Privacy Policy

K.K. Section L (株式会社セクションL) ("K.K. Section L," "we," "us," or "our") recognizes the importance of protecting personal information and is committed to handling personal information appropriately and securely in accordance with the Act on the Protection of Personal Information of Japan ("APPI") and other applicable laws and regulations.

This Privacy Policy explains how we collect, use, disclose, store and otherwise handle personal information in connection with the websites, accommodation services and related services operated by K.K. Section L.

01 Scope of This Privacy Policy

This Privacy Policy applies to the following websites operated by K.K. Section L (collectively, the "Sites"):

Eave Hospitality – www.eavehospitality.com
Section L – www.section-l.co
Monograph Hotels – www.monographhotels.com
VOL. – www.vol-hotels.com

It also applies to personal information collected through services connected with these Sites, including reservation systems, inquiry forms, membership or subscription services, recruitment forms and other online services operated by or on behalf of K.K. Section L.

Eave Hospitality is primarily a corporate and informational website. Section L, Monograph Hotels and VOL. provide accommodation information and online reservation functionality and may therefore collect additional information necessary to process and manage accommodation reservations and guest stays.

This Privacy Policy applies regardless of which of the above brands or Sites you interact with, unless a separate privacy notice is specifically provided for a particular service.

02 Personal Information We Collect

Depending on how you interact with us and which Site or service you use, we may collect the following categories of information.

A. Identification and Contact Information

This may include: name, address, email address, telephone number, date of birth, gender, where required or voluntarily provided, nationality, country or region of residence, occupation, preferred language and other contact or identification information you provide to us.

B. Reservation and Accommodation Information

When you make or manage a reservation with Section L, Monograph Hotels or VOL., we may collect information such as: hotel or property selected, check-in and check-out dates, number and names of guests, room type and accommodation preferences, reservation number and booking details, special requests, arrival and departure information, stay history, communications relating to your reservation or stay, information required under applicable Japanese laws and regulations for accommodation registration.

Where required by applicable law, we may also request passport or other identification information from guests.

C. Payment and Transaction Information

When you make a reservation or purchase a service, payment-related information may be collected, including: payment method, billing information, transaction details, payment status, partial or tokenized payment card information.

Payment card information may be collected and processed directly by third-party payment processors or reservation service providers. We may not directly store complete payment card details where such information is processed by those providers.

D. Membership, Marketing and Subscription Information

Where you register as a member, subscribe to communications, participate in an offer or otherwise interact with our marketing services, we may collect: name, email address, subscription status, communication preferences, booking and stay history associated with your account, promotional offer usage, responses to surveys, campaigns or promotions.

E. Inquiry and Communication Information

When you contact us through a Site, email, telephone, social media or other communication channel, we may collect: your name and contact details, company or organization, nature of your inquiry, content of your correspondence, any files, documents or other information you voluntarily provide.

For the Eave Hospitality website, this may include inquiries from investors, development partners, media representatives, business partners, prospective employees and other corporate stakeholders.

F. Recruitment Information

If you apply for employment with us through one of our Sites or related recruitment channels, we may collect information including: name and contact details, resume or curriculum vitae, employment history, education and qualifications, language abilities, information contained in your application, interview and assessment information, other information you voluntarily provide in connection with your application.

G. Website and Device Information

When you access or use our Sites, certain information may be collected automatically, including: IP address, browser type and version, device type, operating system, referring website, pages viewed, date and time of access, time spent on pages, click and navigation activity, cookie identifiers and similar technologies, approximate geographic information derived from your IP address, other technical or usage information.

03 How We Collect Personal Information

We may collect personal information:

  • directly from you when you make a reservation, submit a form, register as a member, subscribe to communications, apply for employment or contact us;
  • during your stay or other interactions with our hotels and team members;
  • automatically when you access or use our Sites;
  • through reservation platforms, booking engines and payment service providers;
  • through travel agencies, online travel agencies and other booking partners where you make a reservation through those services;
  • from corporate clients, travel coordinators or other persons arranging accommodation on your behalf;
  • through social media platforms and other third-party services where permitted; and
  • from other lawful sources where permitted by applicable law.

Where another person makes a reservation or provides personal information on your behalf, we may receive your information from that person.

04 Purposes for Which We Use Personal Information

Accommodation and Reservations

  • To process, confirm, modify and manage reservations;
  • To provide accommodation and related guest services;
  • To communicate with guests before, during and after their stay;
  • To process payments, refunds and other transactions;
  • To respond to guest requests, questions and complaints;
  • To maintain reservation and stay records;
  • To provide personalized guest services where appropriate; and
  • To comply with accommodation registration and other legal requirements.

Customer Service and Communications

  • To respond to inquiries and requests;
  • To provide information requested by users;
  • To communicate important information concerning reservations, stays or services;
  • To manage feedback, complaints and customer support; and
  • To maintain records of our communications.

Membership and Marketing

  • To create and administer membership accounts;
  • To provide membership benefits and rates;
  • To send newsletters, promotions, offers and information about our hotels, brands, services and events where permitted;
  • To manage marketing preferences and subscriptions;
  • To understand guest interests and preferences;
  • To measure and improve the effectiveness of marketing campaigns; and
  • To provide information that may be relevant to users based on their interactions with our services.

You may unsubscribe from marketing communications at any time by using the unsubscribe function provided in the relevant communication or by contacting us.

Website Operation and Improvement

  • To operate, maintain and secure our Sites;
  • To understand how users interact with our Sites;
  • To analyze website traffic and performance;
  • To diagnose technical problems;
  • To improve website functionality, content and user experience;
  • To prevent unauthorized access, fraud, misuse and security incidents; and
  • To develop and improve our services.

Corporate and Business Activities

In relation to Eave Hospitality and our wider corporate activities, we may use information:

  • To respond to media, investor, development, partnership and other corporate inquiries;
  • To communicate with existing and prospective business partners;
  • To evaluate potential business relationships;
  • To manage corporate communications and public relations; and
  • To administer other legitimate corporate activities.

Recruitment

We may use applicant information:

  • To process and evaluate employment applications;
  • To communicate with applicants;
  • To conduct interviews and recruitment assessments;
  • To verify information provided by applicants where appropriate; and
  • To manage our recruitment and hiring processes.

Legal and Administrative Purposes

We may also use personal information:

  • To comply with applicable laws, regulations and lawful requests from governmental or regulatory authorities;
  • To establish, exercise or defend legal rights;
  • To enforce our agreements and policies;
  • To prevent and investigate fraud, unlawful activity or security incidents;
  • To protect the safety, rights and property of our guests, employees, K.K. Section L and others; and
  • For other purposes permitted or required by applicable law.

05 Sharing and Disclosure of Personal Information

We do not sell personal information.

We may disclose or provide personal information to third parties where necessary for the purposes described in this Privacy Policy and as permitted by applicable law.

Such recipients may include:

Service Providers

We may engage third-party service providers to perform services on our behalf, including:

  • hotel reservation and booking system providers;
  • property management systems;
  • payment processors;
  • website hosting and cloud service providers;
  • customer relationship management systems;
  • email and newsletter platforms;
  • analytics providers;
  • advertising and marketing service providers;
  • IT and cybersecurity providers;
  • customer support providers; and
  • professional advisers and consultants.

We take appropriate measures in accordance with applicable law when entrusting the handling of personal data to service providers.

Booking and Travel Partners

Where your reservation involves an online travel agency, travel agency, corporate travel provider or other booking partner, we may exchange information with that partner as necessary to process and manage your reservation.

Legal and Regulatory Authorities

We may disclose personal information where required or permitted by law, including in response to lawful requests from courts, police, government agencies, regulatory authorities or other public bodies.

Corporate Transactions

If all or part of our business or assets are reorganized, transferred, acquired, merged or otherwise subject to a corporate transaction, personal information may be transferred as part of that transaction in accordance with applicable law.

With Your Consent

We may disclose personal information to another party where you have given us your consent or otherwise requested or authorized the disclosure.

06 International Transfers of Personal Information

Some of the service providers and technology platforms we use may operate or store information outside Japan.

Accordingly, personal information may be processed, transferred to or stored in countries or regions outside Japan.

Where personal data is provided to a third party located outside Japan, we will take measures required under the APPI and other applicable laws, including obtaining consent or confirming appropriate arrangements for the protection of personal data where required.

Information concerning applicable foreign data protection systems or measures implemented by relevant overseas recipients will be provided where required by applicable law.

07 Cookies and Similar Technologies

Our Sites may use cookies, pixels, tags and similar technologies to operate the Sites, remember user preferences, understand how visitors use the Sites and measure the effectiveness of our content and marketing.

