Scope of the Policy
This Policy only applies to this Website and our other Websites, but not to any external websites or other organisations, companies, individuals to which we provide links or any advertisers or merchants who use our Website. It does not apply to those external websites, applications, and entities which we do not control.
Purpose of the Policy
This Policy applies to the type of information and how we collect and store personal information about you and your use of the Website, the way that we use such information and the circumstances in which we will disclose information about you.
What Information Do We Collect?
We process information about you:
- if you sign up for our newsletters.
- if you sign up for one of our competitions
- in relation to your use of the Services generally
- if you engage with us on another website or platform (for example, commenting or Direct Messages)
The information we gather enables us to personalise, improve and continue to operate our Services. In connection with certain aspects of the Services, we may request, collect and/or display some of your Personal Information. We collect the following types of information from our users.
YOU PROVIDE US WITH
When you interact with us (for example, registering for any of our newsletters, or sending us an e-mail), we collect the following types of Personal Information:
- Sign-up information: When you sign up to one of our newsletters, you will provide us with your email address. If you sign-up by providing your email address through Facebook, we will get your email address from Facebook. That's it, we don't ask for anything extra.
- Competition information: If you enter one of our competitions, you provide agree to the relevant competition terms, and may provide us with your first and last name, age, email address, postal code and any further information listed in the relevant competition form. You may also need to provide us with further information to verify your identity if you win.
- Contact information: If you email us, you provide us with your email address, and any other information you choose to provide (for example, your name or information in your email signature).
OTHER PARTIES MAY PROVIDE US WITH
- We do not get any information about you from any third parties. Social Media information: If you follow us on another website or platform, we generally do not get any Personal Information about you from them.
- However, if you engage with us on another website or platform, for example by leaving a comment on our page, we can view these comments via that relevant website or platform. Similarly, if you message us directly on another website or platform, we will have access to the Personal Information you have chosen to provide to us via that relevant website or platform (for example, if you send us a picture) – we don't, however, copy or store that information anywhere else.
WE AUTOMATICALLY COLLECT
- Technical information and information about your visit (see also the Cookies section below for more detail). We use this for marketing and advertising analysis, including providing more relevant advertising on our Sites.
- We may also receive a confirmation when you open and engage with an email from us.
- Technical information may include the partial Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- Information about your visit may include the full Uniform Resource Locators (URL), clickstream to, through and from our Platform (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and potentially any social media handle used to connect with our team. While we collect and store IP address information, this information is not made public and converted into pseudonyms.
- Location data - we collect information through the Sites as to your real time location to provide location services where requested or agreed to by you in order to deliver content, advertising or other services that are dependent on knowing where you are.
- Delivery of location services will involve reference to one or more of the following: (a) the coordinates (latitude/longitude) of your location; (b) look-up of your country of location by reference to your IP address against public sources; and/or (c) potentially your Identifier for Advertisers (IFA) code for your Apple device, or the Android ID for your Android device, or a similar device identifier.
Our promotional updates and communications
With your prior consent we will use your personal information to send you our newsletters, and to provide you with promotional update communications by email or Site pop-ups about our Services.
You can opt-out of further marketing at any time by by sending us an email at email@example.com.
Use and Provision of Information
Use of your personal information.
Posting of your information on the Website
Use and provision of personal information received.
We may use it to enhance our website and the services we provide as well as to monitor the use of our website. We may arrange with other websites and advertisers to share aggregate information and statistics for marketing and campaign purposes. We may provide the aggregate information to third parties from time to time, but these statistics will not include personally identifiable information.
Sale of personal Information
We will not sell your personal information to third parties without your consent; we will not use your email address or other personally identifiable information to send commercial or marketing messages without your consent or unless you have specifically opted in to a particular feature, for example, a newsletter.
Non-Marketing and Administrative usage
We may use your personal information for non-marketing, administrative purposes.
Protection of your information
The internet is not a secure medium. We have, however, put in place various security procedures to help to protect your personal information.
We keep your personal information confidential. Our internal procedures cover the storage, access and disclosure of your information.
We do not represent, warrant or guarantee the security of any information you transmit to us, and any transmission is carried out at your sole risk. Once we receive information we have our own security systems in place, but we do not represent or warrant or guarantee that such systems cannot be breached. Although we will take steps to protect your personal details, the security measures are not perfect and we cannot guarantee that only authorized persons will have access to your personal information.
Breach of security
If our security systems have been breached, then we will take appropriate steps to remedy this and to notify you of any breach.
Updating your details
If any of the details you have provided to us change, then it is your responsibility to inform us of any such changes.
