Last Updated: January 6, 2023
Personal information is processed by or on behalf of the controller: firstname.lastname@example.org.
- Personal Information We Collect About You. We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, to you when you use our Services.
This information may include your name, contact information, other unique identifiers, financial information, information regarding your use of our Services, or any other personal information you voluntarily share with us.
This personal information is required to provide products and/or services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products and/or services to you.
- How Your Personal Information is Collected and Used. We collect most of this personal information directly from you - via our Services. However, we may also collect information:
- From publicly accessible sources (e.g., property records);
- Directly from a third party (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers);
- From a third party with your consent (e.g., your bank);
- From cookies on our website; and
- Automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email and messaging systems.
We use the personal information listed above for the following business purposes:
- To provide our Services to you;
- To comply with our legal and regulatory obligations;
- For the performance of our relationship with you or to take steps at your request before entering into a contract;
- For our legitimate interests or those of a third party; and
- Where you have given consent.
Legitimate Interests/Consent: To the extent we rely on our legitimate interests as a legal basis for processing of your personal information, we have considered the balance between our own interests (among other things, the lawful and efficient operation of our Services) and your interests and we believe that (a) you would reasonably expect us to carry out the kind of processing referenced above and (b) such processing will not cause you any harm and/or will not seriously impact your rights and freedoms with regard to data privacy. You have the right to withdraw any consent given to us for the processing of your personal information.
The table below explains what we use your personal information for and our reasons for doing so:
|What we use your personal information for||Our reasons|
|To provide Services to you||For the performance of our TOS with you or to take steps at your request before entering into a contract|
|To prevent and detect fraud against you and/or NotShibuya, Inc.||For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you|
|Conducting checks to identify our customers and verify their identity; Screening for financial and other sanctions or embargoes; Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business||To comply with our legal and regulatory obligations|
|Gathering and providing information required by or relating to audits, inquiries or investigations by regulatory bodies||To comply with our legal and regulatory obligations|
|Ensuring business policies are adhered to, e.g. policies covering security and internet use||For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you|
|Operational reasons, such as improving efficiency, training and quality control||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price|
|Ensuring the confidentiality of commercially sensitive information||For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information; To comply with our legal and regulatory obligations|
|Statistical analysis to help us manage our business, e.g. in relation to customer base, product and service range or other efficiency measures||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price|
|Preventing unauthorized access and modifications to systems||For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you; To comply with our legal and regulatory obligations|
|Updating customer records||For the performance of our contract with you or to take steps at your request before entering into a contract; To comply with our legal and regulatory obligations; For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products|
|Statutory returns||To comply with our legal and regulatory obligations|
|Ensuring safe working practices, staff administration and assessments||To comply with our legal and regulatory obligations; For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you|
|Marketing our services and those of selected third parties to: existing and former customers; third parties who have previously expressed an interest in our services; third parties with whom we have had no previous dealings.||For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers|
|External audits and quality checks||For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards; To comply with our legal and regulatory obligations|
Promotional Communications. We may use your personal information to send you updates (by email, text message, telephone or mail) about our products and/or services, including exclusive offers, promotions or new products or services.
We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
You have the right to opt out of receiving promotional communications at any time by:
- Contacting us at email@example.com; or
- Using any “unsubscribe” link in emails or “STOP” number in texts.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.
- Who We Share Your Personal Information With. For the reasons identified above, we may share personal information with:
- Our affiliates;
- Service providers we use to help deliver our products and/or services to you;
- Other third parties we use to help us run our business, such as marketing agencies or website hosts;
- Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
- Our insurers and brokers;
- Third parties in connection with, or during negotiations of, any reorganization, merger, or sale of our business; and
- Third parties when we believe it is necessary under applicable law; to enforce our terms and conditions; to protect our rights, privacy, safety, or property of yours or others; and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other governmental authorities. We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We may also share personal information with external auditors.
- How Long Your Personal Information Will Be Kept. We will only keep your personal information for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.
Cross-Border Data Transfers. We may transfer your personal information to a third party that is located in a jurisdiction other than the one from which we collected your personal information, including to countries that have not been deemed to have an adequate level of protection for the rights and freedoms of data subjects. If we do transfer your personal information to another jurisdiction, we will do so following due diligence and provided that the data recipient is subject to contractual agreements imposing obligations on it to ensure appropriate technical and organization measures are implemented and maintained at all times to prevent the unauthorized and unlawful processing of personal information, and the accidental loss or destruction of, or damage to, personal information, consistent with our obligations under applicable data protection laws.
- Your Rights Under the GDPR. If you are an EU or UK resident, you are entitled to certain rights under the GDPR and UK GDPR with respect to personal information that we have collected. We have listed below how these rights operate in the context of using our Services.
|Right to Access||The right to be provided with a copy of your personal information (the right of access)|
|Right to Rectification||The right to require us to correct any mistakes in your personal information|
|Right to be Forgotten||The right to require us to delete your personal information - in certain situations|
|Right to Restriction of Processing||The right to require us to restrict processing of your personal information - in certain circumstances, e.g. if you contest the accuracy of the data|
|Right to Data Portability||The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party - in certain situations|
|Right to Object||The right to object: at any time to your personal information being processed for direct marketing (including profiling); in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.|
|Right Not to be Subject to Automated Individual Decision-Making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
If you would like to exercise any of the above rights or if you have questions about your privacy rights, please use the contact details in the How to Exercise Your Rights section.
- Your Rights Under In California.
“Shine the Light” and “Eraser” Laws: Residents of the State of California may request a list of all third parties to which we have disclosed certain information during the preceding year for those third parties’ direct marketing purposes.
Do-Not-Track Disclosures. We do not support Do Not Track (“DNT”) requests. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser
Keeping Your Personal Information Secure. We have appropriate security measures in place designed to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
- Email us at firstname.lastname@example.org.
GDPR Complaint. We hope that we can resolve any query or concern you raise about our use of your information. The General Data Protection Regulation gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
Children. Our Services are not directed to children under the age of 18 and we do not knowingly solicit, collect, use, or disclose Personal Information from children under the age of 18. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it.
Our contact details are shown below: