as of June 20, 2022

ANA Cargo Privacy Policy

Basic Policy

In providing our main businesses, which are the cargo and commissioned businesses, ANA Cargo Inc. (hereinafter, "ANA Cargo", "we", "our", or "us") recognizes that customers' personal information is essential for us to provide fully satisfactory services. We recognize the importance of the information received from our customers, and make efforts to take the utmost care in handling such information.
For our customers utilize ANA Cargo with a sense of safety and trust, we educate our executives and employees thoroughly about laws and company regulations relating to personal information, and have established our company's structure to include measures for security, thereby exerting maximum effort toward appropriate management and use of each customer's personal information.

Chapter 1 deals with the handling of personal information pertaining to all customers,Chapters 2, 3, 4 and 5 provide territory-specific information for customers in the European Economic Area /United Kingdom, China, the State of California (U.S.A), and the Kingdom of Thailand respectively.

Chapter 1.Handling of personal information by All of our customers

1. Introduction

This Privacy Policy explains how and why the personal information of customers and other individuals obtained by ANA Cargo is used. Please read this Privacy Policy carefully before providing personal information to ANA Cargo or using our products or services.

Chapter 1 of this Privacy Policy provides an overview of how we use your personal information.

Additional policies may apply to certain ANA Cargo products or services, details of which will be provided alongside the terms of such service.

2. Scope of Application

This Privacy Policy will apply when customers and other individuals provide personal information to ANA Cargo or use ANA Cargo's services and products.

3. Purpose of Using Personal Information

ANA Cargo will use customers' personal information for the following purposes of use. 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.

(1) Reservations, sales, transportation and airport services with regard to air cargo services
(2) Reservations, sales, transportation and airport services for interline transportation, joint acceptance of carriage, codeshare, successive carriage and consigned carriage
(3) Research and analysis of usage of services/products by ANA Cargo
(4) All operations incidental or related to purposes (1) through (3) above
(5) Implementation of questionnaires concerning service and products, etc., offered by ANA Cargo
(6) Development of new services and products
(7) Notification of services and products offered by ANA Cargo
(8) Guidance, operation, management and notification of services, products, events and campaigns of ANA Group companies and partner companies and preferences; as well as provision of various pieces of information through methods including direct email, email newsletters, notices, and advertisements
(9) Response to inquiries, requests
*In addition to the above-mentioned purposes, personal information will be utilized for the purposes described in Chapter 1 Article 7 (Data sharing) below.

4. Acquisition of Personal Information

ANA Cargo will obtain the following personal information by fair and appropriate means for the purpose of achieving the previously mentioned purposes.

(1) Identity, contact and payment information, etc.
The customer's name, address, telephone number, fax number, email address, employment information (company name, division/department the customer belongs to, title, address, telephone number, fax number), mailing address, payment information including details of credit/debit card and other payment methods, personal online identifier, etc.

(2) Details of enquiries and complaints to ANA Cargo
Details of enquiries, requests and complaints contained in correspondence with customers, (including their cause and resolution), etc.
*We may monitor, record, store and use any telephone, email or other communication with you in order to check any instructions given to us, for training purposes, for crime prevention and to improve the quality of our customer service

(3) IT and system data, including about the usage of the ANA Cargo website
Information on the use of ANA Cargo website including cookies, advertising identifiers (IDFA/GAID), location information, unique device identifiers, details on OS and browser type, etc., and action log on the website, etc.
(Details on the use of cookies, including the purpose for which they are used, are described in our Cookie Policy)

ANA Cargo will never obtain and use information of a sensitive nature to the customer (hereinafter "sensitive information"), such as information on race, beliefs, social standing, history of illness, crime records, and history of having been afflicted by crime, unless required by laws and regulations or by the consent of the customer.

5. Choice by the Customer

As a rule, ANA Cargo obtains personal information by the volition of the customer. Customers may experience disadvantages if they refuse to provide their personal information, such as being unable to make use of the various services provided by ANA Cargo, or being unable to receive notices and other information from ANA Cargo because a part of the functions of ANA Cargo's system become inoperable and thereby unavailable. Please note that customers may change their contact information and E-mail magazine distribution at any time they wish, in a manner designated separately by ANA Cargo.

6. Disclosure and Provision of Information to a third Party

ANA Cargo will not disclose or provide personal customer information to any third parties except under the following circumstances. Also, customers' personal information including sensitive information will not be disclosed or provided to third parties under any circumstances, unless allowed by laws and regulations or by consent of the customer. Note that provision of information to data sharing partners and business entrusted companies are not deemed to constitute disclosure or provision to third parties.
(1) Customer consent has been obtained.
(2) Disclosure or provision is required within the scope allowed by laws or regulations.
(3) Disclosure is required to protect human life, health, or property in cases where obtaining customer consent is difficult.
(4) Disclosure is required to cooperate with the public affairs of national or local governments, and when obtaining customer consent is likely to hinder the administration of public affairs.
(5) Disclosure or provision of information as statistical data (in a format that does not disclose the customer's identity).
(6) Provision of information in accordance to procedures based on laws and regulations, under the condition that the following information can be easily checked by the customers themselves through the ANA Cargo website, etc., and that the customers have not declared their wish to refuse provision of their information.
1) The purpose of obtaining information is to provide such information to a third party
2) Specific personal data items to be provided to a third party
3) The means by which such personal information is provided to a third party
4) Provisions of information will be suspended upon the customers' request
5) Methods for accepting requests from customers
(7) Provision of information as a result of the succession of business due to a merger, company split, transfer of business or otherwise.

