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Privacy Notice
The official website (hereinafter called the "RMHC website") sets forth the privacy notice below ("Notice"), based on Japan’s Act on the Protection of Personal Information "Japanese Privacy Policy Law" and the EU General Data Protection Regulation ("GDPR") and describes how the Ronald McDonald House Charities Japan ("RMHC" or "we" or "us" or "our") [dmhcj@jp.mcd.com] as controller processes the Personal Data and other information of the users ("you" or "your") when using the RMHC website [https://www.dmhcj.or.jp/english/].
Article 1: Definition
"Personal Data" means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Article 2: Information control
RMHC has established a Personal Data control supervisor role which strictly controls all acquired Personal Data in accordance with internal regulations that are based on the Japanese Privacy Policy Law and related laws. The office director will be responsible for the Personal Data control supervisor role.
Article 3: Categories of Personal Data, processing purposes, legal basis and source
RMHC may obtain personal information while operating the RMHC website.
(1) Personal Data actively provided by you:
If you make a donation on the RMHC website, you will be asked to provide the following Personal Data about you: Name, postal address, email address, date of birth, phone number. RMHC processes such Personal Data for the purpose of providing our services to you. Providing such Personal Data is voluntary. However, without providing such Personal Data, you will not be able to make the donation. The legal basis for the processing of such Personal Data is the contract on the use of the RMHC website concluded with you (Art. 6 (1) lit. b GDPR).
(2) Other passively collected information:
In addition to the Personal Data that you actively provide, the RMHC website may automatically collect, process and store certain information on a pseudonymous basis from you:
•Device and usage information – that may include (i) information specific to the used device to access the RMHC website (including, but not limited to, model, operating system, IP address, language, carrier and similar information) and (ii) information about the use of features, functions, or notifications on the device, to recognize you and to analyze trends; and
•website analytics – such as how often a user uses the RMHC website, aggregated usage, performance data. We use RMHC website analytics to allow us to better understand the functionality and use of the RMHC website.
The legal basis for this purpose are our legitimate interests (Art. 6 (1) lit. f GDPR) which are the following: to monitor and maintain the performance of the RMHC website and to analyze trends, usage and activities in connection with RMHC website. More information on the balancing test is available upon request.
RMHC does not engage in automated decision-making in the context of its processing activities on the RMHC website.
Article 4: Provision of Personal Data to a third party
RMHC will not provide any obtained Personal Data to any third party except for the recipients described below.
RMHC may share Personal Data in order to process that data, after executing a strict Personal Data protection contract with business partners that will be subject to contractual obligations to implement appropriate technical and organizational security measures to safeguard the Personal Data and to process the Personal Data only as instructed.
Some of our colleagues administering the RMHC website and providing IT services may be employees of our group companies. When administering the RMHC website, our colleagues may have access to and/or may process your Personal Data. The respective transfer of your Personal Data is based on our legitimate interests. Our legitimate interests are the transmission of Personal Data within the group of companies for internal administrative and support purposes. The access is limited to colleagues with a need to know. More information on the balancing test is available upon request.
In addition, if there is a request for Personal Data from law enforcement agencies, governmental authorities, legal counsel and external consultants, RMHC agrees to disclose Personal Data to such bodies only in compliance with applicable data protection law. The legal basis for such processing is compliance with a legal obligation to which RMHC is subject to or legitimate interests, such as exercise or defense of legal claims. More information on the balancing test is available upon request.
Article 5: International transfers of Personal Data
The Personal Data that we collect or receive about you may be transferred to and processed by recipients which are located inside or outside the European Economic Area ("EEA") and which do not provide for an adequate level of data protection. The countries that are recognized to provide for an adequate level of data protection from an EU law perspective (Art. 45 GDPR) are Andorra, Argentina, Canada, Faeroe Islands, Guernsey, the State of Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland, the Eastern Republic of Uruguay and the United Kingdom. To the extent your Personal Data are transferred to countries that do not provide for an adequate level of data protection from an EU law perspective, we will base the respective transfer on appropriate safeguards, such as standard data protection clauses adopted by the European Commission (Art. 46 (2) GDPR) and additional safety measures, where this is required under applicable law. You can ask for a copy of such appropriate safeguards by contacting us as set out in Article 9: Contact information.
Article 6: Rights of the individual
Provision of Personal Data to RMHC is voluntary. As an individual you can choose to not provide such data, but such refusal may create problems in your stay at the house or the activities performed by the volunteers.
If you have declared your consent for any Personal Data processing activities, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.
Pursuant to applicable data protection law you may have the right to: request access to your Personal Data, request rectification of your Personal Data; request erasure of your Personal Data, request restriction of processing of your Personal Data; request data portability, and object to the processing of your Personal Data. Please note that these aforementioned rights might be limited under the applicable national data protection law. For further information on these rights please refer to the Exhibit Your Rights.
You also have the right to lodge a complaint with a data protection supervisory authority. To exercise your rights please contact us as stated in Article 9: Contact information.
Article 7: How long do we keep your Personal Data?
Your Personal Data will be retained as long as necessary to provide you with the services requested. When RMHC no longer needs to use your Personal Data to comply with contractual or statutory obligations, we will remove it from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it, unless we need to keep your information, including Personal Data, to comply with legal or regulatory obligations to which RMHC is subject, e.g. statutory retention periods which can result from tax law and usually contain retention periods from 7 years, or if we need it to preserve evidence within the statutes of limitation, which is usually 10 years but can be up to 20 years.
Article 8: Revision of this Notice
This Notice may be revised in order to protect Personal Data. The new privacy notice will take effect after the revision is made. A separate notice will not be made when revising the Notice.
Article 9: Contact information
If you have concerns or questions regarding this Notice, please contact us as follows:
[Adress: Shinjuku i-Land Tower 5-1 Nishi-Shinjuku 6 Chome Shinjuku-ku, Tokyo 163-1339 JAPAN
E-mail:dmhcj@jp.mcd.com
TEL: +81-3-6911-6068]. You can also contact us via our Contact Forms
Supplementary provision
This Notice will take effect from the date of registry of Ronald McDonald House Charities Japan inception.