Privacy Policy

Introduction

We at The Japan Investor (“TJI”, “Us”, “We”) want to provide you with the best possible experience when you access our website at www.thejapaninvestor.com (“Website”) and use the services we deliver through it (“Services”). To accomplish this, we need information on how you access and use our Website and Services.

Your privacy and security of your Personal Data is and will always be enormously important to Us. In this policy (“Privacy Policy”) we want to transparently explain how and why we gather, store and use your Personal Data, as well as outline the controls and choices regarding the Personal Data we collect and process about you and how we will protect your privacy.

For the purposes of this Privacy Policy “Personal Data” refers to all data which relates to a living individual who can be identified from such data such as for instance, name, address or identification number. It does not include data that has been de-linked from your identity such as anonymised aggregated Services usage data.

About this Policy

This Privacy Policy sets out the essential details relating to your Personal Data relationship with TJI.

From time to time, we may adapt and further enhance the Services. If the change to the Services results in a material change to the way we collect or process your Personal Data we will provide you with more information or additional terms or policies. Unless stated otherwise when We introduce changes to the Services, such changes will be subject to the Privacy Policy.

If you have any questions about the Privacy Policy, including any requests in relation to your legal rights, please address them to Us at the following address:

TJI

contact@thejapaninvestor.com

You always retain the right to forward a complaint to the Office of the Commissioner for Data Protection, the supervisory authority for data protection issues in the Republic of Cyprus. We would, however, appreciate the opportunity to address your concerns at first instance before you approach the Commissioner for Data Protection.

Data we Collect from You

The below list sets out the data, including Personal Data that we may collect from you in the course of providing you with the Services

• User Data
  • This is data that you might provide if you were to subscribe or sign up to the Services and would include information such as your username, e-mail address, phone number, profession, street address and country of residence.
  • At the moment we do not offer subscription services and therefore do not collect such user data.
• Usage Data
  • This is data, which may include Personal Data and which is collected when you are accessing the Website or using the Services.
  • It includes information about your interaction with the services, browsing history on the Website, your search queries and use of links to Third-Party Sites.
  • It includes inferences drawn about your areas of interest based on your usage of the Services.
  • It includes certain technical data such as URL information, IP address, information on the devices used to access the Services and non-precise geographic location.
• Payment and Purchase Data
  • We may collect certain Personal Data if you sign for a paid subscription or make any purchases through the Services. The exact Personal Data collected will vary depending on the payment method but will include information such as your name, date of birth, credit or debit card type, expiration date, certain digits of your card number, your postal code and address.
  • We currently do not offer paid subscriptions or other take any payments from you through our Services.
• Cookies
  • The Website consist of cookies to help improve and personalise your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programmes or deliver viruses to your computer or device. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to save your time when you access the Website or use the Services. The purpose of cookies is to tell the web server that you have returned to a specific page. For example, if you access the Website or use the Services, a cookie helps Us recall your information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses (if applicable) and so on. When you return to the Website, the information you previously provided can be retrieved, so you can easily use the Website features that you customised. You have the ability to accept or decline cookies, other than cookies that are necessary for the proper functioning of the Website and Services.
• Special Categories
  • We do not collect information “Special Categories” of Personal Information relating to your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership or genetic or biometric data.

What We Use Your Personal Data For

In delivering the Services We use your Personal Data in a number or ways, as allowed by applicable local law and the EU General Data Protection Regulation (EU) 2016/679 (“GDPR Regulation”). More specifically we process Personal Data that we collect for the following purposes:

• Where we need to perform any Contract We have entered into with you;
• Where it is necessary for compliance with a legal or regulatory obligationWe are subject to; and
• In pursuit of a legitimate interest related to the conduct of our business.

In deciding whether to process your Personal Data in pursuit of our legitimate business interests we always make sure to consider and balance any potential impact on you, and where there is room for any doubt as to where this balance lies, we will ask for your consent before processing your Personal Data. Below are examples of legitimate interests for which Personal Data can be used:

• To understand, diagnose, troubleshoot and fix issues with the Website and the Services;
• To evaluate and develop new features and improvements for the Website and the Services;
• For marketing, promotion and advertising purposes (in certain cases subject to your consent);
• To conduct business planning, reporting and forecasting.

