1.1 We are committed to safeguarding the privacy of our website visitors.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website
visitors; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 In this policy, “we”, “us” and “our” refer to the Min-On Concert Association. For more information about us, see
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).
3. How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
3.2 We may process data about your use of our website (“usage data“). The usage data may include your IP address,
geographical location, browser type and version[/retweet], operating system, referral source, length of visit, page
views and website navigation paths, as well as information about the timing, frequency and pattern of your service
use. The source of the usage data is our analytics tracking system. This usage data may be processed for the
purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate
interests, namely monitoring and improving our website and services.
3.3 We may process your information included in your personal profile on our website (“profile data“). The profile
data may include your name, address, telephone number, email address, profile pictures, gender, date of birth,
relationship status, interests and hobbies, educational details and employment details. The profile data may be
processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this
processing is our legitimate interests, namely the proper administration of our website and business.
3.4 We may process information that you post for publication on our website or through our services (“publication
data“). The publication data may be processed for the purposes of enabling such publication and administering our
website and services. The legal basis for this processing is consent.
3.5 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry
data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or
services to you. The legal basis for this processing is consent.
3.6 We may process information relating to our customer relationships, including customer contact information
(“customer relationship data“). The customer relationship data may include your name, your contact details, and
information contained in communications between us and you. The source of the customer relationship data is you. The
customer relationship data may be processed for the purposes of managing our relationships with customers,
communicating with customers, keeping records of those communications and promoting our products and services to
customers. The legal basis for this processing is our legitimate interests, namely the proper management of our
3.7 We may process information relating to transactions, including purchases of goods and services, that you enter
into with us and/or through our website (“transaction data“). The transaction data may include your contact details,
and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods
and services and keeping proper records of those transactions. The legal basis for this processing is the
performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and
our legitimate interests, namely the proper administration of our website and business.
3.8 We may process information that you provide to us for the purpose of subscribing to our email notifications
and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the
relevant notifications and/or newsletters. The legal basis for this processing is consent.
3.9 We may process information contained in or relating to any communication that you send to us (“correspondence
data“). The correspondence data may include the communication content and metadata associated with the
communication. Our website will generate the metadata associated with communications made using the website contact
forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The
legal basis for this processing is our legitimate interests, namely the proper administration of our website and
business and communications with users.
3.10 We may process any of your personal data identified in this policy where necessary for the establishment,
exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal
rights, your legal rights and the legal rights of others.
3.11 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining
or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this
processing is our legitimate interests, namely the proper protection of our business against risks.
3.12 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we
may also process any of your personal data where such processing is necessary for compliance with a legal obligation
to which we are subject, or in order to protect your vital interests or the vital interests of another natural
3.13 Please do not supply any other person's personal data to us, unless we prompt you to do so.
4. Providing your personal data to others
4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our
ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the
legal bases, set out in this policy.
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary
for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or
the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or
4.3 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal
data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order
to protect your vital interests or the vital interests of another natural person. We may also disclose your personal
data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure.
4.4 We do not store credit card details nor do we share financial details with any third parties.
5. International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred
to countries outside the European Economic Area (EEA).
5.2 The hosting facilities for our website are situated in Japan. The European Commission has made an “adequacy
decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries
will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved
by the European Commission, a copy of which you can obtain from
5.3 You acknowledge that personal data that you submit for publication through our website or services may be
available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we
comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that
purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) personal data category or categories will be retained for a minimum period of 6 months following 25th May 2018,
and for a maximum period of 12 months following 25th May 2018
6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is
necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital
interests or the vital interests of another natural person.
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We may notify you of significant changes to this policy by email.
8. Your rights
8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are
complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant
laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to
the personal data, together with certain additional information. That additional information includes details of the
purposes of the processing, the categories of personal data concerned and the recipients of the personal data.
Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.
The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes
of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those
circumstances include: the personal data are no longer necessary in relation to the purposes for which they were
collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing
under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the
personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general
exclusions include where processing is necessary: for exercising the right of freedom of expression and information;
for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances
are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need
the personal data for the purposes of our processing, but you require personal data for the establishment, exercise
or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where
processing has been restricted on this basis, we may continue to store your personal data. However, we will only
otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the
protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular
situation, but only to the extent that the legal basis for the processing is that the processing is necessary for:
the performance of a task carried out in the public interest or in the exercise of any official authority vested in
us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we
will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the
processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise
or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including
profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data
for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical research
purposes or statistical purposes on grounds relating to your particular situation, unless the processing is
necessary for the performance of a task carried out for reasons of public interest.
8.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take
steps at your request prior to entering into a contract,
and such processing is carried out by automated means,
you have the right to receive your personal data from us in a structured, commonly used and machine-readable format.
However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.11 If you consider that our processing of your personal information infringes data protection laws, you have a
legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the
EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the
right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the
8.13 You may exercise any of your rights in relation to your personal data by written notice to us.
9. About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a
web browser and is stored by the browser. The identifier is then sent back to the server each time the browser
requests a page from the server.
9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web
browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a
session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that
we store about you may be linked to the information stored in and obtained from cookies.
10. Cookies used by our service providers
10.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website
use by means of cookies. The information gathered relating to our website is used to create reports about the use of
are: [identify cookies].]
11. Managing cookies
11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from
browser to browser, and from version to version. You can however obtain up-to-date information about blocking and
deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(e) https://support.apple.com/ja-jp/guide/safari/sfri11471/mac (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
11.2 Blocking all cookies will have a negative impact upon the usability of many websites.
11.3 If you block cookies, you will not be able to use all the features on our website.
12. Our details
12.1 This website is owned and operated by the Min-On Concert Association
12.2 We are registered in Japan under registration number 6011105000291, and our registered office is at Min-On Culture
Center, 8, Shinanomachi, Shinjuku-ku, Tokyo 160-8588
12.3 You can contact us by:
(a) by post, to Min-On Culture Center, 8, Shinanomachi, Shinjuku-ku, Tokyo 160-8588
(b) sending email to email@example.com
13. Data protection officer
13.1 Our data protection officer's contact details are Mr. Kiyoshi Nakajima, Director, Department of IT Strategy
Planning Division of Business Development Min-On Concert Association