7. Data Sharing

ANA Cargo may share customer information as follows.

Scope of entities that data can be shared ANA Group companies
Purpose of using data by the user (1)For provision of air transportation services, travel services including tours and hotels, and other products/services handled by ANA Cargo or companies that share data
(2)For sending of direct mail and information on products/services, and distribution of questionnaire(s) to customers, etc. by the Company or companies that share data
(3)For sales analysis, other research/studies, and development of new products/services, etc. by ANA Cargo or companies that share data
(4)For delivery and transfer of data when we receive inquiries, application for use or other offers from customers regarding products/services provided by ANA Cargo or companies that share data
(5)For appropriate and smooth fulfillment of other transactions with customers by ANA Cargo or companies that share data
(6)For business management/internal management by the ANA Group
Items of personal information to be shared Customer's name, address, telephone number, fax number, email address, employment information (company name, division/department the customer belongs to, title, address, telephone number, fax number), mailing address, payment information including details of credit/debit card and other payment methods, personal online identifier, details of enquiries, requests and complaints contained in correspondence with customers, information on the use of ANA Cargo website, including cookie and action log on the website, etc.
Name, address and representative name of the Party responsible for the management of personal information ANA Holdings Inc.
Shiodome City Center, 1-5-2 Higashi-Shinbashi, Minato-ku, Tokyo 105-7140, Japan
Koji Shibata, President and Representative Director

8. Business Entrustment

In providing products and services to customers, ANA Cargo may entrust a part of its business operations to third parties to which personal information may also be disclosed to the extent required to achieve the purpose of the entrustment. In these cases, ANA Cargo will implement appropriate measures in managing and supervising such third parties to safeguard the handling of customers' personal information, including establishing agreements on the handling of such personal information.

9. Transfer to Outside of Japan

ANA Cargo may transfer your personal information (name, address, phone number, etc.) outside of Japan depending on the destination of the flight carrying the air cargo you have reserved. You can check the countries in which we operate flights on our website. The country or region to which your personal information is transferred may not have the same personal information protection systems in place as 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.

(1)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
(2)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. If you wish to confirm the details of such measures, then please submit a request in accordance with "11. Request about handling of Personal Information".

10. Management of Personal Information

ANA Cargo manage customers' personal information appropriately and take the necessary security management measures to prevent the leakage, loss and alteration, etc. of such personal information.
to the strictest standards and take the utmost care to prevent leaks, loss, or alterations. ANA Cargo ensures that the executives and employees are properly trained regarding appropriate handling to safeguard the security of information identifying individual customers. An appropriate retention period for personal information will be established in accordance with the purpose for which such information is used. After the purpose of the information has been achieved, ANA Cargo will dispose of the information in question by appropriate methods. If you wish to confirm the details of our security management measures, then please submit a request in accordance with "11. Request about handling of Personal Information".
*For ANA's action policy for information security, please refer to "ANA Group Information Security".
https://www.ana.co.jp/group/csr/risk_management/security/

11. Request about handling of Personal Information

If ANA Cargo receives a request from a customer, submitted in the manner specified, for the (1) disclosure, (2) correction, deletion or addition, or (3) discontinuance or erasure (hereinafter "disclosure, etc.") of the customer's personal information stored in a database held by ANA Cargo, the request will be handled according to the laws and regulations as follows, within a reasonable timeframe and scope, Provision of information about our personal information security management measures prescribed in "9. Transfer to Outside of Japan" and "10. Management of Personal Information" (hereinafter, "Disclosure, etc.") after confirming that the request was submitted by the customer themselves.

(1) Request for disclosure
We will disclose the items of personal information that you have requested, the purpose of use, or records of provision to third parties.
(2) Request for correction, deletion or addition
Correction, deletion, or addition of personal information will be undertaken wherever possible and appropriate after due review of the request.
(3) Request for discontinuance or erasure
We will discontinue usage of, or erase, the items of your personal information that you have specified to the extent that is appropriate and possible in accordance with the contents of your request. But please be aware that we may no longer be able to provide you with the services that had been available to you until then, or provide you with services in accordance with your requests, as a consequence of discontinuing use of, or erasing, your personal information.
(4) Requests for the provision of information about our personal information security management measures
We will provide you with the following information in accordance with the contents of your request:
1) The details of the security management measures we take when we retain your personal information;
2) The details of the measures we take when we transfer your personal information to third parties outside of Japan (in the case item (2) under "9. Transfer to Outside of Japan" is applicable.)

ANA Cargo 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.

12. Submission of request for disclosure, etc.

The method for submitting requests for disclosure, etc. or notification of purpose of use of personal information (hereinafter "requests for disclosure, etc.") received by ANA Cargo from customers, and contact information are as follows.

