ITO EN strictly complies with all laws and regulations regarding the protection of personal information.
2. Use of Personal Information
ITO EN collects personal information through proper means, fully specifies, discloses and provides notice regarding the purpose for any use of personal information, and uses information within the limits of that purpose.
Information is provided to third parties in accordance with proper procedures stipulated by law.
3. Safeguarding of Personal Information
Personal information held by ITO EN is safely and carefully managed, with necessary and appropriate safeguards in place to prevent leak, loss or damage.
4. Management of Personal Information by Business Partners
ITO EN conducts the proper oversight of external business partners to ensure sufficient safeguards for personal information.
5. Procedures for Disclosure of Personal Information
ITO EN responds quickly to any requests from customers for disclosure or other action regarding personal information held by the Company.
6. Ensuring the Accuracy of Personal Information
ITO EN continually reviews and revises its policies regarding customer information in response to changes in the social environment in order to ensure proper management.
Privacy Notice for Personal Data in the European Economic Area
SUMMARY OF PRIVACY NOTICE
This summary Privacy Notice (“Summary Notice”) will provide you with a summary of the accompanied, detailed Privacy Notice (hereafter “Full Notice”, together "Summary and Full Notice") on the data processing activities of ITO EN LTD., located at [47-10, Honmachi 3-chome, Shibuya-ku, Tokyo 151-8550], Japan. ("ITO EN LTD.", "our", "we" or "us") with respect to individually identifiable information ("Personal Data").
Scope of applicability
This Summary and Full Notice applies to you where:
- a ) you are a user of our site http://www.itoen.co.jp ("Website");
- b ) you apply for our prizes or campaigns;
- c ) you are a user of our services (including our online or mail order sales);
- d ) you visit our facilities and participate in our events;
- e ) you are involved in our research and development.
Processing of your Personal Data (categories of Personal Data)
We process the following of your Personal Data: your full name, your postal address including your street and number, city, zip code, your phone number , your date of birth, your sex, your IP-address, host name, user agent, browser identification, referrer, the date/time of your access to the Website, your email address, your country and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you. For more details see 1. of the Full Notice or click here.
We process your Personal Data for the following purposes: such as getting in contact with you, sending marketing materials, delivering our products or other purposes for us to review, develop and improve the quality of our products and service. For more details see 2. of the Full Notice or click here.
Legal justifications for the processing of your Personal Data
One of the key privacy law requirements is that any processing of Personal Data has to have a legal justification. We generally use the following legal justifications:
- (1) You have given your consent to the processing (Art. 6 (1) (a) GDPR; “Consent Justification”),
- (2) the processing is necessary for (a) compliance with a legal obligation (Art. 6 (1) (c) GDPR; “Legal Obligation Justification”) and (b) realizing a legitimate interest (Art. 6 (1) (f) GDPR; “Legitimate Interest Justification”). For more details and the matching of purposes and corresponding legal justifications see 3. of the Full Notice or click here.
Data transfers and recipients and legal justification for such transfers
We transfer your Personal Data to our service providers, and, in accordance with applicable law, other governmental authorities, courts, external advisors, and similar third parties, some of the aforementioned recipients located in jurisdictions outside the EU. For more details see 4. of the Full Notice or click here.
Retention periods for and deletion of your Personal Data
Your Personal Data will be deleted once they are not any longer needed for the purposes motivating their original collection or as required by applicable law. For more details see 5. of the Full Notice or click here.
Your statutory rights
You have a number of rights with regard to the processing of your Personal Data, each as per the conditions defined in applicable law, such as the right to have access to your Personal Data, to have them corrected, erased or handed over. Please refer any of your questions to email@example.com. For more details see 6. of the Full Notice or click here.
Changes of this Summary and Full Notice as well as further notices
This Summary and Full Notice are subject to change. You will be notified adequately of any such changes. Further, you will be notified adequately through further relevant privacy notices (e.g. for specific purposes) in case such is not covered by this Summary and the Full Notice.
How to contact us
If you wish to exercise your data subject rights or if you have any other questions concerning this Summary and Full Notice, please address your request to us.
ITO EN LTD.
47-10, Honmachi 3-chome, Shibuya-ku, Tokyo 151-8550, Japan
Your privacy is important to us. Hereafter, we provide you with detailed information on dealing with your personal data.
1. Categories of Personal Data
We process the following Personal Data about you (hereinafter jointly "Your Data"):
- ( i ) your IP-address, host name, user agent, browser identification, referrer, and the date/time of your access to the Website (hereinafter jointly "Technical Data");
- ( ii ) your full name, your phone number, your email address, your postal address including your street and number, city, zip code (hereinafter jointly "Contact Data");
- ( iii ) your sex, your age, your country and your city (hereinafter jointly "Marketing Data"); and
- ( iv ) any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you (hereinafter jointly "Form Data").
2. Processing purposes
We process Your Data to the extent permitted or required under applicable law, for the following purposes:
- to provide the Website in an optimized way for you and to currently enhance the user experience of the Website (hereinafter "Quality Purposes");
- to send you marketing materials, such as newsletters to provide you with the latest information about our products and services which might be of interest to you (hereinafter jointly "Marketing Purposes");
- to get in contact with you concerning your queries and to administrate records of queries (hereinafter "Contact Purposes");
- to get in contact with applicants for our prizes or campaigns and to send prizes or premiums to winners (hereinafter "Campaign Purposes");
- to deliver our products and administrate order history in connection with our online or mail-order sales (hereinafter "Business Purposes");
- to manage visitors to our facilities and our events (hereinafter jointly "Visitor Management Purposes"); and
- to get in contact with those who conduct research and development in connection with our business (hereinafter jointly "R&D Purposes").
