Privacy Policy. Implemented on: November 2, 2017

Transcription

1 Implemented on: November 2, 2017 Privacy Policy STH JAPAN K.K. (the "Company") will strictly control any personal information received from you (the "User(s)") via the website (the "Site") and which is held by it, in compliance with the Personal Information Protection Act (the "Act") as well as any relevant laws and ordinances, and will endeavour to handle personal information appropriately by setting forth its privacy policy (this "Privacy Policy") as follows. 1. Definition of Personal Information "Personal Information" means information about a living individual which: (1) can identify the specific individual by name, date of birth or other written description, etc. (meaning records made up of documents, graphics, or electronic records) contained in such information (including such information as will allow easy reference to other information and will thereby enable the identification of the specific individual); or (2) contains an individual identification code, as set forth under the Act. Contact details, information about User preferences, payment details, and dietary requirements as well as IP addresses, geographical locations, browser type, referral source, length of visit and the number of page views is included in the Personal Information and other information collected by the Company. 2. Collection of Personal Information The Company will collect Personal Information by appropriate and fair methods, in compliance with the Act. In the event Personal Information is acquired directly, either in writing or via the web, the Company will clarify the purpose of use for such in advance. Please be advised that, in the event that User does not consent or if User later withdraws his/her consent to provide his/her Personal Information to the Company, it is possible that a portion of the services provided by the Company may not be made available to the User. When User submits information to the Company about another person, User must only do so when User has already obtained the relevant individual's consent. The Company will use such information in accordance with this Privacy Policy. 1

2 3. Purpose of Use of Personal Information The Company will handle Personal Information within the scope of the purposes of use indicated below. (1) Purpose of use for Personal Information concerning Users To ensure that the Site is presented in the most effective manner; To administer, support, improve, and develop the Site; To provide customer service; To address inquiries and complaints; To notify Users about changes to the Company's services; To send Users non-marketing communications; To send Users promotional (marketing) communications; To administer User accounts; To provide third parties with anonymous statistical information about Users; To process payments; To provide purchased goods and services; Investigation for protecting the Company and its affiliates against negligence, fraud, theft and other illegal activities; Notification or reporting to public authorities; and To comply with laws, regulations, court orders, or other obligations under applicable laws and ordinances. (2) Other purposes individually set forth and notified either orally or in writing. 4. Supervision of Employees/Consignees In allowing the Company's employees to handle Personal Information, the Company will provide necessary and appropriate supervision of such employees so as to protect Personal Information. Further, when the Company entrusts a third party with the handling of Personal Information, it will make it a condition of such entrustment for the consignee to conduct necessary and appropriate security controls, and will limit the consignee's handling of Personal Information to the scope necessary for the achievement of 2

3 the purpose of the entrustment, providing necessary and appropriate supervision so as to protect privacy. 5. Provision to Third Parties The Company will not provide Personal Information to a third party without obtaining the individual's prior consent unless such provision falls under "7. Joint Use" or the cases set forth below: When done so pursuant to laws or ordinances. When necessary for the protection of the life, body, or property of an individual and when it is difficult to obtain the consent of the person. When it is especially necessary for the enhancement of public safety or promoting the sound growth of children and when it is difficult to obtain the consent of the person. When it is necessary to cooperate with a national institution, a local public body, or an individual or entity entrusted thereby to execute operations prescribed by laws or ordinances and when obtaining the consent of the person might impede the execution of the operations concerned. When entrusting the handling of Personal Information within the scope necessary for the achievement of the purpose of use. When it is provided as a result of business transfer due to merger or other cause. 6. Anonymised Information, etc. In the event that the Company generates, utilises, or provides information relating to individuals which has been obtained by processing Personal Information such that a specific individual can no longer be identified ("Anonymised Information"), the Company shall appropriately process it in compliance with the Act, any relevant laws and ordinances as well as applicable guidelines, etc., and shall properly handle the generated Anonymised Information as well as information about the method(s) of processing, etc. Further, the Company shall take necessary and appropriate security measures when generating Anonymised Information and shall conduct necessary and appropriate supervision of employees and consignees (including re-consignees, etc.) that handle such Anonymised Information and information about the method(s) of processing, etc. When handling Anonymised Information, the Company shall not obtain the deleted portion(s) of Personal Information, individual identification code(s), or information about the method(s) of processing used to generate Anonymised Information, nor shall it reference the applicable Anonymised Information against other information, for the purpose of identifying the individual whose Personal Information was used to generate the applicable Anonymised Information. The Company generates and provides to third parties Anonymised Information which includes in the following information relating to individuals: 3

