Privacy Notice for Visitors and Customers
We are committed to protecting and respecting your privacy. This privacy notice (Notice) explains how Japan House London (we, our, us) collects, uses and shares your personal data, and your rights in relation to the personal data we hold.
Updating the Notice
We may modify this Notice at any time. We will endeavour to update you to any significant changes to this Notice. This Notice was last updated in [April 2020].
Data controller and contact details
Japan H.L. Limited (trading as Japan House London) is the data controller of your personal data and is registered with the Information Commissioner’s Office (ICO) (registration number ZA443318).
If you have any questions about this Notice, or if you would like to exercise any of your legal rights in respect of your personal data, please contact our Data Protection Representative using the following details:
- Email: email@example.com
- Post: FAO Data Protection Representative, Japan House London, 101-111 Kensington High St, Kensington, London W8 5SA.
How we collect your information
We may collect your personal information:
- from the information you provide to us when you fill in forms on our websites (for example, to sign-up to receive our newsletters);
- when you correspond with us by phone; email, or by other means;
- when you complete surveys to provide feedback, either online or at Japan House London;
- when you register to attend exhibitions and events;
- from third-party social media platforms when you engage with us through these platforms. For example, if you interact with us by using a hashtag on Twitter or Instagram, we and other users of the social media platform may be able to view your profile, depending on your privacy settings on that platform;
- when you register to use our Wi-Fi at Japan House London; on our CCTV system when you attend Japan House London (please see our CCTV Policy);
- from the information provided to us through cookies when you browse our website (please see our Cookies Policy).
The types of information we collect
We may collect and process the following personal information about you:
- your name, title, gender, age and date of birth;
- your address, email address and phone number;
- your social media usernames;
- information about your visit to Japan House London events you may have attended in the past;
- your interests, opinions and marketing preferences (where you have provided this information);
- technical information gained from your use of our websites, including your internet protocol (IP) address, cookie identifier, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- demographic information such as age group, gender and geographic location where this information is provided by you in our surveys or available from your social media posts on our social media sites;
- information about your website visit (such as which pages you visited, how you navigated to our website, and how long you spent browsing our website) and engagement with our direct marketing emails (such as whether the email was opened and if you opened hyperlinks within the email); and
- personal information provided by you in connection to competition entries, or in other correspondence with us.
Special category data. Our visitor surveys provide you with an option to declare your ethnicity. We use this information to better understand the diversity of visitors to Japan House London. We will only process this information with your explicit consent.
How we use your information, our legal basis for using your information and who we share your information with
Where we have a contractual relationship with you
We will process your personal data because it is necessary for the performance of a contract with you or to take steps at your request prior to entering into a contract. In this respect, we use your personal data for the following:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the products and services that you request from us;
- to interact with you before you enter into a contract with us, such as when you express your interest in our products or services (for example, to send you information about our events and exhibitions or answer enquiries about them). In this respect we will provide your data to our subcontractors as necessary whom we engage to assist us in conducting our operations, such as our IT providers, caterers, event organisers, payment providers and delivery companies.
We also process your personal data because it is necessary for our or a third party's legitimate interests. Our legitimate interests include operating Japan House London in accordance with our objective to create an authentic and immersive visitor and learning experience for visitors. In this respect, we may use your personal data for the following:
- to enable you to attend events at Japan House (for example, for administering access);
- to enable you to participate in our competitions and other promotions;
- to advertise and market upcoming events (unless it is required or appropriate to gain your consent – please see our section below on Marketing and advertising);
- to produce films or take photographs of events. Where possible we will seek your consent beforehand; however, in some instances this may not be possible (for example if you appear in a background shot). We will endeavour to alert individuals to the fact that filming/photography may be taking place where it is practicable to do so;
- capturing images on our CCTV system at Japan House London for the purposes of security and detecting criminal activities (please see our CCTV policy here); and
- to analyse and improve the services we provide, including processing feedback, conducting market research and to improve our website.
In this respect, we will provide your data to third parties who assist us in conducting our operations such as our caterers, event organisers, payment providers, IT providers, security providers and delivery companies. In addition, for the purposes outlined above, we will also share your data with organisations we use for our marketing operations, visitor surveys and analysis, and partners who are involved in our competitions (for example, sponsors who require your information to administer prizes).
We process your Personal Data for our compliance with our legal obligations including for tax and reporting requirements, and to report crimes and serious incidents. In this respect and if required, we will share your data with HMRC, the Charity Commission, the police and other competent authorities.
We also process your Personal Data where we have your specific consent to do so (for example, where we have sought and obtained your consent to send you direct marketing by email or to set cookies via our website for advertising purposes). We will only process special category data, such as data that you have provided in our visitor surveys on your ethnicity, with your explicit consent. If you have given your consent and you wish to withdraw it, please contact us using the contact details set out above or click the “unsubscribe” link in the emails we send.
Please note that where our processing of your personal data relies on your consent and where you then withdraw that consent, we may not be able to provide all or some aspects of our services to you and/or it may affect the provision of our services.
International transfers of data outside of the United Kingdom
We may occasionally be required to transfer personal data to Japan, for example, if we report to the Ministry of Foreign Affairs on Japan House London’s operations or if we use Japanese organisations to provide our events and services.
Such transfers of personal data are based on the adequacy decision made by the European Commission in respect of Japan’s data protection safeguards. In the event that this basis is no longer available as a result of the United Kingdom leaving the European Union then Japan House London will enter into data sharing agreements with the respective Japanese organisation that will incorporate the approved standard contractual clauses to safeguard your personal data.
How long your information is kept
We will retain your personal data for as long as is required for legal purposes and our legitimate business purposes after the termination of our relationship with you. In particular:
- in relation to personal data relating to any products or services we have provided, we will retain that data for a period of seven years after that transaction has concluded in case any legal claims arise out of the provision of those products or services;
- we will retain your details on our marketing database until you inform us that you no longer wish to receive our marketing communications. However, where you do unsubscribe from our marketing communications we will keep your details on a suppression list to ensure that we do not send you information you have asked not to receive.
Under the GDPR you have the following rights in relation to our processing of your personal data:
- to obtain access to, and copies of, the personal data that we hold about you;
- to require us to correct the personal data we hold about you if it is incorrect;
- to require us to erase your personal data in certain circumstances;
- to require us to restrict our data processing activities in certain circumstances (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal);
- to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for transmitting that personal data to another data controller;
- to object, on grounds relating to your situation, to any of our processing activities where you feel this has a disproportionate impact on your rights;
- to complain about the processing of your data to the relevant supervisory authority (for example, in the UK this is the Information Commissioner’s Office).
Please note that the above rights are not absolute, and we may be entitled to refuse your requests where exceptions apply.