(1) Method for submitting request
Please send the required documents by postal mail to the address below.
Address:
ANA Cargo Personal Information Handling Desk
Shiodome-City Center, 1-5-2, Higashi-Shimbashi, Minato-ku, Tokyo 105-7140, Japan

(2) Required documents
< Application forms >(choose one of the following in accordance with your request.)

①Form requesting disclosure(PDF format/136KB)

②Form for various requests(PDF format/127KB)

Customer requests for disclosure, etc., may not be acknowledged if any of the required information is missing.

< Documents required for confirmation of identification of individual, etc. >

◆ For requests by the individual
Copies of two from the following: driver's license, passport, health insurance certificate(masking insurance card numbers and identification symbols / numbers of insured individuals), basic resident registration card with photo, pension insurance booklet, physical disability certificate, resident card or special permanent resident certificate, certificate of seal registration, or Individual Number Card (front page only)

◆ For requests by a representative
In addition to "◆ For requests by the individuals", the following documents described in (1) and (2) are required.
(1) Power of Attorney (legal representatives must provide a document certifying such status)
(2) Documents to identify the representative (copies of two from the following: driver's license, passport, health insurance certificate(masking insurance card numbers and identification symbols / numbers of insured individuals), basic resident registration card with photo, pension insurance booklet, physical disability certificate, resident card or special permanent resident certificate, certificate of seal registration, or Individual Number Card(front page only))

(3) Fee
A fee will be charged depending on type of the request. Please note that handling procedures may differ depending on the laws and regulations of the relevant country.

13. Modification of the Privacy Policy

ANA Cargo may make modifications to this Privacy Policy. If modifications are made, details will be posted on the ANA Cargo website.

14. Compliance with Laws and Regulations and Continuous Improvement

ANA Cargo will comply with all laws and regulations of Japan as well as other relevant standards applicable to the personal information held by ANA Cargo, and continuously and flexibly review the management systems and company regulations on a periodic basis. Also, ANA Cargo will seek to continuously improve the handling of personal information in light of changes in the environment such as the development of information technology and changes in social demands.

Chapter2.Handling of personal information of EEA and UK residents by ANA Cargo

1. Introduction

This Chapter 2 provides additional information about the handling of personal information of customers and other individuals in the European Economic Area (hereinafter, "EEA") and/or the United Kingdom (hereinafter, "UK") in accordance with EU General Data Protection Regulation 2016/679 (hereinafter, "GDPR") and the UK Data Protection Act 2018 (hereinafter, "DPA 2018") and other national and international data protection and privacy laws (together, "Data Protection Laws").

Please note that the UK's laws are similar to those in the EEA, and customers from both jurisdictions have very similar rights. Accordingly, references to the GDPR in this Chapter should also be read as references to corresponding UK law.

A guardian's consent or permission must be obtained in the event that a customer under the age of 16 uses ANA Cargo's service and consents to this Privacy Policy. The data subject's consent to this Privacy Policy must be obtained in the event that a person such as family member apply for ANA Cargo's service on behalf of the data subject.

In the event that any provisions of this Chapter 2 contradict those of Chapter 1, the provisions of this Chapter 2 shall prevail.

2. The controller of personal information

The controller of your personal information is ANA Cargo.

ANA Cargo protects personal information which is collected and used by controllers (who make decisions about how and why your personal information is used) and processors (who act on the controller's written instructions) on the basis of Data Protection Laws.

3. Our lawful basis for processing personal information

ANA Cargo protects your personal information by ensuring that it can only be used to the extent necessary for specific purposes (as set out in Part 3 of Chapter 1 of this Privacy Policy) and by requiring that there is a lawful basis for each processing activity on the basis of Data Protection Laws.

ANA Cargo may process customer personal data on one or more of the following lawful bases:

(1) When your consent is obtained to the processing (Article 6(1)(a) GDPR)
Consent will usually only be relied upon for promotional and marketing related processing, or in some cases, in relation to sensitive personal data.
(2) When processing is necessary in order to perform or take steps to enter into a contract (Article 6(1)(b) GDPR).
This is typically why we process customer information which is essential to providing our services, including a customer's identity, contact, payment, etc.
(3) ANA Cargo needs to process the information to comply with a lawful obligation (Article 6(1)(c)).
This includes the requirement to share personal information with customs and immigration authorities or law enforcement, as well ANA Cargo's legal duties towards its staff and customers.
(4) The information is required to protect your, or a third party's, vital interests (Article 6(1)(d)), for example in the event of a medical emergency.
(5) It is in ANA Cargo's or a third party's legitimate interests to process the personal data, and these interests are not overridden by your rights under Data Protection Laws (Article 6(1)(f) GDPR).
This includes the use of personal information necessary to operate ANA Cargo's business and also to maintain, develop and improve its products and services.

