Privacy & Cookies Policy Statement
The purpose of the Walk Japan Limited (“Walk Japan”, “we”, “us” or “our”) Privacy & Cookies Policy Statement (“PCPS”) is: (a) to ascertain our policies and practices in relation to personal data; (b) to inform you of the types of personal data regarding you that we collect and process; (c) to inform you of the main purposes and legal bases for which personal data held by us is used; and (d) to advise you of your rights in connection with the processing of personal data. The PCPS should be read in conjunction with our Personal Information Collection Statement (“PICS”).
Please read the following carefully (together with our Booking Conditions) to understand our practices regarding personal data, including how we collect, use and otherwise process personal data relating to you or that you provide to us:
> when you visit or use our website at https://walkjapan.com/ (the “Website”); and/or
> when you contact us (for example via the Website, by email, by telephone or via social media), for example to make a booking, to request our brochure, newsletter and updates or to submit a query or comment.
For the purposes of laws regarding data protection in relation to individuals within the European Economic Area (“EEA”) (including, for the avoidance of doubt, the United Kingdom) (“EEA Data Subject”) the data controller is Walk Japan, a company registered in Hong Kong with registered number 1170198 and registered office address at Unit 59, Level 24, Lee Garden One, 33 Hysan Avenue, Causeway Bay, Hong Kong SAR.
In this PCPS, the terms “personal data”, “processing”, “data controller” and “data processor” shall have the meaning in applicable law and regulations and, where necessary, shall include any analogous term or expression.
Our policy
Walk Japan is committed to protecting the privacy, confidentiality and security of the personal data we hold, and to ensuring that our employees, agents, contractors and providers do the same. We are also committed to processing personal data in a lawful, fair and transparent manner
Our basis for collecting and processing personal data
We will collect, store, use and otherwise process personal data relating to you only if we have a legal basis to do so. The grounds on which we may collect and use personal data about you are:
- where there exists a contract between Walk Japan and you to provide you with our services;
- it satisfies our legitimate interests (which are not overridden by your data protection interests), such as to provide customer support or personalised features and to protect the safety and security of our services;
- you give us express consent to do so for a specific purpose;
- we need to process personal data relating to you to comply with a legal obligation we have;
- to protect your vital interests;
- for reasons of substantial public interest;
- we need to establish, exercise or defend legal claims.
You have the right to withdraw your consent at any time. If you wish to exercise this right, please contact us.
How we obtain your personal data
We obtain your personal data from you through your interactions with us and/or when you use our Website.
The interactions in which you provide us with your personal data may be that you:
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submit, make, manage or confirm a booking; |
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contact us (via the Website, by email, telephone or social media) , for example, as a customer, when you submit a query or comment (such as an accident, illness or incident that occurred in connection with your tour) or, as a potential customer, when you request our brochure, newsletter or updates; or |
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participate in our promotions. |
We also collect personal data automatically when you use the Website and when you navigate through the Website. Data collected automatically may include usage details, geo-location data, IP addresses and other data collected through cookies and other tracking technologies. For more information on our use of these technologies, please refer to our “Cookies” section below.
Which personal data do we process about you?
The information we collect is determined by our actual operational needs and the information you provide to us and generally includes but is not limited to:
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Name |
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Address |
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Telephone numbers |
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Email address |
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Nationality |
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Passport details (excluding biometric data) |
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Gender |
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Date of birth |
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Details of a travel group (number of persons, itinerary, dates) |
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Type of tour and dates |
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Medical conditions |
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Dietary requirements |
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Payment information, such as your bank account number |
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IP address |
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Website usage details |
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Geo-location data |
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Further information that you may provide to us via the Website, by email, telephone or social media |
Some of the information we require is mandatory. Without it, we will be unable to provide our products or services (including providing tours, travel services and related products and services) and/or contact you. The information that is mandatory for a specific processing purpose is indicated as such in the respective forms on our Website.
Special categories of personal data
In the course of providing services to you, we may collect types of information that are considered “special categories of personal data” under applicable law or regulation. Such information may relate to your medical conditions or reveal your racial or ethnic origin, or religious beliefs (for example, if you ask us to provide you with special assistance during your tour, or if you specify a meal preference that indicates a medical condition or a particular religion). We only collect special categories of personal data (i) where you have given your explicit consent for one or more specified purposes, (ii)it is necessary to protect your vital interests or those of other people, like our tour participants or tour guides, and you are incapable of giving consent, (iii) if and when this is necessary for the establishment, exercise or defence of legal claims, or (iv) where you have deliberately made it public. If you do not consent to us processing your personal data that is considered a special category of personal data, this may mean we are unable to provide all or parts of the services you have requested from us.
