Privacy Policy

OpenSky Inc. (hereinafter referred to as the “Company”) provides private jet services (hereinafter referred to as the “Services”) to its customers (hereinafter referred to as the “Users”). The Company has established this Privacy Policy (hereinafter referred to as the “Policy”) concerning the handling of personal information of Users who utilize the Company’s Services. The Company is committed to protecting personal information by implementing a comprehensive personal information protection system. All employees recognize the importance of safeguarding personal information and are fully aware of their responsibilities in this regard.

personal information

“Personal information” refers to the meaning defined in the Act on the Protection of Personal Information (Act No. 57 of 2003). It means information about a living individual that can identify a specific person by name, date of birth, or other details, or that includes a personal identification code.

Acquisition and Use of Personal Information

1. The information we obtain from users and information we obtain in connection with the use of the Service is as follows
   1. Information obtained from users
      1. Name and other profile information
      2. Contact information such as e-mail address, telephone number, address, etc.
      3. Information related to means of payment, such as bank account information
      4. Still image information including portraits of all users
      5. Cookies and other data temporarily written and recorded on a PC through a web browser
      6. Users’ browsing history, search history, and other activity history on web pages
      7. Information entered or transmitted by users through input forms or other methods determined by the Company
2. Information acquired in connection with this service
   1. Information related to your use and browsing of the Service includes, but is not limited to, the contents of the Service, the date, time, and number of times you use the Service, and your online behavior while using the Service. This includes, without limitation, referrers, ADID/IDFA and other identifiers, cookie information, access logs, and other information related to your use of the Service. Such information further includes device information, location information, and user communications, including IP addresses, browser information, browser language, and other related data.
   2. Postings, photos, videos, comments, messages, ratings and other information posted or transmitted by users on the Service
   3. Information regarding the payment status of users of the Service
3. We use this information to manage your account, respond to your inquiries, provide customer service and support, process financial transactions, and for other purposes related to the provision of the Service. If we intend to use your personal information beyond the scope of these purposes, we will obtain your consent in an appropriate manner in advance.
   1. To communicate and provide information on various matters related to this service
   2. To provide this service
   3. To simplify the input of information required for user registration for this service.
   4. To bill and pay for this service and to confirm such payment
   5. To improve and enhance the contents of this service, or to develop and operate new services
   6. To provide information on new features, updates, campaigns, etc. of this service and other services provided by the Company (including sending e-mails, flyers, and other direct mailings)
   7. To contact you as necessary for maintenance, important notices, etc.
   8. To respond to inquiries from users regarding this service (including to confirm the identity of the user)
   9. To report to users on the use of this service
   10. To request cooperation for questionnaires, interviews, etc., or participation in various events related to this service, or to report the results of such activities.
   11. To survey the level of satisfaction with this service
   12. To research and analyze the usage history of this service and use the results to improve and develop this service and to deliver advertisements.
   13. To statistically process the acquired information, aggregate it, and publish the results of the survey.
   14. To identify users who have violated the Terms of Use or who are attempting to use the Service for fraudulent or unjustified purposes, and to refuse their use of the Service.
   15. To distribute or display advertisements of the Company or third parties
   16. To distribute or display product information within services provided by the Company or third parties
   17. To resolve problems in the operation of this service

Management and Protection of Personal Information

Personal information shall be strictly managed and shall not be disclosed or provided to third parties without the consent of the User, except in the following cases. Furthermore, in consideration of safety, we will implement measures to prevent and address risks such as unauthorized access, loss, destruction, falsification, and leakage of personal information.

1. When it is necessary for the protection of a person’s life, body, or property and it is difficult to obtain the user’s consent
2. When it is especially necessary to improve public health or promote the sound growth of children and it is difficult to obtain the user’s consent
3. When it is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and obtaining the user’s consent is likely to impede the execution of such affairs.
4. When all or part of the handling of personal information is outsourced within the scope necessary to achieve the purpose of use in order to facilitate the smooth performance of business operations.
5. When personal information is provided as a result of the succession of business due to merger or other reasons
6. In cases where personal information is jointly used with a specific third party, if the User is notified in advance or if the name of the person responsible for managing the personal information, the items of personal information to be jointly used, the scope of such joint use, and the purpose of use by the joint user are made readily available to the User, such joint use may be conducted accordingly.
7. Other cases permitted by laws and regulations

Outsourcing the handling of personal information

We may outsource all or part of the handling of personal information within the scope necessary to achieve the purpose of use. In such cases, the Company will thoroughly examine the eligibility of the consignee, stipulate confidentiality obligations in the contract, and exercise necessary and appropriate supervision over the consignee.

