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Privacy Policy

Seirai Group Japan Ltd. (the "Company", "we" or "us") operates ACOE, our accommodation brand in Tokyo, and this website, https://www.acoe.jp/ (the "Website"). This policy explains how we handle the personal information of guests who stay at ACOE accommodation, visitors to the Website, and people who contact ACOE. We comply with the Act on the Protection of Personal Information (the "Act"), other applicable laws and regulations, and the guidelines of the Personal Information Protection Commission, and handle personal information as set out below.

This policy is based on the Company's privacy policy (https://seiraigroup.jp/en/privacy/) and applies it to ACOE and the Website. For matters this policy does not cover, including the personal information of business partners, property owners and job applicants, the Company's privacy policy applies. Where the two policies differ on a matter concerning ACOE guests or the Website, this policy applies.

Basic policy

Our management philosophy is "Keeping the promise is how we earn trust." We regard the proper handling of the personal information entrusted to us as a foundation of that trust, and adopt the following policy.

  1. Compliance: We comply with the Act and other applicable laws, regulations and guidelines.
  2. Proper acquisition and use: We acquire personal information by proper means and use it only within the purposes of use we have specified in advance.
  3. Security: We take necessary and appropriate security measures to prevent the leakage, loss or damage of personal information.
  4. Supervision of contractors: When we entrust the handling of personal information to others, we supervise them as necessary and appropriate.
  5. Requests and complaints: We respond to requests for disclosure and other requests, complaints and enquiries in accordance with the law.
  6. Review and improvement: We review and improve our handling of personal information as necessary.

1. Personal information we acquire

We acquire the following personal information by proper means.

(1) Guests

For guests staying at accommodation we operate under the ACOE brand, we acquire the following information.

  • Reservation details: name, email address, telephone number, dates of stay, number of guests, reservation number, booking channel, etc.
  • Guest register details: the items that applicable laws require to be recorded in the guest register (name, address, contact details and, for foreign nationals with no address in Japan, nationality and passport number, etc.)
  • A copy of the passport (for foreign nationals with no address in Japan)
  • Stay details: check-in and check-out records, the content of enquiries and messages before, during and after the stay, requests, information about lost property, etc.
  • Payment information: records of payments and refunds and similar information (payment is made through booking sites or payment services, and we do not keep card numbers)
  • Questions asked on in-room tablets and in the online guidebook, and security camera footage (only at the entrances and similar areas of properties where cameras are installed), and similar information

We acquire this information directly from guests (for example, through our booking page, which runs on Beds24, and our online check-in) or through booking sites and other booking channels. Information about accompanying guests (including children) may be provided by the lead guest who made the booking. If you give us information about other guests, please let them know about this policy. Information acquired through a booking site is also handled in accordance with that site's terms.

(2) Visitors to the Website

When you visit the Website, information about your device and your visit is collected through cookies and server access logs, by us or by the service providers described in section 8. This includes your IP address, your browser and device type, the pages you view and the page you came from.

(3) People who contact us

  • Through the form on the Contact page: your first name, last name, email address and message, and the room you are asking about if you enter it
  • By email: the name, email address, organisation, content of the enquiry and any other information included in the email

(4) Business partners, property owners and job applicants

Please see the Company's privacy policy (https://seiraigroup.jp/en/privacy/).

Special care-required personal information

Except where permitted by law, we do not acquire special care-required personal information (personal information specified by law as requiring special care in its handling, such as race, creed, social status and medical history) without the prior consent of the individual.

2. Purposes of use

We use the personal information we acquire within the following purposes. Except where permitted by law, we do not use it beyond these purposes without the individual's consent.

