JAPANET AMERICA
Privacy Policy and Cookie Notice and Controls
Last updated August 13, 2024
Japanet America, Inc., a California corporation, referred to in this Privacy Policy as“JAPANET AMERICA”, “we,” “us,” or “our.” We are committed to respecting your privacy
and protecting your personal information. In support of our commitment, we developed
this Privacy Policy (together with our Cookie Notice and Controls, collectively, “Privacy
Policy”) in order to be transparent about how we collect, use, disclose and safeguard your(and/or the members of your group/traveling party’s) personal information submitted by
you at https://www.japanetamerica.com/detail/viking2025.html (“Website”), as well as
any other media form, media channel (including, without limitation, email), mobile
website, mobile application, or call center, related or connected thereto our Website,
regardless of whether they directly display or link to this Privacy Policy (individually, a“connected service”, and collectively, “connected services”).
This Privacy Policy applies to the following:●

All connected services relating to JAPANET AMERICA, including all informationcollected through our connected services.

●

Information collected by us (or on our behalf) but excluding instances where yourinformation is collected under a different Privacy Policy or notice made available
to you at the time your information is collected.

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Information shared with us by third parties for our own use, as well as publicly
available information collected by us.

The collection, use, and disclosure (collectively, “processing”) of information described inthis Privacy Policy is controlled by JAPANET AMERICA. Please read this Privacy Policy
carefully before using the site or submitting any personal information. If you have any
questions or concerns about this Privacy Policy or our practices with regards to theinformation processed under this notice, please contact us using the contact informationand methods provided under How To Contact Us below. By using the Website, you areaccepting the practices described in this Privacy Policy. These practices may be changed
from time to time, but any changes will be posted to our Website and we will take theappropriate steps to inform you consistently of the significance of the changes, and inaccordance with applicable law. You can see the date the policy was last updated bylooking at the Copyright date shown on the last page of this Privacy Policy document. You
are encouraged to review the Privacy Policy whenever you visit the site to make sure thatyou understand how any personal information you provide will be used. Your continued
use of our services (including without limitation using our Website or submitting any
personal information) after any changes to the Privacy Policy constitutes your consent tosaid changes.
Note: The privacy practices set forth in this Privacy Policy are for this Website only. If you
link to or utilize other websites, you must review the privacy policies posted at those sites.

Information We Process
We collect information that can be used to identify or contact a particular person (we referto this type of data as “personal information”). Personal information includes
information that does not directly identify you by name or include your contact
information, but which may be used to identify that a specific computer or device hasaccessed our connected services and which if combined with certain other information
could be used to identify you. We collect personal information when you provide it to us
directly (e.g., when you submit a contact form through our connected services); whengenerated by your activity on our connected services (e.g., the amount of time spent on aparticular page of our website); and when shared with us by our business partners (e.g.,email marketing vendors or collected from other sources (e.g., publicly-available sources).
Information You Give To Us
We collect personal information that you provide to us such as name, address, contact
information, passwords and security data, and payment information. You may visit ourconnected services without you submitting any information about yourself. However, we
do collect personal information that you voluntarily provide to us when registering withus, expressing an interest in obtaining information about us, when engaging with us, orotherwise contacting us or utilizing our connected services. This includes:●

Registering an account as one of our members, a family member of a member ora guest of a member.

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Requesting our communications.

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Participating at one of our events.

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Purchasing products or services from us.

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Participating in member profiles and directories, apps, message boards, chatrooms or other connected services where registration is required.

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Communicating by any other means with us.

The personal information that we collect depends on the context of your interactions withus, the choices you make and the products and features you use. The personal
information we collect can include the following:●

Name and Contact Data. We may collect your first and last name, email address,
postal address, phone number, and other similar contact data.

●

Biographical Data. We may collect your birthday, country of citizenship, name andcontact data for your emergency contact.

Credentials. We may collect passwords, password hints, and similar security
information used for authentication and account access.
● Photos. We may collect profile photos and other pictures and videos you sharewith us.
●●Social Media Handles and Account Information. We may collect third-party social
media handles and account information that you choose to share with us, such as
LinkedIn, YouTube, Facebook, and Twitter account names and profile data.

●

Event Data. We may collect information regarding the events in which you
participate.

●

Payment Data. We may collect data necessary to process your payment if you
make purchases or donations, such as your payment instrument number (such asa credit card number), and the security code associated with your payment
instrument. All payment data is stored by our payment processor, and you should
review its privacy policies and contact the payment processor directly to respondto your questions.

ALL PERSONAL INFORMATION THAT YOU PROVIDE TO US MUST BE TRUE,COMPLETE AND ACCURATE, AND YOU MUST NOTIFY US OF ANY CHANGES TO
SUCH PERSONAL INFORMATION.
Information We Collect AutomaticallySome information – such as IP address and/or browser and device characteristics anddevice geolocation data – is collected automatically when you visit our connected services.
We use cookies and similar technologies on our connected services that automaticallyreceive and track certain data about how you and other visitors interact with ourconnected services, preferences expressed, and settings chosen. For example, we may
collect information about your device (such as your device and browser type, operating
system, IP address, mobile network carrier, and device and advertising identifiers), andyour use of our connected services (such as access dates and times, online features or
pages viewed, system activity and the third-party site or service you were using before
interacting with our connected services). In some cases, we do this through the use of
cookies, pixel tags, local storage, statistical identifiers, software development kits, andsimilar technologies that create and maintain unique identifiers. Some third party
software we utilize includes Google Analytics, Google Tag Manager, Meta Pixel, andGoogle Ads.
PLEASE SEE OUR COOKIE NOTICE AND CONTROLS TO LEARN MORE ABOUT OURUSE OF COOKIES AND SIMILAR TECHNOLOGIES, THE TYPES OF DATACOLLECTED THROUGH THESE TECHNOLOGIES, AND YOUR CHOICESREGARDING THEIR USE ON OUR ONLINE SERVICES.
Information Collected From Other Sources
We may collect limited data from public databases, marketing partners, event organizers,
and other outside sources.
We may obtain information about you from other sources, such as public databases,
marketing partners, event organizers, as well as from other third parties. Examples of theinformation we receive from other sources include social media profile information, andregistration information submitted to third parties event sponsors and organizers.
Combining Information

