For residents of member states of the European Economic Area (EEA), please see and read carefully here as well as this Privacy Policy to understand the contents of the special provisions for the GDPR (Regulation (EU) 2016/679, General Data Protection Regulation).

This website is operated by Toyooka City.

The terms “we”, “us” and “our” refer to Toyooka City Hall. The terms “you” and “your” refer to the customer visiting this website and/or using Services and/or Membership Services through this website. The term “Service(s)” refers to any kinds of services provided by the Toyooka City site through this website.

The Toyooka City site provides many different kinds of Services. When you make use of these Services, we collect, use, and store your information accordingly.

This Privacy Policy (the “Policy”) was created to help you understand why and how the Toyooka City site uses your information, and the rights and choices you have in this regard. The Toyooka City site wants to ensure that, no matter how you use our services, you are empowered to make real choices about your information.

1. What This Policy Covers

The Toyooka City site aims to provide you with a unique and personalized experience when you interact with our services.

This Privacy Policy applies where the Toyooka City site is acting as a data controller with respect to the personal information of it’s websites visitors, Service users, and Membership Service users; in other words, where the Toyooka City site determines the purposes and means of the processing of that personal information.
Please only use the Services or the Membership Service after you have carefully read and understood this Policy and other applicable terms. In using the website, Services or the Membership Service, you represent that you understand the contents of this Policy, and that you consent to our collection, use, transfer and retention of information about you as described herein.

You have a right to withdraw your consent to our collection, use, transfer and retention of your personal information any time, except for the case that such personal information is required (1) to fulfil our contractual obligations to you, (2) to comply with our legal obligations, and (3) to meet our legitimate interests.

If you have any questions or inquiries regarding this Policy, please contact us using the information provided in Section 9 (“Contact Us”).

2. The Information We Collect

2-1. Device information and information obtained using Cookie Technologies:

We use cookies on our websites. Insofar as those cookies are not strictly necessary for the provision of our websites, Services, and Membership Services, if you choose not to opt out of cookies there will be a presumption of your consent.

When you use the Membership Service or the Services, interact with any content or advertising related to such services, or validate any cookies, web beacons, unique identifiers and other related technologies (collectively, the “Cookie Technologies”) that we employ, we automatically collect certain information about you and the device you are using.

Such information may include:

• Device ID or other information that allows us to identify the device you are using;
• Operating system and internet connection related information;
• Geo-location information;
• Referring URL;
• IP Address;
• URLs viewed and time stamp of time viewed
• Server log information other than the above
• Information related to products and services displayed and searched

For a more detailed explanation on the information we collect through the Cookie Technologies, please refer to the Cookie Policy webpage.

2-2. Sensitive Information

Unless necessary for the purpose of providing you with the service in question or for another legally permissible reason, during your use of the Services, we do not intentionally collect or use information of yours that may be considered sensitive, such as information relating to your race, religion, social status, medical or criminal history, or whether you were a victim of a crime (together, “Sensitive Information”). In the event that you voluntarily give your Sensitive Information to us, we will treat such information as information in accordance with this Policy. Before we handle Sensitive Information about you, we require your consent to do so. Such consent may of course be withdrawn at any time. We do not handle Sensitive Information that we are not permitted by you to handle, or that you have not provided us with. A limited amount of our personnel will have access to your Sensitive Information, and after handling Sensitive Information in accordance with your request, we will erase the data as soon as possible.

3. Use and Retention of Your Information

We use the personal information that we collect to conduct research and development, to respond to customer inquiries, and to prevent and mitigate fraudulent or illegal activities.

Specifically, we may use the personal information we collect about you for the purposes listed below:

3-1. To undertake service improvement, research and development:

• To analyze the use of this website, Services and Membership Services
• To improve existing services and conduct research and development of our new services

3-2. To respond appropriately to customer inquiries:

• So that we may respond appropriately to customer inquiries, complaints, or requests in relation to our services and advertisements

3-3. To prevent and mitigate fraudulent or illegal activities:

• For the prevention, identification and investigation of scams, cyber-attacks, and other potentially illegal or fraudulent activities, or in relation to any other activities necessary to protect the legal rights of Toyooka City and/or the rights of third parties

We may retain information about you for as long as it is necessary to fulfill the purposes described above. In order to comply with our obligations under applicable law, collect fees owed, resolve disputes, enforce our legal rights, and to undertake any investigations necessitated by the foregoing, some of your information may be retained in our systems even after your account becomes closed.

4. Disclosure of Information about You

4-1. Disclosure to Other Third Parties

In addition to the disclosures described above, we may also disclose your personal information to certain trusted third party service providers, including those located outside of Japan, where necessary to carry out our business operations.

Please be assured that we will only disclose your personal information in compliance with applicable law, and with the appropriate management and supervision of the relevant third parties.

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 defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

On occasion, judicial or regulatory authorities may request access to or disclosure of information about you for law enforcement purposes. Such requests typically pertain to criminal investigations or other legal proceedings. Where they are necessary and legitimate, we will respond to such requests in accordance with our internal policies and applicable law.

Additionally, in cases where it is necessary to prevent and mitigate fraudulent or illegal activities (3-5), or to protect life, body, or property, we may disclose your personal information to a third party.

We will not use or disclose your information for purposes not set forth in this Policy without informing you and taking any necessary steps in advance as required under applicable law. Regardless of the purpose, we will not sell or rent information about you to a third party without your express consent.

