ANA 私隱政策
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截至 2026 年 4 月 1 日
第 1 章描述我們如何處理所有客戶的個人資料。第 2 章、第 3 章、第 4 章和第 5 章是分別為身處或居住在歐洲經濟區/英國、中華人民共和國、美國加利福尼亞州和泰國的客戶提供的有關特定地區的資料。
第1章 ANA 對客戶個人資料的處理
1. 簡介
本私隱政策說明 ALL NIPPON AIRWAYS CO., LTD （下稱「ANA」、「我們」或「我們的」）取得客戶和其他人士之個人資料的方法及原因。閣下在向 ANA 提供個人資料或使用我們的產品或服務前，請仔細閱讀本私隱政策。
本私隱政策的第 1 章概述我們如何使用您的個人資料。
其他補充政策可能適用於特定 ANA 產品或服務，詳情將另行提供，或列於該等產品或服務的條款內。
對於居於日本的客戶，第 1 章中的「個人資料」是指與在世自然人有關的資料，其中包含 (i) 姓名、出生日期或其他識別號碼或同樣可用於識別特定個人的信息，或 (ii) 個人識別碼。
2. 適用範圍
本私隱政策於客戶和其他人士向 ANA 提供個人資料或使用 ANA 的服務和產品時適用。
3. 個人資料的用途
ANA 向客戶收集的個人資料將用於以下用途。然而，即使在下述用途之範圍内，ANA 亦不會在有可能鼓勵或導致非法或不當行為的情況下使用客戶之個人資料。
- (1) 與航空運輸服務相關的預訂、機票銷售、登機手續、機場服務及機上服務
- (2) 聯航運輸、共同承運、代碼共享、連續承運及委託承運相關之預訂、機票銷售、登機手續及機場服務
- (3) 為 ANA Mileage Club（里數俱樂部）會員提供服務
- (4) 就 ANA 服務/產品之使用情況進行研究與分析
- (5) 與上述（1）至（4）項相關或附帶之一切作業
- (6) 就 ANA 所提供的服務和產品等進行問卷調查
- (7) 新服務和產品開發
- (8) 就 ANA 提供的服務和產品作出通知
- (9) ANA、ANA 集團公司、合作夥伴公司等所實施的活動、以及推廣活動之營運和管理
- (10) 就 ANA、ANA 集團公司、合作夥伴公司等服務、產品、各種活動及推廣活動提供資訊，以及透過郵寄、電子郵件通訊、通知和廣告等方式發送各種資訊
- 客戶的個人資料（ANA、ANA 集團公司等服務和產品的使用詳情、ANA 網站及流動應用程式瀏覽紀錄的分析數據等）可能會經由人工智能（AI）等進行分析，以推測客戶的興趣、品味、購買傾向和特徵等，分析結果將用於制定針對客戶投放的廣告以及市場推廣策略。
- (11) 回覆查詢和請求
- ANA 可能會使用人工智能及其他技術分析客戶的查詢、請求、對話及口述內容，並將其用於向客戶提供的客戶支援服務。
除上述（1）至（11）項用途外，個人資料亦將用於以下第 1 章第 8 條（資料共享）中所述的用途。
4.個人資料的取得
ANA 為達成上述用途，將以公平和適當的方式取得下列個人資料。
(1) 身份、聯絡和付款資料等
客戶的姓名、地址、電話號碼、傳真號碼、電郵地址、就業資料（公司名稱、所屬的部門／單位、職位、地址、電話號碼、傳真號碼）、郵寄地址、護照資料、與登機相關的健康和醫療資料、飲食限制、付款資料（包括信用卡/扣帳卡及其他付款方式之詳細資料）等。
(2) 旅遊資料
旅遊計劃和安排之詳情，包括 ANA 和其他航空公司的航班資訊、住宿和其他交通安排等。
(3) 客戶的 ANA 里程俱樂部會員資訊及合資格服務之使用資訊
客戶的 ANA 里程俱樂部會員號碼、會員卡類別、會員狀態、會籍區域、里數狀態、信用卡號碼及到期日、信用卡
使用紀錄及相關資料、輪椅服務或其他特別安排的需求、航班預訂和取消資料，以及有關航班和其他服務的使用紀錄等。
(4) 向 ANA 之查詢和投訴詳情
可識別個人身份之語音錄音或其他類似資訊（例如包含個人姓名或其他可識別個人身份之資料）。
- 我們可能會監控、記錄、儲存和使用與您透過電話、電郵或其他方式進行的通訊，以核對向我們所作之指示，以及作培訓、預防犯罪以及提高客戶服務質素之用。
(5) IT 和系統資料，包括有關 ANA 網站和流動應用程式之使用資訊
有關客戶瀏覽 ANA 網站和流動應用程式的資料，包括 Cookie 、廣告識別碼（IDFA/GAID）、位置資訊、裝置唯一識別碼、IP 位址、作業系統和瀏覽器類型等資訊，以及 ANA 網站活動紀錄等可用於識別特定個人的資料。
（如要了解使用 Cookie 之用途和其他相關事項的詳情，請參閱 ANA Cookie 政策內的「3. 使用 Cookie 的目的」等）
除非法律法規要求或已取得客戶同意，否則 ANA 絕對不會獲取及使用屬於客戶的敏感資料（下稱「敏感資料」），例如涉及種族、信仰、社會地位、病歷、犯罪紀錄，以及犯罪受害紀錄之資訊。
5.獲取與個人資料相關之資訊
ANA 可能會直接從客戶、第三方或 ANA 集團公司取得與客戶個人資料相關的資訊。第 1 章中的「與個人資料相關的資訊」是指與個人有關的信息，並不屬於日本《個人情報保護法》（2003 年第 57 號））所定義的個人資料、化名個人資料或匿名化個人資料。
（個人資料相關之資訊範例）
如「4.個人資料的取得」「(5) IT 和系統資料，包括有關 ANA 網站和流動應用程式之使用資訊」所列出的Cookie、廣告識別碼（IDFA/GAID）、位置資訊、裝置唯一識別碼和IP 位址的資訊，而ANA 無法憑這種方式識別特定個人身份的資訊。
（取得個人資料相關之資訊的範例）
從第三方或 ANA 集團公司取得廣告識別碼以進行廣告發佈。
如果我們將上述與個人資料相關之資訊連結至 ANA 或 ANA 集團公司所持有的客戶個人資料並作為個人資料使用，則我們將事先徵得客戶的同意，並根據其目的適當處理該資訊。並依「3.使用個人資料的目的」中所列的用途（除非另行載明）適當處理該等資料。
6.客戶的選擇
原則上，ANA 會在獲得客戶同意後方會取得其個人資料。客戶如拒絕提供其個人資料，有可能會引起不便，例如無法使用某些由 ANA 提供的服務，或因部分系統功能無法運作而未能接收推廣活動通知及其他有關ANA的資訊。客戶可隨時透過 ANA 另行指定的方式，更改其聯絡資料及是否接收電子郵件通訊之選擇。
7.向第三方披露和提供資訊
(1) ANA 向第三方披露或提供客戶個人資料時之一般原則