Your Rights and Control over Personal Data we Collect

The GDPR gives certain rights to individuals in relation to their Personal Data. The rights afforded to individuals are:

• Right to Access – the right to be informed of, and request access to, the Personal data We process about you.
• Right to Rectification – the right to request that we amend or update your Personal Data where it is inaccurate or incomplete.
• Right to Erasure – the right to request that we delete your Personal Data where there is no good reason for Us continuing to process it. You also have the right to ask Us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed our information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that We may not always be able to comply with your request for erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.
• Right to Restrict – the right to request that We temporarily or permanently stop processing all or some of your Personal Data. This might apply in scenarios where you want Us to establish the data’s accuracy, where our use of the data might be unlawful but you do not want us to erase it, where you need us to hold the data for your exercise or defence of legal claims even if We no longer require it for legitimate reasons, or where you have objected to our use of your Personal Data but we need to verify whether We have overriding legitimate grounds to use it.
• Right to Object– the right to object to the processing of your Personal Data. This may arise in situations where we are processing your Personal Data for the purposes of legitimate interests and where your objections relate to your particular situation, or where We are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which override your rights and freedoms.
• Right to Data Portability – the right to request a copy of your personal data in electronic format and the right to transmit that Personal Data for use or processing in another party’s service.
• Right not be Subject to Automated Decision-Making – the right to not be subject to a decision based solely on automated decision making, including profiling where the decision would have a legal effect on you or produce a similarly significant effect.
• Right to Withdraw Consent – the right to withdraw consent at any time where We are relying on your consent to process your Personal Data.

Sharing your Personal Data

We may share your Personal Data with third parties under the following circumstances:

• Service Providers – We work with service providers which work on our behalf and which may need access to certain Personal Data in order to provide their services to Us. These companies include those We’ve hired to provide customer service support, operate technical infrastructure that we need to deliver the Services, assist in protecting and securing our systems and services.
• Payment Processors – Once We start offering paid subscriptions, We will share your personal data with our payment processors as necessary to enable them to process your payments, and for anti-fraud purposes.
• Advertising Partners – We work with advertising partners to enable us to customise the advertising content you may receive on the Website and through the Services. These partners help Us deliver more relevant ads and promotional messages to you, which may include interest-based advertising, contextual advertising, and generic advertising. We and our advertising partners may process certain Personal Data to help Us understand your interests or preferences so that we may deliver advertisements that are more relevant to you.
• Employers – We may share certain Personal Data with employers who wish to post job-listing on the Website or through our Services to Us and the employers better adapt such job listings to the interests of the users of our Services.

Data Retention and Deletion

We keep your Personal Data only as long as necessary to provide you with the Services and for legitimate and essential business decisions about features and offerings, complying with our legal obligations and resolving disputes.

If you request, we will delete or anonymise your Personal Data so that it no longer identifies you, unless We are legally allowed or require to maintain certain Personal Data.

International Transfers

Where your Personal Data is transferred outside of the European Union for processing, We shall ensure that the transfer of your Personal Data is carried out in accordance with applicable privacy laws, and in particular, that appropriate contractual, technical, and organisation measures are in place such as the Standard Contractual Clauses approved by the EU Commission.

Links

We may display advertisements from third parties and other content that links to Third-Party Sites. We cannot control or be held responsible for third parties’ privacy practices and content. If you click on a third-party advertisement or link, please understand that you are leaving the Services and any Personal Data you provide will not by covered by the Privacy Policy. Please read their privacy policies to find out how they collect and process your Personal Data.

Security

The security of your Personal Data is important to us. We implement appropriate technical and organisational measures to help protect the security of your Personal Data. We have implemented various policies including anonymisation, encryption, access and retention policies to guard against unauthorised access and unnecessary retention of Personal Data in our systems, however, please note that no system is ever completely secure.

Children

The Services are not directed to children under the age of 16 years. Children aged 13 years or older can access the Services subject to parental consent.