These technologies may collect information including:

  • IP address;
  • browser and device information;
  • pages visited;
  • referral source;
  • time and duration of visits;
  • interactions with website content; and
  • cookie or device identifiers.

We may use third-party analytics, advertising and other technology providers in connection with these activities.

Where required, users may be provided with options to manage their cookie preferences. You may also be able to control cookies through your browser settings. Disabling certain cookies may affect the functionality of parts of our Sites.

Additional information regarding the cookies and similar technologies used on our Sites may be provided through a cookie notice or cookie preference tool where applicable.

08 Analytics and Third-Party Services

Our Sites may use third-party services for website analytics, mapping, embedded content, social media functionality, advertising, reservation functionality and other purposes.

These third parties may independently collect or receive information about your device or use of our Sites in accordance with their own privacy policies.

Where personal information or other user information is transmitted through third-party platforms integrated into our Sites, we take reasonable measures to understand the nature of the information transmitted and to manage such integrations appropriately.

09 Security of Personal Information

We take necessary and appropriate organizational, personnel, physical and technical security measures to protect personal information against unauthorized access, loss, destruction, alteration, disclosure and other improper handling.

These measures may include:

  • access controls;
  • restrictions on personnel authorized to handle personal information;
  • appropriate management of systems and devices;
  • security measures for electronic data;
  • employee training and internal procedures;
  • oversight of service providers handling personal data on our behalf; and
  • appropriate measures relating to environments outside Japan where personal data is handled.

While we take reasonable measures to protect personal information, no electronic transmission or storage system can be guaranteed to be completely secure.

10 Retention of Personal Information

We retain personal information for as long as reasonably necessary to fulfil the purposes for which it was collected, including providing accommodation and other services, maintaining business and transaction records, resolving disputes and complying with legal, accounting and regulatory obligations.

Retention periods may differ depending on the nature of the information, the service concerned and applicable legal requirements.

When personal information is no longer required, we will appropriately delete, dispose of or anonymize it in accordance with applicable laws and our internal procedures.

11 Your Rights Regarding Personal Information

Subject to the requirements and limitations of applicable law, you may request:

  • notification of the purposes of use of your retained personal data;
  • disclosure of retained personal data relating to you;
  • correction, addition or deletion of inaccurate retained personal data;
  • suspension or deletion of the use of retained personal data;
  • suspension of provision of retained personal data to third parties; and
  • disclosure of records concerning certain third-party transfers, where applicable.

We may need to verify your identity before processing a request.

Certain requests may be declined or limited where permitted by applicable law. Where required, we will explain the reason for such a decision.

To exercise these rights, please contact us using the details provided in Section 15 below.

12 Marketing Communications

Where permitted by applicable law or where you have provided the necessary consent, we may send you promotional communications relating to:

  • Section L;
  • Monograph Hotels;
  • VOL.;
  • Eave Hospitality; and
  • other accommodation, services, offers or events operated by K.K. Section L.

You may unsubscribe from promotional email communications at any time by following the unsubscribe instructions included in the email or contacting us.

Please note that even if you unsubscribe from marketing communications, we may continue to send service-related communications necessary for reservations, transactions, membership administration or your stay.

13 Third-Party Websites

Our Sites may contain links to websites, services or platforms operated by third parties.

This Privacy Policy does not govern the privacy practices of third-party websites or services that are not operated by K.K. Section L.

We encourage you to review the privacy policies of third-party services before providing personal information to them.

14 Changes to This Privacy Policy

We may revise this Privacy Policy from time to time to reflect changes in our services, Sites, business practices, technologies or applicable laws and regulations.

The updated Privacy Policy will be published on our Sites with the revised "Last Updated" date.

Where required by applicable law, we will provide additional notice or obtain consent regarding material changes.

15 Privacy Inquiries

For inquiries, requests or complaints regarding this Privacy Policy or our handling of personal information, please contact:

K.K. Section L (株式会社セクションL)
2-2-1 Kanda Nishikicho,
Chiyoda-ku, Tokyo
101-0054
Japan.

enquiries@eavehospitality.com


When submitting a request concerning your personal information, we may ask you to provide information necessary to verify your identity.

16 Governing Law

This Privacy Policy and our handling of personal information are governed by the laws of Japan, including the Act on the Protection of Personal Information and other applicable laws and regulations.

Last Updated: 30 September 2026