Where permitted by law, we may combine the personal information you provide to us
through our connected services with information we collect through other connected
services, information collected offline, and information provided to us by third
parties. Where permitted by law and feasible, we may also combine your personal
information with data collected automatically through your use of our connected services,in which case we will treat any information that is combined or associated with yourpersonal information as personal information for as long as it can reasonably be linked
with your personal information. We use this consolidated information to improve ourconnected services and product and service offerings, enhance our marketing andresearch activities, communicate information to you, and for any other legitimate purpose
described in this Privacy Policy.
How We Use Your Information
We process your information for a variety of legitimate business purposes described
below, such as providing access to and securing your account, organizing andadministering events, contacting you, and other operational purposes.
Broadly speaking, parties we employ directly, or as contractors or agents at our direction,
use Active Information for purposes of administering our core business functions, suchas the fulfillment of services and the furnishing of customer care and support. We use
Passive Information to gather information about our users and to enhance our Site to
make it easier, faster and friendlier for users. Additionally, cookies help us better
understand the usage pattern of the people that visit our site, which helps us improve ourservices. Passive Information may result in your viewing of particular advertising basedon your user habits.
We use your personal information for a variety of legitimate business purposes, including
the following:●

To facilitate account creation and logon process and administer user accounts. We
use your registration information and information collected automatically throughcookies and similar technologies to create, administer, and provide you with accessto your account. In some cases, we process your information for these purposes
pursuant to your consent. In other cases, we process your information for these
purposes in order to fulfill our obligations under an agreement with you. In othercases, we process your information for these purposes based on our legitimate
interest in providing members with a forum and mechanism to connect.

●

To supplement account profiles and sharing. If you choose to link your accountwith us to a third-party account such as your Google or Facebook account, we use
the information you allowed us to collect from those third parties to supplement
your profile information and to enable you to easily share information with otherson the applicable third-party services. In some cases, we process your information
for these purposes pursuant to your consent. In other cases, we process yourinformation for these purposes based on our legitimate interest in enhancing our
products and services.

●

To send you marketing and promotional communications. We and/or our thirdparty marketing partners may use the personal information you send to us for ourmarketing purposes, if this is in accordance with your marketing preferences. Youcan opt-out of our marketing emails at any time (see Your Privacy Rights
below). In some cases, we process your information for these purposes pursuant
to your consent. In other cases, we process your information for these purposes
based on our legitimate interest in direct marketing.
●

To send administrative information to you. We may use your personal information
to send you product, service and new feature information and/or information
about changes to our terms, conditions, and policies. In some cases, we process
your information for these purposes in order to fulfill our obligations under anagreement with you. In other cases, we process your information for these
purposes based on our legitimate interest in providing you with relevant
information about our products, services, and events.

●

Administer events. We may use your information to administer events when you
elect to participate in events. In some cases, we process your information for these
purposes pursuant to your consent. In other cases, we process your information
for these purposes in order to fulfill our obligations under an agreement with you,such as a registration agreement. In other cases, we process your information forthese purposes based on our legitimate interest in facilitating events.

●

Request feedback. We may use your information to request feedback and to contact
you about your use of our connected services. In some cases, we process yourinformation for these purposes pursuant to your consent. In other cases, we
process your information for these purposes based on our legitimate interest in
product, service and event development.

●

To protect our connected services. We may use your information as part of ourefforts to keep our connected services safe and secure (for example, for fraud
monitoring and prevention). We process your information for these purposes
based on our legitimate interest in preventing fraud and securing our connected
services and information.

●

To enforce our terms, conditions and policies. In some cases, we process yourinformation for these purposes in order to fulfill our obligations under anagreement with you, such as a registration agreement, or membershipagreement. In other cases, we process your information for these purposes basedon our legitimate interest in ensuring network and information security andpreventing fraud. In other cases, we process your information for these purposesin order to comply with or enforce our rights under applicable law.

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To receive and issue payments. In some cases, we process your information forthese purposes in order to fulfill our obligations under an agreement with you. In
other cases, we process your information for these purposes based on ourlegitimate interest in debt collection and facilitating payments.

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To respond to legal requests and prevent harm. If we receive a subpoena or otherlegal request, we may need to inspect the data we hold to determine how to
respond. In some cases, we process your information for these purposes based on
our legitimate interest in complying with applicable laws and preventing harm. In

other cases, we process your information for these purposes in order to comply
with or enforce our rights under applicable law.
●

For the purposes identified in our Cookie Notice and Controls. In some cases, we
process your information for these purposes pursuant to your consent. In othercases, we process your information for these purposes based on our legitimate
interests in performing connected service analytics, product development, direct
marketing, understanding user preferences, and securing our connected
services. In other cases, we process your information for these purposes in order
to comply with or enforce our rights under applicable law.

●

For other business purposes. We may use your information for other businesspurposes, such as data analysis, identifying usage trends, determining theeffectiveness of our promotional campaigns and to evaluate and improve our
ventures, products, services, marketing and your experience. In some cases, we
process your information for these purposes pursuant to your consent. In othercases, we process your information for these purposes based on our legitimate
interests in performing connected service analytics, product development, direct
marketing, and understanding user preferences.

