Introduction
Welcome to the Nippon Kaiji Kyokai's privacy notice for General Data Protection
Regulation (GDPR) (EU).
Nippon Kaiji Kyokai 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 our website (regardless of where you visit it from) andtell you about your privacy rights and how the law protects you.
1.

Important information and who we are
Purpose of this privacy noticeThis privacy notice aims to give you information on how Nippon Kaiji Kyokai collects
and processes your personal data through your use of this website, including any
data you may provide through this website when you contact us.
This website 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 othernotices and is not intended to override them.
Controller
Nippon Kaiji Kyokai is the controller and responsible for your personal data(collectively referred to as "Company", "we", "us" or "our" in this privacy notice).
If you have any questions about this privacy notice, including any requests toexercise your legal rights, please contact below.
Contact details
Our full details are:Full name of company: Nippon Kaiji Kyokai
General Affairs Department
Email address: gad@classnk.or.jp
Postal address: 4-7, Kioi-cho, Chiyoda-ku, Tokyo, 102-8567, Japan
Telephone number: +81-3-5226-2011

You have the right to make a complaint at any time to the supervisory authority inyour country for data protection issues. We would, however, appreciate the1chance to deal with your concerns before you approach the authority so pleasecontact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 25 May 2018.
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 withus.
Third-party links
This website may include links to third-party websites, plug-ins and applications.
Clicking on those links or enabling those connections may allow third parties tocollect or share data about you. We do not control these third-party websites andare not responsible for their privacy statements. When you leave our website, we
encourage you to read the 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 theidentity 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:

Identity Data includes first name, last name, marital status, title, date of birth andgender.

Contact Data includes billing address, delivery address, email address andtelephone numbers.

Technical Data includes internet protocol (IP) address, your login data, browser
type and version, time zone setting and location, browser plug-in types andversions, operating system and platform and other technology on the devices
you use to access this website.

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 candirectly 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, sexual2

orientation, political opinions, trade union membership, information about yourhealth and 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
we have 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 (forexample, to provide you with goods or services). In this case, we may have tocancel a product or service you have with us but we will notify you if this is the caseat the time.
3.

How is your personal data collected?
We use different methods to collect data from and about you including through:4.

Direct interactions. You may give us your Identity and Contact Data by filling informs or by corresponding with us by post, phone, email or otherwise.



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 this personal data by using cookies, server logs
and other similar technologies. We may also receive Technical Data about you if
you visit other websites employing our cookies. Please see our cookie policy forfurther details.

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.



Where it is necessary for our legitimate interests (or those of a third party) andyour interests and fundamental rights do not override those interests.

Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data
other than in relation to sending third party direct marketing communications to you via
email or text message. You have the right to withdraw consent to marketing at any time bycontacting us.

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 touse your personal data, and which of the legal bases we rely on to do so. We havealso identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground3

depending on the specific purpose for which we are using your data. Pleasecontact us if you need details about the specific legal ground we are relying on toprocess your personal data where more than one ground has been set out in thetable below.
Purpose/Activity

Type of data

Lawfulbasis
forincludingbasisofinterest

To recruit new staff for the (a) Identity
Company through online(b) Contact
job application

processing
legitimate(a) Performance of a contract withyou(b) Necessary to comply with alegal obligation(c) Necessary for our legitimate
interests (to keep our records
updated)Cookies
You can set your browser to refuse all or some browser cookies, or to alert you whenwebsites set or access cookies. If you disable or refuse cookies, please note thatsome parts of this website may become inaccessible or not function properly. For
more information about the cookies we use, please see our cookies policy.
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
and we 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 by
law.

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 as set out in the Glossary.
4External Third Parties as set out in the Glossary.



Third parties to whom we may choose to sell, transfer, or merge parts of ourbusiness or our assets. Alternatively, we may seek to acquire other businesses ormerge 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 in this privacy notice.

We require all third parties to respect the security of your personal data and to treat
it in accordance with the law. We do not allow our third-party service providers to
use your personal data for their own purposes and only permit them to process yourpersonal data for specified purposes and in accordance with our instructions.
6.

International Transfers
Some 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
degree of 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 toprovide 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.

Where we use providers based in the US, we may transfer data to them if they
are part of the Privacy Shield which requires them to provide similar protection
to personal data shared between the Europe and the US.

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
breach and will notify you and any applicable regulator of a breach where we arelegally required to do so.
Data retention
5

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.
In some circumstances you can ask us to delete your data: see Request erasure in
YOUR LEGAL RIGHTS 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.
8.

Your legal rights
Under certain circumstances, you have rights under data protection laws in relation
to your personal data. Please refer to “9. Glossary” below to find out more about
these rights:Request access to your personal data.



Request correction of your personal data.



Request erasure of your personal data.

Object to processing of your personal data.



Request restriction of processing your personal data.



Request transfer of your personal data.

Right to withdraw 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 isclearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply
with your request in these circumstances.

What we may need from you
6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.
9.

Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing
our business to enable us to give you the best service/product and the best andmost secure experience. We make sure we consider and balance any potential
impact on you (both positive and negative) and your rights before we process yourpersonal data for our legitimate interests. We do not use your personal data for
activities where our interests are overridden by the impact on you (unless we haveyour consent or are otherwise required or permitted to by law). You can obtainfurther information about how we assess our legitimate interests against any
potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the
performance of a contract to which you are a party or to take steps at your request
before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data
where it is necessary for compliance with a legal or regulatory obligation that weare subject to.
THIRD PARTIES
External Third Parties

Service providers based in the UK and EU who provide IT and systemadministration services.



Professional advisers including lawyers, bankers, auditors and insurers based in
the UK and EU who provide consultancy, banking, legal, insurance andaccounting services.



HM Revenue & Customs, regulators and other authorities based in the UK and EU
who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS
7

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
to have 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
we may have processed your information unlawfully or where we are required toerase 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 toobject 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.
Request restriction of processing of your personal data. This enables you to ask us tosuspend 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
be able to provide certain products or services to you. We will advise you if this is
the case at the time you withdraw your consent.

8