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Privacy Policy for Users Residing in EEA and UK
This Privacy Policy (hereinafter referred to as “Policy”) sets forth our company’s policy on how we will handle the personal data of people who use or access DeepExperience (hereinafter referred to as the “Service”) operated by DeepExperience Co., Ltd., (hereinafter referred to as “Company”) and who reside in European Economic Area (hereinafter referred to as “EEA”) or the United Kingdom (hereinafter referred to as “Users”). This Policy conforms to the General Data Protection Regulation (hereinafter referred to as “GDPR”) of the European Union and the UK.
1. Compliance with the GDPR
The Company will comply with the GDPR in handling the personal information of Users.
2. Handling of personal data in the Service
2.1. Name
The Company will handle the User’s name for the following purposes. The purposes of use and the grounds on which the Company is able to legally handle personal data under the GDPR are as stated in the table below.
| [Purpose of Use] | [Grounds on which the Company is able to legally handle the information] |
|---|---|
| For the Company and tour sponsor to identify the data subject | GDPR Article 6, paragraph 1 (b) This is a purpose of use that is necessary for providing the Service. |
| To receive provision of information that is necessary for applying for the service and facilities used in the tour (information will be provided to the service and facility operator to the extent necessary for the application.) | GDPR Article 6, paragraph 1 (b) A purpose of use that is necessary for providing the tour to the User. |
| To provide information about the use of the Service. | GDPR Article 6, paragraph 1 (b) This is a purpose of use that is necessary for providing the Service. |
| To receive necessary communication from the Company or tour operator in relation to participation in the tour. | GDPR Article 6, paragraph 1 (b) This is a purpose of use that is necessary for providing the Service. |
| To distribute e-mail magazines. | GDPR Article 6, paragraph 1 (a) E-mail magazines will only be distributed to consenting Users. Users may revoke their consent at any time using the email magazine distribution settings of the Service. |
2.2. Date of birth
The Company will handle the date of birth of the User and other tour participants for the following purposes. The purposes of use and the grounds on which the Company is able to legally handle personal data under the GDPR are as stated in the table below.
| [Purpose of Use] | [Grounds on which the Company is able to legally handle the information] |
|---|---|
| To receive provision of information that is necessary for applying for the service and facilities used in the tour (information will be provided to the service and facility operator to the extent necessary for the application.) | GDPR Article 6, paragraph 1 (b) This is a purpose of use that is necessary for providing the Service. |
| To analyze the attributes of the Users who use the Service and use such data for marketing | GDPR Article 6 paragraph 1 (f) The data will only be used for marketing by the Company, so the potential disadvantages to the User will be limited compared to the benefits provided by the Company. |
2.3. Gender
The Company will handle the gender of the User and other tour participants for the following purposes. The purposes of use and the grounds on which the Company is able to legally handle personal data under the GDPR are as stated in the table below.
| [Purpose of Use] | [Grounds on which the Company is able to legally handle the information] |
|---|---|
| To receive provision of information that is necessary for applying for the service and facilities used in the tour (information will be provided to the service and facility operator to the extent necessary for the application.) | GDPR Article 6, paragraph 1 (b) This is a purpose of use that is necessary for providing the Service. |
| To identify the gender of the User when it is desirable to provide a different service based on the gender | GDPR Article 6, paragraph 1 (f) Information that is beneficial for providing better service to the User and the potential disadvantages to the User will be limited. |
| To analyze the attributes of the Users who use the Service and use such data for marketing | GDPR Article 6 paragraph 1 (f) The data will only be used for marketing by the Company, so the potential disadvantages to the User will be limited compared to the benefits provided by the Company. |
2.4. Nationality and place of residence
The Company shall handle the nationality and place of residence of the User and other tour participants for the following purposes. The purposes of use and the grounds on which the Company is able to legally handle personal data under the GDPR are as stated in the table below.