We may generate aggregate or de-identified data that does not contain your personallyidentifiable information. We are not restricted in how we use or share such aggregated ir
de-identified data.
How We Share Your Information
We share information with our affiliates, service providers, marketing partners,
business partners, with other members or users of our connected services, in the eventof a business transfer, and for legal purposes.
We may share or otherwise disclosure your personal information with/to the categories
of recipients identified below for the following purposes:●

JAPANET AMERICA and Our Affiliates. Any information collected by JAPANETAMERICA will be shared with other Affiliates of JAPANET AMERICA in order tojointly engage in the activities described in this Privacy Policy, and otherwise
provide you with our travel-related products and services. We may also share yourinformation with our other affiliates, in which case we will require those affiliates
to honor this Privacy Policy. “Affiliates” include any subsidiaries, joint venture
partners, or other companies that we control or that are under common control
with us. In some cases, we share your information for these purposes pursuant toyour consent. In other cases, we share your information for these purposes inorder to fulfill our obligations under an agreement with you, such as a registrationagreement, or membership agreement. In other cases, we share your information
for these purposes based on our legitimate interest in supporting our internal
administrative operations.

●

Vendors, Consultants and Other Third-Party Service Providers. We may shareyour data with third party vendors, service providers, contractors or agents who
perform services for us or on our behalf and require access to such information to
do provide such services. Examples include payment processing, data analysis,email delivery, hosting services, customer service and marketing efforts. We may
allow selected third parties to use tracking technology on the connected services,which will enable them to collect data about how you interact with the connected
services over time. This information may be used to, among other things, analyze
and track data, determine the popularity of certain content and better understandonline activity. In some cases, we share your information for these purposes
pursuant to your consent. In other cases, we share your information for these
purposes in order to fulfill our obligations under an agreement with you. In othercases, we share your information for these purposes based on our legitimate
interest in supporting our operational activities. Unless described in this Privacy
Policy or at the time your information is collected, we do not share, sell, rent or
trade any of your information with third parties for their promotional purposes.
●

Third-Party Advertisers. We may use third-party advertising companies to serveads when you visit our connected services. These companies may use information
about your visits to our connected services and other websites that are containedin or generated by cookies and similar technologies in order to provide
advertisements about goods and services of interest to you. Please see our Cookie
Notice and Controls below for additional information. In some cases, we shareyour information for these purposes pursuant to your consent. In other cases, weshare your information for these purposes based on our legitimate interest in
marketing and improving our products, services and events.

●

Business Partners. We may share your information with our business partners tooffer you certain products, services or promotions. If we offer products, services,
events or content on a ‘co-branded’ basis, you may see both our logo and the logoof the co-branded partner. To access, use, or participate in co-branded products,
services, events or content, you may have to provide certain requested information
which may be shared with our co-branded partners. You should read theindividual privacy policies and terms of use of our co-branded partners, as thesemay differ in some respects from this Privacy Policy. Remember, you can always
opt-out of sharing your information with a co-branded partner by choosing not touse or participate in the product, service, event, or content provided. In somecases, we share your information for these purposes pursuant to your consent. In
other cases, we share your information for these purposes in order to fulfill our
obligations under an agreement with you, such as a registration agreement, or
membership agreement. In other cases, we share your information for these
purposes based on our legitimate interest in promoting and facilitating our
products, services and events.

●

Other Members and Users. Your member profile information and posted content(if any) may be shared with other registered members through account directories,
apps, message boards, chat rooms or other interactive connected services in which
you participate. In some cases, we share your information for these purposes
pursuant to your consent. In other cases, we share your information for these
purposes in order to fulfill our obligations under an agreement with you, such as aregistration agreement, or membership agreement. In other cases, we share yourinformation for these purposes based on our legitimate interest in providing
members with a forum and mechanism to connect.

●Business Transfers. We may share or transfer your information in connection with,or during negotiations of, any merger, sale of Japanet America assets, financing,or acquisition of all or a portion of our business to another Japanet America. We
share your information for these purposes based on our legitimate interest or inorder to comply with or enforce our rights under applicable law.

●

Legal Purposes. We may also disclose information we collect to legal counsel, law
enforcement, and other appropriate authorities in special cases, including when
we have a reason to believe that such disclosure is necessary to identify, contact, orbring a legal action against someone who may be causing injury to or interferencewith our rights and property or those of any other person; or when we believe that
it is required by applicable laws, court orders, or government regulations. We
share your information for these purposes in order to comply with or enforce ourrights under applicable law.

●Marketing. You agree that we may send marketing or advertising materials to you
via email or mail, including but not limited to, newsletters, blog updates, travel
developments, etc. If you do not wish to receive marketing materials from us or
any Japanet America we are affiliated with, please Contact Us and submit a request
to remove your personal information from our marketing list. Any personal
information shared with our affiliates (including, without limitation, our hostagency, if applicable) will be protected by and subject to this Privacy Policy as wellas the privacy policies of our affiliates. We also may share your information withother third-party suppliers who provide services for your booking(s) and theirprivacy policies apply to the information they receive from us.

Use Of Cookies and Similar Technologies
We may use cookies and other tracking technologies (like web beacons and pixels) tocollect and store your information. Specific information about how we use suchtechnologies and how you can refuse certain cookies is set out in our Cookie Notice andControls.
International Transfers
We may transfer, store, and process your information in, to, through or with countries
other than your own. We have taken appropriate steps and put safeguards in place to help
ensure that your information remains protected in accordance with this Privacy Policy.
JAPANET AMERICA and our servers are located in the United States. If you are engaging
with us from outside the United States, please be aware that your information will betransferred to, stored, and processed by us in our facilities located in the United States
and by those third party service providers with whom we may share your personal
information, which third parties may be located in the United States or in other countries
other than the country in which you reside. Those countries may have data protection
laws that are different from the laws of your country. The level of protection for yourinformation in the United States or such other countries may not be the same as the levelof protection in your country.
If you are a resident in the European Economic Area, then these countries may not havedata protection or other laws as comprehensive as those in your country. We will however

take all necessary measures to protect your personal information in accordance with thisPrivacy Policy and applicable law.
In particular, we comply with the EU-U.S. Privacy Shield Framework as set forth by the
U.S. Department of Commerce regarding the collection, use, and retention of personal
information transferred from the European Union to the United States and has certified
its compliance with it. As such, we are committed to subjecting all personal information
received from European Union (EU) member countries, in reliance on the Privacy Shield
Framework, to the Framework’s applicable Principles. To learn more about the Privacy
Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.
JAPANET AMERICA is responsible for the processing of personal information it receives,
under the Privacy Shield Framework, and subsequently transfers to a third party acting
as an agent on its behalf. With respect to personal information received or transferredpursuant to the Privacy Shield Framework, JAPANET AMERICA is subject to theregulatory enforcement powers of the U.S. FTC. In certain situations, we may be required
to disclose personal information in response to lawful requests by public authorities,
including to meet national security or law enforcement requirements.
Links To Third-Party Websites
We are not responsible for and do not endorse the content of third-party websites orresources available through our connected services. This Privacy Policy only applies toour connected services that link to this Privacy Policy. However, our connected services
may contain links to third-party sites or services. We do not endorse and are notresponsible for the content of third-party websites or resources, and our Privacy Policy
does not apply to any sites that are not controlled by JAPANET AMERICA, even if youaccess such sites via a link on our connected services. You should review the privacy
policies and terms of use of any third-party site before providing any information to thecontroller of such site.
Retention Of Your Personal Information
We keep your information for as long as necessary to fulfill the purposes outlined in thisPrivacy Policy unless otherwise required by law. We will only keep your personal
information for as long as it is necessary for the purposes set out in this Privacy Policy,
unless a longer retention period is required or permitted by law (such as tax, accounting
or other legal requirements).
The criteria we use to determine our retention periods include:•••

The duration of our relationship with you, including any open accounts or recent
bookings or other transactions you have madeWhether we have a legal obligation related to your Personally Identifiable
Information, such as laws requiring us to keep records of your transactions withus
Whether there are any current and relevant legal obligations affecting how long
we will keep your Personally Identifiable Information, including contractual
obligations, litigation holds, statutes of limitations, and regulatory investigations

When we have no ongoing legitimate business need to process your personal information,
we will either delete or anonymize it, or, if this is not possible (for example, because yourpersonal information has been stored in backup archives), then we will securely store yourpersonal information and isolate it from any further processing until deletion is possible.
We will deidentify, aggregate, or otherwise anonymize your Personally Identifiable
Information if we intend to use it for analytical purposes or trend analysis over longer
periods of time.
How We Protect Your Information
We have implemented appropriate technical and organizational security measuresdesigned to protect the security of any personal information we process. To the extent
appropriate or required by applicable law, these security measures include the following:●

Access to personal information is limited to authorized employees and service
providers who need access to perform the activities described in this Privacy Policy
on our behalf.

●

Personal information is pseudonymized where appropriate or required by law, andsensitive personal information transferred to or stored on any mobile device isencrypted using industry-accepted encryption solutions.

●

Personnel engaged in the processing of personal information are informed of theconfidential nature of personal information, receive appropriate training on their
responsibilities, and are obligated pursuant to our policies to maintain theconfidentiality of personal information.

●

The effectiveness of our security measures are regularly tested, assessed, andevaluated to ensure the ongoing security of processing systems.

●

Internet-connected databases containing personal information are monitored forunauthorized intrusions using network-based and/or host-based intrusion
detection mechanisms.

●

Service providers and other third parties engaged by us to process personal
information on our behalf are contractually obligated to process personal
information only on our documented instructions and must provide similar
security measures as those used by us or as required under applicable law.

Although we strive to provide reasonable and appropriate security for the personal
information we process, no security system can prevent all potential security breaches. In
particular, email or forms sent using our connected services may not be secure. You
should take special care before deciding to send us information via email and thetransmission of personal information to and from our connected services is at your own
risk. Further, if you create an account through our connected services, it is yourresponsibility to protect your access credentials from unauthorized access or use.
Your Privacy Rights
You have the rights and choices regarding the processing of your information as described
below.
Account Information

We take reasonable measures to ensure that any information we collect on our Site isaccurate, current, complete, and reliable for its intended use. If you wish to update orotherwise correct information provided to us, you may edit your information by email tothe following: contact@japanetamerica.com
Additionally, if you would at any time like to review or change the information in youraccount or terminate your account, you can log into your account settings and update youruser account. Upon your request to terminate your account, we will deactivate or delete
your account and information from our active databases. However, some information
may be retained in our files to prevent fraud, troubleshoot problems, assist with any
investigations, enforce our Terms of Use and/or comply with legal requirements.
Cookies and Similar Technologies
You can manage and change your cookie preferences or delete cookies entirely as
described in our Cookie Notice and Controls.
Opting Out of Email Marketing
You can unsubscribe from our marketing email list at any time by clicking on theunsubscribe link in the emails that we send or by contacting us using the details provided
under How To Contact Us below. You will then be removed from the marketing email list
– however, we will still need to send you service-related emails that are necessary for theadministration and use of your account.
Jurisdiction-Specific Rights
In some regions and jurisdictions (such as California, Nevada and the European
Economic Area), you may have certain additional rights under applicable data protection
laws. To the extent that relevant jurisdictions grant additional privacy rights toindividuals, these rights are described separately under the applicable Supplemental
Information and Rights section included with and incorporated in this Privacy Policy
below.
Controls For Do-Not-Track Features
Our connected services do not respond to “do not track” requests or signals at this time.
Certain web browsers may allow you to enable a “do not track” (DNT) option that sends
signals to the websites you visit indicating that you do not want your online activities
tracked. Right now, there is no industry standard for how companies should respond to
DNT signals, although one may be adopted in the future. Until a universal standard for
DNT is set, our Site will not support DNT signals. If we do so in the future, we will modify
this Privacy Policy accordingly. More information about “do not track” is contained in
our Cookie Notice and Controls below.
Important Information Regarding Minors
Our connected services are intended for general audiences. We do not knowingly collectany personal information from children through our connected services, except after
obtaining verifiable parental consent or as otherwise permitted under applicable law.
IF YOU ARE NOT OLD ENOUGH TO FORM LEGALLY BINDING OBLIGATIONS IN
YOUR APPLICABLE JURISDICTION, PLEASE TALK TO YOUR PARENTS OR
GUARDIANS BEFORE USING OUR ONLINE SERVICES OR PROVIDING YOUR NAMEOR OTHER PERSONAL INFORMATION TO JAPANET AMERICA. YOU CANNOTSUBMIT INFORMATION TO OUR ONLINE SERVICES WITHOUT YOUR PARENT’S
OR GURDIAN’S PERMISSION. If the parent or guardian of a child believes that theirchild has provided us with personal information without permission, the parent or
guardian should contact us using the details provided under How To Contact Us below torequest access to the information and deletion of such information where required. For
more information regarding protecting children’s privacy online visit
www.consumer.ftc.gov/articles/0031-protecting-your-childs-privacy-online
Supplemental Information
To the extent that certain jurisdictions require us to disclose additional information
regarding our processing activities or grant additional privacy rights to individuals, suchjurisdictions and the respective Supplemental Information and Rights section of thisPrivacy Policy describing these additional requirements/rights are identified below.
How To Contact Us
If you have any questions or comments about this Privacy Policy, or to submit a requestor otherwise exercise your privacy rights under this Privacy Policy, please contact (orsubmit your request to) our Data Protection Officer (DPO) using the contact information
below.
E-mail: contact@japanetamerica.com

JAPANET AMERICA
Cookie Notice and Controls
Our connected services use cookies and similar technologies to help us understand how
you interact with our products and connected services, to improve your experience, andto allow you to use certain features made available through our connected services (suchas sharing content via social networks or other communications channels).
This Cookie Notice describes how cookies and similar technologies are used with ourconnected services, as well as your choices regarding the use of cookies on our services
and the tools available to you to exercise your preferences. For more information
regarding the collection and use of information via our connected services, please read
our Privacy Policy
Overview of Cookies and Similar Technologies
A cookie is a small text file that a website saves on your computer or mobile device when
you visit the site, either for the duration of your visit (a session cookie) or for repeat visits(a persistent cookie). Session cookies are deleted from your computer or device once you
leave the connected service. Persistent cookies remain on your device and are sent backto the originating website on subsequent visits (or to another website that recognizes thecookie) to notify the website of your previous online activity. Cookies on this connected
service may be delivered by JAPANET AMERICA (a first-party cookie) or a third-party (athird-party cookie) and may also be set in association with emails you receive from us.
Cookies help us enhance your experience when using our connected services. They also
help us understand how people use our connected services (such as which pages orfeatures are most popular) so that we can better serve our users and members.
In addition to cookies, we may also use other similar technologies with our connected
services, such as pixel tags (also known as clear GIFs, web beacons, pixels, or web bugs),
local storage, statistical identifiers, and software development kits. Pixel tags are small
blocks of code installed on a website that allow a third party to deliver its third-party
cookies when a visitor goes to the website and are generally used by third parties tomonitor and track user activity on a website. Local storage (such as HTML 5) allows a
website to store and retrieve data on an individual’s device with no expiration date.
Statistical identifiers refer to identifiers created using certain device and server data.
Collectively, this information makes a user’s browser or device sufficiently distinct for a
website to reasonably determine that it is encountering the same browser or device overtime and used for the same purposes as cookies. Software development kits (also calledSDKs) function like third-party cookies and pixel tags but operate in the mobile app
environment where cookies and pixel tags do not function as effectively. Instead of using
cookies and pixels tags, an app developer can install pieces of code provided by third
parties (such as analytics providers) in its mobile app in order for the third parties tomonitor and analyze the use and performance of the mobile app.
These technologies enable us and our partners to recognize when someone has visited ourconnected services or opened an email, allowing us to do things such as monitor the traffic
patterns of users from one page within our website to another, understand whether avisitor has come to our website from an online advertisement displayed on a third-partysite or in an email, and measure and improve the performance of our connected services.

In many instances, these technologies are reliant on cookies to function properly and sodisabling or declining cookies will also disable their functioning.
Cookies Used with Our Online Services
Like most websites, we use certain cookies and similar technologies with our connected
services that allow us to collect various information that does not (on its own) identify any
particular individual. This helps us identify visitors who return to our connected services,
informs us of things such as how many users visited our connected services, the services,
web pages and features accessed, and whether there were any technical problems inloading pages or navigating through our connected services. By collecting thisinformation, we learn what parts of our connected services are the most interesting or
valuable to our users and members and can monitor overall interest in our products andservices. It also lets us spot technical problems with our connected services so we canaddress them right away and helps us upgrade our services and improve our offerings forour users and members.
The types of information typically collected through cookies and similar technologies
include IP address (which is used to infer approximate location); Internet service
provider; browser type and settings; device information (for example, type of device,
operating system, device manufacturer); referring/exiting URL; request/response date
and time; clickstream data; device ID or advertising ID; and your name, email address
and password if you are logging into your account. We may use Google Analytics cookies
to collect information about how visitors use our connected services. These cookies
collect information in the aggregate to give us insight into how our connected services arebeing used. We anonymize IP addresses in Google Analytics, and the anonymized data istransmitted to and stored by Google on servers in the United States. Google may alsotransfer this information to third parties where required to do so by law, or where suchthird parties process the information on Google’s behalf. Google will not associate yourIP address with any other data held by Google. The following table has more information
about these cookies.
For an overview of these Google Analytics cookies, please visit:https://support.google.com/analytics/answer/6004245.
You may install a Google Analytics Opt-out Browser Add-on by going here:
https://tools.google.com/dlpage/gaoptout.
Geolocation Information
Depending on the connected services and your computer or device permissions, we may
collect information about your device’s approximate (for example, country or zip code) or
precise location. Various technologies may be used to collect this location information,such as IP address, GPS, and other sensors that may provide information on nearby
devices, Wi-Fi access points, and cell towers. We will only collect your computer’s ordevice’s precise location with your consent. In addition, some photos or other content
you place within the connected services (such as your profile picture or competition
videos) may contain recorded location information. Location information is used tomeasure and improve the performance of our connected services and to optimize yourexperience.
How to Manage and Disable Cookies

You can manage and change your cookie preferences or delete cookies entirely as
discussed below.
Website and/or Browser Settings
Our website may feature a pop-up or other means to allow you to opt-out of certain
cookies. Browser settings allow you to choose whether or not to accept cookies or limit
certain cookies. Most browsers also provide functionality that lets you review and erase
cookies. To disable cookies through your browser, follow the instructions usually locatedwithin the “Help,” “Tools” or “Edit” menus in your browser. If you need additional
assistance, information on how to manage a disable cookies on commonly used bowsers
is available in this guide. If you use our connected services without changing your browser
settings, we will assume that you are ok to receive all cookies on the connected services.
Please be aware that if cookies are disabled, not all features of our connected services may
operate as intended. Also, please note that disabling a cookie or category of cookies does
not delete the cookie from your browser unless manually completed through your browser
function.
Cookies Used for Personalized Advertising
If you would prefer that we not sell or share information that may be used to help
determine which advertisements to serve you, opt out by clicking the applicable “OPTOUT” button, which can be found on most of our connected services. You may also opt
out or change your behavioral advertising cookie preferences by visiting the opt-out pagefor the Digital Advertising Alliance (U.S. residents and those not in the EU or Canada),
the European Interactive Digital Advertising Alliance (European residents), or the Digital
Advertising Alliance of Canada (Canadian residents).
Flash Cookies
Flash cookies cannot be changed by browser settings. If you do not want Flash cookies
stored on your computer, you can adjust the settings of your Flash player to block Flashcookies storage using the tools contained in the Website Storage Settings Panel. You canalso control Flash Cookies by going to the Global Storage Settings Panel and following the
instructions (which may include instructions that explain, for example, how to delete
existing Flash cookies, how to prevent Flash LSOs from being placed on your computer
without your being asked, and (for Flash Player 8 and later) how to block Flash cookies
that are not being delivered by the operator of the page you are on at the time). Please
note that setting the Flash Player to restrict or limit acceptance of Flash cookies may
reduce or impede the functionality of some Flash applications, including, potentially,
Flash applications used in connection with our services or online content.
Mobile Devices
Your mobile operating system may let you opt out from having your information collectedor used for interest-based advertising on mobile devices. You should refer to the
instructions provided by your mobile device’s manufacturer, but this functionality is
usually available in the “Settings” section of your device.
Do Not Track (DNT)
Certain web browsers may allow you to enable a “do not track” (DNT) option that sends
signals to the websites you visit indicating that you do not want your online activities
tracked. This is different from blocking cookies as browsers with the DNT option selectedmay still accept cookies. Right now, there is no industry standard for how companies
should respond to “do not track” signals, although one may be adopted in the future. We
do not respond to DNT signals at this time. If we do so in the future, we will modify thisCookie Notice accordingly. More information about “do not track” is available atwww.allaboutdnt.com.
Cookie Notice Changes
We may update this Cookie Notice from time to time. Any changes will be posted on thispage with an updated revision date. If we make any material changes, we will provide
notice through the connected service or by other means.

Supplemental Information and Rights
for CALIFORNIA RESIDENTS
If you are a California resident, the following additional information and rights apply to
you with respect to JAPANET AMERICA’s collection, use, and disclosure of personal
information about you. For purposes of this section, “personal information” means
information that identifies, relates to, describes, is capable of being associated with, or
could reasonably be linked, directly or indirectly, with a particular California consumer
or household. “Personal information” does not include publicly available information or
information that is deidentified or in the aggregate.
Collection, Use, and Disclosure of Personal Information
Categories of Personal Information CollectedJAPANET AMERICA has collected the following categories of personal information about
California consumers in the preceding 12 months:● Identifiers, such as a real name, alias, postal address, unique personal
identifier, online identifier, Internet Protocol address, email address, telephone
number, account name, Social Security Number, driver’s license number orstate identification card number, passport number, or other similar identifiers.
● Other identifiers or consumer information, such as physical characteristics
or description, insurance policy number, education, employment, employment
history, bank account number, credit card number, debit card number, or any
other financial information, medical information, or health insurance
information.
● Characteristics of protected classifications under California or federal law,such as race, color, sex, age (40 and older), religion, national origin, disability,
citizenship status, genetic information, marital status, sexual orientation andidentity, political affiliations or activities, military or veteran status, medical
condition, or status as a victim of domestic violence, assault, or stalking.
● Commercial information, including records of personal property, products
or services purchased, obtained, or considered, or other purchasing or
consuming histories or tendencies.
● Internet or other electronic network activity information, including, but notlimited to, browsing history, search history, and information regarding a
consumer’s interaction with an Internet Web site, application, or advertisement.
● Geolocation data.
● Audio, electronic, visual, thermal, olfactory, or similar information.
● Professional or employment-related information.

Inferences drawn from any of the information identified above to create aprofile about a consumer reflecting the consumer’s preferences, characteristics,
psychological trends, preferences, predispositions, behavior, attitudes,
intelligence, abilities, and aptitudes.
●

JAPANET AMERICA uses these categories of personal information for the purposes
described under How We Use Your Information above.
Categories of Personal Information Disclosed for Business PurposesJAPANET AMERICA has disclosed for a business purpose the following categories of
personal information about California consumers in the preceding 12 months:● Identifiers, such as a real name, alias, postal address, unique personal
identifier, online identifier, Internet Protocol address, email address, telephone
number, account name, Social Security Number, driver’s license number orstate identification card number, passport number, or other similar identifiers.
● Other identifiers or consumer information, such as physical characteristics
or description, insurance policy number, education, employment, employment
history, bank account number, credit card number, debit card number, or any
other financial information, medical information, or health insurance
information.
● Characteristics of protected classifications under California or federal law,such as race, color, sex, age (40 and older), religion, national origin, disability,
citizenship status, genetic information, marital status, sexual orientation andidentity, political affiliations or activities, military or veteran status, medical
condition, or status as a victim of domestic violence, assault, or stalking.
● Commercial information, including records of personal property, products
or services purchased, obtained, or considered, or other purchasing or
consuming histories or tendencies.
● Internet or other electronic network activity information, including, but notlimited to, browsing history, search history, and information regarding a
consumer’s interaction with an Internet Web site, application, or advertisement.
● Geolocation data.
● Audio, electronic, visual, thermal, olfactory, or similar information.
● Professional or employment-related information.
● Inferences drawn from any of the information identified above to create aprofile about a consumer reflecting the consumer’s preferences, characteristics,
psychological trends, preferences, predispositions, behavior, attitudes,
intelligence, abilities, and aptitudes.
“Business purposes” include the use of personal information as reasonably necessary andproportionate for operational purposes, such as performing services on our behalf (e.g.,maintaining or servicing accounts, providing customer service, processing orders,verifying member information, processing payments, or providing marketing or analytic
services), auditing related to a current interaction with you and concurrent transactions,detecting and protecting against security incidents, debugging to identify and repair
errors, conducting research, and undertaking activities to verify or maintain the quality
or safety of our products and services.
Categories of Personal Information SoldJAPANET AMERICA has not sold personal information about California consumers in
the preceding 12 months.

Your Privacy Rights Under California Law
In addition to the rights described under Your Privacy Rights above, California residents
also have the rights described below.
Right to Notice and Access
You have the right to request that JAPANET AMERICA disclose additional information
regarding our collection and use of your personal information, including the following:● The categories of personal information we have collected about you.
● The categories of sources from which personal information is collected.
● The purpose for collecting or selling personal information.
● The categories of third parties with whom we share personal information.
In addition, you have the right to request access to the specific pieces of personal
information we have collected about you. To request this additional information or toaccess your personal information, please submit a request to JAPANET AMERICA using
one of the methods described under How to Exercise Your California Privacy Rights below.
Right to Deletion of Personal Information
You have the right to request that JAPANET AMERICA delete any personal information
about you which we have collected from you. To request deletion of your personal
information, please submit your request to JAPANET AMERICA using one of themethods described under How to Exercise Your California Privacy Rights below. Please
be aware that such a request does not ensure complete or comprehensive deletion of yourpersonal information and that there may be circumstances in which the law does not
require or allow deletion even if requested.
Right to Transparency Regarding Disclosure or Sale of Personal Information
You have the right to request that JAPANET AMERICA disclose additional information
regarding the disclosure or sale of your personal information, including the following:
The categories of personal information that JAPANET AMERICA disclosed
about you for a business purpose.
●

The categories of personal information that JAPANET AMERICA soldabout you and the categories of third parties to whom the personal information
was sold (by category or categories of personal information for each third party
to whom the personal information was sold).
●

In addition, you have the right to request information regarding the disclosure of yourpersonal information by JAPANET AMERICA to third parties for the third parties’ direct
marketing purposes.
To request additional information regarding the disclosure and sale of your personal
information (as applicable), or to opt-out of the disclosure of your personal information
to third parties for their direct marketing purposes, please submit your request toJAPANET AMERICA by using one of the methods described under How to Exercise Your
California Privacy Rights below.
Right to Opt-Out of the Sale or Sharing of Personal Information
JAPANET AMERICA generally does not sell your personal information, and only shares
your personal information with necessary suppliers and vendors in connection with thetravel products and services being providing to you. If JAPANET AMERICA sells yourpersonal information to third parties, you can opt-out of the sale of your personal
information at any time by submitting a request to JAPANET AMERICA using one of themethods described under Do Not Sell Or Share My Personal Information below.
DO NOT SELL OR SHARE MY PERSONAL INFORMATION
You have the right to opt-out of the sale or sharing of your personal information. Once we
receive and confirm a verifiable consumer request from you, we will stop selling or sharing
your personal information. To exercise your right to opt-out, please contact us via email
provided above.
Rights of Children
Notwithstanding anything else contained in this Privacy Policy, JAPANET AMERICA will
not sell the personal information of individuals if JAPANET AMERICA has actual
knowledge that the individual is less than 18 years of age, unless the individual, in thecase of individuals between 13 and 18 years of age, or the individual’s parent or guardian,in the case of individuals who are less than 13 years of age, has affirmatively authorized
the sale of the individua’s personal information (the “right to opt-in”).
Right to Removal of Content Posted Publicly by Minors
If you are a California resident under the age of 18, and a registered user of any connected
services where this Privacy Policy is posted, you may request and obtain removal ofcontent or information you have publicly posted. To make such a request, please use oneof the methods described under How to Exercise Your California Privacy Rights below
and include a detailed description of the specific content or information to be
removed. Please be aware that such a request does not ensure complete orcomprehensive removal of the content or information you have posted and that there may
be circumstances in which the law does not require or allow removal even if requested.
Right Not To Be Subject To Discrimination
JAPANET AMERICA will not and cannot discriminate against you for exercising any ofyour rights described above, such as by denying you goods or services or by providing you
with a different level of goods or services. However, we can charge a different price orrate, or provide a different level or quality of goods or services, if that difference isreasonably related to the value provided to you by your personal information. In addition,
we may offer financial incentives, including payments to you as compensation, for thecollection, sale, or non-deletion of your personal information. If we offer you any suchfinancial incentives, we will first notify you of the applicable incentives and will only
include you into a financial incentive program with your prior opt-in consent (which may
be revoked by you at any time).
How to Exercise Your California Privacy Rights
To exercise any of your California privacy rights described above—including to request
additional information regarding our collection and use of your personal information, torequest access to your personal information, to request that we delete your personal
information, to request additional information regarding the disclosure and sale of yourpersonal information, or to opt-out of the disclosure of your personal information to third
parties for their direct marketing purposes—please submit your request to JAPANETAMERICA using one of the methods provided under How To Contact Us above.

