JIJI PRESS Ltd, GDPR Privacy Policy
Last Update June 28, 2021
Introduction
Welcome to the JIJI PRESS Ltd, GDPR (General Data Protection Regulation)
privacy notice. This privacy notice is for people who are located in the European
Union as well as the UK, Iceland, Liechtenstein and Norway.
JIJI PRESS Ltd, (collectively referred to as "JIJI PRESS", "we", "us" or "our" inthis privacy notice) respects your privacy and is committed to protecting yourpersonal data. This privacy notice will inform you as to how we look after yourpersonal data when you visit or use our service including website (hereinafterreferred to as “OUR SERVICE”) and tell you about your privacy rights and how thelaw protects you.
This privacy notice may be updated occasionally, and you will always be able to findthe latest version here.
※GDPR（欧州一般データ保護規則）が適用される国（EU およびアイスランド、リヒテ
ンシュタイン、ノルウェー ）以外、または UK GDPR が適用される英国以外に居住の方は、「時事通信社 JIJI Financial Solutions プライバシーポリシー」をご覧ください。
1. Important information and who we are
Purpose of this privacy noticeThis privacy notice aims to give you information on how JIJI PRESS collects andprocesses your personal data through your use of OUR SERVICE, including any data
you may provide through OUR SERVICE.
OUR SERVICE is not intended for children and we do not knowingly collect data
relating to children.
It is important that you read this privacy notice together with any other privacy
notice or fair processing notice we may provide on specific occasions when we arecollecting or processing personal data about you so that you are fully aware of howand why we are using your data. This privacy notice supplements the other notices
and is not intended to override them.
Controller
JIJI PRESS is the controller and responsible for your personal data.
We have appointed a data privacy manager who is responsible for overseeing
questions in relation to this privacy notice. If you have any questions about thisprivacy notice, including any requests to exercise your legal rights, please contact
the data privacy manager using the details set out below.
Contact details
Our full details are:Full name of company: JIJI PRESS Ltd.
Name or title of data privacy manager: Data Protection Manager of London Bureau
of JIJI PRESS.
Email address: it@jiji.co.uk
You have the right to make a complaint at any time to the Information
Commissioner's Office (ICO), the UK supervisory authority for data protection
issues (https://www.ico.org.uk) or any supervisory authority a data subject may
reside. We would, however, appreciate the chance to deal with your concerns before
you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 1st December 2020.
It is important that the personal data we hold about you is accurate and current. Please keep us
informed if your personal data changes during your relationship with us.
Third-party links

Our website in OUR SERVICE (hereinafter referred to as “OUR WEBSITE”) may
include links to third-party websites, plug-ins and applications. Clicking on those
links or enabling those connections may allow third parties to collect or share data
about you. We do not control these third-party websites and are not responsible for
their privacy statements. When you leave OUR WEBSITE, we encourage you to readthe privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individualfrom which that person can be identified. It does not include data where the identity
has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you
which we have grouped together follows:
1. Identity Data includes first name, maiden name, last name, corporate name,user name or similar identifier, title, date of birth and gender.
2. Contact Data includes billing address, delivery address, e-mail address,
telephone numbers and facsimile number.
3. Financial Data includes bank account and payment card details.
4. Transaction Data includes details about payments to and from you and otherdetails of products and services you have purchased from us.
5. Technical Data includes internet protocol (IP) address, your login data,browser type and version, time zone setting and location, browser plug-in
types and versions, operating system and platform and other technology on
the devices you use to access OUR WEBSITE.
6. Profile Data includes your username and password, purchases or orders
made by you, your interests, preferences, feedback and survey responses.
7. Usage Data includes information about how you use OUR WEBSITE, products
and services.
8. Marketing and Communications Data includes your preferences in receiving
marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic
data for any purpose. Aggregated Data may be derived from your personal data but
is not considered personal data in law as this data does not directly or indirectlyreveal your identity. For example, we may aggregate your Usage Data to calculate
the percentage of users accessing a specific website feature. However, if we
combine or connect Aggregated Data with your personal data so that it can directly
or indirectly identify you, we treat the combined data as personal data which will be
used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes
details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual
orientation, political opinions, trade union membership, information about your healthand genetic and biometric data). Nor do we collect any information about criminal
convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract wehave with you and you fail to provide that data when requested, we may not be able
to perform the contract we have or are trying to enter into with you (for example, toprovide you with goods or services). In this case, we may have to cancel a productor service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:

Direct interactions.
You may give us your Identity, Contact and Financial Data by filling in forms
or by corresponding with us by post, phone, email or otherwise. This includes
personal data you provide when you.
apply for our products or services; create an account on our products and services or OUR WEBSITE;
 subscribe to our products and services featured on OUR WEBSITE;
 request marketing to be sent to you;
 enter a competition, promotion or survey; or enter give us some feedback.
Automated technologies or interactions.
As you interact with OUR WEBSITE, we may automatically collect Technical
Data about your equipment, browsing actions and patterns. We collect thispersonal data by using cookies (including "unique IDs" similar to cookies, thatare consisted of a unique string of characters for each user's browser),server logs and other similar technologies.


Third parties or publicly available sources.
We may receive personal data about you from various third parties and public
sources as set out below:
Technical Data from the following parties:(a) analytics providers such as Google Analytics and SATORI basedoutside the EU;(b) search information providers such as Google based outside the EU.

Contact, Financial and Transaction Data from providers of technical,
payment and delivery services based outside the EU.
Identity and Contact Data from publicly availably sources such as
Companies House and the Electoral Register based inside the EU.

4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we
will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or haveentered into with you. Insofar as the contracting party is an individual, thelegal basis is Article 6 (1) (b) of the GDPR. In case the contracting party isan organization which you belong to, the legal basis is Article 6 (1) (f) of the
GDPR.
Where it is necessary for our legitimate interests (or those of a third party)
and your interests and fundamental rights do not override those interests. We
do not use your personal data for activities where our interests areoverridden by the impact on you (unless we have your consent or areotherwise required or permitted to by law). The legal basis for such

processing is Article 6 (1) (f) of the GDPR. You can obtain further information
about how we assess our legitimate interests against any potential impact on
you in respect of specific activities by contacting us.
Where we need to comply with a legal or regulatory obligation. The legal basis
for such processing is Article 6 (1) (c) of the GDPR.

Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use
your personal data, and which of the legal bases we rely on to do so. We have also
identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground
depending on the specific purpose for which we are using your data. Please contact
us if you need details about the specific legal ground we are relying on to process
your personal data where more than one ground has been set out in the table below.

Purpose / Activity

Type of data

To register you as a newcustomer(a) Identity(b)Contact

To process and deliver your(a) Identity

order including:(a) Manage payments, fees
and charges(b) Collect and recovermoney owed to us
To manage our relationshipwith you which will include:(a) Notifying you aboutchanges to our terms or
privacy policy(b) Asking you to leave areview or take a survey

Lawful basis for processing
including basis of legitimate
interest
Performance of a contract with
you(a) Performance of a contract(b) Contact
with you(c) Financial(b) Necessary for our legitimate(d) Transaction
interests (to recover debts due to(e) Marketing andus)
Communications(a) Performance of a contract(a) Identitywith you(b) Contact(b) Necessary to comply with a(c) Profile
legal obligation(d) Marketing and (c) Necessary for our legitimate
Communications interests (to keep our records
updated and to study howcustomers use our
products/services)(a) Identity(a) Performance of a contract

with you(b) Contact
To enable you to partake in a(b) Necessary for our legitimate(c) Profile
prize draw, competition orinterests (to study how(d) Usagecomplete a survey
customers use our(e) Marketing andproducts/services, to develop
Communications
them and grow our business)(a) Necessary for our legitimate
interests (for running ourbusiness, provision of

To administer and protect
our business, OUR WEBSITE(a) Identity(including troubleshooting,(b) Contact
data analysis, testing, system(c) Technicalmaintenance, support,
reporting and hosting of data)

