Privacy Policy

(This Privacy Policy was last updated on 18th January 2020.)

Scope of Application

This Privacy Policy refers and applies to the RONJIRU JAPAN website (https://www.ronjirujapan.com/) [the “Website”] and RONJIRU JAPAN [the “Owner” of the Website, also “We/Us/Our”] and users [also “You/Your” (an individual acting on behalf of Yourself or a business entity)] who visit the Website. The Privacy Policy does not apply to other individuals’, companies’ or organizations’ websites, social media or other online resources to which the Website links.

Preamble

RONJIRU JAPAN is committed to safeguarding the privacy of users who visit the Website. This Privacy Policy [the “Privacy Policy”] sets out RONJIRU JAPAN’s personal information collection and sharing practices and is intended to inform You of the ways in which the Website collects personal information, the uses of that personal information and the ways in which RONJIRU JAPAN might share any personal information You choose to provide to RONJIRU JAPAN through the Website.

This Privacy Policy

This Privacy Policy is intended to explain RONJIRU JAPAN’s privacy practices and covers the following areas:

• What personal information about You We may collect
• How We may use Your personal information
• How We protect Your personal information
• Contacting Us and Your rights to prevent marketing and to access and update Your personal information
• Our Cookies Policy
• How changes to this Privacy Policy and the Cookies Policy will be made

Definition of “Personal Information”

As used in this Privacy Policy, the term “personal information” means information that specifically identifies an individual (such as a name, address, telephone number, mobile number, e-mail address, or photograph), or information about that individual that is directly linked to personally identifiable information. Personal information does NOT include “aggregate information”, which is data RONJIRU JAPAN collects about the use of the Website or about a group or category of services or users from which individual identities or other personal information has been removed. Personal information also does NOT include Usage Information (as defined below) or Device Identifier (as defined below) that is not connected to personal information. This Privacy Policy in no way restricts or limits RONJIRU JAPAN’s collection and use of aggregate information, Usage Information or Device Identifier information that is not connected to personal information.

External Links

The Website may contain links to external websites, social media or other online resources owned or maintained by a third party [“Third-party Websites”]. If You follow a link to any of those Third-party Websites, please note that they have their own privacy policies and that RONJIRU JAPAN does not accept any responsibility or liability for their policies or processing of Your personal information. Please check these policies before You submit any personal information to such Third-party Websites.

Embedded Content from Third-party Websites

Content on this Website may include embedded content (e.g. videos, images, articles, etc.). Embedded content from Third-party Websites behaves in almost exactly the same way as if You had visited that Third-party Website. Such Third-party Websites may collect data about You, use cookies, embed additional third-party tracking, and monitor Your interaction with that embedded content, including tracking Your interaction with the embedded content if You have an account and are logged in to that website.

RONJIRU JAPAN does not and cannot know what information is gathered by any third-party, and does not accept any responsibility or liability whatsoever for any third-party’s information collection or processing of Your personal information obtained from Your use of the Website or any of its Content, including embedded content.

I. What Information Does RONJIRU JAPAN Collect about You?

RONJIRU JAPAN will collect and process all or some of the following personal information about You:

Information Collected by Automated Means

Whenever You visit or interact with the Website, RONJIRU JAPAN, as well as any third-party advertisers and/or service providers, may use a variety of technologies that automatically or passively collect information about how the Website is accessed and used (“Usage Information”). Usage Information may include, in part, browser type, operating system, the page served, the time, how many users visited the Website, and the preceding page views. This statistical data provides RONJIRU JAPAN with information about the use of the Website, such as how many visitors visit a specific page on the Website, how long they stay on that page, and which hyperlinks, if any, they click on. This information helps RONJIRU JAPAN to keep the content of the Website fresh and interesting to users and to tailor content to a user’s interests. Usage Information is generally non-identifying, but if RONJIRU JAPAN associates it with You as a specific and identifiable person, We treat it as personal information.