4. Request about processing of personal information

(1) Data Protection Laws provide you with the following legal rights:
1) Request for disclosure: You can request copies of your personal information and details of how we process it.
2) Request for correction or updating: Corrections or updates to personal information will be undertaken wherever possible after due review of the request.
3) Request for erasure: You may request that we delete all or part of the personal information we hold about you. We will consider your request and, where the information is no longer required or the law does not permit us to continue to retain it, we will delete it.
4) Transferring your personal information: You can request a copy of your personal information in a structured, common, machine-readable format. This only applies to personal information which we obtain from you and process on the basis of your consent or in order to perform a contract, and which is processed by automated means.
5) Objecting to processing: You can object to processing which is carried out on the basis of our or a third party's legitimate interests or for the purpose of direct marketing. We will stop processing your information unless we have a strong reason to continue which overrides your objection. If your objection is to direct marketing, we will always stop.
6) Restricting how your personal information is processed. You can limit how we process your personal information in certain circumstances. Where this applies, any processing of your personal information (other than storing it) will only be lawful with your consent or where required for legal claims, protecting certain rights or important public interest reasons.
7) The right to withdraw consent. If we are relying on consent to process your personal information, you have the right to withdraw that consent at any time.
Please note, the rights set out above are not absolute and do not apply in every situation. There are also legal exemptions which apply in some situations and mean a request may be refused. If your request is denied, please contact us at we will inform you of the reasons for this when we respond.
Records of requests made to us will be retained so that we can ensure we have complied with our legal obligations.

(2) Method for submitting request
You can exercise your rights free of charge (except in the case of unreasonable, excessive or repeated requests in which case we may charge a fee or refuse the request). The method for submitting request and contact information are as follows.

(Submission of requests)
Please send the required documents by postal mail to the address below.

Address:
ANA Cargo Personal Information Handling Desk
Shiodome-City Center, 1-5-2, Higashi-Shimbashi, Minato-ku, Tokyo 105-7140, Japan

(Required documents)

・Form requesting disclosure (for EEA/UK residents).

・Form for various requests (for EEA/UK residents).

(3) Responding to a request
We will respond without delay and usually within one month. We may, in some cases, ask for identification or (if you are making the request on behalf of a third party) proof of your authority to submit a request. If your request is particularly complex or you have made a number of requests, it may take longer to provide a detailed response. Please also bear in mind that there are exceptions to the rights above and some situations where they do not apply.

If you are not satisfied with our response to a data protection request or if you think your personal information has been mishandled, then you have the right to complain to a supervisory authority. Please see Part 9 of this Chapter 2 ("Lodging a complaint with an authority") for further details.

5. Data sharing which is necessary to provide products or services

ANA Cargo's products and services are provided with the assistance of other companies and organizations and often ANA Cargo will need to share personal information with third parties in order to run its business. These third parties include:

(1) Other companies in the ANA Group

(2) Organizations with which ANA Cargo is legally required to share personal information
including: government organizations, regulatory and law enforcement authorities, judicial, customs and immigration authorities, third-party organization, etc.

(3) Service providers
including: subcontractor handling ANA flights, airports and airlines who we partner with, various service providers, providers with whom we have a marketing partnership, etc.

Where ANA Cargo instructs companies, contractors or service providers to process data on its behalf, then it will ensure that it does so pursuant to a contract which meets the requirements of applicable Data Protection Laws.

6. Marketing communications

ANA Cargo sends out marketing communications from time to time to notify interested persons of news and provide details of products and services which may be of interest to them. ANA Cargo will only do this if the recipient has consented to receive marketing or if they are an existing customer who purchased products or services from ANA Cargo and were given the opportunity to opt-out from marketing at the time but chose not to do so.

7. Where your personal information is stored and transferred

ANA Cargo is located in Japan and many of the service providers and other organizations with whom we share your personal information will be located in jurisdictions outside the EEA and UK. It should be noted that Japan has been recognized by the European Commission as providing adequate protection for personal information.

When transferring personal information to third parties, ANA Cargo will ensure that it complies with the requirements of Data Protection Laws, including the onward transfer requirements of the EU-Japan adequacy decision and related Japanese laws. However, you should be aware that recipients outside the EEA and UK may be subject to national laws which do not necessarily provide equivalent protection for your personal data. If you would like more information regarding where your personal information is stored and transferred, please contact ANA Cargo using the details set out in Part 10 of this Chapter 2 ("The contact information of the controller and ANA Cargo's Data Protection Officer").

8. Retention of personal information

ANA Cargo retains customers' personal information until the purpose of use is achieved. Particularly, ANA Cargo has set the retention period for personal information as follows. For most other personal information, the appropriate retention period will be determined based on the nature of the information and the purpose for having it by reference to legal and accounting requirements and our business needs.

(1)Customers' personal information
Until completion of transportation and related work stipulated in Conditions of Carriage -domestic cargo, international cargo and by Charter Flight.

(2)Other personal information
Required period for the purpose which customers have consented

9. Lodging a complaint with an authority

Customers have the right to lodge a complaint on the processing of their personal information with the data protection authority having jurisdiction over their residence.
(1)EEA residents: Please contact your national supervisory authority, details of which can be found on the European Data Protection Board's website (https://edpb.europa.eu/about-edpb/board/members_en).
(2)UK residents: Please contact the Information Commissioner's Office (www.ico.org.uk).

10. The contact information of the controller and ANA Cargo's Data Protection Officer

Controller: ANA Cargo Inc,
Address: Shiodome City Center, 1-5-2 Higashi-Shimbashi, Minato-ku, Tokyo, Japan
Data Protection Officer email: personalinfodesk@anacargo.jp

Chapter 3.Handling of personal information of residents of China residents by ANA Cargo

Besides Chapter 1, Chapter 3 also shall be applied to the handling of personal information of persons residing in China's Personal Information Protection Law and related regulations(hereinafter,"PIPL"). In the event that any provisions of this chapter contradict those of chapter 1, the provisions of this chapter shall prevail.

1. Introduction

A guardian's consent or permission must be obtained in the event that a customer under the age of 18 uses ANA Cargo's service and consents to this Privacy Policy. The data subject's (If you are a minor under 14 years of age, your parent or guardian) consent to this Privacy Policy must be obtained in the event that a person such as family member applies for ANA Cargo's service on behalf of the data subject.

2. Acquisition of sensitive personal information

ANA Cargo may handle personal information such as your personal details, contact information, payment information, and information that may be classified as sensitive personal information under the PIPL, etc. for the purpose of use.
We recognize that the leakage or illegal use of customers' sensitive personal information may adversely affect their interests (e.g., It could easily bring about damage to personal dignity, or harm the safety of body or property), and will therefore strictly manage and legally handle such information in order to prevent its leakage or illegal use.

3. Retention period for personal information

ANA Cargo will retain the customer's personal information until the purpose of use is achieved. In particular, ANA Cargo sets the retention period for personal information as follows.

(1) Customers' personal information
Until the completion of transportation and related work stipulated in conditions of carriage -domestic cargo, international cargo and by Charter Flight.
(2) Other personal information
Shortest period for the purpose which customers have consented.

4. Technology and measure to protect customers' personal information

(1) ANA Cargo take security measures to protect the personal information you provide from leakage, tampering and loss. Specifically, ANA Cargo takes the following measures to protect customers' personal information.
・ANA Cargo have established and are implementing an internal control system and operation rules regarding the protection of personal information.
・ANA Cargo manage the classification of personal information.
・ANA Cargo develops website with https and sets SSL encryption to secure important customers' data (Credit card information, etc.) communication between the customers' web browser and the server.
・ANA Cargo use encryption technology to protect personal data.
・ANA Cargo set reasonable access rights and implement access restrictions so that unauthorized persons cannot access personal information.
・In order to raise employee awareness of the importance of protecting personal information, ANA Cargo provides education and training on security and privacy protection.
・ANA Cargo have established and are operating an emergency response plan to respond to incidents involving personal information.

(2) ANA Cargo will take all reasonable and practicable steps to ensure that no irrelevant personal information is collected. ANA Cargo will retain your personal information for the shortest period of time necessary to accomplish the purposes described in this Privacy Policy, unless an extension of time is permitted by law.

(3) In the event of personal information being at risk, ANA Cargo will promptly inform customers of the relevant circumstances of the incident in accordance with the PIPL and regulations and report to the regulatory authorities.

5. Request about handling of Personal Information

In the event that ANA Cargo receives a request of the customer's personal information held by ANA Cargo from a resident of China, the request will be handled according to the PIPL and regulations within a reasonable timeframe and manners besides Chapter 1 Article 11 (Request about handling of Personal Information), after confirming that the request was submitted by the customer themselves.

(1) Request for withdrawal
If ANA Cargo are handling your personal information based on your consent, then you have the right to withdraw such consent at any time. In this case we will erase the items of your personal information that you have specified to the extent that is appropriate and possible in accordance with the contents of your request.
However, please note that such requests may prevent customers from being provided with services that they had utilized, or may impede the provision of services in accordance with their wishes.

(2) Request for interpretation and explanation of our Privacy Policy
You have the right to request interpretation and explanation of this Privacy Policy.

(3) Methods for submission of requests
Customers may submit requests by following methods.

1) Submission of requests
Please send the required documents by postal mail to the address below.
Shiodome-City Center, 1-5-2, Higashi-Shimbashi, Minato-ku, Tokyo 105-7140, Japan

2) Required documents
< Application forms >(choose one of the following in accordance with your request.)

①Form requesting disclosure (PDF format/163KB)

②Form for various requests (PDF format/139KB)

< Documents required for confirmation of identification of individual, etc. >

◆For individuals
Copies of any two of the following: passport, health insurance certificate(masking insurance card
numbers and identification symbols / numbers of insured individuals), basic resident registration
card with photo, pension insurance booklet, physical disability certificate, resident card or special
permanent resident certificate, certificate of seal registration, Individual Number Card (front page
only), identification card issued by the Chinese government

◆For representatives
In addition to "◆For the individual," the following documents described in (1) and (2) below are required.
(1) Power of Attorney (legal representatives must provide a document certifying such status)
(2) Documents to identify the representative (copies of two of the following: the representative's
passport, health insurance certificate(masking insurance card numbers and identification symbols /
numbers of insured individuals), basic resident registration card with photo, pension insurance
booklet, physical disability certificate, resident card or special permanent resident certificate,
certificate of seal registration, Individual Number Card (front page only), identification card issued
by the Chinese government)

6. About provision to third parties and transfer to outside of China

ANA Cargo will comply with the provisions of PIPL, etc. when providing customers' personal information to a third party (including provision to our data sharing partners and to entrusted companies involving transfer to outside of China).

7. Change of purposes of use of personal data

In the case of a change to the purposes of use of personal information, ANA Cargo will announce the revised Privacy Policy in advance on ANA Cargo website and ANA Cargo will use personal information in accordance with the new purposes of use of personal information after obtaining consent from customers.