3. Legal justification for the processing of Your Data
Generally, the processing of Your Data is voluntary. However, if you do not provide Your Data, the use of the Website or our services may be different. Also, you cannot apply for our prizes or campaigns or be involved with our research and development activities without providing your personal data to us.
Furthermore, We rely on the following legal justifications for the processing of Your Data:
|Processing purposes||Categories of Your Data involved||Legal basis|
|Quality Purposes||Technical Data||Legitimate Interest Justification. Our legitimate interest is
Legitimate Interest Justification. Our legitimate interest is
Legitimate Interest Justification. Our legitimate interest is to provide our products and services.
Legitimate Interest Justification. Our legitimate interest is to improve and operate our business.
Legitimate Interest Justification. Our legitimate interest is
|Visitor Management Purposes||
||Legitimate Interest Justification. Our legitimate interest is to secure safety for visitors to our facilities and events and our officers and employees.|
|R&D Purposes||Contact Data||Legitimate Interest Justification. Our legitimate interest is
4. Data transfers and recipients and legal justification for such transfers
- 4.1 Recipients
- ( i )Other group companies: We transfer Your Data to other ITO EN LTD. group companies, as permitted under applicable data protection law pursuant to Legitimate Interest Justification of ITO EN LTD. to facilitate the contact with you and your queries.
- ( ii ) Third parties: We may transfer Your Data to governmental agencies and regulators, courts, and government authorities, all in accordance with applicable law based on Legal Obligation Justification and to external advisors acting as controllers (e.g., lawyers, accountants, auditors etc.) based on Legitimate Interest Justification.
- ( iii ) Service providers: We contract with third party service providers as part of our normal business operations to provide our services to you.
- ( iv ) A list of data recipients can be found in the Annex containing the identity, short description of the processing activity and location of the relevant data recipients.
- 4.2 Cross-Border Data Transfers
- ( i )Your Data may be transferred outside of the country you are located. Some recipients of Your Data are located in Japan and also other countries for which the European Commission has not issued a decision that this country ensures an adequate level of data protection.
- ( ii )We have established that all recipients located outside the EEA will provide an adequate level of data protection for Your Data and that appropriate technical and organizational security measures are in place to protect Your Data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. Any onward transfer is subject to appropriate onward transfer requirements as required by applicable law.
5. Retention periods for and deletion of Your Data
- 5.1 Your Data processed for the purposes hereunder will be stored only to the extent necessary. If a judicial or disciplinary action is initiated, Your Data may be stored until the end of such action, including any potential periods for appeal, and will then be deleted or archived as permitted by applicable law.
- 5.2 In principle, we will retain Your Data as long as required or permitted by applicable law. Afterwards, we will remove Your Data from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it.
6. Your statutory rights
Under the conditions set out under applicable law (i.e., the GDPR), you have the following rights:
6.1 Right of access:
You have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, to request access to the Personal Data. The access information includes – inter alia – the purposes of the processing, the categories of Personal Data concerned, and the recipients or categories of recipients to whom the Personal Data have been or will be disclosed. You have the right to obtain a copy of the Personal Data undergoing processing. For additional copies requested by you, we may charge a reasonable fee based on administrative costs.
6.2 Right to rectification:
You have the right to obtain from us the rectification of inaccurate Personal Data concerning you. Depending on the purposes of the processing, you have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.
6.3 Right to erasure (right to be forgotten):
You have the right to ask us to erase your Personal Data.
6.4 Right to restriction of processing:
You have the right to request the restriction of processing your Personal Data. In this case, the respective data will be marked and may only be processed by us for certain purposes.
6.5 Right to data portability:
You have the right to receive the Personal Data concerning you which you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit those Personal Data to another entity without hindrance from us.
6.6 Right to withdraw your consent:
If you have given your consent regarding certain types of processing activities, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.
6.7 Right to object:
You have the right to object, on grounds relating to your particular situation, at any time to the processing of your Personal Data by Us and We can be required to no longer process your Personal Data. If you have a right to object and you exercise this right, your Personal Data will no longer be processed for such purposes by Us. Exercising this right will not incur any costs. Such a right to object may not exist, in particular, if the processing of your Personal Data is necessary to take steps prior to entering into a contract or to perform a contract already concluded.
Please note that the aforementioned rights might be limited under the applicable national data protection law. We remain the universal point of contact for your execution of these rights.
Please refer any of your questions to : firstname.lastname@example.org
In case of complaints you also have the right to lodge a complaint with the competent supervisory authority, in particular in the member state of your habitual residence or alleged infringement of the GDPR.
Summary and Full Notice last updated:
[October 15, 2018]
|Name of Data Recipient||Location||Receiving Data as Controller or Processor||Short description of processing activities|
|PR KOMBINAT INC.||3-23 Kioicho, Chiyoda-ku, Tokyo 102-8025||Processor||Assisting us in marketing campaigns including ITO EN Oi Ocha Shinhaiku Contest|