| [Purpose of Use] | [Grounds on which the Company is able to legally handle the information] |
|---|---|
| To receive provision of information that is necessary for applying for the service and facilities used in the tour (information will be provided to the service and facility operator to the extent necessary for the application.) | GDPR Article 6, paragraph 1 (b) This is a purpose of use that is necessary for providing the Service. |
| To confirm the nationality or residential area of the User when it is necessary to give cultural considerations based on the nationality or place of residence | GDPR Article 6, paragraph 1 (f) Information that is beneficial for providing better service to the User and the potential disadvantages to the User will be limited. |
| To analyze the attributes of the Users who use the Service and use such data for marketing | GDPR Article 6 paragraph 1 (f) The data will only be used for marketing by the Company, so the potential disadvantages to the User will be limited compared to the benefits provided by the Company. |
2.5. Email address
The Company will handle the User’s email address for the following purposes. The purposes of use and the grounds on which the Company is able to legally handle personal data under the GDPR are as stated in the table below.
| [Purpose of Use] | [Grounds on which the Company is able to legally handle the information] |
|---|---|
| To provide information about the use of the Service. | GDPR Article 6, paragraph 1 (b) This is a purpose of use that is necessary for providing the Service. |
| To receive necessary communication from the Company or tour operator in relation to participation in the tour. | GDPR Article 6, paragraph 1 (b) This is a purpose of use that is necessary for providing the Service. |
| To distribute e-mail magazines. | GDPR Article 6, paragraph 1 (a) E-mail magazines will only be distributed to consenting Users. Users may revoke their consent at any time using the email magazine distribution settings of the Service. |
2.6. Telephone number
The Company will handle the User’s telephone number for the following purposes. The purposes of use and the grounds on which the Company is able to legally handle personal data under the GDPR are as stated in the table below.
| [Purpose of Use] | [Grounds on which the Company is able to legally handle the information] |
|---|---|
| To receive necessary communication from the Company or tour operator in relation to participation in the tour. | GDPR Article 6, paragraph 1 (b) This is a purpose of use that is necessary for providing the Service. |
2.7. Language used
The Company will handle the language used by the User for the following purposes. The purposes of use and the grounds on which the Company is able to legally handle personal data under the GDPR are as stated in the table below.
| [Purpose of Use] | [Grounds on which the Company is able to legally handle the information] |
|---|---|
| To select the language that is easy-to-read for the User in the Service website or emails | GDPR Article 6, paragraph 1 (f) Information that is beneficial for providing better service to the User and the potential disadvantages to the User will be limited. |
2.8. Height, weight, and other physical attributes (excluding physical disabilities)
The Company will handle the height, weight, and other physical attributes (excluding physical disabilities) of the User and other tour participants for the following purposes. The purposes of use and the grounds on which the Company is able to legally handle personal data under the GDPR are as stated in the table below.
| [Purpose of Use] | [Grounds on which the Company is able to legally handle the information] |
|---|---|
| To provide service details that are appropriate to the data subject’s physical attributes in experience-type services | GDPR Article 6, paragraph 1 (b) or (f) Either a purpose of use that is necessary for providing the Service to the User, or information that is beneficial for providing better service to the User. |
2.9. Emergency contact
The Company will handle the personal information of the emergency contact designated by the User or other tour participants for the following purposes. The purposes of use and the grounds on which the Company is able to legally handle personal data under the GDPR are as stated in the table below.
| [Purpose of Use] | [Grounds on which the Company is able to legally handle the information] |
|---|---|
| To secure safety in the event of an accident in the tour | GDPR Article 6, paragraph 1 (f) Information that is necessary for safely providing the tour, and the provision of such information will lead to the benefits for the User. |
2.10. Whether or not the User possesses an international driver’s license
The Company will handle the information about whether the User possesses an international driver’s license for the following purposes. The purposes of use and the grounds on which the Company is able to legally handle personal data under the GDPR are as stated in the table below.
