GDPR Privacy Policy


The protection of your personal data is of great importance to ADDA TOURS JAPAN co., ltd (hereinafter ‘ADDA TOURS’). This Privacy Policy therefore intends to inform you about how we, whose entities may act as data controllers or processors, collect and processes your 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.


We routinely collects, uses, stores and transfers a variety of data, including Personal Data. We commit to ensure the privacy of Personal Data throughout its global business, and to 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 for 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, and your customer experience may be impacted.


1. Your Personal Data


This refers to a combination of personal data such as your name, address, telephone number, credit card 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. 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 partners 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 us for business purposes and also to our service providers who act as ‘controller’ or ‘processor’ on our behalf.  These purposes include:


1.  Fulfilling the contract with you and legal obligations (Articles 6(1)(b) and (c) of the GDPR: In order for you to travel abroad, it may be mandatory as required by government authorities at the point of departure and/or destination to disclose and process your personal data for immigration, border control and/or any other purposes. Also we need to provide airlines/accommodation 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.

2.  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.

3.  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.

4.  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.




Our products and services are intended for adult customers.  However, we may knowingly collect and process personal data on children under sixteen.  On these occasions, we will take account of this event when processing the personal data of children and implementing the legal basis for such processing.  For example, where the processing of personal data of children is based on their consent such as the processing of his/her sensitive personal data, we will seek the consent of parents, tutors, or other adults holding parental responsibility over children, if required under the GDPR.


Links to other sites


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




When we process your personal data, we will store it in our systems located within the European Economic Area (EEA), which comprises the Member States of the EU, Norway, Iceland and Lichtenstein, as well as outside the EEA.  In the event of a merger, reorganization, acquisition, joint venture, assignment, spin-off, transfer, or sale or disposition of all or any portion of our business, including in connection with any bankruptcy or similar proceedings, we may transfer any and all personal data to the relevant third party.


Your data may also be processed by staffs operating outside the EEA who work for us or for one of our suppliers (e.g., travel guides, transportation services, accomodation services). Such staffs may be engaged in, among other things, the provision of support services.


Service providers


For the purpose of providing you with our services, including your booking of flight, booking of accomodation, security, incident/accident management etc., we may disclose and process your personal data outside of the EEA countries. In order for you to travel abroad, it may be mandatory as required by government authorities at the point of departure and/or destination to disclose and process your data for immigration, border control and/or any other purposes. Also, we need to provide airlines/accommodation providers with your name, passport number, contact details, etc. in accordance with their terms and conditions.


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.


Safeguards to protect your personal data


Where we share your data with a data processor, we will put the appropriate legal framework in place in order to cover such transfer and processing (Articles 26, 28 and 29 GDPR).  Furthermore, where we transfer your data from EEA to any entity outside the EEA, we will put appropriate legal frameworks in place, notably Binding Corporate Rules (Article 47 GDPR), controller-to-controller (2004/915/EC) and controller-to-processor (2010/87/EU) Standard Contract Clauses approved by the European Commission, in order to cover such transfers (Articles 44 ff. GDPR), or we will share your data based on rules of the GDPR.


By submitting your personal data, you agree to this transfer, storing or processing, we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, in particular, by adopting Binding Corporate Rules and Standard Contract Clauses where possible.


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 on 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 unauthorised or unlawful processing, accidental loss, destruction or damage.  We use appropriate technical or organisational 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 the 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 the 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.

You also have the right to obtain from us a copy of the Binding Corporate Rules or of any Standard Contract Clauses that we use if we transfer your personal data outside the EEA and take such arrangements.


To exercise your rights, or if you require further information about how your personal data is used by us, you can contact the staff member in charge of your travel or write to us at: rsv@adda-tours.co.jp.


Following is the procedure when you want to execute these rights;


Upon receiving your request, we will contact you to confirm the request is being handled, and we will indicate the reasonable timeframe for us to respond.

Our team will make an initial assessment of the request to decide whether it is a valid request and whether confirmation of identity is required.

If no further action from you is required, we will proceed with the processing of your request.

At the end of our assessment and internal procedure, we will provide a confirmation as to our compliance or processing of your request.

For any unfounded or excessive (e.g., further repeated) requests, we may charge a reasonable fee based on administrative costs.


8. When you want to complain about your personal data


We have appointed appropriate staffs with management support to oversee and ensure compliance with the GDPR.


You can bring complaints in writing by contacting the staff member in charge of your travel or our data protection staffs at rsv@adda-tours.co.jp.


After receiving the complaint, our data protection staffs will send an acknowledgement of receipt within one week to you. The confirmation may include further questions necessary for the clarification of the issues. Our data protection staffs will provide an answer to you as soon as reasonably practicable, but no later than one month upon receiving the complaint. If, due to complexity of the complaint, a substantive response within one month cannot be provided, you will be notified with a reasonable estimate of the timeframe, but not exceeding two months from the notice.


You may also raise the complaint to the relevant Data Protection Authority or lodge a claim with a court of competent jurisdiction.


9. 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.


10. Contact


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




Tohmi bldg 6F, 2-16-5 Nihombashi-hamacho

Chuo-ku Tokyo

JAPAN 103-0007

Email: rsv@adda-tours.co.jp


11. About Cookies


We use cookie information to provide better services, secure security, analyze and distribute appropriate advertisements to customers. Third-party companies may distribute advertisements or obtain behavioral information for the purpose of advertising their company. Third-party companies use cookies only for advertisement distribution purposes and acquire information. If you wish to invalidate this function, please disable (opt out) from the site of the corresponding company below.


If you change browser, delete cookie, etc., you need to set opt-out and opt-in again.















1. 個人データ




2.  個人データの処理






1.  契約の履行及び法的義務を遵守する場合(GDPR6(1)(b)(c)):お客様が海外に渡航される場合には、出発時/到着時において、行政機関により、出入国、国境管理その他の目的のため、個人データを開示又は処理することが義務付けられることがあります。当社は、航空会社/宿泊業者に対し、契約の条件により、お客様の氏名、旅券番号、連絡先その他の情報を提供する必要があります。お客様が個人データを提供されない場合には、当社のサービスをご提供できない可能性があります。

2.  お客様と当社の正当な利益を追求する場合(GDPR6(1)(f)):当社の事務処理、サービスの品質の維持、お客様に対する対応、ビジネス/マネージメント、リスク・アセスメント/マネージメント、安全及び業務の一部として、個人データを処理することをお客様及び当社の利益の両方に適う場合。

3.  同意:マーケティングの目的その他お客様の承諾を必要とする同様のデータの処理(GDPR6(1)(a)):当社が個人データをこのような目的に利用する場合又はこのような目的で個人データを第三者に開示する場合は、通常、個人データを収集する前にお客様に通知いたします。

4.  明示の同意(GDPR9(2)(a)):健康又は宗教といった事項に関する情報は、GDPRではセンシティブ個人データとされています。このような個人データには、アレルギー、障害その他健康に関する情報等、予約や旅程を計画するのに必要な情報が含まれています。当社は、これらの個人データについて、サービスを提供したり、お客様のニーズを満たしたり、お客様の利益を追求するために収集するものとし、お客様の明示の同意があることを条件としてセンシティブ個人データを受領するものとします。




































3.  当社のデータ処理の記録




4.  安全性の確保の措置






5. 監督当局に対するデータ侵害の通知




6.  権利及び自由に対する高度のリスクを生じる可能性のある処理






7.  お客様の権利






















8.  個人データについて異議を述べられる場合










9. 当社のプライバシーポリシーの変更




10. 連絡先









12  クッキー




※ お客様がブラウザを変更したり、クッキーを消去したりする場合には、あらためてオプト・アウト及びオプト・インの設定を変更するひつようがあります。