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as of June 1, 2022
Built on a foundation of security and trust
“the wings within ourselves” help to fulfill
the hopes and dreams of an interconnected world.
ANA always offers safe and hospitable service in its air transportation service, in accordance with the above Mission Statement.
In ANA’s business operations, our customers’ personal information is essential for us to provide fully satisfactory services. We recognize the importance of the information received from our customers, and make efforts to take the utmost care in handling such information.
For our customers to utilize ANA with a sense of safety and trust , we educate our executives and employees thoroughly about laws and company regulations relating to personal information, and have established our company’s structure to include measures for security, thereby exerting maximum effort toward appropriate management and use of each customer’s personal information.
Chapter 1 describes the handling of personal information as it applies to all customers. Chapter 2, Chapter 3, Chapter 4, and Chapter 5 provide region-specific information for customers who are located or reside in the European Economic Area/the United Kingdom, the People's Republic of China, the state of California of the United States, and the Kingdom of Thailand respectively.
This Privacy Policy explains how and why the personal information of customers and other individuals obtained by ALL NIPPON AIRWAYS CO., LTD. (“ANA”, “we”, “our” or “us”) is used. Please read this Privacy Policy carefully before providing personal information to ANA or using our products or services.
Chapter 1 of this Privacy Policy provides an overview of how we use your personal information.
Additional policies may apply to certain ANA products or services, details of which will be provided alongside the terms of such service.
The Privacy Policy will apply when customers and other individuals provide personal information to ANA or use ANA’s services and products.
ANA utilizes personal information obtained from its customers for the following purposes. However, even within the intended scope, it will not use customers’ personal information in a way that may encourage or induce illegal or improper conduct.
ANA will obtain the following personal information by fair and appropriate means for the purpose of achieving the previously mentioned purposes.
The customer’s name, address, telephone number, fax number, email address, employment information (company name, division/department the customer belongs to, title, address, telephone number, fax number), mailing address, passport information, physical and medical information relating to flying, dietary restrictions, payment information including details of credit/debit card and other payment methods, etc.
Details of travel plans and arrangements, including flights with ANA and other airlines, accommodations, and other transportation arrangements, etc.
The customer’s ANA Mileage Club membership number, type of membership card, membership status, membership area, mileage status, credit card number and 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, etc.
Details of enquiries, requests and complaints contained in correspondence with customers, (including their cause and resolution), etc.
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, details on OS and browser type, etc., and website activity logs
(For details on the purpose of use of cookies and other related matters, please see the Cookie Policy.)
ANA will never obtain and use information of a sensitive nature to the customer (hereinafter, “sensitive information”), such as information on race, beliefs, social standing, history of illness, crime records, and history of having been afflicted by crime, unless required by laws and regulations or by the consent of the customer.
As a rule, ANA obtains personal information by the volition of the customer. Customers may experience disadvantages if they refuse to provide their personal information, such as being unable to make use of the various services provided by ANA, or being unable to receive campaign notices and other ANA information because a part of the functions of ANA’s system become inoperable and thereby unavailable. Please note that customers may change their contact information as well as their decision on whether or not they wish to receive email magazines at any time they wish, in a manner designated separately by ANA.
ANA will not disclose or provide personal customer information to any third parties except under the following circumstances. Also, customers’ personal information including sensitive information will not be disclosed or provided to third parties under any circumstances, unless allowed by laws and regulations or by consent of the customer. Note that provision of information to data sharing partners and business entrusted companies are not deemed to constitute disclosure or provision to third parties.
ANA may share customer information as follows.
| Scope of entities that data can be shared | ANA Group companies |
|---|---|
| Purpose of using data by the user |
|
| Items of personal information to be shared | The customer’s ANA Mileage Club membership number, the customer’s name, address, telephone number, fax number, email address, employment information (company name, division/department the customer belongs to, title, address, telephone number, fax number), mailing address, passport information, physical and medical information relating to flying, dietary restrictions, payment information including details of credit/debit card and other payment methods, details of travel plans and arrangements, including flights with ANA and other airlines, accommodations, and other transportation arrangements, type of membership card, membership status, membership area, mileage status, credit card number and 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 enquiries, requests and complaints contained in correspondence with customers, information on the use of ANA website and mobile application, including cookie and action log on the website, 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 |
In providing products and services to customers, ANA may entrust a part of its business operations to third parties to which personal information may also be disclosed to the extent required to achieve the purpose of the entrustment. In these cases, ANA will implement appropriate measures in managing and supervising such third parties to safeguard the handling of customers’ personal information, including establishing agreements on the handling of such personal information.
