In such case, the third party uses your personal information for displaying advertising as instructed from us.

※For more information on advertising partners’ list and countries that these partners are located, please refer to this page.

6. Personal Referable Information

We may receive information related to you (Personal Referable Information) such as identifiers and behavioral history from entities that do not have information to identify you. Such information may be matched with your personal information that we manage and used for the purposes stated in Section 3-1 (“Use of Your Information”) unless otherwise specified. More specifically, we collect the information listed below as Personal Referable Information. For any other types of information collected, we will ask your consent separately.

7. Your Rights and Choices

7-1. Your Rights

You may have certain rights regarding your personal information, subject to the applicable law. These may include the following rights to:

• access your personal information: you can request access the information about your personal information, such as the categories, the purposes of the processing or any other information required under the applicable law;
• rectify your personal information: you can rectify inaccurate personal information concerning you;
• erase your personal information: you can ask us to erase your personal information we have collected;
• restrict our use of your personal information;
• object to our use of your personal information: you can object to certain types of our processing of your personal information depending on the circumstances, such as profiling or any other processing required under the applicable law;
• data portability: receive your personal information in a usable electronic format and transmit it to an external party;
• learn more about the sources from which we collect information, the purposes for which we collect and share information, the information we hold, and the categories of parties with whom we share your information;
• opt out of “sales”: for California residents, opt out of certain disclosures of personal information that California law defines as “sales” even if no money is exchanged (you may exercise that right here: Do Not Sell My Personal Information). We may “sell” your personal information in accordance with the following provisions:
  • Disclosure and use of information by Rakuten Group companies that oversee R&D operations (5-1-2)
  • Disclosure to Other Third Parties (5-3); and
  • Our Cookie Policy
  Where you intentionally direct us to do so, where we share your personal information for a business purpose or where any other circumstances permitted by the applicable law exist, such disclosures may not be considered as “sales.” We do not “sell” personal information of minors under 16 years of age without affirmative authorization;
• be free from discrimination: You can freely exercise these rights without fear of being denied goods or services.; and
• lodge a complaint: you can lodge a complaint to the Global Privacy Manager of the Rakuten Group or a data protection authority in accordance with the Rakuten Group's BCRs (https://corp.rakuten.co.jp/privacy/en/bcr.html).

If you would like to ask about or exercise such rights, please contact us in accordance with Section 12(“Contact Us”). You may use an authorized agent to exercise your rights in accordance with the applicable law. In that case, please ensure that you give the written permission to the agent.

Once we receive the request, we will verify your identity based on your personal information that we already have and that we may additionally require from you for the verification purpose.

Please note that we may also require additional information from you in order to respond your request appropriately.

We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate.

Please also note that your rights are not absolute, and there are some grounds where we may decline your request as permitted under the applicable law.

7-2. Your Choices

As a principle, you will have a choice whether to provide information to us. However, where you have a choice and decide not to provide us with certain information, you may not be able to make use or take advantage of all the features provided by the Services. You may also be unable to receive certain information that may otherwise benefit you, such as notifications of campaigns or promotions.

You can change your preferences for receiving promotional email and your preferred contact methods at any time by following the relevant instructions on our websites.

8. Updating Your Information

We want to do all we can to keep your personal information accurately recorded in our system. To this end, we endeavor to provide you with easy access to your information. You are able to view, modify and remove most of the information that you have given to us through your Account management page. Please remember to update information about yourself that has become inaccurate or outdated.

If you would like to access your information in written form, or through a means other than your Account management page, please contact us via the method described in Section 12 (“Contact Us”). Subject to applicable law and depending on the scope of the inquiry, fees may apply. In some cases, depending on the nature of the information and how it is stored, it may not be possible for us to fulfill your request.

9. Information Security

We are committed to handing your personal information in accordance with high security standards and in compliance with applicable law. We do so in order to prevent unauthorized access or unauthorized disclosure of your information, to maintain the accuracy of such information and, when necessary, to ensure its proper destruction. When collecting or transferring your personal information, we employ data encryption technology, and restrict access only to those persons who require it to fulfil their job responsibilities. We conduct periodic reviews of our practices to ensure that our safeguards are properly implemented and remain state of the art.

In order to maintain the security of your Account it is essential that you take adequate measures to protect your password. You should not use the same password that you use for other services, and you should never share your password with anyone. Please treat any email or other communication requesting your password as unauthorized and suspicious and forward the communication to us, using the contact method provided in Section 12 (“Contact Us”).

If you do share your password with a third party for any reason, including when the third party has promised to provide you additional services such as account aggregation, the third party will have access to your Account and your personal information. In such cases, to the extent that the liability is not attributable to us, we are not liable for any losses or damages that you may incur as a result of activities that take place on your Account. If you believe someone else has obtained unauthorized access to your password, please change it and contact us immediately.

Please refer to this page for more details about our security practices.

10. International Transfers

Because of the global nature of our business, the information that we collect from you may be transferred to countries whose data protection laws are not as comprehensive as those from where you are based. The countries that we may transfer your personal information to includes, but is not limited to Singapore, Japan, Taiwan, Korea and Hong Kong. When transferring personal information globally, we research the data protection regulations in the destination countries and regions, and we have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details in accordance with Section 12 (“Contact Us”). For global data processing within Rakuten Group, we put in place adequate measures including Binding Corporate Rules we implemented, a recognized European data protection standard. Binding Corporate Rules (the “BCRs”) provide for an appropriate level of protection. Our rules have been approved by the relevant European Union Authorities and these are also a strong commitment to protect your privacy around the world. Rakuten Group's BCRs are available here: https://corp.rakuten.co.jp/privacy/en/bcr.html

11. Changes to this Privacy Policy

From time to time, in order to comply with changes in applicable laws or for legitimate business purposes, we may make changes to this Policy. Any changes we make will be displayed on this page. Please check back from time to time to ensure that you have read the most recent version of this Policy.