除下述情況外，ANA 不會向任何第三方披露或提供個人客戶資料。此外，除非法律和法規允許，或已獲得客戶同意；否則在任何情況之下，包含敏感資料的客戶個人資料，都不會向第三方披露或提供。為免生疑，基於資料共享或業務受託而提供的資料，均不視為向第三方披露或提供。
- 已取得客戶同意。
- 在法律或法規允許之範圍內、必須披露或提供。
- 為保障性命、健康或財產，且難以取得客戶同意。
- 為配合國家或當地政府執行公共事務，且取得客戶同意有可能會妨礙該等事務之執行。
- 以數據統計方式（透過不披露客戶身分之形式）披露或提供資料。
- 通過合併、公司分拆、業務轉讓或其他方式進行的業務承繼所引致的資料提供。
- 依照法律和法規所定程序提供資料，且滿足以下條件，而客戶並未表明拒絕提供之意願（客戶可自行透過 ANA 網站查看以下條件）：
- 取得資料的目的在於向第三方提供
- 特定個人資料項目將提供予第三方的
- 此類個人資料提供予第三方的方式
- 資料提供可依照客戶要求暫停
- 受理客戶請求之方式
(2) ANA 可能披露或提供個人資料之第三方
ANA 可能會向以下類別的接收者披露或提供客戶個人資料。
- 關聯機構：ANA 可能會向 ANA 集團旗下公司以及與 ANA 集團相關之組織披露或提供客戶個人資料。
- ANA 之員工：ANA 可能會向獲授權且因業務需要而需存取該等資料的 ANA 員工披露或提供客戶個人資料。
- 服務供應商：ANA 可能會向執行某些服務的第三方服務供應商披露或提供客戶個人資料，包括資訊科技服務供應商（包括數據伺服器和雲端服務供應商）、數據分析服務供應商、廣告發佈服務供應商和法律顧問等。
8.資料共享
ANA 可能會在以下情況共享客戶個人資料。
| 共享資料之實體範圍 | ANA 集團公司 (English only) |
|---|---|
| 使用者使用資料之用途 |
|
| 共享的個人資料項目 | 客戶的 ANA 里程俱樂部會員號碼、客戶的姓名、地址、電話號碼、傳真號碼、電郵地址、就業資料（公司名稱、所屬的部門／單位、職位、地址、電話號碼、傳真號碼）、郵寄地址、護照資料、與登機相關的健康和醫療資料、飲食限制、付款資料（包括信用卡/扣帳卡及其他付款方式之詳細資料）、旅遊計劃和安排之詳情，包括 ANA 和其他航空公司的航班資訊、住宿和其他交通安排等、會員卡類別、會員狀態、會籍區域、里數狀態、信用卡號碼及到期日、信用卡使用紀錄及相關資料、輪椅服務或其他特別安排的需求、航班預訂和取消資料、有關航班和其他服務的使用紀錄等、與客戶往來通訊中之查詢、請求及投訴之詳情、使用 ANA 網站及行動應用程式之資訊（包括 Cookie 及網站活動紀錄等）。 |
| 個人資料管理責任方之名稱、地址和代表人 | ANA Holdings Inc. 地址：Shiodome City Center，1-5-2，Higashi-Shimbashi，Minato-ku，Tokyo，Japan 105-7140 代表人：芝田浩二（總裁兼行政總裁，President & Chief Executive Officer） |
9.業務委託
於向客戶提供產品和服務時，ANA 有可能會將部分業務委託予第三方辦理，並會於達成委託目的之所需範圍內向該等第三方提供個人資料。 在這些情況下，ANA 會採取適當的措施以管理和監督此等第三方，以保護客戶個人資料的處理，當中包括達成有關處理個人資料之協議。
10.轉移至日本境外
因應客戶的航班目的地，ANA 可能會將其個人資料（姓名、護照號碼和旅程資料等）轉移至日本境外。您可在 ANA 網站上找到 ANA 提供服務的國家/地區。該等資料之接收地的個人資料保障制度，可能與日本並不相同。
如果 ANA 向日本境外的第三方業務運營商（包括委託公司和資料共分合作伙伴）提供客戶個人資料，ANA 將會先徵求客戶同意，惟以下情況除外：
- (1) 該第三方位於法律和法規指定，具備與日本等同的個人資料保護制度的國家；或
- (2) 該第三方已建立相應的制度，使其可持續實行相當於日本業務經營者處理個人資料時應當採取的相關措施。
在上述情況 (2) ，ANA 將採取必要和適當的措施，確保第三方持續採取相應措施。如要了解 ANA 的具體措施的詳情，請根據「12.就處理個人資料的相關請求」提出有關申請。
11.個人資料的管理
ANA 在接收客戶的個人資料時，將妥善地管理，並會採取必要的安全管理措施以防止資料外洩、遺失或變更。ANA 會確保董事會成員和員工獲得適切的培訓，以保障可識別個人之資訊的安全。ANA 將根據此類資料的用途，制定個人資料的適當保留期限。在達成使用資料的用途後， ANA 將以適當的方式刪除有關資料。
如要了解安全管理措施的詳情，請根據「12.就處理個人資料的相關請求」提出申請。
- 關於 ANA 的資訊安全行動政策，請參閱「ANA 集團資訊安全 (English only)」。
12.就處理個人資料的相關請求
如果ANA 接獲客戶以指定方式提出之請求，就其儲存於由 ANA 之資料庫中的個人資料提出的披露、更正、刪除、補充、停止使用或清除的申請，或要求我們就「10.轉移至日本境外」和「11.個人資料的管理」
（下稱「披露資料等」）的個人資料保護措施的有關資訊，ANA 將按照相關法律和條例，於合理的時間及範圍內處理該請求，並在確認申請確實由客戶本人提交後辦理。
(1) 披露請求
個人資料項目、用途、或向第三方提供個人資料的紀錄，將會按客戶的申請而披露。
(2) 修正、刪除或補充請求
ANA 將在經過適當審批後，對個人資料進行修正、刪除或補充。
(3) 停止使用或清除請求
如有需要，ANA 會依照所提交的申請，停止使用客戶指定的個人資料項目，並且清除其相關資訊。請留意，該等要求可能會導致客戶無法享用既有的服務，或可能妨礙我們按客戶的需求提供服務。
(4) 提供個人資料保護措施的有關資訊之請求
我們將按照客戶的申請提供以下資料。
- ANA 接收客戶的個人資料時，所採取的安全管理措施詳情
- ANA 向日本境外的第三方提供客戶個人資料時，所採取的措施詳情（如屬「10.轉移至日本境外」(2) 項情形）
如果滿足上述的請求可能對 ANA 的業務運營造成嚴重影響、導致違反法律和法規、或妨礙個人資料的安全管理，則 ANA 可能無法滿足客戶的請求。
13.提交披露請求等
向 ANA 提出披露個人資料等請求或個人資料用途通知（「披露請求等」）的提交方式和聯絡資訊如下。
披露請求等
(1) 提出請求的方式
如果您希望透過郵寄方式接收披露請求的回覆
請將所需文件郵寄至以下地址。
地址：