8. Basic information of Controller of personal information

ANA Cargo Inc.
Address: Shiodome City Center, 1-5-2 Higashi-Shimbashi, Minato-ku, Tokyo, 105-7140, Japan

Chapter4.Handling of personal information of California residents by ANA Cargo

Last updated on June 20, 2022

Besides Chapter 1, Chapter 4 also shall be applied to the handling of personal information of persons residing in California, United States of America based on the California Consumer Privacy Act of 2018(hereinafter, "CCPA"). In the event that any provisions of this chapter contradict those of chapter 1, the provisions of this chapter shall prevail.

The terms used in this chapter are based on the definitions provided in CCPA. For example, the term "sale", among others, means ANA Cargo's selling, lending, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information to another business or a third party for monetary or other valuable consideration. However, if ANA Cargo concludes an appropriate agreement concerning the handling of personal information with another business or a third party, the activities mentioned above are not regarded as "sale" from the perspective of CCPA.

1. Acquisition and use of personal information

Personal information collected by ANA Cargo in the preceding 12 months or likely to be collected in the future is classified as defined in the following table. ANA Cargo will use this personal information for the purposes specified in Chapter 1.3. (Purpose of Using Personal Information).

It will acquire such personal information directly from customers.

Type of personal information collected Example of personal information
Identifiers (name or symbol, etc. used to uniquely identify a particular subject) The customer's name, address, telephone number, fax number, mailing address, email address, passport Information, personal online identifier, etc.
Additional data subject to the California Customer Records statute (personal information categories in Cal. Civ. Code Sec. 1798.80(e)) Payment information including your credit card number and details of other payment methods
Characteristics of protected classifications under California or federal law -
Commercial information Credit card expiration date, credit card usage history and related information, air shipment cancellation information, service usage record, and information contained in correspondence with the customer. The details of enquiries, requests and complaints contained in correspondence with customers, etc.
Internet or other electronic network activity information. Information on the use of ANA Cargo website including cookies, advertising identifiers (IDFA/GAID), location information, unique device identifiers, details on OS and browser type, etc., and action log on the website, etc.
Professional or employment-related information Employment information (company name, division/department the customer belongs to, title, address, telephone number, fax number) and related information

2. The sharing of personal information

(1) Sale of personal information
ANA Cargo will not sell customers' personal information (including personal information concerning minors) to any third parties, and has not sold the same in the past 12 months.

(2) Disclosure of personal information for business purposes
The types of customers' personal information that ANA Cargo has disclosed in the past 12 months for business purposes and the types of third parties to which such personal information has been disclosed are shown below.

Type of personal information collected Example of personal information Third party to which the personal information has been disclosed in the past 12 months
Identifiers (name or symbol, etc. used to uniquely identify a particular subject) The customer's name, address, telephone number, fax number, mailing address, email address, passport Information, personal online identifier, etc. Other companies in the ANA Group, subcontractor handling ANA flights, airports and airlines who we partner with, various service providers, providers with whom we have a marketing partnership, government organizations, regulatory and law enforcement authorities, judicial, customs and immigration authorities, third-party organization, etc.
Additional data subject to the California Customer Records statute (personal information categories in Cal. Civ. Code Sec. 1798.80(e)) Payment information including your credit card number and details of other payment methods ANA Group companies, entrusted companies that handle ANA flights, affiliated airports/airlines, various service providers, marketing affiliates, government agencies, law enforcement agencies, courts, customs/immigration authorities, third-party organizations, etc.
Characteristics of protected classifications under California or federal law - -
Commercial information Credit card expiration date, credit card usage history and related information, air shipment cancellation information, service usage record, and information contained in correspondence with the customer. Details of enquiries, requests Other companies in the ANA Group, subcontractor handling ANA flights, airports and airlines who we partner with, various service providers, providers with whom we have a marketing partnership, government organizations, regulatory and law enforcement authorities, judicial, customs and immigration authorities, third-party organization, etc.
Internet or other electronic network activity information. Information on the use of ANA Cargo website including cookies, advertising identifiers (IDFA/GAID), location information, unique device identifiers, details on OS and browser type, etc., and action log on the website, etc. Other companies in the ANA Group, various service providers, providers with whom we have a marketing partnership, government organizations, regulatory and law enforcement authorities, judicial, customs and immigration authorities, third-party organization, etc.
Professional or employment-related information Employment information (company name, division/department the customer belongs to, title, address, telephone number, fax number) and related information Other companies in the ANA Group, various service providers, providers with whom we have a marketing partnership, government organizations, regulatory and law enforcement authorities, judicial, customs and immigration authorities, third-party organization, etc.

3. Request about handling of Personal Information

Customers living in California have the following rights concerning their personal information:

(1) Access right
Customers have the right to make a request to ANA Cargo for the disclosure of the following information regarding their personal information collected/used/disclosed by ANA Cargo within the 12 months before the date of request (hereinafter "Access Right"), up to twice in 12 months.