How we use personal data
It is necessary for us to use personal data relating to you to provide our products and services to you. The activities for which it is necessary for us to use personal data relating to you include: (a) processing and confirming your booking; (b) contacting you and/or responding to your enquiries (with regards to your booking or in general); (c) arranging your tour, including making arrangements with our tour leaders, guides, hotels and other contractors and providers; (d) personalising your customer experience, which includes accommodating any medical conditions and dietary restrictions; (e) managing your customer account, issuing invoices and handling payments, (f) providing our newsletter and updates to you, (g) promoting our tours and enabling your participation in our promotions, (h) interacting with you via social media connected with us, (i) optimising the Website and keeping the Website safe and secure; and (j) if and when applicable: establishing, exercising or defending legal claims.
We do not use automated decision-making.
Marketing
We will only send you marketing material electronically if you explicitly consent. When we send you marketing material, we may monitor whether or not you open and/or click on the material that we send you.
If you have consented to receive marketing material from us, you have the right at any time to ask us not to process personal data relating to you for marketing purposes. If you wish to exercise this right, please contact us.
Third parties and direct marketing
We do not provide personal data regarding you to third parties for direct marketing purposes.
Minors
Our Website, products and services are not specifically directed to individuals under the age of 16 (“Minors”). We do not knowingly collect or process personal data relating to Minors without the express prior consent or authorisation of a person with parental responsibility. Such consent or authorisation shall be obtained either by us from a person with parental responsibility or by another person (for example a teacher who makes the booking) from a person with parental responsibility. If we become aware that a Minor has provided us with personal data without such consent or authorisation, we will take steps to delete such information from our databases. If you become aware that a Minor has provided us with personal data regarding them, please contact us.
Retention of personal data
We will take all practicable steps to ensure that we do not keep personal data relating to you for longer than is necessary which, generally, is until the time your tour is completed. Where you have explicitly consented to receive promotional information about our products and services, then we will retain personal data relating to you for a longer period but we will only retain personal data that is relevant to sending you promotional information. Accordingly, for example, we will not retain sensitive personal data relating to medical conditions beyond the completion of the tour. We take steps to destroy or to anonymize personal data when the information is no longer required for any purpose for which it may be used or disclosed by us and we are no longer required by law and/or for compliance reasons to retain the information.
External links
Although the Website only looks to include safe and relevant external links, users should always adopt a policy of caution before clicking any external web links mentioned throughout the Website.
The Website may, from time to time, contain links to and from the websites of media publications that contain travel reviews and of parties that we collaborate with. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or their actions. Please check these policies before you submit any personal data to these websites.
Social media platforms
Communication, engagement and actions taken through external social media platforms that Walk Japan engages with are subject to the terms and conditions as well as the privacy policies of those social media platforms.
This Website may use social sharing buttons which help share web content directly from our web pages to the social media platform in question. Where you use such social sharing buttons you do so at your own discretion. You should note that the social media platform may track and save your request to share a web page through your social media platform account. Please note these social media platforms have their own privacy policies, and we do not accept any responsibility or liability for these policies or their actions. Please check these policies before you submit any personal data to these social media platforms.
Disclosure of personal data
Your personal data will be processed on a need-to-know basis for the purposes described above. We may disclose personal data relating to you to the following third parties:
- any of our group or affiliated companies;
- our third party service providers that help us provide services to you, such as our agents, vendors, contractors, those we engage to host and maintain the Website and our IT systems and/or third party service providers we engage to assist us with marketing campaigns, including marketing platform Mailchimp;learn more about Mailchimp’s privacy practices here;
- medical professionals, insurers and clinics/hospitals or to anyone else in order to protect life, body, limb or property;
- analytics and search engine service providers that assist us in the improvement and optimization of this Website;
- relevant government bodies (including immigration, customs and border control agencies); and/or
- courts and tribunals as necessary or desirable or in order to comply with law, regulation or codes of practice or in order to enforce or apply our Booking Conditions and rights.
Before we disclose personal data to a third party, we take steps to ensure that the third party will protect personal data in accordance with applicable privacy laws and in a manner consistent with this policy. Third parties are required to restrict their use of this personal data to the purpose for which the data was provided.
