Privacy Policy

Sync Sloan Co., Ltd.

Last updated: 26 January 2026

Company: Sync Sloan Co., Ltd.
Registered Address: 6-chōme-7-5 Minami Aoyama, #712, Minato City, Tokyo 107-0062, Japan
Representative Director: XIA YUKI YU
Privacy Contact:info@reflections.group

1. INTRODUCTION

This Privacy Policy explains how Sync Sloan Co., Ltd. ("Sync Sloan", "we", "us", or "our") collects, uses, stores, discloses, and protects personal information in connection with our hospitality businesses, including Kamo Residences by Reflections, Miya Townhouse by Reflections, our websites, reservation services, concierge services, customer support, marketing activities, and related services (collectively, the "Services").

This Policy is intended to comply with Japan's Act on the Protection of Personal Information (APPI) and, where applicable, aligns with international privacy laws, including the EU General Data Protection Regulation (GDPR) and the California Consumer Privacy Act, as amended by the CPRA (CCPA/CPRA).

2. DEFINITIONS

2.1 Personal Information / Personal Data

Information relating to an identified or identifiable natural person, as defined under applicable data protection laws.

2.2 Sensitive Personal Information

Information requiring enhanced protection under applicable law, including health information, biometric identifiers, government-issued identification, financial account information, and precise location data.

2.3 Processing

Any operation performed on personal information, including collection, recording, storage, use, disclosure, transfer, deletion, or other handling.

3. SCOPE

This Policy applies to personal information processed by Sync Sloan in relation to:

visitors to our websites
guests and prospective guests
individuals making enquiries or reservations
concierge and transportation requests
suppliers, business partners, and professional contacts

Where we process personal information on behalf of third parties, such processing is governed by the applicable contractual arrangements.

4. PERSONAL INFORMATION WE COLLECT

4.1 Information You Provide

We may collect:

full name
postal address
email address
telephone number
nationality and country of residence
reservation details
arrival and departure dates
payment and billing information
guest preferences and special requests
communications with our team
information required under applicable Japanese accommodation laws

4.2 Information Collected Automatically

When you use our websites, we may collect:

IP address
browser type and operating system
device information
website usage information
referring websites
approximate geographic location
cookies and similar technologies

4.3 Information from Third Parties

We may receive information from:

online travel agencies and booking platforms
payment service providers
travel agents
business partners
publicly available sources where necessary for verification or compliance

5. PURPOSES OF USE

We use personal information only where necessary for legitimate business purposes, including:

processing accommodation reservations
providing hospitality and concierge services
arranging transportation, dining, cultural experiences, and other guest services
communicating before, during, and after a stay
processing payments and issuing invoices
complying with Japanese accommodation regulations
maintaining the safety and security of guests and property
preventing fraud and unauthorized activity
improving our services and websites
responding to enquiries and customer support requests
sending marketing communications where permitted by law
complying with legal and regulatory obligations

We will not use personal information for purposes materially different from those described above without providing appropriate notice or obtaining consent where required.

6. LEGAL BASES FOR PROCESSING (GDPR)

Where the GDPR applies, we process personal data on one or more of the following legal bases:

performance of a contract
compliance with legal obligations
legitimate business interests
consent, where required

7. DISCLOSURE OF PERSONAL INFORMATION

We may disclose personal information to:

payment processors
booking platforms
property management and reservation system providers
technology service providers
transportation and concierge partners where necessary to fulfil guest requests
professional advisers
auditors
government authorities where required by law
parties involved in corporate restructurings or business transfers

We do not sell personal information.

8. INTERNATIONAL DATA TRANSFERS

Personal information may be transferred to and processed outside Japan where our service providers or technology infrastructure are located.

Where such transfers occur, appropriate safeguards are implemented in accordance with applicable law, including APPI and, where applicable, GDPR.

9. DATA RETENTION

Personal information is retained only for as long as reasonably necessary for the purposes described in this Policy or as required by law.

Typical retention periods include:

reservation and guest records: up to 24 months following the most recent stay, unless longer retention is required
accounting and tax records: 7 years
customer correspondence: 3 years
website security logs: 6–12 months
marketing preferences: until consent is withdrawn or an unsubscribe request is received, together with a reasonable suppression period

Information is securely deleted or anonymised once it is no longer required.

10. SECURITY

We implement appropriate technical and organisational measures designed to protect personal information, including:

role-based access controls
encrypted data transmission
secure hosting infrastructure
system monitoring
periodic security reviews
employee confidentiality obligations
incident response procedures

While no system can guarantee absolute security, we take reasonable steps to safeguard personal information.

11. YOUR RIGHTS

Under Japanese Law (APPI)

Subject to applicable law, individuals may request:

notification of purposes of use
access to retained personal information
correction or updating
deletion where applicable
suspension of use

Under the GDPR (where applicable)

Individuals may have rights including:

access
rectification
erasure
restriction of processing
objection
data portability
withdrawal of consent
lodging a complaint with a supervisory authority

Under the CCPA/CPRA (where applicable)

California residents may have rights to:

know what personal information is collected
access personal information
request deletion
request correction
opt out of sale or sharing where applicable
receive equal service regardless of exercising privacy rights

12. COOKIES

Our websites use cookies and similar technologies to:

operate essential website functions
improve website performance
analyse website usage
remember user preferences

You may manage cookies through your browser settings. Where required by law, consent mechanisms are provided.

13. MARKETING COMMUNICATIONS

Where permitted by law, we may send information about our properties, offers, or services.

You may unsubscribe at any time by following the instructions included in our communications or by contacting us directly.

Operational communications relating to reservations or guest services may continue where necessary.

14. CHILDREN'S PRIVACY

Our websites are intended for adults making accommodation reservations.

We do not knowingly collect personal information directly from children except where such information is provided by a parent or legal guardian as part of a reservation or guest stay.

15. AUTOMATED DECISION-MAKING

We do not use automated decision-making or profiling that produces legal or similarly significant effects on individuals.

16. THIRD-PARTY WEBSITES

Our websites may contain links to third-party websites or services.

We are not responsible for the privacy practices or content of those third parties, and we encourage users to review their respective privacy policies.