ALL NIPPON AIRWAYS CO., LTD. Personal Information Handling Desk
1-331-90 Kaminoshima-cho，Nagasaki-shi，Nagasaki，850-0078 Japan
如果您希望透過電子檔案方式接收披露請求的回覆
請透過 ANA 網站上的網上表格提交所需文件。
(2) 所需文件
確認個人身分所需文件等
- （個人申請）
- (1) 下列其中一項證明文件之副本：駕駛執照、護照、個人編號卡（僅正面）、身體障礙證明書、在留卡
- （代理人申請）
除了上述（個人申請）的其中一項外，並請提交下列 (1) 和 (2) 中所述的文件。- (1) 授權書（法定代理人須另附證明文件）
- (2) 代理人之身分證明文件（下列其中一項的副本：駕駛執照、護照、個人編號卡（僅正面）、身體障礙證明書、在留卡
(3) 費用
費用將視乎申請類型而定。就多項訂位及搭乘資訊之披露，每一航班將被視為一項披露。根據不同國家的法律和法規規定，處理程序上可能有所不同。
- 有關 ANA 預訂確認、登機確認，以及更新 ANA 里程俱樂部會員資料等事宜，請透過 ANA 網站 (www.ana.co.jp) 或 ANA 電話客服中心辦理。 ANA 僅於能確認客戶身分之情況下，相關請求方得以受理。
14.停用 Cookie 及廣告識別碼
- (1) 停用 Cookie
詳情請參閱 ANA Cookie 政策內的「5. 停用 Cookie」。 - (2) 停用廣告識別碼
ANA 會獲取並使用廣告識別碼（Apple iOS 為「廣告商識別資料 (Identification For Advertisers, IDFA)」；Google Android 操作系統等則為「Google 廣告 ID (Google Advertising ID, GAID)」）
如欲停止以該等廣告識別功能投放廣告，請前往 iOS（外部網站）或 Android（外部網站）於裝置進行下列設定：
15.本私隱政策之修訂
ANA 可能會修訂本私隱政策的內容。如有修訂，詳情將於 ANA 網站 (www.ana.co.jp) 上公佈。
ALL NIPPON AIRWAYS CO., LTD.
井上慎一，ANA 總裁兼首席執行官
Shiodome-City Center, 1-5-2, Higashi-Shimbashi, Minato-ku, Tokyo 105-7140, Japan
Chapter 2. Handling of personal data of EEA and UK residents by ANA
1. Introduction
This Chapter 2 provides additional information about the handling of personal data of customers and other individuals in the European Economic Area ("EEA") and/or the United Kingdom ("UK") in accordance with EU General Data Protection Regulation 2016/679 ("GDPR") and the UK Data Protection Act 2018 ("DPA 2018") and other national and international data protection and privacy laws in the EEA and UK (collectively, "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.
The consent shall be given or authorized by the holder of parental responsibility in the event that a customer under the age of 16 uses ANA's service. Customer's consent to this Privacy Policy must be obtained in the event that a person such as family member applies for ANA's service on behalf of the customer.
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 data
The controller of your personal data is ANA.
ANA protects personal data which is collected and used by controllers (who make decisions about how and why your personal data is used) and processors (who act on the controller's written instructions) on the basis of Data Protection Laws.
3. Our legal basis for processing personal data
ANA protects your personal data 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 legal basis for each processing activity on the basis of Data Protection Laws.
ANA may process customer personal data on one or more of the following legal basis:
- (1) When your consent is obtained for 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 when we process customer information which is essential to providing our services, including a customer's identity, contact, payment and travel details, etc. - (3) When ANA needs to process the data to comply with a legal obligation (Article 6(1)(c)).