Depending on customers’ flight destinations, ANA may transfer their personal information (name, passport number, and travel details, etc.) to outside of Japan. The countries served by ANA can be found on ANA’s website. The countries or regions to which customers’ personal information is transferred may not have a system for personal information protection equivalent to Japan’s.
If ANA provides customers’ personal information to third party business operators outside of Japan, including entrusted companies and data sharing partners, ANA will do so based on customer consent, except in either of the following cases:
In the case of (2) above, ANA will take necessary and appropriate measures to ensure that the third party takes the corresponding measures on an ongoing basis. If you wish to know the details of ANA’s measures, please make a request in accordance with “11. Request about handling of Personal Information”.
In receiving customers’ personal information, ANA will manage such information according to the strictest standards and take necessary safety management measures to prevent leaks, loss, or alterations. ANA ensures that the board members and employees are properly trained regarding appropriate handling to safeguard the security of information identifying individual customers. An appropriate retention period for personal information will be established in accordance with the purpose for which such information is used. After the purpose of the information has been achieved, ANA will dispose of the information in question by appropriate methods.
If you wish to know the details of the safety management measures, please make a request in accordance with “11. Request about handling of Personal Information”.
If ANA receives a request from a customer, submitted in the manner specified, for the disclosure, correction, deletion, addition, discontinuance of use, erasure, or information provision concerning the personal information protection measures referred to in “9. Transfer to outside of Japan” and “10. Management of personal information” (“disclosure, etc.”) with regard to the customer’s personal information stored in a database held by ANA, the request will be handled according to the laws and regulations as follows, within a reasonable timeframe and scope, after confirming that the request was submitted by the customer themselves.
Personal information items, purpose of use, or records on the provision of personal data to third parties will be disclosed in accordance with the customers’ request.
Correction, deletion, or addition of personal information will be undertaken wherever possible after due review of the request.
The use of personal information items designated by the customer will be discontinued, and the relevant information erased if so desired, in accordance with the submitted request. However, please note that such requests may prevent customers from being provided with services that they had utilized, or may impede the provision of services in accordance to their wishes.
The following information will be provided in accordance with the customer’s request.
ANA may not be able to fulfill the customers’ requests if compliance with such requests would seriously impact ANA’s business operations, result in a violation of laws and regulations, or disrupt the safety management of personal information.
The method for submitting requests for disclosure, etc or notification of purpose of use of personal information (“requests for disclosure, etc.”) received by ANA from customers, and contact information are as follows.
Request for disclosure, etc.
(1) Method for submitting request
If you wish to receive response to your disclosure request by mail
Please send the required documents by postal mail to the address below.
Address:
Personal Information Handling Desk, ALL NIPPON AIRWAYS CO., LTD
1-331-90 Kaminoshima-cho, Nagasaki-shi, Nagasaki, 850-0078 Japan
If you wish to receive response to your disclosure request by electronic file format
Please send the required documents via webform listed on ANA’s website.
(2) Required documents
Application form (choose one of the following in accordance with your request)
Customer requests for disclosure, etc., may not be acknowledged if any of the required information is missing.
Documents required for confirmation of identification of individual, etc.
(For individuals)
(For representatives)
(3) Fee
This Chapter 2 provides additional information about the handling of personal information 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 (together, “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.
A guardian’s consent or permission must be obtained in the event that a customer under the age of 16 uses ANA’s service and consents to this Privacy Policy. The data subject’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 data subject.
In the event that any provisions of this Chapter 2 contradict those of Chapter 1, the provisions of this Chapter 2 shall prevail.
The controller of your personal information is ANA.
ANA protects personal information which is collected and used by controllers (who make decisions about how and why your personal information is used) and processors (who act on the controller’s written instructions) on the basis of Data Protection Laws.
ANA protects your personal information 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 lawful 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 lawful bases:
(1) Data Protection Laws provide you with the following legal rights:
2.Request for correction or updating: Corrections or updates to personal information will be undertaken wherever possible after due review of the reques
3.Request for erasure: You may request that we delete all or part of the personal information 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.
4.Transferring your personal information: You can request a copy of your personal information in a structured, common, machine-readable format. This only applies to personal information 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.
5.Objecting 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 stop processing your information unless we have a strong reason to continue which overrides your objection. If your objection is to direct marketing, we will always stop.
6.Restricting how your personal information is processed. You can limit how we process your personal information in certain circumstances. Where this applies, any processing of your personal information (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.
7.The right to withdraw consent. If we are relying on consent to process your personal information, 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. Of course, if a 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 ensure we have complied with our legal obligations.
(2) Method for submitting 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 webform listed on ANA’s website.
(3) Responding to a request
We will respond without 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 information 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.
