Privacy Policy for EEA Residents

Processing of Personal Data

Shapla Neer = Citizens’ Committee in Japan for Overseas Support (hereinafter referred to as Shapla Neer, we,or us) recognizes the importance of personal data and carries out its processing to strictly ensure its protection.
This Privacy Policy applies to the processing of personal data obtained from data subjects residing in theEuropean Economic Area (EEA) who make donations to Shapla Neer through the Tokyo Marathon Charity orTokyo Legacy Half Marathon Charity (hereinafter referred to as Donors) or who visit our website (hereinafterreferred to as Visitors).

1. Types of Personal Data

In this Privacy Policy, personal data means any data relating to an identified or identifiable natural
person. We may collect and process the following types of personal data. Please note that some of thefollowing types of data may not be categorized as personal data by the applicable laws andregulations, depending on the context thereof.

Personal data of “Donors“
We collect and process personal data about Donors, including name, gender, date of birth,email address, address, nationality, and whether a guide runner is needed.

Personal data of “Visitors” to our website
We may collect cookies, device information, software information, and website browsing
history, etc. of the Visitors.

Other personal data provided to us
We collect and process personal data, including name, email address, telephone number,and postal address, which is necessary for specific procedures, such as responding toinquiries about the Tokyo Marathon Charity or requests for information of our activities ordonation.

2. Compliance with All Applicable Laws and Regulations and Performance of Statutory and Regulatory Obligations

We have established internal rules in accordance with the EU General Data Protection Regulation(GDPR) and other applicable laws and regulations. We strictly manage the personal data we collect,use, and disclose in compliance with such rules.

13. Collection, Use and Disclosure of Personal Data

When processing personal data, we clearly indicate the purposes of the processing to Donors/Visitors
prior to processing, unless otherwise stipulated by laws and regulations, and we carry out theprocessing to the extent necessary to achieve such purposes.

(1) Purposes of Processing Personal Data

We process personal data for the purposes listed below or for the purposes notified toDonors/Visitors.

To provide and manage services related to Donors and to carry out relevant procedures

To provide information on various events or campaigns and to carry out relevant proceduresTo carry out procedures related to inquiries or requests for information regarding theservices mentioned above(2) Additional Processing

When processing personal data for purposes other than those listed above, we will notify
Donors/Visitors, prior to such processing, of such purposes and other matters as required byapplicable laws and regulations.

(3) Legal Basis

For the purposes mentioned in the sub-section 1, we shall, in principle, process the personal data ofDonors/Visitors based on their consent to this Privacy Policy or the legitimate interests in conducting
Shapla Neer's activities.
Donors/Visitors may withdraw such consent at any time. Withdrawal of consent, however, does notaffect the lawfulness of the processing of personal data based on the prior consent. If Donors/Visitors
wish to withdraw their consent, they can do so by contacting us through the channels indicated in thesection 7.

(4) Necessity of Providing Personal Data

The personal data of Donors/Visitors is necessary for Shapla Neer to provide its services toDonors/Visitors. Therefore, there may be cases where Donors/Visitors who have not provided suchdata may be unable to receive our services or make donations to us.

2(5) Retention Period

We retain the personal data of Donors/Visitors as long as we need it to provide services toDonors/Visitors, and will promptly delete such data when it is no longer necessary. The criteria usedfor us to determine the retention period include: (i) the duration of the ongoing relationship with theDonors/Visitors and (ii) whether there are any legal obligations applicable.

(6) Transfer of Personal Data

We may disclose the personal data of Donors/Visitors to third parties, including those acting on ourbehalf to execute certain operations, for the processing purposes mentioned above.
Consequently, the personal data of Donors/Visitors may be disclosed to parties based in countries orjurisdictions outside the EEA, including, but not limited to, Japan (the same shall apply hereinafter).
In such countries or jurisdictions, there may not be data protection laws equivalent to those of theEEA, and the rights granted to Donors/Visitors in the EEA may not potentially be recognized. However,when transferring personal data to a third party in such countries or jurisdictions, we will ensure thatsufficient measures are taken to protect the personal data of Donors/Visitors, including theconclusion of Standard Contractual Clauses based on GDPR.
If Donors/Visitors wish to obtain further information, they can do so by contacting us through thechannels indicated in the section 7.