This includes the requirement to share personal data with customs and immigration authorities or law enforcement, as well as ANA's legal obligations towards its staff and customers. - (4) When the processing 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) When the processing of personal data is required for legitimate interests of ANA or a third party, and these interests are not overridden by your rights under Data Protection Laws (Article 6(1)(f) GDPR).
This includes the use of personal data necessary to operate ANA's business and also to maintain, develop and improve its goods and services and provide the best possible customer experience.
4. Request about processing of personal data
(1) Data Protection Laws provide you with the following legal rights:
- Request for access: You can request copies of your personal data and details of how we process it.
- Request for rectification: Rectifications to personal data will be undertaken where possible after due review of the request.
- Request for erasure: You may request that we erase all or part of the personal data we hold about you. We will consider your request and, where the personal data is no longer required or the law does not permit us to continue to retain it, we will erase it.
- Request for data portability: You can request a copy of your personal data in a structured, common, machine-readable format. This only applies to personal data 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.
- Objections to processing: You can object to processing which is carried out for ANA's or a third party's legitimate interests or for the purpose of direct marketing. We will cease processing customer's information unless we can prove any legitimate grounds to show that the legitimate interests override the customer's interests. If you object to direct marketing, we will cease the processing.
- Restrictions to processing: You can restrict our processing of the customers' personal data under certain circumstances. Where this applies, any processing of your personal data (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.
- Withdrawal of consent: If we rely on consent to process your personal data, 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 the 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 demonstrate that we have complied with the legal obligations.
(2) Method for submitting a 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 a request and contact information are as follows.
(Website)
Please send the required documents via the webform listed on ANA's website.