(1) Guests

  • To accept, confirm, change and cancel reservations
  • To prepare and keep the guest register and otherwise meet our legal obligations
  • To handle check-in
  • To provide information needed for the stay, including how to enter the accommodation
  • To respond to enquiries and requests before, during and after the stay
  • To personalise stays using the answers guests give to the trip questions during online check-in
  • To invoice, settle charges and make refunds
  • To operate the accommodation, including cleaning, inspection and handling lost property
  • To contact guests and respond if an accident, a problem, damage to the facilities or a similar event occurs
  • To prevent crime, keep guests and the property safe, and check the facts if an incident occurs, using security camera footage from entrances and similar areas
  • To review enquiries, feedback, reviews and questions asked on in-room tablets and in the online guidebook, so that we can improve our accommodation, guidebooks and services
  • To ask for your feedback or a review after your stay

(2) Visitors to the Website

  • To display the Website and deliver its images and videos
  • To keep the Website secure and working properly
  • To understand how visitors use the Website, through statistics such as the number of visits and the pages viewed, and to improve it

(3) People who contact us

  • To reply to enquiries and make any contact needed for that purpose
  • To keep a record of enquiries and our responses

(4) Business partners, property owners and job applicants

Please see the Company's privacy policy (https://seiraigroup.jp/en/privacy/).

Retention

We keep personal information for the period needed to achieve the purposes of use and for any period required by law. The guest register is kept for three years from the date it is made, as required by law. Records of messages with guests are currently kept without a set period, so that enquiries after a stay can be answered. We are setting a retention period for each type of information. Information that is no longer needed is erased or disposed of by appropriate means.

Information collected through Google Analytics and the other services described in section 8 is kept for the periods set in each service.

3. Provision to third parties

Except in the following cases, we do not provide personal data to third parties without the prior consent of the individual.

  1. Where the provision is based on laws or regulations (for example, responding to an enquiry made under the law by an investigative authority)
  2. Where necessary to protect a person's life, body or property and it is difficult to obtain the individual's consent
  3. Where especially necessary to improve public health or to promote the healthy development of children and it is difficult to obtain the individual's consent
  4. Where necessary to cooperate with a national government body, a local government or a person entrusted by either of them in carrying out duties prescribed by law, and obtaining the individual's consent would be likely to impede those duties
  5. Other cases permitted by the Act

The following do not constitute provision to a third party. However, where we entrust the handling of personal data to a business in a foreign country, section 5 applies.

  • Entrusting the handling of personal data within the scope necessary to achieve the purposes of use (see section 4)
  • Provision in connection with the succession of a business as a result of a merger or otherwise
  • Joint use: at accommodation that we run on behalf of a property owner, we jointly use personal data as follows. (a) Items: name, address, contact details, nationality and passport number (for foreign nationals with no address in Japan), dates of stay, number of guests and the other items recorded in the guest register. (b) Joint users: the owner of that property. (c) Purposes: preparing and keeping the guest register and other steps required by law, and running and managing the property. (d) Party responsible: the Company (name, address and representative as in section 9).

4. Entrustment

We may entrust all or part of the handling of personal data to external businesses within the scope necessary to achieve the purposes of use. When we do so, we select businesses that handle personal information appropriately, set out the matters necessary for its security in contracts or otherwise, and supervise them as necessary and appropriate.

The main categories of entrustment are as follows.

  • Reservation and room management systems (including the exchange of reservation data with booking sites)
  • Email, document, spreadsheet and other business cloud services
  • The infrastructure on which online check-in and our other business systems run (server, database and file storage services)
  • Services used to run the Website (hosting, content management, image and video delivery, and the contact form)
  • AI services used to answer guests' questions, draft replies and translate (used under contracts or settings that keep the information entered from being used to train the AI)
  • Messaging services used for communication between staff
  • Payment services
  • Contractors for cleaning, linen and similar work (where this work is outsourced)
  • Tax accountants and other professionals

Booking sites are not our contractors. Information held by each booking site is handled under that site's own terms.

5. Provision of personal data to third parties in foreign countries

Some of the contractors described in section 4 are located outside Japan, and personal data may be handled in a foreign country.

  • Countries: the United States, Singapore and others. A full list of the countries is available on request. Where a provider does not tell us which country its servers are in, we will tell you on request what we know about the possible countries.
  • Contractors: providers of cloud, AI, messaging and website services. The providers used for the Website are named in section 8. The names of the others are available on request.