Disclosure of information
Sharing of your personal information
We may provide personally identifiable information and non-personally-identifiable information to our subsidiaries, affiliated companies, or other businesses or persons for the purpose of processing such information on our behalf. We require that these parties agree to process such information in compliance with our Policy, and we use reasonable efforts to limit their use of such information and to use other appropriate confidentiality and security measures.
Anonymous personal information
We may share information that is not personally identifiable (such as anonymous User usage data) with interested third-parties to assist them in understanding the usage patterns for certain content, services, advertisements, promotions, and/or functionality on our Website.
When we must disclose your personal information
We will disclose your personal data, personally identifiable information and your User activity and any other details if we are requested to do so by law or by any regulatory or governmental authority or by any law enforcement agency, or upon receipt of a court order or summons or a legitimate request by a third party (for example, the police) in investigating illegal activities to provide information concerning your activities on our Website.
Other disclosure of your personal information
We reserve the right to disclose information that we believe is appropriate or necessary to enforce our Terms and Conditions, take precautions against liability, to investigate and defend ourselves against any third-party claims or allegations, to protect the security or integrity of our Website, and to protect our Users and our Users’ rights, property, or personal safety.
Non disclosure of personal information to advertisers
The data that we collect from you may be transferred to, and stored at, a destination outside Japan. It may also be processed by staff operating outside of Japan who works for us or for one of our suppliers. Such staff may be engaged in, amongst other things, the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. Please do not share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features with a view to preventing unauthorised access.
In case of a sale, asset transfer or liquidation of the website.
If we become involved in a merger, acquisition or other transaction involving the sale of some or all of our assets, user information, including personal information collected from you through your use of our services, could be included in the transferred assets.
Changes to the Policy
Consent to the Policy
By submitting your information, you consent to the use of that information as set out in the Policy. The Policy may be revised periodically so please check the website frequently for details on new policies.
Changes and notice
If we change our Policy we will post the changes on this page and may place notices on other pages of the Website. We will indicate at the top of this page the date the Policy was last amended.
Legal bases explained
Consent: We will only process your personal information for promotional or marketing purposes where you have given us your express consent for us to do this, where required by law. For more information, please refer to Our Promotional Updates and Communication section.
You can opt out from further marketing at any time by sending an email to firstname.lastname@example.org.
Contract: We collect, store and process your personal information where it is necessary based upon a contract you have with us (such as our competition terms and conditions – please refer to the specific relevant terms for each competition), or where you have asked us to take specific steps before entering into that contract. If you enter any of our competitions, you will be provided with the full terms and conditions prior to entering – please ensure you read these carefully.
Legal Obligation: we may need to process your personal information to comply with our legal obligations, including under applicable local and national law, and any court orders.
When processing your personal information in order to manage our relationship with you, including complying with any rights requests, we ensure that we comply with the General Data Protection Regulation 2016/679 (GDPR) and the Directive on Privacy and Electronic Communications 2002/58/EC, and applicable local laws which implements these rules.
Legitimate interests: processing your data is necessary for our legitimate interests or the legitimate interests of a third party, provided those interests do not exceed your rights and interests.
Our legitimate interests are
- Gaining insights on how you use our Platform and Services
- Delivering, developing and improving our Platform and Services,, including using data to conduct surveys and run focus groups
- Enabling us to enhance, customise or modify our Platform, Services and communications
- Growing our business and informing our marketing strategy
- Keeping our records updated and studying how customers use our Services
- Improving our Platform and data security
- Product development
In each case, these legitimate interests are only valid if they are not outweighed by your rights and interests. If you would like further information about how we assess our legitimate interests, please contact us at email@example.com.
We also use different types of cookies (including automatically collected information) on our Platform in our legitimate interests or with your consent – we explain this in the Cookies section.
How long we keep your information
If you have subscribed to any of our newsletters, we retain Personal Information for as long as you remain subscribed. If you opt-out, we will retain only the minimum information needed to make sure you don't receive any unwanted communications from us.
We retain any first-party cookie information as set out in our Cookies section.
We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.
What Choices Do I Have Regarding My Information?
You can always opt not to disclose certain information to us, even though it may be needed to take advantage of some of our features (e.g. newsletter sign-ups).
Readers can access and delete cookies through their web browser settings.
You may have the right, under certain circumstances:
- to be provided with a copy of your Personal Information held by us;
- to request the correction or deletion of your Personal Information held by us;
- to request that we restrict the processing of your Personal Information (while we verify or investigate your concerns with this information, for example);
- to object to the further processing of your Personal Information, including the right to object to marketing (as mentioned in Our promotional updates and communications section;
- to request that your provided Personal Information be moved to a third party.