(Required documents)
(3) Responding to a request
We will respond without undue 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 data 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 goods or services
ANA's goods and services are provided with the assistance of other companies and organizations and often ANA will need to share personal data 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 is legally required to share personal data
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 whom we partner with, various service providers, providers with whom we have a marketing partnership, etc.
Where ANA 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 sends out marketing communications from time to time to notify interested persons of news and provide details of goods and services which may be of interest to them. ANA will only do this if the recipient has consented to receive marketing or if they are an existing customer who purchased goods or services from ANA and were given the opportunity to opt-out from marketing at the time but chose not to do so.
7. Where your personal data is stored and transferred
ANA is located in Japan and many of the service providers and other organizations with whom we share your personal data 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 data.
When transferring personal data to third parties ANA will ensure that it complies with the requirements of Data Protection Laws, including the EU-Japan adequacy decision and the onward transfer requirements under the related Japanese laws. However, please note 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 data is stored and transferred, please contact ANA using the details set out in Part 13 of this Chapter 1 ("Submission of a request for disclosure, etc.").
8. Retention of personal data
ANA retains customers' personal data until the purpose of use is achieved. Particularly, ANA has set the retention period for personal data as follows. For most other personal data, 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) Personal data of ANA Mileage Club membership
Until withdrawal of the ANA Mileage Club membership - (2) Personal data of passengers
Until completion of transportation and related services stipulated in Conditions of Carriage for Domestic Flights and Conditions of Carriage for International Flights - (3) Other personal data
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 data 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's Data Protection Officer
Controller: ALL NIPPON AIRWAYS CO., LTD.
Address: Shiodome City Center, 1-5-2 Higashi-Shimbashi, Minato-ku, Tokyo, Japan
Data Protection Officer email: dataprotection@ana.co.jp
- Please note that this e-mail address is for data protection related matters only.
- For requests for processing of personal data (access, erasure, rectification, etc.), please refer to Part 4 of this Chapter 2 (Request about processing of personal data, (2) Method for submitting a request).
- For inquiries regarding reservations, tickets, baggage, ANA Mileage Club, services, etc., please access Contact Information in Each Region and ANA Branch Office.
- Please choose your city and language.
Chapter 3. Handling of personal information of China residents by ANA
Besides Chapter 1, Chapter 3 also applies to the handling of personal information of persons residing in the People's Republic of China (hereinafter, "China") based on China's Personal Information Protection Law and related regulations (hereinafter, "PIPL etc."). 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's service. In the event that a person such as a family member applies for ANA's service on behalf of the customer, the consent of the customer (when he/she is under the age of 14, his/her guardian) to this Privacy Policy must be obtained.
2. Collection of sensitive personal information
For the purpose of use, ANA may handle personal information that can be classified as sensitive personal information under PIPL etc., such as information about one's passport, health condition, payment, or accommodations.
Since sensitive personal information can negatively affect the interests of customers if it is leaked or used unlawfully (for example, it is likely that individual dignity will be damaged or that personal safety and asset security will be put at risk), ANA will carefully manage such information and handle it in a lawful manner.
3. Retention period for personal information
ANA will retain the customer's personal information until the purpose of use is achieved. In particular, ANA sets the retention period for personal information as follows.
- (1) Personal information of ANA Mileage Club membership
Until ANA Mileage Club membership cancellation - (2) Passengers' personal information
Until the completion of transportation and related work stipulated in the Conditions of Carriage for Domestic Flights and Conditions of Carriage for International Flights - (3) Other personal information
The shortest required period for the purpose to which customers have consented
4. Technology and measure to protect customers' personal information
- (1) ANA takes security measures to protect customers' personal information from leakage, alteration or loss. Specifically, ANA takes the following measures to protect customers' personal information.
- ANA establishes and implements an internal management system and operational rules relating to the protection of personal information.
- ANA conducts classification management for personal information.
- ANA 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 uses encryption technology for protecting personal information.
- ANA allocates access rights reasonably and controls access, so that access by unauthorized persons to personal information will be prevented.
- In order to raise employee awareness of the importance of protecting personal information, ANA provides education and training on security and privacy protection.
- ANA establishes and implements emergency response plans for personal information incidents.
- (2) ANA will take all reasonable and practicable steps to ensure that no irrelevant personal information is collected. ANA will only retain customers' personal information for the shortest period of time required to achieve the purposes stated in this Privacy Policy, unless an extension of the retention period is permitted by law.
- (3) In the event of a personal information incident, ANA will promptly inform customers of the relevant circumstances of the incident in accordance with the requirements of PIPL, etc. and report to the regulatory authorities.
5. Request about handling of Personal Information
In the event that ANA receives a request regarding the personal information it holds of a customer who is a resident of China, the request will be handled in a reasonable timeframe and scope in accordance with PIPL, etc. and Chapter 1 "Part 12 Request about handling of Personal Information". In responding to the request, ANA may confirm that it was submitted by the customer himself/herself.