4 IP addresses, geographical location, browser type, referral source, length of visit and number of page views in relation to User's use of the Site The method(s) of providing such: Cookies, pixel tracking, direct transfer over the internet, and other electronic methods 7. Joint Use There may be cases where the Company may jointly use Personal Information it has acquired, subject to any necessary consents under the Act, as follows. In such cases, the Company will strictly administer security controls in accordance with this Privacy Policy. Personal Information to be used jointly Data such as address, name, telephone number, age, gender, date of birth, ID number, address as well as the content and history of shopping transactions, delivery locations, inquiries made to the Company, etc. Depending on the payment method User uses, the User s driver's license, passport number, bank account information, and/or payment card information may also be used jointly. Name and scope of joint users Sports Travel & Hospitality Group Limited, One Southampton Row, London WC1B 5HA, England Purpose for which the Personal Information is used by joint users Joint users will use Personal Information within the scope of the purposes of use stated in "3. Purpose of use of Personal Information". Name of the entity responsible for management of Personal Information used jointly STH JAPAN K.K. 4

5 8. Transfer of Personal Information to Other Countries/Provision to Third Parties in Other Countries The Company's servers are located in the United Kingdom, and therefore, User's information will be held in the United Kingdom. User Personal Information stored in the United Kingdom shall be protected to a standard substantially equivalent to that set out by this Privacy Policy. The Company may also transfer Personal Information to additional countries other than the country in which Users originally provided it, subject to any necessary consent from Users under the Act. These countries may not have the same data protection laws as the country in which the Users provided the information. In the event the Company transfers Personal Information to such additional countries, Personal Information shall be protected to a standard substantially equivalent to that set out by this Privacy Policy. Additionally, in the event that the consignee or the joint user handling the Personal Information qualifies as a 'Foreign Third Party' as specified in Article 24 of the Act, the Company shall adopt systems to ensure that the applicable consignee or joint user takes measures that continuously and substantively approximate those measures required to be taken in accordance with the Act and any relevant laws and ordinances. 9. Links to Other Sites This website may contain links to other sites for User convenience and information. Companies not affiliated with the Company may operate these sites. Linked sites may have their own privacy policies, which the Company strongly suggests User review if he/she visits any linked websites. The Company is not responsible for the content of any websites that are not affiliated with the Company, any use of those sites, or the privacy practices of those sites. 10. Security The Company will take reasonable security measures to prevent any unauthorised access to, and loss, destruction, tampering, and disclosure of Personal Information held by the Company. As part of necessary remedial measures of technical and physical safeguards for Personal Information, the Company uses Secure Sockets Layer ("SSL") technology to protect the transmission over the Internet of User payment card data. The Company shall endeavour to maintain that Personal Information is up-to-date and accurate. 11. Cookies The Company may use cookies to recognise User when User returns to the Company site in order to provide User with a better user experience. Please read the Cookie Policy page of the Site for more information. By using the Site, User agrees to the Company's use of cookies to process Personal Information. 5

6 12. Disclosure, Correction, Suspension of Use, etc. of Personal Information Any Personal Information which a User provides to the Company must be complete and accurate. User agrees to notify the Company at the following address without delay in the event of any change in User's Personal Information: info@sthjapan.com. In the event a person or his/her agent makes any of the following specified requests concerning his/her Personal Information to the Company, the Company will respond to the request without delay after completing verification in accordance with the method stated below. Processing of Personal Information shall be arranged for a fee of JPY1,500 per request; provided however, this shall not apply in those cases permitted under the Act and other relevant laws and ordinances. Request for notification of the purpose of use; Request for disclosure; Request for correction, addition, and/or deletion; Request for suspension of promotional service; Request for suspension of use and/or request for erasure; and Request for suspension of provision to third parties. Method to make request To make a request, please send a written document stating the name, address, and address of the person making the inquiry and content of the inquiry to the contact address specified in the "How to Contact the Company" section below by registered mail. Alternatively, User may stop receiving promotional s from the Company by clicking on the unsubscribe link in the relevant marketing s. Please be advised that any expenses such as postage fee will be borne by the person making the request. *Please kindly refrain from visiting the Company for inquiry purposes. How to Contact the Company STH JAPAN K.K. Address: 8F 4-1 Kasumigaoka-machi, Shinjuku-ku, Tokyo Japan, Phone number: address: info@sthjapan.com 6

7 Verification procedure Requests made by User The Company will verify User s identity by examining a copy of a public identification document such as a driver s license, passport, or health insurance card. Requests made by User s agent The Company will verify that the individual is User s legitimate agent by examining the agent's letter of authorisation and seal certificate for User s registered seal, or a copy of a public identification document such as both User s and User s agent s driver s license, passport, or health insurance card, in addition to telephone communication made by User. *The Company will respond to inquiries sent by User via registered mail. If User would prefer the response be sent to User s agent, please make an express statement to that effect in User s request document. 13. Review of the Privacy Policy The Company may from time to time review and modify this Privacy Policy. In the event the Company makes any amendment thereto, it will publicise said amendment using a reasonable method. 14. Contact for Inquiries on Personal Information For any inquiry regarding the Company s handling of Personal Information and/or this Privacy Policy, please contact the address or telephone number below: STH JAPAN K.K. Address: 8F 4-1 Kasumigaoka-machi, Shinjuku-ku, Tokyo Japan, Phone number: address: info@sthjapan.com *Please kindly refrain from visiting the Company directly for inquiry purposes. 7