GDPR

Privacy Policy for Personal Data of Customers in Europe

Kochi Prefectural Trade Association (“Kochi Prefectural Trade Association”, “we”, “us” or “our”) will carefully handle customers’ personal data and will strive for appropriate management and operation of the data so that customers (“you” or “your”) can use the services provided by Kochi Prefectural Trade Association (including Kochi Prefectural Trade Association’s website (hereinafter referred to as the "Website")) with security.

This privacy policy (hereinafter referred to as the "Privacy Policy") describes the processing of personal data of customers in the European Economic Area (hereinafter referred to as the “EEA”; consisting of the EU Member States, Norway, Iceland, and Liechtenstein) and the UK, in relation to the services provided by Kochi Prefectural Trade Association. Please refer to the privacy policy of Kochi Prefectural Trade Association’s website for the handling of personal information of customers located outside of Europe. Capitalized terms not defined herein shall have the meaning set out in the EU General Data Protection Regulation 2016/679 (the “GDPR”).

For the purpose of this Privacy Policy, Kochi Prefectural Trade Association is responsible for the processing of your Personal Data as a Controller. The contact details of Kochi Prefectural Trade Association are described in Section 13 below.

1. We will collect and process the following personal data about you:
(a) Information you give us. This includes information about you that you give us by using our services (including but not limited to this Website), or by communicating with us, whether by e-mail, letter or otherwise. The information you give us is likely to include your name, occupation, address (including but not limited to the country, state and city where you are located), e-mail address, and content of your inquiries and opinions.
(b) Information we collect about you. When you visit this Website, it automatically collects certain types of data related to you (“access data”). These types of data include access logs, web beacons (also known as pixels), cookies, etc. These types of data may remain on your computer and continue to collect data. For more information about how we use your access data and the respective legal bases, please see our Policy regarding the Use of Access Data.
You may be required to provide your personal data only to the extent necessary to use the services provided by Kochi Prefectural Trade Association. Personal data provided will be used within the scope necessary to achieve the purpose of use, and will not be used for any purpose other than the purpose of use without the consent of the customer.

2. Kochi Prefectural Trade Association will use the personal data it has collected with respect to customers for the following purposes. Kochi Prefectural Trade Association will use your personal data only to the extent necessary to achieve these purposes.
・Accepting customer opinions and inquiries, and responding to such opinions and inquiries (based on the legitimate interests, performance of contractual obligations or your consent); and
・To invite business partners in Europe to Japan (based on legitimate interests or your consent).

3. Kochi Prefectural Trade Association will only process your personal data within the scope permitted by law. Kochi Prefectural Trade Association will process your personal data based on the following grounds:
Performance of contractual obligations: This is when Kochi Prefectural Trade Association needs to process your personal data in order to perform a contract entered into with you.
Consent: This is when Kochi Prefectural Trade Association receives consent from the customer for processing personal data. However, even when we obtain consent from you, we may process your personal data based on other legal grounds. The withdrawal of your consent (please see Section 10.g of this Privacy Policy below) shall not affect the lawfulness of processing performed based on the consent obtained before your withdrawal.
Legal obligations: This is when Kochi Prefectural Trade Association needs to comply with legal obligations. Legitimate interests: This is when processing of the customer’s personal data is necessary for the legitimate interests pursued by Kochi Prefectural Trade Association or by a third party, provided that the customer’s interests and fundamental rights are not overridden by the above interests. More specifically, we use your personal data, the collection of which is limited only to the information we require and which does not contain personal data of a high risk nature, for the limited purposes of accepting, and responding to, your requests, and inviting our business partners to Japan, which are necessary for us to provide or improve our services. Given the nature of the personal data we collect and retain and the security measures we take, we believe that no serious privacy risk would arise even in the event of an unauthorized data breach.

4. Kochi Prefectural Trade Association may share your personal data with the following types of recipients. Kochi Prefectural Trade Association requires that when personal data of a customer is received by a processor for processing, the data must be processed in accordance with contractual provisions stipulating that the information will be protected, processed in accordance with applicable data protection laws, including GDPR, and used only in accordance with Kochi Prefectural Trade Association’s instructions, and that the information shall not be used for the purposes of the processor itself.
Kochi Prefecture: Kochi Prefectural Trade Association is a public utility association entrusted by Kochi Prefecture to carry out promotional activities to facilitate the exports of Kochi produce. We may periodically report the status of the operation of this Website to Kochi Prefecture, and may disclose some of your personal data to it.
Service providers: Service providers include service providers in the IT industry, such as internet service providers and cloud service providers. Subcontractors: This is when the processing of personal data is necessary for the execution of operations relating to Kochi Prefectural Trade Association’s outsourcing of operations to a third party, such as questionnaire surveys in the EEA and inviting EEA business partners to Japan.

