1. PERSONAL DATA
In this Policy, personal information means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly.
We collect personal information directly from the user. We also collect personal information from a user’s device when they connect to the Website.
We do not knowingly process special care-required personal information or special categories of your personal information as defined in the GDPR nor personal information from children under the age of 16 without verifiable parental consent.
When using the Services, personal information such as your name, email address and phone number are required. The other personal information is not required by law or contract. However, if you do not provide such data, you may not be able to use the Services or some of the features of the Website.
2. PURPOSE AND LAWFUL BASIS
As a data controller under the GDPR or UK GDPR, we will process the personal information that we have acquired for our own purposes for the purposes set out below.
2-1 Lawful basis: When given consent by the data subject
|Purpose of Processing||Category of Personal Data|
|Collecting data on Website usage and improving the Website||Non-identifiable identifier about your usage of the Website|
|Facilitating your interactions with social media||Non-identifiable identifiers provided by social media|
2-2 Lawful basis: When necessary to perform or enter into a contract
|Purpose of Processing||Category of Personal Data|
|Management of user account||Name, email address, phone number and information on consent to the terms of service|
|Management, operation and provision of the Services||Name, email address, and phone number|
|Requesting payment and monitoring the payment status of the users||Name, credit card information and payment history|
|Preservation of evidence related to contracts and claims||Name, email address, phone number, information on consent to the terms of service, purchase history and payment history|
2-3 Lawful basis: When necessary for WOVN’s legitimate interests (conducting normal business operations of WOVN)
|Purpose of Processing||Category of Personal Data|
|Detecting and protecting against unauthorized use of the Website or the Services, and preventing the use of the Services by those who violate the WOVN.io Terms of Service, and those who attempt to use the Services for illegal purposes||Source IP address, browser type/version, operating system/version, pages and time accessed, preceding page view, event log record containing a summary of the operation, etc.|
|Improving the quality of the Website or the Services||Source IP address, browser type/version, operating system/version, pages and time accessed, preceding page views (what web page you came from) and other identifiers about your usage of the Website|
|Contacting users regarding the use of the Services and information about our services and products provided by us, regardless of the method, such as email, flyers or other direct mail (the same shall apply hereinafter)||Name, email address, phone number and status of use|
|Contacting users regarding information on seminars and events involving WOVN||Name, email address, phone number and status of use|
|Contacting our customers about surveys or with requests for cooperation, as well as reporting said results, to perform surveys that enhance and improve our Services and advertisements||Name, email address, phone number and status of use|
|Improving the Services, developing new services, marketing, conducting market research, and cultivating new business relationships||Source IP address, browser type/version, operating system/version, pages and time accessed, preceding page view, and other identifiers about your usage of the Website|
|Responding to your inquiries||Name, email address, phone number, and information provided to us relating to your inquiries|
|Notifying information about maintenance of or system issues with the Services||Name, email address|
Regarding the personal information acquired by users who enter into a contract with WOVN for the purpose of using the Services (users who enter into a contract with WOVN for the Services contract and localize their websites will hereinafter be referred to as “WOVN users”) as data controllers under the GDPR or UK GDPR, we will process said information on our Services as a trustee under the APPI and a data processor under the GDPR or UK GDPR.
4. USER DATA RETENTION PERIOD
We will retain your personal information during your membership and thereafter as long as reasonably necessary for the purpose of user account management and preservation of evidence related to contracts and claims, which is normally seven (7) years after the lapse of your membership.
Personal data related to sales and provision of the Services, as well as payments will be retained during your membership.
Personal data related to your inquiries will be retained for the period reasonably necessary for the purpose of processing said inquiries.
Personal data related to monitoring the usage of the Website or the Services, detecting and preventing fraudulent use, and improving the product quality will be retained for a maximum of 1,100 days after being collected.
After that time, we will delete your personal information so that we cannot identify you any longer by reference to any data we retain.
5. THIRD PARTY DATA PROCESSING
As shown in the table below, we entrust the processing of your personal information to the respective trustees as a data controller insofar as may be necessary for the purposes described in “2. PURPOSE AND LAWFUL BASIS”.
|Categories of Personal Data for which Processing is Entrusted||Categories of Trustees|
|Information we retain for the management of your account, provision of services, etc.||Cloud service providers such as: Amazon Web Service, Inc, Elasticsearch, Inc., Rapid7, Inc., Rollbar, Inc., HiCustomer|
|Your information necessary for facilitating payment||Payment service providers such as follows, PAY, Inc., Stripe Inc.|
|Your browsing history on the Website||Analytics service providers such as follows, Google LLC, Adobe, Inc., Datadog, Inc.|
|Information about your social networking accounts and web browser IDs|
* Social networking service provider plug-ins are embedded in the Website
|Social media providers such as follows, Meta Platforms, Inc., Twitter, Inc., Google LLC, LinkedIn Corporation|
|Information entered in the inquiry form on the Website||Cloud service providers such as follows, Adobe, Inc., Salesforc.com, Inc., Zendesk, Inc., Atlassian, Inc., nulab|
|Information necessary for sending surveys and collecting information||Cloud service providers such as follows, Momentive.ai|
|Information necessary for notifying about maintenance of or system issues with the Services||Cloud service providers such as follows, Atlassian, Mailchimp|
|User activity and page visit information to the Website collected by cookies and other similar technologies by third party advertising service providers we use|
|Advertising service providers such as Google, Meta Platforms, Yahoo,Sansan, Inc.,LinkedIn Corporation,Sendenkaigi Co., Ltd.,CRAID, INC.|
As a data processor of WOVN user data, we entrust the processing of the personal information of visitors to WOVN users’ sites to the trustees shown in the Infrastructure Providers and Sub-processors list.