To deliver relevant website
content and advertisements(a) Identity(b) Contact(c) Profile

administration and IT services,
network security, to prevent fraud
and in the context of a businessreorganisation or group
restructuring exercise)(b) Necessary to comply with alegal obligation
Necessary for our legitimate
interests (to study how

to you and measure orcustomers use our(d) Usage
understand the effectivenessproducts/services, to develop(e) Marketing andof the advertising we serve
them, to grow our business and to
Communications
to youinform our marketing strategy)(f) Technical
To use data analytics to
improve OUR WEBSITE(a) Technicalproducts/services,(b) Usage
marketing, customer
relationships and experiences

Necessary for our legitimate
interests (to define types ofcustomers for our products andservices, to keep OUR SERVICE
updated and relevant, to develop
our business and to inform ourmarketing strategy)

(a) Identity
To make suggestions and(b) Contact
recommendations to you(c) Technicalabout goods or services that(d) Usage
may be of interest to you(e) Profile

Necessary for our legitimate
interests (to develop our
products/services and grow ourbusiness)

Marketing
We strive to provide you with choices regarding certain personal data uses,
particularly around marketing and advertising. We have established the following
personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a viewon what we think you may want or need, or what may be of interest to you. This is
how we decide which products, services and offers may be relevant for you (we callthis marketing).
You will receive marketing communications from us if you have requested
information from us or purchased goods or services from us or if you provided us
with your details when you entered a competition or registered for a promotion and,in each case, you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data withany company outside the JIJI PRESS group of companies for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any timeby contacting us.
Where you opt out of receiving these marketing messages, this will not apply topersonal data provided to us as a result of a product/service purchase, warranty
registration, product/service experience or other transactions.

Cookies
OUR WEBSITE may uses cookies (including "unique IDs" similar to cookies, that areconsisted of a unique string of characters for each user's browser. Hereinafterreferred to simply as "Cookies") to distinguish you from other users of OUR
WEBSITE. This helps us to provide you with a good experience when you browse
OUR WEBSITE and also allows us to improve our site. By continuing to browse thesite, you are agreeing to our use of cookies.
A cookie is a small file of letters and numbers that we store on your browser or the
hard drive of your computer if you agree. Cookies contain information that istransferred to your computer's hard drive.
We may use some or all of the following cookies:
Essential/Strictly necessary cookies. These are cookies that are required for theoperation of OUR WEBSITE. They include, for example, cookies that enable you to
log into secure areas of OUR WEBSITE
Analytical/performance cookies. They allow us to recognise and count the numberof visitors and to see how visitors move around OUR WEBSITE when they are using
it. This helps us to improve the way OUR WEBSITE works, for example, by ensuringthat users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to OURWEBSITE. This enables us to personalise our content for you, greet you by nameand remember your preferences (for example, your choice of language or region).
Please note that third parties (including, for example, advertising networks andproviders of external services like web traffic analysis services) may also use
cookies, over which we have no control. These cookies are likely to beanalytical/performance cookies or targeting cookies.
Google Analytics and SATORI
We may use analytical/performance cookies of Google Analytics and SATORI in
OUR WEBSITE. You can find more details at the links below.

<Google Analytics>

https://policies.google.com/technologies/partner-sites?hl=en-GB<SATORI>
https://satori.marketing/privacypolicy/

You can opt-out Google Analytics and/or SATORI tracking by clicking the link
below.

<Google Analytics>
https://tools.google.com/dlpage/gaoptout?hl=en_GB<SATORI>
https://satori.marketing/optout/
You can set your browser to refuse all or some browser cookies, or to alert you
when websites set or access cookies. If you disable or refuse cookies, please notethat some parts of OUR WEBSITE may become inaccessible or not function
properly.
Change of purpose
We will only use your personal data for the purposes for which we collected it,
unless we reasonably consider that we need to use it for another reason and thatreason is compatible with the original purpose. If you wish to get an explanation as
to how the processing for the new purpose is compatible with the original purpose,
please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you andwe will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge orconsent, in compliance with the above rules, where this is required or permitted bylaw.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the
purposes set out in the table in paragraph 4 above.
Internal Third Parties
External Third Parties

Service providers acting as processors based in Japan who provide IT andsystem administration services.
Professional advisers acting as processors including lawyers, bankers,
auditors and insurers based in Japan who provide consultancy, banking, legal,
insurance, tax and accounting services.
Third parties to whom we may choose to sell, transfer, or merge parts of ourbusiness or our assets. Alternatively, we may seek to acquire otherbusinesses or merge with them. If a change happens to our business, then
the new owners may use your personal data in the same way as set out inthis privacy notice.