ANA’s products and services are provided with the assistance of other companies and organizations and often ANA will need to share personal information with third parties in order to run its business. These third parties include:
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.
ANA sends out marketing communications from time to time to notify interested persons of news and provide details of products 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 products or services from ANA and were given the opportunity to opt-out from marketing at the time but chose not to do so.
ANA is located in Japan and many of the service providers and other organizations with whom we share your personal information 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 information.
When transferring personal information to third parties ANA will ensure that it complies with the requirements of Data Protection Laws, including the onward transfer requirements of the EU-Japan adequacy decision and related Japanese laws. However, you should be aware 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 information is stored and transferred please contact ANA using the details set out in Part 12 of this Chapter 1 (“Submission of request for disclosure, etc.”).
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.
Customers have the right to lodge a complaint on the processing of their personal information with the data protection authority having jurisdiction over their residence.
Controller: ALL NIPPON AIRWAYS CO., LTD.
Address: Shiodome City Center, 1-5-2 Higashi-Shimbashi, Minato-ku, Tokyo, Japan
Data Protection Officer email: anag_infosec@ana.co.jp
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.
A guardian's consent or permission must be obtained in the event that a customer under the age of 18 uses ANA's service and consents to this Privacy Policy. In the event that a person such as a family member applies for ANA's service on behalf of the data subject, the consent of the data subject (when he/she is under the age of 14, his/her guardian) to this Privacy Policy must be obtained.
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.
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.
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 “Article 11 Request about handling of Personal Information”. In responding to the request, ANA may confirm that it was submitted by the customer himself/herself.
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.
Customers have the right to ask for the interpretation/explanation of this Privacy Policy.
Customers may submit requests by following methods.
1. Submission of requests
Website:
Please send the required documents via webform listed on ANA’s website.
2. Required documents
Documents required for confirmation of identification of individual, etc.
(For individuals)
(For representatives)
3. Contact Desk
China
4008-82-8888
(Charged)
| 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, 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, accomodations, and other transportation arrangements, details of enquiries, requests and complaints contained in correspondence with customers, 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, 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 |
(1) Sale of personal information
ANA will 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) 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.
| Type of personal information collected | Example of personal information | Third party 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, 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, |
| 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, accomodations, and other transportation arrangements, details of enquiries, requests and complaints contained in correspondence with customers, 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, 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. |
Customers living in California have the following rights concerning their personal information:
(1) Access right
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 “Access Right”), up to twice in 12 months.
(2) Deletion right
Customers have the right to make a request to ANA for the deletion of their certain personal information collected by ANA (hereinafter “Deletion Right”).
When exercising the Access Right or Deletion Right, please contact the following. 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 requests
Website:
Telephone:
Please contact the following
U.S.
1-800-235-9262
(Toll-free)
310-782-3011
(Charged)
2. Procedures for individual identification
(For individuals)
(For representatives)
(4) The information 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) It is in ANA’s or a third party’s legitimate interests to process the personal information, and these interests are not overridden by your fundamental rights regarding your personal information under the law (Article 24(5) PDPA).
This includes the use of personal information necessary to operate ANA’s business and also to maintain, develop and improve its products and services and provide the best possible customer experience to the extent permissible under the PDPA.
(Website)
Please send the required documents via the webform listed on ANA’s website.
We will respond without 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 information has not been processed appropriately, 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.
ANA’s products and services are provided with the assistance of other companies and organizations and often ANA will need to share personal information with third parties in order to run its business. These third parties include:
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.
ANA sends out marketing communications from time to time to notify interested persons of news and provide details of products and services which may be of interest to them. ANA will only do this if the recipient has consented to receive marketing communications.
ANA is located in Japan and many of the service providers and other organizations with whom we share your personal information will be located in jurisdictions outside Thailand.
When transferring personal information to third parties, ANA will ensure that it complies with the requirements of the PDPA and related Japanese laws.
However, you should be aware that recipients outside Thailand may be subject to national laws which do not necessarily provide equivalent protection for your personal information. If you would like more information regarding where your personal information is stored and transferred please contact ANA using the details set out in Part 12 of this Chapter 1 (“Submission of request for disclosure, etc.”).
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.
Please note that ANA may retain your personal information for a longer period than mentioned above if it is for the purposes of the establishment, compliance, or exercise of legal claims, the defense of legal claims, or the purpose for compliance with the law.
Customers have the right to lodge a complaint on the processing of their personal information with the Personal Data Protection Committee of Thailand.
Controller: ALL NIPPON AIRWAYS CO., LTD.
Address: Shiodome City Center, 1-5-2 Higashi-Shimbashi, Minato-ku, Tokyo, Japan
Data Protection Officer email: anag_infosec@ana.co.jp
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