When we entrust the handling of personal data to a business in a foreign country, we ensure by contract or similar means that the business has a system that meets the standards set by the rules of the Personal Information Protection Commission, and take the steps needed to ensure that equivalent measures continue to be taken. On request, we will provide information about those steps.

6. Security measures

We take, or are putting in place, the following measures to prevent the leakage, loss or damage of personal data and otherwise to keep it secure.

  1. Basic policy: We have established this policy to ensure the proper handling of personal data.
  2. Handling rules: We are putting in place rules covering the methods of handling, the persons responsible and in charge, and their duties, at each stage of acquisition, use, storage, provision, deletion and disposal.
  3. Organisational measures: We have appointed a person responsible for the handling of personal data, and defined which employees handle personal data and the scope of the data they handle. We are putting in place a reporting line for any fact or sign of a breach of the law or our rules, and regular checks of how personal data is handled.
  4. Human measures: We are putting in place training for employees on points to note in handling personal data, and confidentiality obligations concerning personal data in our work rules or similar documents.
  5. Physical measures: Guest registers and passport copies are kept as electronic data in systems that only authorised staff can open. Together with the handling rules, we are putting in place measures to prevent the theft or loss of equipment, electronic media and documents containing personal data, and viewing by unauthorised persons.
  6. Technical measures: We control access so as to limit the persons who handle personal data and the scope of the databases they handle. We encrypt communications and use services that have protection against unauthorised external access.
  7. Understanding the external environment: We handle personal data in the United States, Singapore and other countries. We take these security measures, or are putting them in place, with an understanding of those countries' systems for the protection of personal information.

Where a leak or other incident involving personal data occurs and falls within the cases specified by law, we report it to the Personal Information Protection Commission and notify the individuals concerned, in accordance with the law.

7. Requests for disclosure, correction, suspension of use, etc.

You, or your representative, may make the following requests concerning our retained personal data, as provided in the Act.

  • Notification of the purposes of use
  • Disclosure (including provision as an electronic record)
  • Disclosure of records of provision to third parties
  • Correction, addition or deletion of content
  • Suspension of use or erasure
  • Suspension of provision to third parties

You may ask for suspension of use, erasure or suspension of provision to third parties where we handle your data in breach of the Act, where we no longer need to use it, where a leak or similar incident that the law requires us to report has occurred, or where our handling of it is likely to harm your rights or legitimate interests.

(1) How to make a request

Please email the contact point in section 9 with your name, how we can reach you, which of the requests above you are making, and the reservation (reservation number and dates of stay) or enquiry it concerns. We will reply by email with the identity documents we need, as set out in (2), and how to send them.

(2) Identity verification

To confirm your identity, we will ask you to submit a copy of a driving licence, passport or other identity document. If a representative makes the request, please also submit a letter of authorisation (or, for a legal representative, a document proving that status) and a copy of the representative's own identity document. If a document you submit shows an Individual Number (My Number), please cover that number before submitting it. Please send the copies by the method we tell you.

(3) Fees

We charge no fee for requests for notification of the purposes of use or for disclosure (including disclosure of records of provision to third parties).

(4) How we respond

In accordance with the law, we respond by the method you specify (such as provision of an electronic record or delivery of a document). Where disclosure by that method would involve considerable cost or is otherwise difficult, we respond by delivering a document.

(5) Where we may be unable to comply

We may be unable to comply with all or part of a request for disclosure in the following cases.

  • Where compliance is likely to harm the life, body, property or other rights or interests of you or a third party
  • Where compliance is likely to seriously interfere with the proper conduct of our business
  • Where compliance would violate other laws

We may be unable to comply with a request for correction, suspension of use or the like where the requirements set by law are not met. If we do not comply with all or part of a request, we will notify you of that and the reasons.

Because the law requires the guest register to be kept, we may be unable to erase it during the retention period. For information held by a booking site, please contact that booking site.

8. Cookies, analytics and access logs (this website)

This section covers the Website (https://www.acoe.jp/). It does not cover our booking page (booking.acoe.jp or beds24.com) or the other sites that the Website links to.

Cookies are small text files that a website stores in your browser. The Website has no login, accounts or payments.