| [Purpose of Use] | [Grounds on which the Company is able to legally handle the information] |
|---|---|
| To confirm whether the User is able to drive a car | GDPR Article 6, paragraph 1 (f) Information that is necessary for preventing driving without a license and safely providing the tour, and the potential disadvantages to the User will be limited. |
2.11. Pictures and videos while participating in the tour
The Company will handle the information related to the pictures and videos of the User and other tour participants while participating in the tour for the following purposes upon prior consent. The purposes of use and the grounds on which the Company is able to legally handle personal data under the GDPR are as stated in the table below.
| [Purpose of Use] | [Grounds on which the Company is able to legally handle the information] |
|---|---|
| To introduce the tour and use such information for advertising and promotions | GDPR Article 6, paragraph 1 (f) Information that is useful for increasing the number of Users of the Company, and the potential disadvantages to the User will be limited because prior consent will be obtained from the data subject. |
2.12. Physical disability and religious dietary restrictions
The Company will use information about the User’s past illnesses, allergies, religious dietary restrictions, pregnancy, and wheelchair requirements for the purpose of giving appropriate consideration in planning the tour and providing meals.
Such personal data corresponds to “personal data in a special category” set forth in GDPR Article 9, paragraph 1, so the information will be used upon clear consent from the data subject.
The User may revoke the consent and request deletion of the provided information through the inquiry form for the Service.
2.13. Credit card information
The Company will handle the User’s credit card information for the following purposes upon prior consent. The purposes of use and the grounds on which the Company is able to legally handle personal data under the GDPR are as stated in the table below.
| [Purpose of Use] | [Grounds on which the Company is able to legally handle the information] |
|---|---|
| To settle the payment when the User books a tour | GDPR Article 6, paragraph 1 (b) This is a purpose of use that is necessary for providing the Service. |
The management of the credit card information of the User is contracted in its entirety to a credit card payment agency as the processor under the GDPR. This agency will safely manage the credit card information of the User in accordance with the agreement concluded with the Company.
2.14. Web browsing history
2.14.1. Distribution of advertisements
The Company will, in cooperation with the advertising distribution companies listed below, handle information about the User’s preferences assumed based on the Web browsing history of the User for the purpose of effective advertising distribution.
Effective advertising distribution is useful for enabling more Users to use the Service, and the disadvantages to the User as a result of such handling will be limited. Thus, it is legal under GDPR Article 6, paragraph 1 (f).
Each advertising distribution company will safely manage the personal data of the User in accordance with the Privacy Policy that is made public as a processor under the GDPR based on the agreement concluded with the Company.
[List of advertising distribution companies]
- X Corp.
Privacy policy：https://x.com/privacy - Meta Platforms, Inc.
Privacy policy：https://www.facebook.com/privacy/policy/ - Google LLC
Privacy policy：https://policies.google.com/privacy
2.14.2. Analysis of the status of access to the Service
The Company will, in cooperation with the companies listed below, handle information about the results of the analysis of the status of access to the Service for the purpose of improving the specifications of the Service.
Improving the specifications is beneficial for enabling more Users to use the Service, and the disadvantages to the User as a result of such handling will be limited. Thus, it is legal under GDPR Article 6, paragraph 1 (f).
The following companies will safely manage the personal data of the User in accordance with the Privacy Policy that is made public as a processor under the GDPR based on the agreement concluded with the Company.
[List of partner companies]
- Google LLC
Privacy policy：https://policies.google.com/privacy - Vpon JAPAN株式会社
Privacy policy：https://www.vpon.com/jp/privacy-statement-website-platform/
2.14.3. Email distribution
The Company will, in cooperation with the email distribution companies listed below, handle information about the status of opening emails by the User for the purpose of realizing more effective distribution of emails.
Effective email distribution is beneficial for enabling more Users to use the Service, and the disadvantages to the User as a result of such handling will be limited. Thus, it is legal under GDPR Article 6, paragraph 1 (f).
The Company will conclude an agreement with the email distribution company in which the email distribution company pledges to safely manage the personal data of the User as a processor under the GDPR.