・Type of the customer's personal information collected by ANA Cargo
・Source of the collection of such personal information
・Business or commercial purposes for the collection of such personal information
・Type of third party with which such personal information has been shared
・The customer's specific personal information collected by ANA Cargo
・Type of the customer's personal information disclosed by ANA Cargo for a business purpose
・Type of third parties to which each type of such personal information has been disclosed

(2) Deletion right
Customers have the right to make a request to ANA Cargo for the deletion of their certain personal information collected by ANA Cargo (hereinafter "Deletion Right").

When exercising the Access Right or Deletion Right, please contact the following. Once ANA Cargo receives such a request, it will be handled according to the related laws and regulations within a reasonable timeframe and manner, after confirming, through the procedures for individual identification described below, that the request was submitted by the customer himself/herself.

(3) Submission of requests and Procedures for individual identification
1) Submission of requests
E-mail:
Please send e-mail to personalinfodesk@anacargo.jp
Postal Mail:
Address: Shiodome-City Center, 1-5-2, Higashi-Shimbashi, Minato-ku, Tokyo 105-7140, Japan
Tel:
Please contact the following,
+81-3-6735-1900

2) Procedures for individual identification
◆For individuals
Upon receiving a request for the exercise of the Access Right or Deletion Right, ANA Cargo will ask
the customer to submit information sufficient to confirm that such request was submitted by such
customer himself/herself, such as his/her name and email address, and compare the submitted
information with the information held by ANA Cargo.

◆For representatives
In addition to the information required for the identification of individual in "◆For the individual,"
a power of attorney (legal representatives must provide a document certifying such status) needs to
be submitted. In addition, ANA Cargo may ask the customer to directly contact ANA Cargo to
confirm that he/she has granted the representative authority to exercise the Access Right or
Deletion Right.

As a rule, ANA Cargo will not treat customers who have submitted such requests in a discriminatory manner, such as changing their services. However, please note that deletion requests may prevent customers from receiving services which they have been provided with, or may impede the provision of services that are in accordance with their needs.

Chapter5.Handling of personal information of Thailand residents by ANA Cargo

1. Introduction

This Chapter 5 provides additional information about the collection, use, or disclosure ("processing") of personal information of customers and other individuals in the Kingdom of Thailand ("Thailand") in accordance with the Personal Data Protection Act of Thailand B.E. 2562 (A.D. 2019) ("PDPA").

If consent is required for processing of personal information relevant to the use of services of data subjects who are minors by ANA Cargo, quasi-incompetents or incompetents under the law of Thailand and cannot lawfully give consent by themselves, consent or permission of the persons exercising parental power, their curators or custodians (as the case may be) must also be obtained. If data subjects are under the age of 10, only consent or permission of the persons exercising parental power must be obtained.

If ANA Cargo is not aware that the data subjects are minors, quasi-incompetent persons or incompetent persons prior to the collection of their personal information, upon learning that we have collected personal information of minors without the consent of persons exercising parental power (when it is required and the minors cannot lawfully give consent by themselves), or from quasi-incompetent persons and incompetent persons without the consent of their legal curator and custodian, we will delete the personal information at the earliest convenience unless we can rely on other legal grounds apart from consent for such processing.

The data subject's consent to this Privacy Policy must be obtained in the event that a person such as family member or an agent authorized to act on its behalf applies for service on behalf of the data subject by ANA Cargo.
In the event that any provisions of this Chapter 5 contradict those of Chapter 1, the provisions of this Chapter 5 shall prevail.

2. The controller of personal information

The controller of your personal information is ANA Cargo.
ANA Cargo protects personal information which is collected and used by controllers (who make decisions about how and why your personal information is used) and processors (who act on the controller's written instructions) on the basis of the PDPA.

3. Our lawful basis for processing personal information

ANA Cargo protects your personal information by ensuring that it can only be used to the extent necessary for specific purposes (as set out in Part 3 of Chapter 1 of this Privacy Policy) and by requiring that there is a lawful basis for each processing activity on the basis of the PDPA.

ANA Cargo may process customer personal information on one or more of the following lawful bases:

(1) When your consent is obtained to the processing (Article 19 PDPA)
Consent will usually only be relied upon for promotional and marketing related processing, or in some cases, in relation to sensitive personal information.

(2) When processing is necessary in order to perform or take steps to enter into a contract (Article 24(3) PDPA).
This is typically why we process customer information which is essential to providing our services, including a customer's identity, contact, payment and travel details, etc.

(3) ANA Cargo needs to process the information to comply with a lawful obligation (Article 24(6) PDPA).
This includes the requirement to share personal information with customs and immigration authorities or law enforcement, as well ANA Cargo's legal duties towards its staff and customers.

(4) The information is required to protect your, or a third party's, vital interests (Article 24(2) PDPA), for example in the event of a medical emergency.

(5) It is in ANA Cargo's or a third party's legitimate interests to process the personal information, and these interests are not overridden by your fundamental rights regarding your personal information under the law (Article 24(5) PDPA).
This includes the use of personal information necessary to operate ANA Cargo's business and also to maintain, develop and improve its products and services and provide the best possible customer experience to the extent permissible under the PDPA.

4. Request about processing of personal information

(1) The PDPA provides you with the following legal rights:
1) Request for disclosure:
You can request copies of your personal information and details of how we process it.