(1) Request for withdrawal of consent
If the handling of the customer's personal information is based on his/her consent, the customer has the right to withdraw such consent.
Personal information items designated by the customer will be deleted in accordance with the customer's request, wherever possible and appropriate.
However, please note that such deletion 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/explanation of Privacy Policy
Customers have the right to ask for the interpretation/explanation of this Privacy Policy.
(3) Methods for submission of a request
Customers may submit a request by following methods.
1. Submission of a request
Website:
Please send the required documents via the webform listed on ANA's website.
2. Required documents
Application form
Documents required for confirmation of identification of individual, etc.
- (For individuals)
- (1) A Copy of one of the followings: Official ID Card with a photo, such as Driver's License, Passport, etc.
- (For representatives)
In addition to "(For individuals)," the following documents described in (1) and (2) below are required.- (1) Power of Attorney (legal representatives must provide a certifying document)
- (2) Documents to identify the representative (A Copy of one of the followings: Official ID Card with a photo, such as Driver's License, Passport, etc.)
3. Contact Desk
China
4008-82-8888
(Charged)
6. Provision to third parties and transfer outside China
When ANA provides personal information of customers to third parties (including the cases of provision due to shared use and business entrustment that involves the transfer of such information outside China), it will do so in accordance with PIPL, etc.
7. Change of purposes of use of personal information
In the case of a change to the purposes of use of personal information, ANA will announce the revised Privacy Policy in advance on ANA website (www.ana.co.jp) and ANA 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
ALL NIPPON AIRWAYS CO., LTD.
Address: Shiodome City Center, 1-5-2 Higashi-Shimbashi, Minato-ku, Tokyo, Japan
Chapter 4. Handling of personal information of California residents by ANA
Last updated on April 1, 2026
Besides Chapter 1, Chapter 4 also shall apply to the handling of personal information of persons residing in California, United States of America based on the California Consumer Privacy Act of 2018 as amended under the California Privacy Rights Act of 2020 (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" means ANA's selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information to a third party for monetary or other valuable consideration. The term "sharing" means ANA's sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration. However, if ANA concludes an appropriate agreement concerning the handling of personal information with 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 in the preceding 12 months or likely to be collected in the future is classified as defined in the following table. ANA uses such information for the purposes set forth in Chapter 1, Part 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, and ANA Mileage Club membership number (10 digit number), personal online identifier, etc. |
| Additional data subject to the California Customer Records statute (personal information categories in Cal. Civ. Code Sec. 1798.80(e)) | The customer's physical and medical information relating to flying, credit card number, and payment information including details of credit/debit card and other payment methods, etc. |
| Characteristics of protected classifications under California or federal law | The customer's dietary restrictions, etc. |
| Commercial information | The type of customer's ANA Mileage Club membership card, membership status, membership area, mileage status, credit card expiration date, usage history of credit card and related information, need for wheelchair or other special arrangement, flight reservation and cancellation information, usage history of flights and other services, details of travel plans and arrangements, including flights with ANA and other airlines, accommodations, and other transportation arrangements, information contained in correspondence with customers, details of inquiries, requests and complaints, etc. |
| Internet or other electronic network activity information | Information such as that on how customers use the ANA website and mobile application, including details on cookies, advertising identifiers (IDFA/GAID), location information, unique device identifiers, IP address, details on OS and browser type, etc., and website activity logs |
| Professional or employment-related information | Employment information (company name, division/department the customer belongs to, title, address, telephone number, fax number) and related information |
| Sensitive personal information | Passport information, information on physical condition or disease of the customer relevant to his/her boarding, the customer's dietary restrictions, the necessity to arrange for a wheelchair, and location information, etc. |
2. The disclosure of personal information
- (1) Sale of personal information
ANA does 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) The sharing of personal information
The types of personal information that ANA may share with third parties in the future, and the types of personal information that ANA has shared with third parties in the past 12 months and the types of third parties with whom ANA has shared personal information during the said period are shown below. ANA shares such personal information with third parties in order to conduct marketing activities (including personalized advertisements), such as provision of information on events and campaigns. ANA will not share the personal information of a customer with a third party if ANA has actual knowledge that the customer is a minor.
| Type of personal information shared | Example of personal information | Type of third party ANA shared personal information with in the past 12 months |
|---|---|---|
| Internet or other electronic network activity information | Information such as that on how customers use the ANA website and mobile application, including details on cookies, advertising identifiers (IDFA/GAID), location information, unique device identifiers, IP address, details on OS and browser type, etc., and website activity logs | Ad network |
- (3) Disclosure of personal information for business purposes
The types of customers' personal information that ANA 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. ANA discloses these types of personal information to third parties for the purposes specified in Chapter 1., Part 3. (Purpose of using personal information) and Part 8. (Joint use).