5. Your Choices

As a principle, you will have a choice whether to provide information to us. However, where you have a choice and decide not to provide us with certain information, you may not be able to make use or take advantage of all of the features of the Membership Service or the Services. You may also be unable to receive certain information that may otherwise benefit you, such as notifications of special offers, campaigns or promotions.

6. Accessing Your Information

If you would like to access your information in written form, or through a means other than your Account management page, please contact us via the method described in Section 9 (“Contact Us”). Fees may apply. In some cases, depending on the nature of the information and how it is stored, it may not be possible for us to fulfill your request.

7. Security and International Transfers

We are committed to handing your personal information in accordance with high security standards and in compliance with applicable law. We do so in order to prevent unauthorized access or unauthorized disclosure of your information, to maintain the accuracy of such information and, when necessary, to ensure its proper destruction. When collecting or transferring your personal information, we employ data encryption technology, and restrict access only to those persons who require it to fulfil their job responsibilities. We conduct periodic reviews of our practices to ensure that our safeguards are properly implemented and remain state of the art.

In case of breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed, we have the mechanisms and policies in place in order to identify it and assess it promptly. Depending on the outcome of our assessment, we will make the requisite notifications to the supervisory authorities and communications to the affected data subjects, which might include you.

Because of the global nature of our business, the information that we collect from you may be transferred to countries whose data protection laws are not as comprehensive as those from where you are based. When we transfer personal information overseas, we put in place adequate measures. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted by the European Commission.

8. Changes to this Privacy Policy

From time to time, in order to comply with changes in applicable laws or for legitimate business purposes, we may make changes to this Policy. We will notify you about material changes to this Policy by placing a prominent notice on our website. Any changes we make will be displayed on this page. Please check back from time to time to ensure that you have read the most recent version of this Policy.

9. Contact Us

If you have any questions or concerns regarding the contents of this Policy or other aspects of how your personal information is handled, please contact us. We will respond without undue delay to you. Please note that when contacting us, we may ask you for certain information so that we can verify your identity and respond to your request appropriately.

Questions, comments, and requests regarding this Privacy Policy should be sent through to:

Toyooka City Hall
2-4 Chuo-cho, Toyooka city, Hyogo Prefecture, JAPAN 668-8666

Special Provisions for European residents

The special provisions are intending to supplement the main body of the Policy so please be aware of the contents before you read and understand the below.

Legal Basis for Use and Retention Period of Your Information

In relation to Sections 3 (“Use and Retention of Your Information”) and 4 (“Disclosure of Information about You”), we always have the legitimate reason, legal basis, for each processing activity and in most cases, the basis on which we rely will be one of the followings (the “Basis”):
(1)to fulfil our contractual obligations to you, for example to provide the Membership Service and the Services, which includes services for you and a Merchant to arrange a commercial transaction;
(2)to comply with our legal obligations, for example obtaining proof of your identity to enable us to meet our anti-money laundering obligations; and
(3)to meet our legitimate interests, for example to understand how you use the Membership Services and the Services and to improve them and to provide tailored marketing messages to you via certain channels. Our legitimate interests to process your personal information consist of our missions and desires to provide you with a unique and personalized experience.

Additionally, we may ask you to give us your consent to collect and use certain types of personal information, for example, when we would like to send you e-mail marketing messages and process Sensitive Information. If we ask for your consent to process your personal information, we will ensure that you may withdraw your consent at any time.

We will keep your personal information necessary for the Basis for a period of 10 years after your reservation has been completed. Notwithstanding the above, even within such 10 years, once such personal information become unnecessary for the Basis, we will promptly erase such personal information. Other information, such as Device information and information obtained using Cookie Technologies, will used and retained at maximum for 2 years after the collection. We will only retain your personal information after this time if we are required to do so to comply with the law, or if there are outstanding claims or complaints that will reasonably require your personal information to be retained.

Recipients of Your Information

We may share your personal information, in accordance with the Sections 3 (“Use and Retention of Your Information”) and 4 (“Disclosure of Information about You”), with third parties under the following circumstances:
(1)Merchants, service providers and business partners;
(2)Law enforcement agencies, courts, regulators and government authorities.

Because we operate as part of a global business, the recipients referred to above may be located outside the jurisdiction in which you are located (or in which we provide the services). See the Section 4 (“Disclosure of Information about You”) above for more information.

Your Choices and Rights

In relation to Sections 5 (“Your Choices”) and 6 (“Accessing Your Information”), you may be granted the additional rights under the GDPR, including the followings:
(1)The right to correct and/or erase your personal information;
(2)The right to restrict our use of your personal information;
(3)The right to object to our use of your personal information; and
(4)The right to receive your personal information in a usable electronic format and transmit it to a third party (right to data portability).

If you would like to discuss or exercise such rights, please contact us via the method described in Section 9 (“Contact Us”). However, please note that your rights of privacy or personal data will not be absolute rights so we may not be responsible for accepting your requests when the law permits us not to do so.

Records of Processing Activities

We handle records of all processing of personal data in accordance with the obligations established by the GDPR (Article 30), both where we might act as a controller or as a processor. In these records, we reflect on all the information necessary in order to comply with the GDPR and cooperate with the supervisory authorities as required (Article 31).