6. DISCLOSURES TO THIRD PARTIES
We may disclose a users personal information to third parties to the extent permitted by law, with the prior consent of the user, or in the following cases:
- A) When personal information is disclosed to a public institution such as a government agency or court in accordance with a request from the law or a public institution;
- B) When the provision of personal information is necessary to protect the life, body or property of an individual and when it is difficult to obtain consent from the said person;
- C) When such provision is based on laws and regulations.
7. OVERSEAS TRANSFER OF PERSONAL DATA
We may transfer the collected data as a data controller for the purposes described in “2. PURPOSE AND LAWFUL BASIS” to countries/regions outside Japan, including the U.S.A., Australia, Chile, Taiwan, and Singapore, which are not recognized by the European Commission as providing an adequate level of data protection. Please note that the same level of data protection as within Japan may not be provided under the laws and regulations of such countries/regions. In such cases, we will take adequate measures to protect your personal information in compliance with our legal obligations.
If the GDPR or UK GDPR applies to the processing of your personal information and we transfer your personal information to outside of the European Economic Area (the “EEA”), we will implement standard data protection clauses under Article 46.2 of the GDPR or the UK GDPR to protect your personal information.
If you wish to obtain a copy of such clauses, please contact us in the manner stipulated in “12. CONSULTATION DESK FOR PERSONAL DATA PROCESSING”.
We may transfer the collected data as a data processor of WOVN users to the locations in the Infrastructure Providers and Sub-processors list
8. YOUR LEGAL RIGHTS
You may have certain rights regarding your personal information, such as the right to request access to your personal information, and the right to copy, correct and delete the same, under applicable data protection laws. These rights should be exercised in accordance with applicable data protection laws.
If you wish to exercise the above rights, please make a request to us via the inquiry page. We will promptly handle your request after verifying your identity. We will confirm that the request for disclosure is made by the person in question based on identification documents.
We will respond to the exercise of your rights without delay. In addition, if the relevant personal information does not exist, we will notify you. However, in cases where we are not obligated to disclose such personal information under applicable data protection laws and other laws, we may not disclose such personal information, and in such cases, we will notify you as such.
As to the rights of residents of the EEAor the United Kingdom, please see “9. RIGHTS OF RESIDENTS OF THE EEA AND THE UNITED KINGDOM” below.
9. RIGHTS OF RESIDENTS OF THE EEA AND THE UNITED KINGDOM
If you are a resident of the EEA or the United Kingdom, you have the right to request access to your personal information held by us, as well as the right to copy, correct and delete the same and the right to restrict the processing of certain types of personal information. In addition, you have the right to receive your personal information from us in a structured and machine-readable format (right to data portability).
When our processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. Such withdrawal will not affect the processing of past personal information for which you have already given your consent.
Also, when our processing of your personal information is based on our legitimate interests, you have the right to object to such processing including “profiling” (i.e. analyzing or predicting your behavior based on your information). When we process your personal information for direct marketing purposes, you have an absolute right to opt out of direct marketing or the profiling we carry out for direct marketing. If you wish to exercise any of the above rights, please contact the consultation desk listed in “12. CONSULTATION DESK FOR PERSONAL DATA PROCESSING.”
Aside from the above, if you feel that we are processing your personal information in violation of the applicable data protection laws, you have the right to lodge a complaint with the relevant data protection authority.
10. MANAGEMENT OF PERSONAL INFORMATION
We will control access to personal information, restrict the means of taking personal information out, prevent unauthorized external access, prevent leakage, loss, or damage of personal information and take other necessary and appropriate measures (hereinafter referred to as the “Safety Management Measures”) to safely manage personal information.
If we entrust the processing of personal information to a third party, we shall select a trustee that is deemed to process personal information appropriately, and shall properly stipulate the Safety Management Measures, confidentiality, and other matters related to the processing of personal information in a contract with the trustee, and shall conduct necessary and appropriate supervision.
We may update this Policy. For information on the latest updates, please check this page frequently. You can see the date on which the latest version of this Policy was posted. We will notify users of the Services in advance regarding the content that will be changed. After the date specified in the notice, the revised Policy will automatically take effect.
12. CONSULTATION DESK FOR PERSONAL DATA PROCESSING
If you have any requests for disclosure or correction, or any opinions, requests or inquiries regarding our processing of personal information, please contact the following consultation desk:
Wovn Technologies, Inc. – Privacy Manager
Address: D-LIFEPLACE Minami-Aoyama 9th Floor, 2-26-1 Minami-Aoyama, Minato-ku, Tokyo 107-0062 Japan.
13. DIFFERENCE BETWEEN LANGUAGES
If any conflict between the Japanese version and a version translated into other languages of this Policy arises, the Japanese version shall be the governing and prevailing version.
© Wovn Technologies, Inc.
Revised on: May 11, 2022
Published on: June 17, 2015