Privacy Policy

1.Purpose of collecting personal information

Personal information obtained from customers will be used for the following purposes. And we will not use the personal information of customers in any way that may promote or induce illegal or unjust acts, even within the scope of the following purposes of use.

1. Acceptance of applications, provision and contact regarding services/products, etc. offered by the Company
2. Notices, operation and management of various events and campaigns, provision of a variety of information, distribution of questionnaires to customers
3. Development of new services/products, etc.
4. Notices, operation and management regarding services/products, various events and campaigns handled by ANA Group companies/business partners, etc., provision of a variety of information, distribution of questionnaires to customers, development of new services/products, etc.
5. Business management/internal management by the ANA Group
6. Responses to inquiries and requests, etc.

• In addition to the above-mentioned purposes, personal information will be utilized for the purposes described in "4. Data sharing."

2.Collecting personal information

The Company will obtain the following customers' personal information by fair and appropriate means in order to achieve the previously mentioned purposes.

Name, date of birth, telephone number, email address, place of employment, gender, details of transaction, etc.

3.Disclosure to third parties

ANA HOLDINGS will not disclose or provide personal customer information including "sensitive information" to any third parties except under the following circumstances. "Sensitive information" is such as race, beliefs, social standing, history of illness, crime records, and history of having been afflicted by crime. 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 as a result of the succession of business due to a merger, company split, transfer of business or otherwise.
7. 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 HOLDINGS 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

4.Data sharing

ANA HOLDINGS shall share personal customer information as follows.

Scope of Data Sharing

ANA Group companies
For details, see here

Purpose of use by the user

1. For provision of air transportation services, travel services including tours and hotels, and other products/services handled by the Company or companies that share data
2. For sending of direct mail and information on products/services, and distribution of questionnaires 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 the Company or companies that share data
4. For delivery and transfer of data to each company in charge, when we receive inquiries, application for use or other offers from customers regarding products/services provided by the Company or companies that share data
5. For appropriate and smooth fulfillment of other transactions with customers by the Company or companies that share data
6. For business management/internal management by the ANA Group

Items of personal information to be shared

Name, date of birth, address, telephone number, email address, place of employment, gender, details of transaction, etc.

Name, address, and representative of the party responsible for management of personal information

ANA HOLDINGS INC.
Shiodome City Center, 1-5-2, Higashi-Shimbashi, Minato-ku, Tokyo, Japan 105-7140
Koji Shibata,
President & Chief Executive Officer

5.Business entrustment

From time to time, ANA HOLDINGS may entrust its business operations to third parties to which personal information may also be disclosed to the extent required. In these cases, we will implement all appropriate measures with such third parties to safeguard the confidentiality of customer data, including establishing agreements on the handling of such personal information.

6.Transfer to outside of Japan

If ANA HOLDINGS will provide customers' personal information to third parties such as business operators outside of Japan, including companies to whom we have entrusted business and our data sharing partners, we will do so with the consent of the customer except in the following cases:

1. (1) The third party is in a country stipulated by law as a country that has a personal information protection system that is of an equivalent level to Japan; or
2. (2) The third party has established the necessary system to continuously take measures equivalent to the measures that should be taken by Japanese business operators handling personal information.

In the case of (2), we will take necessary and appropriate measures to ensure the continuous implementation of such equivalent measures by the third party. If you would like to confirm the contents of our measures, please submit a request in accordance with "About disclosure, correction, deletion, addition, discontinuation of use, erasure, and provision of information on personal information protection measures".

7.Managing personal information

We will manage our customers' information appropriately and take the security management measures necessary to prevent leaks, loss, alteration, etc. We will provide in-house training to officers and employees regarding the protection and proper handling of personal information. And will separately establish a retention period for personal information in accordance with its purpose of use, and will dispose of such information in an appropriate manner following the expiration of such retention period. If you would like to know about our security management measures in more detail, please submit a request in accordance with "About disclosure, correction, deletion, addition, discontinuation of use, erasure, and provision of information on personal information protection measures".

• Please refer to "ANA Group Information Security" for information about our information security measures and policy.

8.About disclosure, correction, deletion, addition, discontinuation of use, erasure, and provision of information on personal information protection measures

We will respond to customer requests for: (1) the disclosure; (2) the correction, deletion, or addition; (3) the discontinuation of use or erasure; or (4) provision of information on personal information protection measures, in relation to your personal data retained by ANA Holdings, within a reasonable timeframe and scope.

A customer request may be rejected partially or entirely if compliance with such request would endanger the life, health, or property of the customer or a third party; seriously impact ANA HOLDINGS's business operations; or result in a violation of laws or regulations.

1. We will disclose the items of personal information and the purpose of use or records of provision to third parties
2. Correction, deletion, or addition shall be undertaken as necessary after due review of requests.
3. Discontinuance and erasure shall be undertaken by appropriate methods. However, we remind customers that such requests may impede the provision of services to the customer, despite our best intentions.
4. We will provide the following information on personal information protection measures in accordance with the content of the request:
   1. 1) The contents of the security management measures taken when we are entrusted with customers' personal information; and
   2. 2) The contents of measures taken when we provide customers' personal information to a third party outside of Japan (when item (2) of "Transfer to outside of Japan" is applicable).

9.Inquiries and submission of requests for disclosure, etc.

Please direct requests for the disclosure, correction, deletion, addition, discontinuation of use, erasure, and provision of information on personal information protection measures relating to your personal data retained by ANA Holdings to the following contact:

10.Application and modification of the Privacy Policy

This Privacy Policy explains how ANA HOLDINGS handles personal customer information. Use of ANA HOLDINGS services and products by a customer is deemed to constitute full understanding of and consent to the terms of this Privacy Policy.

This Privacy Policy is subject to revision by ANA HOLDINGS at any time. In this case, the revised Privacy Policy shall be effective from the time it was notified to customers via our prescribed method or posted on the ANA Holdings website.

(Revised on April 1, 2022)

1.Purpose of Collecting Shareholders' Personal Information

The personal information of shareholders is used for the following purposes. And we will not use the personal information of shareholders in any way that may promote or induce illegal or unjust acts, even within the scope of the following purposes of use:

1. To facilitate the exercise of rights and fulfill our obligations under the Corporation Law of Japan
2. To provide benefits from ANA Group companies to people holding the position of shareholders
3. To take measures for shareholders to facilitate a smooth relationship between shareholders and the Company
4. To manage shareholders' information, through such means as compiling shareholder data according to prescribed standards set forth in laws and regulations
5. Notices, operation and management regarding services/products, various events and campaigns handled by ANA Group companies etc., provision of a variety of information, distribution of questionnaires to customers, development of new services/products, etc.
6. Business management/internal management by the ANA Group.
7. Responses to inquiries and requests, etc.

• In addition to the above-mentioned purposes, personal information will be utilized for the purposes described in "4. Shared Use of Shareholders' Personal Information."

2.Types of Shareholders' Personal Information to Be Acquired

The Company will obtain the following shareholders' personal information by fair and appropriate means in order to achieve the previously mentioned purposes.

Name, address, number of shares held, date of share acquisition, email address, shareholder's benefit number, etc.

3.Shared Use of Shareholders' Personal Information

We may share the use of personal information we collect from shareholders according to the following conditions.

Scope of parties with whom we may share the use of personal information:

ANA Group companies
For more details, click here.

Purpose of use of parties with whom we share information:

1. For provision of air transportation services, travel services including tours and hotels, and other products/services handled by the Company 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 the Company or companies that share data
4. For delivery and transfer of data to each company in charge, when we receive inquiries, application for use or other offers from customers regarding products/services provided by the Company or companies that share data
5. For appropriate and smooth fulfillment of other transactions with customers by the Company or companies that share data
6. For business management/internal management by the ANA Group

Items of personal information to be shared

The shareholder's name, address, number of shares held, date of share acquisition, email address, shareholder's benefit number, etc.

Name, address, and representative of the party responsible for management of personal information

ANA HOLDINGS INC.
Shiodome City Center, 1-5-2, Higashi-Shimbashi, Minato-ku, Tokyo, Japan 105-7140
Koji Shibata,
President & Chief Executive Officer

4.Contact Information for Inquiries

The following procedures are necessary based on laws or regulations, depending on the nature of the inquiry. We appreciate your understanding but we are unable to accept inquiries in person.