| Type of personal information disclosed | Example of personal information | Types of third parties 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, and ANA Mileage Club membership number (10 digit number), 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)) | The customer's physical and medical information relating to flying, credit card number, and payment information including details of credit/debit card and other payment methods, 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. |
| Characteristics of protected classifications under California or federal law | The customer's dietary restrictions, etc. | Other companies in the ANA Group, subcontractor handling ANA flights, etc. |
| Commercial information | The type of customer's ANA Mileage Club membership card, membership status, membership area, mileage status, credit card expiration date, usage history of credit card and related information, need for wheelchair or other special arrangement, flight reservation and cancellation information, usage history of flights and other services, details of travel plans and arrangements, including flights with ANA and other airlines, accommodations, and other transportation arrangements, information contained in correspondence with customers, details of inquiries, requests and complaints, 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. |
| Internet or other electronic network activity information | Information such as that on how customers use the ANA website and mobile application, including details on cookies, advertising identifiers (IDFA/GAID), location information, unique device identifiers, IP address, details on OS and browser type, etc., and website activity logs | 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. |
| Sensitive personal information | Passport information, information on physical condition or disease of the customer relevant to his/her boarding, the customer's dietary restrictions, the necessity to arrange for a wheelchair, and location information, etc. | ANA Group companies, 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. |
3. Sensitive personal information
ANA does not use or disclose sensitive personal information of customers for any purpose other than certain purposes permitted under the CCPA. ANA does not collect or process sensitive personal information of customers for the purpose of inferring characteristics about customers.
4. Retention of personal information
ANA retains customers' personal information until the purpose of use is achieved. Particularly, ANA 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) Personal information of ANA Mileage Club membership
Until withdrawal of the ANA Mileage Club membership - (2) Personal information of passengers
Until completion of transportation and related services stipulated in Conditions of Carriage for Domestic Flights and Conditions of Carriage for International Flights - (3) Other personal information
Required period for the purpose which customers have consented.
5. Request about handling of personal information
Customers residing in California have the following rights concerning their personal information:
(1) Right to know
Customers have the right to make a request to ANA for the disclosure of the following information regarding their personal information collected/used/disclosed by ANA within the 12 months before the date of request (hereinafter "Right to know"), up to twice in 12 months.
- Type of the customer's personal information collected by ANA
- 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
- Type of the customer's personal information disclosed by ANA for a business purpose
- Type of third parties to which each type of such personal information has been disclosed
(2) Right to delete
Customers have the right to make a request to ANA for the deletion of their certain personal information collected by ANA (hereinafter "Right to delete").
(3) Right to correct
Customers have the right to request ANA to correct incorrect personal information held by ANA (hereinafter the "Right to correct").
(4) Right to opt-out of sharing
Customers have the right to direct ANA to cease sharing their personal information with a third party (hereinafter the "Right to opt-out of sharing").
When, among the rights set out above, exercising the right to know, the right to delete or the right to correct, please contact us using any of the following methods. Once ANA 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.
1. Submission of a request
Website:
Telephone:
U.S.
1-800-235-9262
(Toll-free)
310-782-3011
(Charged)
2. Procedures for individual identification
- (For individuals)
Upon receiving a request for the exercise of the right to know, the right to delete or the right to correct, ANA 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. - (For representatives)
In addition to the information required for the identification of individual in "(For individuals)," the customer needs to submit a certificate signed by him/her certifying that the representative is authorized to exercise rights on his/her behalf. In addition, ANA may ask the customer to directly contact ANA to confirm that he/she has granted the representative authority to exercise the right to know, the right to delete or the right to correct.
When, among the rights set out above, exercising the right to opt-out of sharing, please contact us using any of the following methods or through the link below. Once ANA receives such a request, it will be handled according to the related laws and regulations within a reasonable timeframe and manner.
"Do Not Sell or Share My Personal Information."
ANA responds to an opt-out preference transmitted through the Global Privacy Control and handles it as a valid request based on the right to opt-out of sharing. Please refer to Global Privacy Control for how to set the Global Privacy Control.
As a rule, ANA will not treat customers who have submitted such requests in a discriminatory manner, such as changing their services. Even so, 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 wishes.
6. Contact for inquiries
Website:
Telephone:
U.S.
1-800-235-9262
(Toll-free)
310-782-3011
(Charged)
Chapter 5. Handling of personal data of Thailand residents by ANA
1. Introduction
This Chapter 5 provides additional information about the collection, use, or disclosure ("processing") of personal data 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 data relevant to the use of ANA's services of customers who are minors, quasi-incompetents or incompetents under the law of Thailand and cannot lawfully give consent by themselves, consent of the holder of parental responsibility over the child, their curators or custodians (as the case may be) shall also be obtained. If customers are under the age of 10, only consent of the holder of parental responsibility over the child shall be obtained.