[List of email distribution companies]
- KOZO KEIKAKU ENGINEERING Inc.
Privacy policy：https://www.kke.co.jp/en/privacy/
3. Whether or not it is necessary to provide personal data
The personal data handled by the Company is not necessary for concluding an agreement with the Company, excluding the name of the person.
However, if personal data excluding pictures and videos while participating in a tour is not provided, the use of the Service or participation in a tour may be restricted.
4. Retention period of personal data
4.1. Personal data input by the User
The personal data obtained by the Company through input by the User in relation to the Service will be stored for the period in which the account is maintained, as well as for a certain period that is necessary for the Company to maintain the data for business reasons after deletion of the account. However, the personal data obtained in relation to a tour will be stored for the period that is necessary for the provision of the tour.
4.2. Pictures and videos while participating in a tour
The pictures and videos will be stored for the period that is necessary for use in advertising and promotions.
4.3. Credit card information
The credit card information will be stored for the period that is necessary for processing the payment.
4.4. Web browsing history
The retention period will differ depending on the retention period set forth by each partner company. Please see the Privacy Policy of each company for the details.
5. Provision of personal data to tour operators and operators of facilities/ services used by the User
Personal data of the User (limited to the data listed in 2.1. to 2.12.) will be provided in accordance with the purpose of use listed in 2 above to the operator of the tour to which the User applied (in the case of a tour planned by the Company, the operator refers to the company to which the Company contracts for the tour), as well as the operator of the facilities/services used by the User. The recipient of the personal data will safely manage the User’s personal data as a processor under the GDPR based on the agreement concluded with the Company or the tour operator.
6. Joint management with UNIEARTH Corp.
The personal data of the User will be jointly managed with our parent company UNIEARTH Corp. The Company will be responsible for executing the obligations under GDPR.
7. Rights permitted to the User
7.1. Acquisition of information concerning the handling of personal data
The User has the right to acquire all necessary information from the Company in relation to the handling of personal data by the Company concerning that User (GDPR Article 13 and Article 14).
7.2. Access to the personal data
The User has the right to confirm with the Company whether or not the Company handles the personal data of that User. In addition, in relation to the personal data handled by the Company, the User has the right to access the personal data and related information (GDPR Article 15).
7.3. Correction and deletion of personal data
The User has the right to have corrections made of any inaccurate personal data concerning that User without undue delay and to have incomplete personal information completed (GDPR Article 16). In addition, when certain requirements are satisfied, the User has the right to request and obtain deletion of personal data concerning that User without undue delay (GDPR Article 17).
7.4. Restrictions on the handling of personal data
When certain requirements are satisfied, the User has the right to restrict the handling of personal data (GDPR Article 18).
7.5. Objections to the handling of personal data
When certain requirements are satisfied, the User has the right to object to the handling of personal data related to that User (GDPR Article 21).
7.6. Data portability
When certain requirements are satisfied, the User has the right to receive the personal data concerning the User in a structured, commonly used and machine-readable format and have the right to transmit such data to another controller without hindrance from the Company (GDPR Article 20).
7.7. Not subject to automated decision-making
When certain requirements are satisfied, the User has the right not to be subject to a decision based solely on automated processing (including profiling) when such decision will be legally binding on the User or produce similarly significantly effects on the User (GDPR Article 22). The Company and the company with which the Company contracts the handling of personal data will not make such decisions.
7.8. Filing an objection with the Data Protection Authority
The User may file an objection with the Data Protection Authority of the member state of the place of residence, workplace, or the location where GDPR violation has occurred in relation to the Company’s handling of the User’s personal data.
8. Inquiries on the handling of personal data of the User
The Company will accept inquiries on the handling of personal data of the User (including notifications concerning the exercise of the rights listed in 7 above) at the following email address.
[Direct inquiries to this email address] contact@deep-exp.jp
9. Revision to the Policy
The Company may revise the Policy. In that case, the date of revision and the revised Policy will be made public on the Web page where the Service is provided.