Google Analytics

  • We use Google Analytics 4, a service of Google LLC (United States), to understand how visitors use the Website.
  • Google Analytics uses cookies named _ga and _ga_TNLB994193 to tell visits and visitors apart. It collects information such as the pages you view, the time spent on them, the page you came from, your browser and device type, and your approximate location, which is estimated from your IP address.
  • We use this information as statistics to improve the Website. Google handles the information it collects under its own policies. For details, see Google's page How Google uses information from sites or apps that use our services.
  • To stop Google Analytics from collecting information about your visits, you can install the Google Analytics Opt-out Browser Add-on. You can also block or delete cookies in your browser settings.

Videos

  • Videos on the Website are streamed from Mux (Mux, Inc., United States).
  • The Mux video player sets a cookie named muxData, which holds a random viewer ID and session details, and sends information about playback to Mux, such as your browser and device type and how the video loaded and played. Mux uses your IP address to estimate your approximate location. This information is used to measure the quality of video playback.
  • The player also loads Google Cast software from Google's servers (www.gstatic.com). This software is used to play a video on a compatible device, such as a TV. When this software loads, Google's servers receive your IP address and basic information about your browser.

Images and other files

  • Images on the Website are stored in Brease, the content management system used to build the Website, which is made by Designatives (Hungary). Most images reach your browser through our hosting provider, Vercel, described below. Some images are delivered directly from Brease's servers, and the preview images for videos are delivered from Mux. As with any web server, these servers receive your IP address and basic information about your browser when they deliver an image.
  • The Website also loads an animation player file from jsDelivr (cdn.jsdelivr.net), a public content delivery network. Its servers also receive your IP address and basic information about your browser.

Hosting and access logs

  • The Website is hosted on Vercel (Vercel Inc., United States). The hosting provider's servers may record access logs, including visitors' IP addresses, for purposes such as security. These logs are handled under the provider's own privacy policy.

Contact form

  • The form on the Contact page asks for your first name, last name, email address and message. You may also enter the room you are asking about.
  • The form is processed by Getform (getform.io), an outside form service, which receives and stores what you send so that we can read and answer it.
  • We handle this information as described in sections 1(3) and 2(3). You can also contact us by email at office@acoe.jp.

Other tools

  • Apart from the services described in this section, the Website uses no analytics or advertising tools as at the date shown at the end of this policy. If we introduce any, we will revise this section.

Links to other sites

  • The "Book Now" links take you to our booking page, which runs on the reservation system of Beds24. Depending on the link, the page opens at booking.acoe.jp or at beds24.com. You enter your reservation and payment details on that page, not on the Website. We handle reservation details as described for guests in sections 1(1) and 2(1). Payment is made through a payment service, and we do not keep card numbers.
  • The Website also links to other external sites, such as Instagram, Airbnb and Designatives. Personal information on those sites is handled under the terms of each site's operator.

9. Company information and contact point

Please send questions, complaints and enquiries about our handling of personal information, and requests for disclosure and the like, to the contact point below. We ask that you contact us by email.

  • Name: Seirai Group Japan Ltd. (株式会社セイライグループジャパン)
  • Address: 9F Iidabashi Grand Bloom, 2-10-2 Fujimi, Chiyoda-ku, Tokyo 102-0071, Japan
  • Representative: ASAWA SIRIKAN, Representative Director
  • Corporate Number: 5011103009014
  • Email: office@acoe.jp
  • Person responsible for personal information: Representative Director
  • Accredited personal information protection organisation: We are not a covered business of any accredited personal information protection organisation.

10. Revisions and dates

We may revise this policy in response to changes in the law, changes in our business or as otherwise necessary. Unless otherwise stated, a revised policy takes effect when it is posted on the Website. However, where the law requires the individual's consent for a change, we will obtain that consent.

  • Established: 10 October 2026
Our guest reviews in numbers

Superhost and 7 years hosting

On Airbnb
Our Airbnb profile, Oct 2026

9.4 out of 10 on Booking.com

Average of 581 guest reviews
ACOE's own count, Oct 2026

4.91 out of 5 on Airbnb

969 reviews
Our Airbnb profile, Oct 2026

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