Supplemental Information and Rights
for NEVADA RESIDENTS
Nevada law (SB 220) requires Website operators to provide a way for Nevada consumers
to opt out of the sale of personal identifiable information that the Website operator may
collect about them. Please note we do not sell your personal information to third parties
as defined in Nevada law and will not do so in the future without providing you with notice
and an opportunity to opt-out of such sale as required by law. If you have any questions
regarding our data privacy practices or our compliance with Nevada data privacy law,please email us at contact@japanetamerica.com

Supplemental Information and Rights
for EUROPEAN RESIDENTS
If you reside in Europe or your personal information is otherwise covered by the European
Union’s General Data Protection Regulation or U.K. Data Protection Act (collectively,“European Privacy Regulations”), the following additional information and rights apply
to you with respect to JAPANET AMERICA’s collection, use, and disclosure of personal
information. For purposes of this section, “personal information” means any informationthat identifies an individual or for which there is a reasonable basis to believe theinformation can be used to identify an individual. “Personal information” does notinclude publicly available information or information that is deidentified or in theaggregate.
Controller | European Representative
The processing of personal information described in this Privacy Policy is controlled byJAPANET AMERICA. JAPANET AMERICA has appointed a Data Protection Officer tobe their representative for Europe. To contact our representative for Europe directly,
please email contact@japanetamerica.com. Otherwise, you can contact JAPANETAMERICA and its Data Protection Officer using the contact information and methods
provided under How To Contact Us above.
Your European Privacy Rights
In addition to the rights described under Your Privacy Rights above, you have various
additional rights with respect to the collection, use, transfer, and processing of yourpersonal information, as described below. We reserve the right to limit these rights at any
time where permitted under applicable law, including where your identity cannot bereasonably verified by JAPANET AMERICA or to the extent your rights adversely affectthe rights and freedoms of others. To exercise any of the rights below, please submit yourrequest to JAPANET AMERICA. You have the right to obtain confirmation as to whether
or not your personal information is being processed by JAPANET AMERICA. Where weare processing your personal information, you have the right to access the data and toobtain certain information about the processing of such data.
Right to Rectification
You have the right to obtain rectification of any personal information that is inaccurate or
incomplete, including by means of providing a supplementary statement.

Right to Erasure
You have the right to have your personal information erased where one of the following
applies:● Your personal information is no longer necessary with regards to the
purposes for which it was collected.
You withdraw your consent (where the processing is based on suchconsent).
●

You object to the processing where such processing is based on JAPANETAMERICA’s (or a third party’s) legitimate interest and there are no overriding
legitimate grounds for the processing.
●Your personal information must be erased in order to comply with a legal
obligation under applicable law.
●

However, this right to erasure will not apply to the extent the processing is necessary for:●

Compliance with a legal obligation which requires processing by applicable;orArchiving purposes in the public interest, scientific or historical research
purposes, or statistical purposes, to the extent permitted under applicable law.
●

Right to Restriction of Processing
You have the right to restrict the processing of your personal information where one of
the following applies:●

The accuracy of the personal information is contested.

The processing is unlawful and you oppose the erasure of your personal
information and request the restriction of its use instead.
●JAPANET AMERICA no longer needs the personal information for the
purposes of the processing, but it is required by you for the establishment,
exercise or defense of legal claims.
●

Where the processing is based on JAPANET AMERICA’s (or a third party’s)
legitimate interest and you have objected to processing (as described
immediately below).
●

Right to Object
You have the right to object (on grounds relating to your particular situation) at any timeto the processing of your personal information for direct marketing purposes or where
the processing is based on JAPANET AMERICA’s (or a third party’s) legitimate
interest. When objecting to processing based on our legitimate interest, JAPANETAMERICA will no longer process your personal information unless JAPANET AMERICA
demonstrates compelling legitimate grounds for the processing which override yourinterests, rights and freedoms or for the establishment, exercise, or defense of legal claims.

Right to Withdraw Consent
Where the processing of your personal information is based on your consent, you havethe right to withdraw such consent at any time, without affecting the lawfulness ofprocessing based on consent before such withdrawal.
Right to Data Portability
You have the right to receive your personal information, which you have provided toJAPANET AMERICA, in a structured, commonly used and machine-readable format, andhave the right to transmit such data to another entity without hindrance from JAPANETAMERICA, where each of the following conditions are met:●

Your request does not adversely affect the rights of others;Your request does not adversely affect JAPANET AMERICA’s rights(including intellectual property rights);●

The processing is based on your consent or the performance of a contract towhich you are a party; and●●The processing is carried out by automated means.

Right Not to Be Subject to Solely Automated Decisions
You have the right not to be subject to a decision based solely on automated processing(including profiling) which produces legal effects concerning you or similarly significantly
affects you, unless permitted under applicable law.
Right to Submit a Complaint to Supervisory Authorities
You have the right to lodge a complaint with an applicable data protection authority. If
you reside in Europe, you have the right to lodge such a complaint in the European
country of your habitual residence, place of work, or place of an alleged infringement if
you consider that the processing of your personal information infringes applicable
European Privacy Regulations. A list of all European supervisory authorities and theirrespective contact information is available here.