In the course of collecting Usage Information, the Website also automatically collects Your IP address or other unique identifier (“Device Identifier”) for the computer, mobile device, technology or other device you use to access the Services. A Device Identifier is a number that is automatically assigned to Your device when you access a website or its servers, and RONJIRU JAPAN’s systems identify Your device by its Device Identifier. When you visit the Website, RONJIRU JAPAN may view your Device Identifier. We use this information to determine the general location of Your device in order to understand from what regions of the world users of the Website come. RONJIRU JAPAN also may use this information to enhance Our content or services.

Personal Information Collected by RONJIRU JAPAN

(a) Information You provide to RONJIRU JAPAN
Personal information that You provide to RONJIRU JAPAN, such as when using the contact form on the Website, including Your name, email address, and other contact details;
(b) Your correspondence
If You contact RONJIRU JAPAN, We will normally keep a record of that correspondence;
(c) Survey information
RONJIRU JAPAN may also ask You to complete surveys that We use for research purposes. In such circumstances RONJIRU JAPAN shall collect the information provided in the completed survey;
(d) Website and communication usage
Details of Your visits to the Website and information collected through cookies and other tracking technologies including, but not limited to, Your IP address and domain name, Your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that You access.

II. How Does RONJIRU JAPAN Use Your Personal Information?

This section sets out the purposes for which RONJIRU JAPAN uses Your personal information that is collected via the Website and the “legal grounds” on which RONJIRU JAPAN relies to process the information. These “legal grounds” are similar to those set out in the European Data Protection Law, which stipulates the specific “legal grounds” upon which companies may process personal data.

Usage & Legal Grounds 

A. To communicate effectively with You and conduct business
To conduct required business, including to communicate with you and respond to your emails, submissions, questions, inquiries, comments, requests, and complaints, or to carry out Our obligations arising from any agreements entered into between You and RONJIRU JAPAN;

Use justification:
Legitimate interest (to enable RONJIRU JAPAN to perform Our obligations and provide Our services to You)

B. To provide You with marketing materials
To provide You with updates and offers, where You have chosen to receive these. RONJIRU JAPAN may also use Your information for marketing Our own and Our selected business partners’ products and services to You by post, email, SMS, phone and fax and, where required by law, We will ask for Your consent at the time We collect Your data to conduct any of these types of marketing. RONJIRU JAPAN will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to You or You may opt out by contacting RONJIRU JAPAN through the contact form at www.ronjirujapan.com/contact/.

Use justification:
Consent, legitimate interest (to keep You updated with news in relation to content of the Website, or Our products).

C. For research & development purposes
To analyze Your personal information in order to better understand Your marketing requirements, to better understand RONJIRU JAPAN’s services, and to develop Our products and services;

Use justification:
Legitimate interest (to allow RONJIRU JAPAN to improve Our services)

D. To monitor certain activities
To monitor queries and transactions to ensure service quality, compliance with procedures and to combat fraud;

Use justification:
Legal obligations, legal claims, legitimate interest (to ensure the quality and legality of RONJIRU JAPAN’s services)

E. To inform You of changes
To notify You about changes to RONJIRU JAPAN’s services and products;

Use justification:
Legitimate interest (to notify You about changes to RONJIRU JAPAN’s service)

F. To ensure the Website content is relevant
To ensure that content on the Website is presented in the most effective manner for You and for Your device, which may include passing Your data to business partners, suppliers and/or service providers;

Use justification:
Legitimate interest (to allow RONJIRU JAPAN to provide You with content and services on the Website)

G. To reorganize or make changes to RONJIRU JAPAN’s business
In the event that RONJIRU JAPAN: (i) are subject to negotiations for the sale of Our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organization, RONJIRU JAPAN may need to transfer some or all of your personal information to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analyzing any proposed sale or re-organization. RONJIRU JAPAN may also need to transfer your personal information to that re-organized entity or third party after the sale or reorganization for them to use for the same purposes as set out in this Privacy Policy. 

Use justification:
Legitimate interest (in order to allow Us to change Our business)

H. In connection with legal or regulatory obligations
RONJIRU JAPAN may process Your personal information to comply with regulatory requirements or dialogue with regulators as applicable which may include disclosing Your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so. Where permitted, RONJIRU JAPAN will direct any such request to You or notify You before responding unless to do so would prejudice the prevention or detection of a crime.