2) Request for correction or updating:
Corrections or updates to personal information will be undertaken wherever possible after due review of the request.

3) Request for erasure:
You may request that we erase, destroy or anonymize all or part of the personal information we hold about you. We will consider your request and, where the information is no longer required or the law does not permit us to continue to retain it, we will delete it.

4) Transferring your personal information:
You can request a copy of your personal information in a structured, common, machine-readable format. This only applies to personal information which we obtain from you and process on the basis of your consent or in order to perform a contract, and which is processed by automated means.

5) Objecting to processing:
You can object to processing which is carried out on the basis of our or a third party's legitimate interests or for the purpose of direct marketing. We will stop processing your information unless we have a legitimate reason to continue which overrides your objection. If your objection is to direct marketing, we will always stop.

6) Restricting how your personal information is processed:
You can limit how we process your personal information in certain circumstances. Where this applies, any processing of your personal information (other than storing it) will only be lawful with your consent or where required for legal claims, protecting certain rights or important public interest reasons.

7) The right to withdraw consent:
If we are relying on consent to process your personal information, you have the right to withdraw that consent at any time.
However, the withdrawal of consent shall not affect the processing of your personal information that you have already given consent legally before it is withdrawn.
Please note, the rights set out above are not absolute and do not apply in every situation. There are also legal exemptions which apply in some situations and mean a request may be refused.
Of course, if a request is refused we will inform you of the reasons for this when we respond.

Records of requests made to us will be retained so that we can ensure we have complied with our legal obligations.

(2) Method for submitting request
You can exercise your rights free of charge (except in the case where expenses may be chargeable under the PDPA).The method for submitting a request and contact information are as follows.

(Submission of requests)
Please send the required documents by postal mail to the address below.

Address:
ANA Cargo Personal Information Handling Desk
Shiodome-City Center, 1-5-2, Higashi-Shimbashi, Minato-ku, Tokyo 105-7140, Japan

(Required documents)

・Form requesting disclosure (for Thailand residents).

・Form for various requests (for Thailand residents).

(3) Responding to a request
We will respond without delay and usually within one month. We may, in some cases, ask for identification or (if you are making the request on behalf of a third party) proof of your authority to submit a request. If your request is particularly complex or you have made a number of requests, it may take longer to provide a detailed response. Please also bear in mind that there are exceptions to the rights above and some situations where they do not apply.

If you are not satisfied with our response to a data protection request or if you think your personal information has not been processed appropriately, then you have the right to file a complaint with the Personal Data Protection Committee of Thailand. Please see Part 9 of this Chapter 5 ("Lodging a complaint with an authority") for further details.

5. Data sharing which is necessary to provide products or services

ANA Cargo's products and services are provided with the assistance of other companies and organizations and often ANA Cargo will need to share personal information with third parties in order to run its business. These third parties include:

(1) Other companies in the ANA Group

(2) Organizations with which ANA Cargo is legally required to share personal information
including: government organizations, regulatory and law enforcement authorities, judicial, customs and immigration authorities, third-party organization, etc.

(3) Service providers
including: subcontractor handling ANA flights, airports and airlines who we partner with, various service providers, providers with whom we have a marketing partnership, etc.
Where ANA Cargo instructs companies, contractors or service providers to process data on its behalf, then it will ensure that it does so pursuant to a contract which meets the requirements of PDPA.

6. Marketing communications

ANA Cargo sends out marketing communications from time to time to notify interested persons of news and provide details of products and services which may be of interest to them. ANA Cargo will only do this if the recipient has consented to receive marketing communications.

7. Where your personal information is stored and transferred

ANA Cargo is located in Japan and many of the service providers and other organizations with whom we share your personal information will be located in jurisdictions outside Thailand.
When transferring personal information to third parties, ANA Cargo will ensure that it complies with the requirements of the PDPA and related Japanese laws.
However, you should be aware that recipients outside Thailand may be subject to national laws which do not necessarily provide equivalent protection for your personal information. If you would like more information regarding where your personal information is stored and transferred please contact ANA Cargo using the details set out in Part 12 of this Chapter 1 ("Submission of request for disclosure, etc.").

8. Retention of personal information

ANA Cargo retains customers' personal information until the purpose of use is achieved. Particularly, ANA Cargo has set the retention period for personal information as follows. For most other personal information, the appropriate retention period will be determined based on the nature of the information and the purpose for having it by reference to legal and accounting requirements and our business needs.

(1)Customers' personal information
Until completion of transportation and related work stipulated in Conditions of Carriage ―domestic cargo, international cargo and by Charter Flight.

(2)Other personal information
Required period for the purpose which customers have consented

Please note that ANA Cargo may retain your personal information for a longer period than mentioned above if it is for the purposes of the establishment, compliance, or exercise of legal claims, the defense of legal claims, or the purpose for compliance with the law.

9. Lodging a complaint with an authority

Customers have the right to lodge a complaint on the processing of their personal information with the Personal Data Protection Committee of Thailand.

10. The contact information of the controller and ANA Cargo's Data Protection Officer

Controller: ANA Cargo Inc,
Address: Shiodome City Center, 1-5-2 Higashi-Shimbashi, Minato-ku, Tokyo, Japan
Data Protection Officer email: personalinfodesk@anacargo.jp