(7) Sensitive DataInformation regarding whether a guide runner is needed as mentioned in the section 1 will beprocessed only to the extent necessary for us to provide and manage services related to Donors andto carry out relevant procedures. In addition, in case we obtain special categories of personal datathat are stipulated by GDPR, the processing will be conducted, unless otherwise stipulated by lawsand regulations, only to the extent to which Donors/Visitors have consented.

4. Prevention of Leakage, Falsification, Loss, or Damage of Personal Data

When processing personal data, we shall ensure to store and manage such data in an accurate andcurrent state, while securely accumulating and storing such data under strict control by implementing
our security measures in order to prevent leakage, falsification, loss, or damage. Furthermore, wewill continue to improve the personal data protection management system at Shapla Neer.
Our security measures include the establishment of rules and guidelines for the processing of
personal data, the appointment of staff in charge of the processing of personal data, theimplementation of periodic educative training for and supervision of the staff, data access control, and3

periodic self-inspection of the status of the processing of personal data. In addition, in cases where
the processing of personal data is outsourced, we will conclude an outsourcing contract that imposesappropriate management obligations on the outsourcee, while we ensure to monitor and supervise
the status of the outsourcee’s processing of personal data.

5. Collection of Cookies

We may collect Visitors' cookies, device information, software information, etc. on our website. We
use this information as general statistical information for understanding and analyzing trends in theuse of our website, but not for personal identification.
We use Google Analytics and Google Ads to understand and analyze Visitors’ usage of our website.
Such services use cookies to collect information about Visitors. The information collected will be
managed by Google in accordance with its Terms and Conditions and Privacy Policy. For more
information on how data is collected and processed, please refer to "How Google Uses Informationfrom Sites or Apps That Use Our Services." If Visitors do not wish to have their information collected
by Google Analytics on our website, Visitors can opt out by using the “Google Analytics Opt-Out
Add-On.” Additionally, If Visitors do not wish to have their information collected by Google Ads,
Visitors can refer to “How Google Uses Cookies in Advertising” for opting out.

Google Analytics Terms and Conditions

https://marketingplatform.google.com/about/analytics/terms/us/
Google Ads Terms and Conditions

https://support.google.com/adspolicy/answer/54818?hl=en
Google Privacy Policy

https://www.google.com/intl/en/policies/privacy/
How Google Uses Information from Sites or Apps That Use Our Services

https://www.google.com/intl/en/policies/privacy/partners/
Google Analytics Opt-Out Add-On

https://tools.google.com/dlpage/gaoptout?hl=en
How Google Uses Cookies in Advertisinghttps://policies.google.com/technologies/ads?hl=en
6. Rights of Donors/Visitors4

Donors/Visitors may request, regarding their personal data processed by us, access, rectification,erasure, restriction of processing, data portability (data transfer to the designated destination), etc.
in accordance with the data subject's rights as defined in GDPR.
Donors/Visitors have the right to object to Shapla Neer as well as to lodge a complaint with the dataprotection authority having jurisdiction over the place of residence of the Donors/Visitors regarding
the processing of their personal data.

7. Inquiries and Requests

The purposes and means of processing the personal data of Donors/Visitors are determined by us. If
you have any questions or concerns regarding this Privacy Policy or our processing of personal data or
if you have, concerning your personal data, any requests for access, rectification, erasure, restrictionof processing, or data portability, you can contact us through the channels indicated below.
Please note that if there are requests for access, etc., we may request you to present your personal
data in order to verify your identity by referencing the personal data registered. In case a
representative makes such requests on your behalf, we may request the representative to present
documents proving the representation and the identity.

Shapla Neer = Citizens’ Committee in Japan for Overseas Support
2-3-1 Nishiwaseda, Shinjyuku-ku, Tokyo, Japan 169-8611

Tel: +81-3-3202-7863 (Tue - Sat 10: 00 ~ 18: 00 (JST))
Email: marathon@shaplaneer.org
EU Personal Data Management Officer: Secretary General

8. Revision of This Privacy Policy

Shapla Neer may make changes to this Privacy Policy. If we change the contents of this Privacy Policy,
we will present the latest Privacy Policy on our website. We kindly ask Donors/Visitors to check thecontents of this Privacy Policy as necessary.

Last revised in June 2023

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