5. The personal data Kochi Prefectural Trade Association has with respect to customers may be transferred to third parties outside the EEA and may be retained by such third parties. If Kochi Prefectural Trade Association transfers your personal data to a third party outside the EEA, we will ensure the following:
The region to which the transfer is to be made has been certified by the European Commission as ensuring an adequate level of protection for the rights and freedoms of the customers’ personal data; or
The recipient of personal data has concluded a contract with Kochi Prefectural Trade Association containing the standard contractual clauses approved by the European Commission.
By contacting us as set forth in Section 13 below, you can confirm further details of the protection provided when your personal data is transferred outside the EEA (including receipt of a copy of the standard contractual clauses entered into by Kochi Prefectural Trade Association with the person who receives your personal data).

6. Kochi Prefectural Trade Association will retain personal data collected with respect to you during the period we provide you with our services. Personal data related to customers that is no longer needed after the service provision period will be deleted. The retention period of personal data collected by Kochi Prefectural Trade Association will vary for each category of personal data, and shall not exceed, in any event, 5 years with respect to the services we offer. However, this shall not apply to personal data that is required by law to be retained for a longer period, and such personal data will be retained for the period of time required by law.

7. Kochi Prefectural Trade Association takes the following security measures when operating this Website and will take appropriate care to prevent unauthorized access to personal data, leakage, or falsification of personal data. We limit access to the server from external sources only for those protocols that are strictly necessary to provide the service. We protect against unauthorized access by means of a virus detection system, etc.
Communications are protected by SSL encryption protocols.
For services other than the Website provided by Kochi Prefectural Trade Association, necessary and appropriate organizational and technical measures are taken to ensure security for each type of service.

8. Kochi Prefectural Trade Association will not be able to manage your personal data at websites that are not under Kochi Prefectural Trade Association’s control, including those of enterprises, associations, or individuals that are linked to this Website. These websites linked to this Website may collect your personal data separately. We recommend that you handle your personal data carefully and check the privacy policy of each website.

9. In addition to this Privacy Policy, Kochi Prefectural Trade Association may establish other individual privacy policies that provide for more detailed matters with respect to services provided by Kochi Prefectural Trade Association. In the event that a privacy policy is established separately from this Privacy Policy, if there is any difference between this Privacy Policy and the individual privacy policy, the individual privacy policy will prevail.

10. You have the following rights relating to the personal data Kochi Prefectural Trade Association retains with respect to you.
a. The right to acquire information related to the processing of the customer’s personal data and the right to access the personal data held by Kochi Prefectural Trade Association with respect to the customer.
b. The right to request the correction of any inaccurate or incomplete personal data of the customer.
c. The right to request that Kochi Prefectural Trade Association erase your personal data under certain circumstances, including, but not limited to, the following circumstances:
- when Kochi Prefectural Trade Association is no longer required to retain your personal data in the light of the purpose for which it collected the personal data;
- when Kochi Prefectural Trade Association may process personal data only with the consent of a customer and the customer withdraws the consent;
- when you object to Kochi Prefectural Trade Association’s processing of personal data based on legitimate interests and Kochi Prefectural Trade Association’s legitimate interests do not prevail over your own interests, rights, and freedoms.
d. The right to require Kochi Prefectural Trade Association to restrict Kochi Prefectural Trade Association’s processing of personal data under certain circumstances, including, but not limited to, the following circumstances:
- when you challenge the accuracy of your personal data (only for the period Kochi Prefectural Trade Association needs to confirm its accuracy);
- when Kochi Prefectural Trade Association no longer needs the personal data for the purposes of the processing, but they are required by the customers for the establishment, exercise or defense of legal claims;
- if you object to Kochi Prefectural Trade Association’s processing of personal data based on legitimate interests (only for the period necessary to determine whether the legitimate interests of Kochi Prefectural Trade Association prevail over their own interests, rights and freedoms).
e. The right to object to Kochi Prefectural Trade Association in relation to the processing of the customer’s personal data.
f. The right to receive any personal data which we process about you on the basis of your consent or on a contract (as opposed to any other legal ground) and where the processing is carried out by automated means in a structured, commonly used and machine-readable format and/or request that we transmit that data to a recipient where this is technically feasible. Please note that this right only applies to personal data which you have provided to us.
g. The right to withdraw your consent to the processing of your personal data at any time. Please note, however, that Kochi Prefectural Trade Association may continue processing your personal data if it can rely on another legal basis.
You may exercise your rights by contacting Kochi Prefectural Trade Association as described in Section 13. If you believe that Kochi Prefectural Trade Association has infringed any of your rights, you may file a complaint with a data protection authority.

11. If this Privacy Policy is changed, Kochi Prefectural Trade Association will publish the changed Privacy Policy on this Website and update the revision date.

12. If you have any questions regarding this Privacy Policy, the exercise of your rights, or any other matters related to the protection of personal data, please contact the following contact address:
Kochi Prefectural Trade Association:
Address: 1-2-20 Marunouchi, Kochi City, Kochi, Japan
E-mail: bosyu@kpta.or.jp

Published: January 21, 2021.