Your right to withdraw consent:
Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without any penalty at any time by contacting us at firstname.lastname@example.org. You can also change your marketing preferences at any time as described in Our promotional updates and communications' section;
You can also exercise the rights listed above at any time by contacting us at email@example.com.
Proof of Identity
We may ask for proof of your identity before providing a copy of your personal data.
Request for Data
If you believe that the information held about you is inaccurate or incomplete, please notify us as soon as possible so we can make the necessary corrections.
Information Related to Advertising and the Use of Web Beacons
To support and enhance the Services, we may serve advertisements, and also allow third parties to serve advertisements, through the Services. These advertisements are sometimes targeted and served to particular users and may come from third party companies called “ad networks.” Ad networks include third party ad servers, ad agencies, ad technology vendors and research firms.
Advertisements served through the Services may be targeted to users who fit a certain general profile category may be based on anonymous information inferred from information provided to us by a user, including Personal Information (e.g., gender or age), may be based on the Services usage patterns of particular users, or may be based on your activity on Third Party Services. We do not provide Personal Information to any ad networks for use outside of the Services.
To increase the effectiveness of ad delivery, we may deliver a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymously, aggregated audits, research and reporting for us and for advertisers.
Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from the ad network’s servers, these companies can view, edit or set their own cookies, just as if you had requested a web page from their website.
We collect statistical information about how both unregistered and registered users, collectively, use the Services (“Aggregate Information”). Some of this information is derived from Personal Information. This statistical information is not Personal Information and cannot be tied back to you or your web browser.
Cookies we use
We may use the following types of cookies
You can find more information about the individual cookies we use and the purposes for which we use them here:
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us, subject to your choices and preferences, to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- COOKIE TITLE: Google Analytics User ID
- COOKIE NAME(S): _ga - Used to distinguish users. https://developers.google.com/analytics/devguides/collection/gtagjs/cookie-usage
- DETAILS: Expires in 2 years
- COOKIE TITLE: Google Analytics Session ID
- COOKIE NAME(S): _gid - Used to distinguish users. https://developers.google.com/analytics/devguides/collection/gtagjs/cookie-usage
- DETAILS: Expires in 24 hrs
- COOKIE TITLE: Google Analytics Throttling ID
- COOKIE NAME(S): _gat - Used to throttle request rate. https://developers.google.com/analytics/devguides/collection/gtagjs/cookie-usage
- DETAILS: Expires in 1 min.
- COOKIE TITLE: Google Analytics
- COOKIE NAME(S): _ga - Analytics/Measurement, Optimisation
- DETAILS: Expires in 2 years
- COOKIE TITLE: WordPress Stats Analytics/Measurement, Optimisation
- DETAILS: https://wordpress.org/about/privacy/
- Targeting/Advertising cookies. These cookies record your visit to our Sites, the pages you have visited and the links you have followed. We will use this information, subject to your choices and preferences, to make our Sites more relevant to your interests. We may also share this information with third parties for this purpose.
- COOKIE TITLE: Google Ads
- COOKIE NAME(S): __gads Used for a variety of purposes related to Google AdManager and Adsense, including ensuring frequency caps
- DETAILS: Expires in 2 years
- COOKIE TITLE: Facebook Ad Serving, Ad Targeting, Analytics/Measurement, Content Customisation, Optimisation, Cross Device Tracking
- DETAILS: https://www.facebook.com/privacy/explanation
- COOKIE TITLE: Twitter Ad Serving, Ad Targeting, Analytics/Measurement, Optimisation
- DETAILS: https://twitter.com/en/privacy
How to opt-out of third party data targeting & how to disable cookies
If you prefer not to receive interest-based content and ads enabled by Google, you can opt-out by clicking on the “Opt Out” link at either Network Advertising Initiative (NAI) (http://optout.networkadvertising.org/#/) or Digital Advertising Alliance’s (DAA) (http://optout.aboutads.info/#/).
The effect of disabling cookies depends on which cookies you disable but, in general, the Sites may not operate properly if all cookies are switched off. If you want to disable cookies on our Sites, you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use.
Microsoft Internet Explorer
- Select the Tools menu > Internet Options
- Click on the Privacy tab
- Select the setting the appropriate setting
- Select Settings > Advanced
- Under Privacy and Security > Content settings.
- Click Cookies and select the relevant options
- Select Preferences > Privacy
- Click on Remove all Website Data
- Choose the Tools menu > Options
- Click on the Privacy icon
- Select the Cookie menu and select the relevant options
Opera 6.0 and further
- Choose Files menu > Preferences
- Select Privacy