1.4 You of course may use some of the Website without providing Information. However, if you choose not to provide certain Information, then you may only be able to enjoy limited functionality of the Website.
2 DATA CONTROLLER
Sanshosha UK Limited is the data controller of your Information for the purposes of the Act.
4 THE INFORMATION WE COLLECT
4.1 The type of Information we may collect includes:
(a) your contact information (such as your email address, telephone number and mobile telephone number);
(b) information relating to your use of our Website.]
4.2 We may also collect certain Information about your mobile device, computer hardware and software, which may include the following:
(a) IP address of device(s) used;
(b) browser type;
(c) operating system and device type;
(d) approximate location (e.g. London or Tokyo);
(e) access times and dates; and
(f) referring website addresses.
5 HOW DO WE COLLECT INFORMATION?
5.1 When you visit and use the Website or use our services you may provide us with, or we may collect, your Information in a number of ways:
Information you voluntarily provide to us
5.2 We collect and maintain Information that you voluntarily submit to us during your use of the Website or services. For example:
(a) you may provide us with Information in the course of email exchanges, customer support, interactions and surveys.
Information we collect through your use of the Website
6 HOW WE USE YOUR INFORMATION
6.1 We will use your Information in the ways described below and as described at the time that the Information is collected.
6.2 In general, we use your Information as necessary or appropriate for our business purposes, including:
(a) to ensure that the content on the Website is presented in the most relevant and effective manner for you and your device;
7.1 Where you have provided us with the appropriate consents, or where the Act entitles us to do so, we may send you marketing materials about other products or services offered by us, and/or products or services offered by our group companies. In addition, where you have provided us with the appropriate consents, we may also pass your Information to one or more of our group companies or other selected third parties for marketing purposes.
7.2 However, be assured that we understand the irritations of unsolicited communications and we are fully committed to ensuring that the rights and obligations set out in the Act and the Privacy and Electronic Communications Regulations 2003 are respected.
7.3 If you decide you do not want to receive those marketing communications, there will be an opportunity for you to unsubscribe on each marketing communication.
7.4 You should also note that the Telephone Preference Service (TPS) and the Mailing Preference Service (MPS) allow you to choose to opt out of unsolicited marketing contact by us and any third parties. However, if you are registered on either preference service, we will assume that any subsequent consent to receiving marketing communications given to us via the Website or other means of data capture indicates, for the time being, your consent to receive marketing communications in accordance with your consent.
8 HOW WE DISCLOSE YOUR INFORMATION TO THIRD PARTIES
8.1 We may share your Information with third parties as specifically approved by you or under the circumstances described below:
(a) if we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Information may be disclosed to prospective sellers or buyers and/or be among the assets transferred;
(b) if we or a member of our group is under a duty to disclose or share your Information to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements, or protect the rights, property, or safety of our users, or others;
9 THIRD PARTY LINKS AND SERVICES
9.2 Your browsing and interaction on any other website, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies. We do not monitor, control, or endorse the information collection or privacy practices of any third parties. We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.
10 WHERE WE STORE YOUR INFORMATION
10.1 The Information that we collect from you may be transferred to and stored at a destination outside the European Economic Area.
10.2 Your Information may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.
11 SECURITY OF YOUR INFORMATION
11.1 We follow appropriate security procedures in the storage and disclosure of your Information so as to prevent unauthorised access by third parties. We also require those parties to whom we transfer personal information to comply with the same.
11.2 However, unfortunately, the transmission of information via the Internet is not completely secure. Therefore, we cannot ensure the security of your Information transmitted by you to us via the Internet. Any such transmission is at your own risk, and you acknowledge and agree that we shall not be responsible for any unauthorised use, distribution, damage or destruction of your Information, except to the extent we are required to accept such responsibility by the Act. Once we have received your Information we will use security procedures and features to prevent unauthorised access to it.
12 OUR RETENTION OF YOUR PERSONAL INFORMATION
12.1 We will take all reasonable steps to retain your Information only for as long as reasonably necessary. If you no longer want us to store your Information you may request for it to be removed from our records. Please see below for details of how to request removal.
13 CAN YOU FIND OUT WHAT PERSONAL INFORMATION WE HOLD ON YOU?
13.1 Under the Act, you have the right to request a copy of the Information that we hold about you. [There may be an administration fee of £10 associated with this request and] it will require [two pieces of identification] to prove your identity.
14 CAN YOU CORRECT OR REMOVE INFORMATION ABOUT YOU HELD BY US?
14.1 You also have the right to have Information removed or for any inaccurate Information about you to be corrected.
14.2 If your Information requires amending, this can be done by either:
(a) [editing your Information on your Website profile]; or
14.3 If you require us to correct or update your information, we will endeavour to do so as swiftly as possible. However, until such Information has been correctly amended, communications may be sent using the original details until the changes have been processed.
14.4 If you would like your Information to be removed from our records, this can be done by
(a) [editing your Information on your Website profile;
(b) closing your account with us. If you choose to close your account with us, we will then cease processing your Information for any new purposes, but such closure shall not affect our ability to retain and process any Information required or the performance of obligations arising from law or for the completion of any services which are in process; or]
14.5 Please note:
(a) that the removal of Information may prevent us from supplying certain services to you;
(b) even if you delete Information, we may retain your Information in conformance with our data retention policy; and
HOW TO CONTACT US
If you have any questions about how we collect, use and share your data, you may contact us via:
(a) email at firstname.lastname@example.org;
(b) post at Sanshosha UK Limited, 9 Devonshire Square, London, EC2M 4YF; or
(c) telephone on +44 (0)20 3751 6145.
Last updated: 29 September 2015