Privacy Policy for the EEA and the UK GDPR
Ryugaku Journal Inc. (“Ryugaku Journal”) may have occasion to collect and process
Personal Data (as defined below). This Privacy Policy (this “Policy”) applies to theprocessing of Personal Data concerning data subjects in the European Economic Area(“EEA”) in accordance with the Regulation (EU) 2016/679 (General Data Protection
Regulation, the “GDPR”) and data subjects in the United Kingdom (the “UK”) in accordancewith the UK GDPR as defined in the Data Protection, Privacy and ElectronicCommunications (Amendments etc.) (EU Exit) Regulations 2019 (the “UK GDPR”).

1. Personal Data
In this Policy, Personal Data means any data relating to an identified or identifiable natural
person (“Personal Data”). RYUGAKU JOURNAL may acquire and process Personal Data,including the information written in the counsel sheet or program application form such as
your name, address, telephone number, gender, date of birth, nationality, occupation, email address, existing disease etc.

2. Use of Personal DataRYUGAKU JOURNAL acquires and processes Personal Data for the following purposes:•Providing services to relevant students;•Legitimate business interests, such as undertaking business research andanalysis or managing the operation of the business;•Public relations, such as responding to inquiries;•Engaging in marketing and business development activities in relation to theservices. This may include sending client newsletters, marketing communications
and other information that may be of interest to them;•Defense of certain rights or interests;•Compliance with legal and regulatory obligations that RYUGAKU JOURNAL has
to discharge; and•Managing customer relationships

RYUGAKU JOURNAL relies on the following legal grounds to process Personal Data:•The data subject’s consent expressly given to process his/her Personal Data insuch manner. The data subject may withdraw his/her consent to this processing

at any time; however, this will not affect the lawfulness of any processing carriedout before withdrawal of the consent;•Entering into a contract with a data subject or performing obligations under acontract with a data subject;•Legitimate interests, some examples of which are given above; and•Compliance with applicable laws or regulations

If you fail to provide certain information when requested, we may not be able to perform thecontract we have entered into with you (such as paying you or providing a benefit), or wemay be prevented from complying with our legal obligations.

3. Use of Cookies
We use the support services of marketing companies to manage and optimize our Internet
operations and communications, and to measure the effectiveness of our advertising andhow visitors use our website. For this purpose, we use web beacons and cookies provided
by marketing companies on our website to collect access data and perform integrated
website analysis (Google Analytics). In this case, if it is necessary to obtain "cookie
information" that can be used to identify individuals by matching it with other information in
the analysis or analysis of information, we will obtain your consent before obtaining suchinformation. There are two types of cookies: those that store information sent directly to oursite (first-party cookies) and those that are sent to other companies whose services our siteuses (third-party cookies). The use of Strictly Necessary cookies, which are first-partycookies, corresponds to legitimate processing as defined by Article 6.1 (Lawfulness ofprocessing) of the GDPR. You also have the right to object to the processing of your datafor statistical purposes as defined in Article 89(1) of the Law (Safeguards and derogations
relating to processing for archiving purposes in the public interest, scientific or historicalresearch purposes or statistical purposes). In addition, you have the right to object to theprocessing of your data for statistical purposes as defined in Article 21, paragraph 6 of theLaw (Right to object). In this case, you may withdraw your consent to our use of cookies at
any time in order to exercise your rights as a data subject. For information on withdrawing
consent and disabling cookies, please refer to our Cookie Policy, which can be found on
our website.

4. Disclosure to Third PartiesRYUGAKU JOURNAL may supply or disclose Personal Data, without the data subjects’prior consent, to RYUGAKU JOURNAL’s group companies, insurance companies andother third parties that are RYUGAKU JOURNAL’s service assignees. RYUGAKUJOURNAL may also supply or disclose Personal Data to third parties when it is necessary
for some other justifiable reason permitted by the laws and regulations.

5. Cross-Border Transfer
Personal Data may be transferred to entities in countries or jurisdictions outside the EEAand UK, such as Japan, if required for the purposes as described above. Please note thatsuch countries or jurisdictions may not have the same data protection laws as the EEA andUK and will not afford many of the rights conferred upon data subjects in the EEA and UK.
RYUGAKU JOURNAL will ensure that any such international transfers are made subject toappropriate and suitable safeguards as required by the GDPR, the UK GDPR or otherrelevant laws. When doing so, RYUGAKU JOURNAL will comply with applicable dataprotection requirements and take appropriate safeguards to ensure the security andintegrity of Personal Data.

6. Retention of Personal DataRYUGAKU JOURNAL will retain Personal Data for the period necessary to fulfill thepurposes outlined in this Policy, unless a longer retention period is required or permitted bylaw.

7. Rights of Data Subjects
Data subjects have the right to access, request correction of, request deletion of, request
the limitation of processing of, object to the processing of, and request the data portabilityof their Personal Data retained by RYUGAKU JOURNAL. When RYUGAKU JOURNAL
receives a request based on the right specified above, RYUGAKU JOURNAL shall conduct
any necessary investigation without delay and provide data subjects or nominated third
parties with Personal Data or respond to such rights without delay.

8. Right to Lodge Complaint with Data Protection Authority
Data subjects have the right to lodge a complaint with the local data protection authority ifthey have a complaint with regard to RYUGAKU JOURNAL’s processing of their Personal
Data.

9. Contact
For any questions about this Policy, RYUGAKU JOURNAL’s privacy practices or yourrights described in “Section 6. Rights of Data Subjects”, please contact us at the following:For all data subjects
Department：

RYUGAKU JOURNAL INC. Customer Service OfficeE-mail address：

rj-houmu@ryugaku.co.jp

Phone number：

03-5312-4421

EU Representative for

PLANIT // LEGAL

Data subjects in the EEA：Bischof Freund Schmidt Partnerschaft von Rechtsanwälten mbB
Neuer Wall 54, 20354 Hamburg, GermanyE-mail address：

mail@planit.legal

UK Representative for

TMI Associates London LLP

Data subjects in the UK： Citypoint One Ropemaker Street London EC2Y 9SS, UK
E-mail address：
Enacted as of 2019/Feb/1
Revised as of 2022/Aug/1

london@tmi.gr.jp