Joint Use of Personal Information

We may share the personal information of users within the following scope and purposes to the extent necessary to achieve the purpose of use.

<Purpose of joint use>

• To improve customer satisfaction

<Scope of personal information to be shared>

• Company name, affiliation, title, name, address, telephone number, fax number, e-mail address

<Scope of joint use>

• OpenSky Inc. and outside companies to which OpenSky Inc. outsources part or all of its operations
  In such cases, we will exchange a contract regarding the handling of personal information, and manage and supervise the contractor.

<The person responsible for the management of personal information

• OpenSky Corporation (Representative: Shigeto Honda)

Safety Management System

To prevent leakage, loss, or damage of user information and to ensure its protection, we implement necessary and appropriate measures for the secure management of user information. These measures include restricting access to personal information files, limiting access to the minimum number of authorized personnel, and installing security software to prevent unauthorized external access. Furthermore, the Company has designated its Representative Director as the person responsible for managing user information and oversees the appropriate management and continuous improvement of data protection practices.

Disclosure of Personal Information

When we are requested to disclose personal information by a user, we will disclose it to the user without delay. However, we may decide not to disclose all or part of the personal information in the following cases, and if we decide not to disclose the personal information, we will notify the user to that effect without delay.

1. When there is a risk of harm to the life, body, property, or other rights or interests of the user or a third party
2. If there is a risk of significant hindrance to the proper conduct of our business
3. In case of violation of other laws and regulations

Correction and deletion of personal information

1. If the personal information in our possession is incorrect, we will correct or delete the personal information at the request of the user in accordance with the procedures we have established.
2. If we receive a request from a user as described in the preceding paragraph and deem it necessary to respond to the request, we will correct or delete the relevant personal information without delay and notify the user of such correction or deletion.

Suspension of Use of Personal Information, etc.

If a User requests the suspension or erasure of their personal information (hereinafter referred to as “Suspension, etc.”) on the grounds that any of the conditions set forth below apply, the Company shall promptly conduct the necessary investigation. Based on the results and in accordance with applicable laws and regulations, the Company shall carry out the Suspension, etc. of the personal information and notify the User accordingly. However, if the Suspension, etc. would require an excessive cost or if it is otherwise difficult to carry out, and alternative measures can be taken to protect the rights and interests of the User, the Company shall implement such alternative measures.

1. When it is handled beyond the scope of the purpose of use
2. If the personal information was obtained by wrongful means
3. If the information is used in a manner that may encourage or induce illegal or unjust acts.
4. When we no longer need to use the user’s personal information
5. In the event that personal information containing sensitive personal data is leaked, lost, or damaged (hereinafter referred to as a “Leak, etc.”), or there is a risk that such an event has occurred.
6. In the event that personal information, which may cause financial damage if improperly used, is leaked, lost, or damaged (hereinafter referred to as a “Leak, etc.”), or there is a risk that such an event has occurred,
7. In the event that personal information is leaked, lost, or damaged (hereinafter referred to as a “Leak, etc.”) and there is a suspicion that such Leak, etc. was caused with malicious intent, or there is a risk that such an event has occurred,
8. In the event that a leak, loss, or damage of personal information (hereinafter referred to as a “Leak, etc.”) affects more than one thousand individuals, or there is a risk that such an event has occurred,
9. When there is a risk that the rights or legitimate interests of the user may be harmed by the handling of said personal information

Privacy Policy Modification Procedures

The Company will review this Policy as necessary and make efforts to improve it. Except as otherwise provided by laws, regulations, or specific provisions within this Policy, the Company reserves the right to amend the contents of this Policy. The amended Privacy Policy shall become effective from the time it is notified to Users by the Company’s designated method or published on the Company’s website.

Compliance with laws, regulations and norms

We will comply with Japanese laws and regulations and other norms applicable to personal information in our possession.

Response to complaints and consultations

The Company accepts complaints and inquiries from Users regarding the handling of personal information and will respond appropriately and promptly. In addition, the Company will promptly and properly address any requests from Users for disclosure, correction, addition, deletion, or refusal of use or provision of their personal information.

Contact for Inquiries

If you have any comments, questions, complaints, or other inquiries regarding our handling of personal information, including our security control measures, please contact us at the following address.

OpenSky Corporation
Representative Director Shigeto Honda

(Customer Service Contact)
Daini Watanabe Bldg. 7F, 1-7-3 Higashi-Azabu, Minato-ku, Tokyo 106-0044, Japan
TEL: 03-6384-0030
Mail: support@opensky.jp

Enacted and effective November 19, 2021.
Revised on April 1, 2022