Use justification:
Legal obligations, legal claims, legitimate interest (to cooperate with law enforcement and regulatory authorities)

III. How Does RONJIRU JAPAN Protect Your Personal Information?

Security over the internet

No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, RONJIRU JAPAN maintains commercially reasonable physical, electronic and procedural safeguards to protect Your personal information in accordance with requirements.

All information You provide to RONJIRU JAPAN is stored on Our or Our subcontractors’ secure servers and accessed and used subject to Our security policies and standards. Where RONJIRU JAPAN has given You (or where You have chosen) a password which enables You to access certain parts of the Website, You are responsible for keeping this password confidential and for complying with any other security procedures that RONJIRU JAPAN notifies You of. We ask You not to share a password with anyone. 

Outside the EEA (European Economic Area)

RONJIRU JAPAN and the Website are based in Japan, and use global servers and CDN networks that may be based outside the EEA. Consequently, if You are a user located within the EEA, any of Your personal information obtained as explicated herein will, by definition, be accessed by staff, and/or stored at, a destination outside the country in which You are located. Notwithstanding, RONJIRU JAPAN will safeguard personal information as set out in this Privacy Policy, based on existing legal requirements in Japan, once such personal information is received by RONJIRU JAPAN.

Japan is one of the countries outside the EEA which has been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to process personal information within this jurisdiction. Refer to the European Commission’s website page outlining “Adequacy decisions”, for more details.

By using the Website, or providing RONJIRU JAPAN with any information, you consent to the collection, processing, maintenance and transfer of such information in and to Japan and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to, those in the country where you reside and/or are a citizen.

Storage limits

RONJIRU JAPAN’s retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data. When personal data is no longer needed, RONJIRU JAPAN either irreversibly anonymizes the data (and We may further retain and use the anonymized information) or, typically, destroys the data.

IV. Your Rights and Contacting Us

Marketing

You have the right to ask RONJIRU JAPAN not to process Your personal information for marketing purposes. From time to time, We will inform You if We intend to use Your personal information for certain types of marketing activities, or if We intend to disclose Your information to certain categories of third parties for such purposes. You can exercise Your right to prevent such processing by not checking certain boxes on the forms the Website uses to collect Your personal information. You can also exercise the right at any time by contacting RONJIRU JAPAN via the Website’s contact form here: www.ronjirujapan.com/contact/.

Updating Information

RONJIRU JAPAN will use reasonable endeavors to ensure that Your personal information is accurate. In order to assist with this, You should notify Us of any changes to the personal information that You have provided to us, by contacting RONJIRU JAPAN via the Website’s contact form here: www.ronjirujapan.com/contact/.

Your Rights

If You have any questions in relation to RONJIRU JAPAN’s use of Your personal information, You should first contact Us via the Website’s contact form here: www.ronjirujapan.com/contact/. Under certain conditions, You might have the right to require RONJIRU JAPAN to: 

(a) provide You with details on the use We make of Your information;
(b) provide You with a copy of information that You have provided to Us;
(c) update any inaccuracies in the personal information We hold;
(d) delete any personal information that We no longer have a lawful ground to use;
(e) where processing is based on consent, to withdraw Your consent so that we stop that particular processing;
(f) object to any processing based on the legitimate interest ground unless our reasons for undertaking that processing outweigh any prejudice to Your data protection rights; and
(g) restrict how we use Your information whilst a complaint is being investigated.

Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and RONJIRU JAPAN’s interests (e.g. the maintenance of legal privilege). If You exercise any of these rights RONJIRU JAPAN will check Your entitlement and respond in most cases within a month.

Contacting RONJIRU JAPAN

If You have any questions in relation to this Privacy Policy, please contact RONJIRU JAPAN via the contact form on the Website at www.ronjirujapan.com/contact/. 

V. Cookies

RONJIRU JAPAN uses cookies on this Website. To find out more about how We use cookies, please see RONJIRU JAPAN’s Cookie Policy. 

VI. Annex

Use of personal information under EU and other data protection laws must be justified under one of a number of “legal grounds” and RONJIRU JAPAN has set out the grounds in respect of each use in this Privacy Policy. These are the principal legal grounds that justify RONJIRU JAPAN’s use of Your information: