JAPAN HOUSE SÃO PAULO
Updated on February 4, 2021
Controller: Associação Japan House, headquartered in São Paulo-SP, at Av. Paulista, 52, 2nd floor, corporate taxpayer’s ID (CNPJ/ME) No. 28.876.877/0001-60 (“Japan House São Paulo”).
1. Relevant Definitions
3. Information about the Personal Data Collected
4. Sharing of Personal Data with Third Parties
5. Legal Bases and Purposes of the Handling of Personal Data
6. Storage and Protection of Personal Data
7. International Transfers of Personal Data
8. Rights of the Users, Holders of the Personal Data
9. Personal Data Storage Period
10. Contact Information
1. RELEVANT DEFINITIONS:
1.1.1. IP Address: Internet Protocol address, the code assigned to a terminal on a network to allow its identification, set pursuant to international parameters.
1.1.2. Internet: System consisting of a set of logical protocols, structured on a worldwide scale for public and unrestricted use with the purpose of enabling data communication between terminals through different networks.
1.1.3. Password: Set of characters that may consist of letters and/or numbers with the purpose of verifying the User’s identity to access the Website.
1.1.4. Website: The website made available at https://www.japanhousesp.com.br/ belonging to Japan House São Paulo and through which the User has access to the Content.
1.1.5. Users (or “User,” when considered individually): Everyone who accesses and uses the Website, it being established that the Website is directed only to individuals aged more than 18 (eighteen) years or emancipated and fully capable of practicing acts of civil life or those who are absolutely or relatively incapable, provided, in such case, that they are duly represented or assisted.
2.3. The “Handling,” “Controller,” “Operator,” “Data Holder,” and “Personal Data” concepts are used pursuant to the definitions set forth in the GDPR.
3. INFORMATION ABOUT THE PERSONAL DATA COLLECTED:
3.1 To allow access to certain Website Content, as well as to keep the Website up and running and maintain a relationship with the User, Japan House São Paulo may collect the information and Personal Data below.
3.2 Personal Information and Data that Users choose to provide
3.2.1 The User may choose to provide some Personal Data, such as name and e-mail, to enhance their experience at Japan House São Paulo, by registering to receive mail and registering for specific Japan House São Paulo events.
3.3. Personal Information and Data collected while using the Website
3.3.1. Japan House São Paulo may collect browsing information or Personal Data in an automated way using cookies. Cookies are small files that may or may not be added to your terminal and that allow storing and recognizing your browsing data.
3.3.2. Three (3) types of cookies may be used while you browse:
(i) Authentication Cookies: The purpose of these cookies is to recognize a particular User, enabling access to and use of the Website with restricted content and providing more customized browsing experiences. Authentication Cookies cannot be disabled or rejected to ensure proper Website functioning and do not collect Personal Data for marketing purposes.
Authentication Cookies may collect these Personal Data:
a) IP Address;
b) ID code (IMEI) of the mobile device through which the User accessed the Website, and
c) Information regarding Website use date and time by a given User based on a given IP Address.
Security Cookies may collect these Personal Data:
a) Geographic location;
b) Operating system the User uses;
c) Browser and its versions;
d) IP Address;
e) ID code (IMEI) of the mobile device through which the User accessed the Website, and
f) Information regarding Website use date and time by a given User based on a given IP Address.
(iii) Research, Analysis, and Performance Cookies: The purpose of this type of cookie is to help us understand the Website’s performance, measure the Website’s audience, check the Users’ browsing habits on the Website, as well as how the User arrived at the Website (e.g., through links from other websites, search engines or directly through the address). Research, Analysis, and Performance cookies allow users to store their preferences and customize their experience using the Website and may collect Personal Data for marketing purposes. Users can disable these cookies by means of their browsers’ configuration options. However, when deciding not to allow the use of these cookies, the User is aware of and acknowledges that the Website may not perform all its functions.
Research, Analysis, and Performance Cookies may collect these Personal Data:
a) Geographic location;
b) Operating system the User uses;
c) Browser and its versions;
d) Screen resolution;
e) Java (programming language);
f) Flash player installed;
g) IP Address;
h) ID code (IMEI) of the mobile device through which the User accessed the Website;
i) Information regarding Website use date and time by a given User based on a given IP, and
j) Information regarding the number of clicks and attempts to use the Website, as well as the pages the User accessed.
4. SHARING OF PERSONAL DATA WITH THIRD PARTIES:
4.1 Personal Data collected while using the Website may be shared with the following third parties:
a) Japanese Ministry of Foreign Affairs (“MOFA”), a Japanese government agency that created the “Japan House” project. As the author of the project, MOFA coordinates the budget and sets the project’s guidelines;
b) Dentsu Inc., a Japanese company that has historically provided services to the Japanese government. Because of this historical and contractual relationship, Dentsu Inc. was the company MOFA chose to implement and manage the “Japan House” project in Brazil; and
c) Dentsu Latin America Propaganda Ltda., a Brazilian subsidiary of Dentsu Inc. that, in Brazil, assists and supports Japan House São Paulo’s operations.
4.2 Japan House São Paulo may also share Personal Data with public or private organizations to comply with legal obligations.
5. LEGAL BASES AND PURPOSES OF THE HANDLING OF PERSONAL DATA:
5.1 Consent, execution of contract or preliminary procedures, and credit protection:
a) Registration for the mailing list and newsletter;
b) Resolution of questions or complaints;
c) Resolution of disputes;
d) Verification of the Users’ browsing habits on the Website, and
e) Verification of how Users arrived at the Website (e.g., through links from other
websites, search engines or directly by means of the address).
5.2. Legitimate interest:
a) Improving Website performance and measuring its audience;
b) Evaluation of statistics related to the number of hits and use of the Website, its resources, and functionalities;
c) Creation of internal use reports for developing new services and content;
d) Identification of profiles, habits, and needs for possible strategies at Japan House São Paulo;
e) Carrying out internal management and business procedures, e.g., accounting, audits, main data management;
f) Conducting analyses related to Website security, improving, and developing anti-fraud tools;
g) Sending of marketing material and direct advertising to Users; Communication between Users and Japan House São Paulo, including sending and receiving e-mails;
h) Providing Content that is more customized and appropriate to the Users’ needs and interests, such as profile pages, updates, content, and relevant ads;
i) User relations management, and
j) Resolution of questions or complaints.
5.3. Compliance with legal obligations and regular exercise of rights in process:
5.3.1 Japan House São Paulo Handles Personal Data, when necessary, to comply with the applicable legal obligations, including regarding the preparation of financial and regulatory reports, reports of adverse events and tax obligations, among others, or for the purpose of the regular exercise of rights in legal, administrative, or arbitration proceedings.
6. STORAGE AND PROTECTION OF PERSONAL DATA:
6.1. Japan House São Paulo takes all technical and organizational measures to protect the Website Users’ Personal Data against loss, unauthorized use, or other abuses, ensuring a level of security compatible with the activities carried out by Japan House São Paulo.
6.2. Personal Data will be stored in a secure operating environment that is not accessible to the public. We strive to protect the Personal Data we store, based on measures such as (i) adopting a governance and privacy program; (ii) creating a team responsible for the Protection of Personal Data and a Data Protection Officer; (iii) adding the principles of “Privacy by Design” and "Privacy by Default” during the execution of activities; (iv) creating confidentiality policies with employees; (v) restricting access to Personal Data based on the “need-to-know” and "least privilege” principles, among others. Despite this, unfortunately we cannot guarantee full security. Unauthorized use of accounts, hardware or software failure and other factors may compromise your Personal Data’s security at any time, so we need the Users’ help to maintain a safe environment for everyone.
7. INTERNATIONAL TRANSFERS OF PERSONAL DATA:
7.1. As an organization created at the initiative of the Japanese Government, Japan House São Paulo may, if necessary, transfer Personal Data collected in Brazil for storage on the Website’s server located in Japan. The National Data Protection Authority (“NDPA”) has not yet issued a suitability decision for Japan; however, to ensure the same level of protection for your Personal Data, we have formalized a Contract or Policy with the Handling agents involved in the International Transfer of Data, pursuant to art. 33, paragraph IX of the GDPR.
8. RIGHTS OF THE USERS HOLDERS OF THE PERSONAL DATA:
8.1. When using the Website and providing their Personal Data to Japan House São Paulo, Japan House São Paulo will guarantee to the Users the rights provided for in the Applicable Data Protection Legislation, namely:
a) Access: Being aware of the information and Personal Data about the User Handled by Japan House São Paulo on the Website.
b) Correction: Requesting the correction of the User’s Personal Data stored on the Site.
c) Request for anonymization, blocking or deletion: Requesting the anonymization, blocking or elimination of Personal Data that is excessive, unnecessary, or that is Handled in a manner non-compliant with the GDPR, in which case Japan House São Paulo will conduct an analysis to check for excesses or any non-compliance in the Handling of Personal Data and, if such non-compliance is confirmed, it will comply with the request made.
d) Registration Exclusion: Requesting the deletion of the registration made on the Website. In this case, some Personal Data may remain stored to comply with legal obligations or to exercise the rights of Japan House São Paulo.
e) Revocation of Consent: Revoking the consent provided for some features using the opt-out tool.
f) Portability: Requesting the portability of Personal Data to another supplier of products or services in an interoperable format, such as a txt file, when possible.
g) Review of automated decisions: Requesting a review of an exclusively automated decision that affects your interests.
9. PERSONAL DATA STORAGE PERIOD:
9.1. The Personal Data Japan House São Paulo collects will be subject to Handling only for as long as necessary to comply with the purposes for which we collect it, including for complying with any legal, contractual, and accountability obligations, for defense in administrative or judicial proceedings, or to meet requests from competent authorities.
9.2. All Personal Data collected will be deleted when the User so requests or when they are no longer needed or relevant for the provision of services by Japan House São Paulo. However, Japan House São Paulo may keep any Personal Data, even after the User requests its exclusion, when there is any other reason for it to be kept, such as any legal obligation to retain such Personal Data, or the need to preserve it for protecting Japan House São Paulo’s rights. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of damage from unauthorized use or disclosure of Personal Data, the purpose of the handling of the Personal Data and whether we can achieve these purposes through other means, as well as the applicable legal requirements.