I. General information
1. Who is responsible for processing of personal data
Controller of the processing of personal data is:
Tokyo Creative Co, Ltd., 2-10-13 Aobadai Meguro-ku, 153-0042 Tokyo, Japan
2. What we process
We process personal data provided by you or data that is automatically allocated while using our website. For further information, see section II. – Processing of personal data.
3. For what purpose and on what legal basis do we process personal data
We process your personal data in accordance with the provisions of GDPR for various purposes. In principle, the following can be considered as the purposes of the processing: the processing for the initiation of contractual relationships and the performance of contracts (Art. 6 (1) lit. b GDPR), legitimate interests (Article 6 (1) lit. f GDPR), and/or based on your consent (Article 6 (1) lit. a GDPR).
We explain the legal basis we actually use in sections II.
4. Who receives your personal data
Service providers employed by us (processors, see Art. 4 No. 8 GDPR) may receive and process personal data on our behalf. We use the following processor or category of processors:
- IT service providers
- Google Inc.
We may share your data with the following controllers:
- payment service providers
5. Transfer of personal data to a Third Country
Please note, that we are based in Japan and therefore process your personal data outside of the European Economic Area (EEA) in Japan.
Through the use of Google Analytics, personal data may be transferred to other countries outside of the EEA in exceptional cases. For further information, see section II.6. Also, data collected through the Media.net cookies sent to a third country. For further information please see Section II.7.
6. For how long do we process personal data
We process data only as long as it is necessary in relation to the initial specified, explicit and legitimate purpose.
We will delete your personal data if it is no longer necessary to retain for such purpose.
7. Your rights
Every data subject has the right of access (Art. 15 GDPR), the right to rectification (Art. 16 GDPR), the right to erasure (Art. 17 GDPR), the right to restriction of processing (Art. 18 GDPR) and the right to data portability (Art. 20 GDPR). In addition, as far as the personal data is processed for the purpose of our legitimate interest according to Art. 6 (1) lit. f GDPR, you have the right to object according to Art. 21 GDPR.
To exercise those rights, you can contact us under the contact information given in section III.
If the processing of personal data is based on your consent, you can withdraw it at any time. The withdrawal should be directed to the bodies mentioned in section III.
In addition, if you are of the opinion that the processing of your personal data is unlawful, you have the right to lodge a complaint with the competent supervisory authority (Art. 77 GDPR). This right to complain is without any prejudice to any other administrative or judicial remedy. However, we would appreciate if you would contact us first so that we can response to your concern before you approach the supervisory authority.
II. Processing of personal data (website)
1. Registering an Account
We may collect and process some or all of the following information you make available to us if you register, download or use our services, such as your:
- Email Address
- Encrypted password
Alternatively, you may also register and login via your Facebook account (so-called “Single Sign On”). In this case we store the following registration and login data provided by Facebook: name, email-address.
The processing of personal data for payment services is based on Art. 6 (1) lit. b GDPR.
2. Purchases and Payment Service Providers
The processing of personal data for payment services is based on Art. 6 (1) lit. b GDPR.
With our newsletter we inform you about our products, events and services. When you register for our newsletter, we process your email address and name when registering for the newsletter. After registration, you will receive an email to confirm the registration.
The processing is based on your consent, Art. 6 (1) lit. a GDPR. Purpose is the distribution of our newsletter.
4. Access data/ Server logfiles
While visiting our website, the following personal data is stored:
- IP address
- Client ID
- Browser type and operating system used
This processing of personal data is based on Art. 6 (1) lit. f GDPR. Purpose and our legitimate interest are administration and improved functionality of our website as well as preventing security issues.
- Session cookies are temporary cookie files that are automatically deleted when you close your browser.
- Persistent cookies are cookie files that are stored until they are actively deleted or automatically removed after a certain amount of time.
- First-party cookies are cookies that are set directly by us.
- Third party cookies are cookies set by a third party.
Cookies can be used for different purposes:
- Optimization cookies enable us to analyze the use of our website. The analysis helps us to improve our services and offered products and services.
- Personalization cookies allow us to determine your personal preferences, such as your preferred language. We use these cookies to improve usability and offer you a customized experience.
- Security-relevant cookies are cookies that are necessary to protect the website against attacks and to prevent fraud.
- Social media cookies are used to offer social media functions to the website visitor.
- Advertising cookies are used to deliver personalized advertisement to the website visitor.
You can set your browser so that you are informed about the setting of cookies and individually decide on their acceptance or decline cookies in specific cases or in general. You can delete already set cookies. Declining cookies may limit the functionality of our website.
Processing of personal data through the use of functional, first party cookies is based on Art. 6 (1) lit. f GDPR. Purpose and our legitimate interest are improved functionality of our website.
Usage of third party cookies will be described in detail below.
6. Google Analytics
In case the anonymization of IP-addresses is active on a website, the user’s IP address will be truncated inside the European Union or the European Economic Area. Only in exceptional cases the user’s full IP address will be transmitted to a server of Google in the US and truncated there. IP-anonymization is active on our websites.
On behalf of us, Google will process this data in order to analyze your use of our websites, to generate reports on website activity and to render further services regarding the use of our websites. The IP address transmitted by your browser will not be associated with other data in possession of Google.
You can prevent the storage of cookies by modifying your browser setting to decline cookies. Furthermore, you can prevent the collection and following procession of data by Google through this cookie by downloading a browser-plugin through the following link: https://tools.google.com/dlpage/gaoptout/.
Preventing storage of cookies may prevent you from taking full advantage of our websites.
You can find further information about terms and conditions as well as data protection on https://www.google.com/analytics/terms/us.html, https://www.google.com/policies/privacy/ and https://support.google.com/analytics/answer/6004245?hl=en.
The processing of personal data through Google Analytics is based on Article 6 (1) lit. f GDPR. Purpose and our legitimate interest are analysis of the use of our websites as well as improved functionality.
7. Media.net Cookies
Our website uses the technology provided by Media.net. By using that technology Media.net collects Technical Data (meaning which includes internet protocol (IP) address, cookies, browser and device information, location data and your login data) and Usage Data (meaning information about how you use our website and advertising Media.net serves on our website including how many times you viewed the ad, clicked the ad etc and also mitigate fraudulent activities) regarding your behavior and usage patterns on our website. Media.net collects this type of information about you using cookies, web beacons, and other web tools ("Tools"). We do not use these Tools to store any personal data. Some of the Tools and the ways in which we use them are further described below:
- To inform Media.net if an advertisement has been served to the same computer before, and if so, when the advertisement was served. These cookies are not used by Media.net to build a profile of a user’s behavior nor are they used by Media.net for the purposes of behavioral tracking or behavioral targeting.
- To conduct research and identify fraud and malicious activity.
- To deliver targeted advertisements. This form of advertising is called “behavioral advertising” or “interest based advertising”. We believe that such advertising is helpful because you will see ads that are relevant to your interests. However, if you would like to opt-out of these interest-based advertisements, please see the paragraph below.
Your browser may give you the ability to adjust your settings to delete or disable cookies. If you choose to disable cookies, you may not be able to use certain features on our website you visit. You can also opt-out of receiving personalized ads from us and other third party advertisers and ad networks who are members of the Network Advertising Initiative ("NAI"). The NAI's opt-out tool can be found here http://www.networkadvertising.org/choices/. Media.net complies with the Self-Regulatory Principles for Online Behavioral Advertising set forth by the Digital Advertising Alliance (DAA). Please note that if you use a different web browser, computer, clear, block, delete or restrict your cookies after opting out, you may need to repeat your choices.
The processing of personal data through Media.net is based on Article 6 (1) lit. f GDPR. Purpose is direct marketing.
You can find more how Media.net processes your personal data here: https://www.media.net/privacy-policy
8. Inquiries from customers
When contacting us (i.e. via email), we process your email address and any personal data disclosed in the message itself (i.e. your name).
When you use our contact form, we process the personal data you provide in said contact form: name, email address and subject of your inquiry.
The processing is based on Art. 6 (1) lit. b and lit. f GDPR. Purpose and our legitimate interest is answering your enquiry and, if applicable, follow-up questions
III. Contact Details
Tokyo Creative Co, Ltd.
2-10-13 Aobadai Meguro-ku
153-0042 Tokyo, Japan
Information about your right to object in accordance with Art. 21 General Data Protection Regulation (GDPR)
You have the right to object on grounds relating to your particular situation, at any time to processing of personal data concerning you on the basis of Art. 6 (1) lit. f GDPR.
Should you decide to object the processing, we will stop to process personal data concerning you, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or the processing serves the purpose of establishment, exercise or defense of legal claims.
You also have the right to object at any time to processing of personal data concerning you for the purpose of advertising; this also applies to profiling insofar as it is associated with advertising.
Should you decide to object to the processing for advertising purposes, we will stop to process personal data for advertising purposes. The objection is not subject to any form. Ideally, it should be lodged at the bodies mentioned in section III.