If ANA is not aware that the customers are minors, quasi-incompetent persons or incompetent persons prior to the collection of their personal data, upon learning that we have collected personal data of minors without the consent of the holder of parental responsibility over the child (when it is required and the minors cannot lawfully give consent by themselves), or from quasi-incompetent persons or incompetent persons without the consent of their legal curator or custodian, we will delete the personal data at the earliest convenience unless we can rely on other legal grounds apart from consent for such processing.
The customer'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 ANA's service on behalf of the customer.
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 data
The controller of your personal data is ANA.
ANA protects personal data which is collected and used by controllers (who make decisions about how and why your personal data is used) and processors (who act on the controller's written instructions) on the basis of the PDPA.
3. Our legal basis for processing personal data
ANA protects your personal data 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 legal basis for each processing activity on the basis of the PDPA.
ANA may process customer personal data on one or more of the following legal basis:
- (1) When your consent is obtained for 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 data.
- (2) When processing is necessary in order to perform or take steps to enter into a contract (Article 24(3) PDPA).
This is typically when we process customer's personal data which is essential to providing our services, including a customer's identity, contact, payment and travel details, etc. - (3) When ANA needs to process the personal data to comply with a legal obligation (Article 24(6) PDPA).
This includes the requirement to share personal data with customs and immigration authorities or law enforcement, as well as ANA's legal obligations towards its staff and customers. - (4) When the processing 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) When it is in ANA's or a third party's legitimate interests to process the personal data, and these interests are not overridden by your fundamental rights regarding your personal data under the law (Article 24(5) PDPA).
This includes the use of personal data necessary to operate ANA's business and also to maintain, develop and improve its goods and services and provide the best possible customer experience to the extent permissible under the PDPA.
4. Request about processing of personal data
(1) The PDPA provides you with the following legal rights:
- Request for disclosure: You can request copies of your personal data and details of how we process it.
- Request for correction or updating: Corrections or updates to personal data will be undertaken where possible after due review of the request.
- Request for erasure: You may request that we erase, destroy or anonymize all or part of the personal data 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.
- Transferring your personal data: You can request a copy of your personal data in a structured, common, machine-readable format. This only applies to personal data 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.
- Objections 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 cease processing customer's information unless we can prove a legitimate grounds to show that the legitimate interest overrides the customer's interest. If your objection is to direct marketing, we will cease the processing.
- Restrictions to processing. You can restrict our processing of the customer's personal data under certain circumstances. Where this applies, any processing of your personal data (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.
- Withdrawal of consent. If we rely on consent to process your personal data, you have the right to withdraw that consent at any time. However, the withdrawal of consent shall not affect the processing of your personal data before its withdrawal to which you have given consent legally.
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 the 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 demonstrate that we have complied with the legal obligations.
(2) Method for submitting a 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.
(Website)
Please send the required documents via the webform listed on ANA's website.
(Required documents)
(3) Responding to a request
We will respond without undue delay and usually within thirty (30) days. 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 data has not been mishandled, 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 goods or services
ANA's goods and services are provided with the assistance of other companies and organizations and often ANA will need to share personal data 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 is legally required to share personal data
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 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 sends out marketing communications from time to time to notify interested persons of news and provide details of goods and services which may be of interest to them. ANA will only do this if the recipient has consented to receive marketing communications.
7. Where your personal data is stored and transferred
ANA is located in Japan and many of the service providers and other organizations with whom we share your personal data will be located in jurisdictions outside Thailand.
When transferring personal data to third parties, ANA will ensure that it complies with the requirements of the PDPA and related Japanese laws. However, please note that recipients outside Thailand 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 data is stored and transferred please contact ANA using the details set out in Part 13 of this Chapter 1 ("Submission of a request for disclosure, etc.").
8. Retention of personal data
ANA retains customers' personal data until the purpose of use is achieved. Particularly, ANA has set the retention period for personal data as follows. For most other personal data, 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) Personal data of ANA Mileage Club membership
Until withdrawal of the ANA Mileage Club membership - (2) Personal data of passengers
Until completion of transportation and related services stipulated in Conditions of Carriage for Domestic Flights and Conditions of Carriage for International Flights - (3) Other personal data
Required period for the purpose which customers have consented
Please note that ANA may retain your personal data for a longer period than mentioned above if it is for the purposes of the establishment or 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 data with the Personal Data Protection Committee of Thailand.
10. The contact information of the controller and ANA's Data Protection Officer
Controller: ALL NIPPON AIRWAYS CO., LTD.
Address: Shiodome City Center, 1-5-2 Higashi-Shimbashi, Minato-ku, Tokyo, Japan
Data Protection Officer email: bkkpdpa@ana.co.jp
- Please note that this e-mail address is for data protection related matters only.
- For requests for processing of personal data (disclosure, erasure, correction, etc.), please refer to Part 4 of this Chapter 5 (Request about processing of personal data, (2) Method for submitting a request).
- For inquiries regarding reservations, tickets, baggage, ANA Mileage Club, services, etc., please access Contact Information in Each Region and ANA Branch Office.
- Please choose your city and language.