We require all third parties to respect the security of your personal data and to treat
it in accordance with applicable laws and regulations including the GDPR. We do notallow our third-party service providers to use your personal data for their own
purposes and only permit them to process your personal data for specified purposes
and in accordance with our instructions.
6. International transfers
We may share your personal data within the JIJI PRESS Group companies based inJapan.

Many of our external third parties are based outside the European Economic Area
(EEA) so their processing of your personal data will involve a transfer of data
outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degreeof protection is afforded to it by ensuring at least one of the following safeguards is
implemented:

We will only transfer your personal data to countries that have been deemed
to provide an adequate level of protection for personal data by the European
Commission.
Where we use certain service providers, we may use specific contracts
approved by the European Commission which give personal data the same
protection it has in Europe.

Please contact us if you want further information on the specific mechanism usedby us when transferring your personal data out of the EEA.
7. Data security
We have put in place appropriate security measures to prevent your personal datafrom being accidentally lost, used or accessed in an unauthorised way, altered ordisclosed. In addition, we limit access to your personal data to those employees,
agents, contractors and other third parties who have a business need to know. They
will only process your personal data on our instructions and they are subject to a
duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breachand will notify you and any applicable regulator of a breach where we are legallyrequired to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes
we collected it for, including for the purposes of satisfying any legal, accounting, orreporting requirements.

To determine the appropriate retention period for personal data, we consider theamount, nature, and sensitivity of the personal data, the potential risk of harm fromunauthorised use or disclosure of your personal data, the purposes for which we
process your personal data and whether we can achieve those purposes throughother means, and the applicable legal requirements.
By Japanese law we have to keep basic information about our customers (including
Contact, Identity, Financial and Transaction Data) for 10 years after they cease
being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure
below for further information.
In some circumstances we may anonymise your personal data (so that it can nolonger be associated with you) for research or statistical purposes in which case we
may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation
to your personal data. You have the right to:
Request access to your personal data (commonly known as a "data subject accessrequest"). This enables you to receive a copy of the personal data we hold about
you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you tohave any incomplete or inaccurate data we hold about you corrected, though we
may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or
remove 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 wemay have processed your 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 of erasure for specific legal reasons which will
be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate
interest (or those of a third party) and there is something about your particularsituation which makes you want to object to processing on this ground as you feel it
impacts on your fundamental rights and freedoms. You also have the right to object
where we are processing your personal data for direct marketing purposes. In somecases, we may demonstrate that we have compelling legitimate grounds to process
your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us
to suspend the processing of your personal data in the following scenarios: (a) if you
want us to establish the data's accuracy; (b) where our use of the data is unlawful
but you do not want us to erase it; (c) where you need us to hold the data even if
we no longer require it as you need it to establish, exercise or defend legal claims; or(d) you have objected to our use of your data but we need to verify whether wehave overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide
to you, or a third party you have chosen, your personal data in a structured,commonly used, machine-readable format. Note that this right only applies toautomated information which you initially provided consent for us to use or where
we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process yourpersonal data. However, this will not affect the lawfulness of any processing carriedout before you withdraw your consent. If you withdraw your consent, we may not beable to provide certain products or services to you. We will advise you if this is thecase at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of
the other rights). However, we may charge a reasonable fee if your request is clearly
unfounded, repetitive or excessive. Alternatively, we may refuse to comply with yourrequest in these circumstances.
What we may need from you

We may need to request specific information from you to help us confirm youridentity and ensure your right to access your personal data (or to exercise any ofyour other rights). This is a security measure to ensure that personal data is notdisclosed to any person who has no right to receive it. We may also contact you to
ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may
take us longer than a month if your request is particularly complex or you havemade a number of requests. In this case, we will notify you and keep you updated.
Please confirm that you will conform to all the requirements pursuant to GDPR in
respect of handling of personal data for the purpose of our contract.
END