Our operations are based in Hong Kong and Japan. We are not based in the EEA or in the United Kingdom. If you are a data subject based in the EEA or the United Kingdom and we collect personal data relating to you, you should be aware that personal data relating to you may be transferred between countries or jurisdictions outside of the EEA and the United Kingdom (for example, between Hong Kong and Japan). Personal data relating to you may also be processed by staff operating outside the EEA and the United Kingdom who work for us or for one of our service providers.
Countries and territories where personal data relating to you may be stored and/or processed, or where recipients of personal data relating to you may be located, may have data protection laws which differ to the data protection laws in your country or territory of residence. By submitting personal data about you, you accept that personal data relating to you may be transferred, stored or processed in this way. We will take all steps reasonably necessary to ensure that the recipients of your data will treat that data securely and in accordance with this policy.
Security
Unfortunately, the transmission of information and data via the internet is not completely secure. Although we will do our best to protect personal data relating to you, we cannot guarantee the security of such data transmitted to the Website; any transmission is at your own risk. Once we have received personal data relating to you, we use strict procedures and security features to try to prevent unauthorized access.
The security of personal data relating to you is a high priority. We take appropriate technical and organisational measures to securely store personal data relating to you so that it is protected from unauthorized use or access, misuse, loss, modification or unauthorized disclosure. This includes both physical and electronic security measures. Examples include the use of passwords, restricted transfer of and access to electronic files and information, and locked storage cabinets.
Business reorganization
We may, from time to time, reorganize our business, and this may involve the transfer of certain divisions or the whole business to other parties. Personal data relating to you will, where it is relevant to any division transferred, be transferred along with that division and the new owner or newly controlling party will, under the terms of this PCPS, be permitted to use personal data relating to you for the purposes for which it was supplied by you. We will inform you in advance if such reorganization is to take place.
Your rights
It is important that you know your rights and that generally you may:
- Ask us to confirm whether we are processing personal data relating to you and, if so, you may also ask us information about our processing and request access to personal data relating to you (the right to information);
- object to the processing of personal data relating to you on grounds relating to your particular situation (the right to object);
- ask for personal data relating to you to be rectified where there are inaccuracies (the right to rectification);
- ask for personal data relating to you to be erased (the right to be forgotten);
- ask to receive the personal data relating to you and transmit these to another controller (the right to data portability);
- ask for processing of personal data relating to you to be restricted (the right to restriction of processing);
- lodge a complaint with a supervisory authority (please find an overview of the EEA and European Free Trade Association authorities here).
To protect your privacy, we may take steps to verify your identity before taking any action in response to any request. Any access request may be subject to a fee to meet our costs in providing you with details of the personal data that we hold relating to you.
If you would like to exercise any of these rights or if you have any questions about our processing of personal data relating to you, please contact us – see “Contact us” section.
We will respect and provide you with all rights in relation to personal data relating to you that we hold, and to which you are entitled, under applicable law.
If you have a concern about the way we are collecting or using personal data relating to you, we request that you raise your concern with us in the first instance. Alternatively, you can contact the relevant authority in your country or territory of work or residence (please find an overview of the EEA and European Free Trade Association authorities here and please find the United Kingdom Information Commissioner’s Office at https://ico.org.uk/concerns/)
Variations to this PCPS
We review and amend our PCPS from time to time. Any changes we make to this policy in the future will be posted on this page and notified to you by e-mail. Please check back frequently to see any updates or changes to this policy. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the Website.
Cookies
This Website uses cookies. Cookies are small files containing letters and numbers that are placed on your device when visiting our website. Cookies, including cookie-like techniques, allow us and third parties using the cookies to recognize your device and collect information on your website visits, settings and preferences. The information stored or collected via cookies can include specific webpages you visited, your IP-address, the specific content stored in a cookie depending on the specifics of why the cookie is used, the previous website you visited, the device and equipment you use, and your settings.
Cookies we use
Functional cookies
These cookies are strictly necessary for using our website or providing you the functionalities of our website and enable you to move around the website and remember the choices you have made, including remembering your cookie settings.
Analytical cookies
Analytical cookies are used to record how visitors use our website and generate user statistics on a privacy-friendly basis that help us to improve the quality, effectiveness and user friendliness of our website
Tracking cookies
Tracking cookies are used to show you relevant advertisements tailored to you on our website and on websites of third parties
Most browsers are standard set to accept cookies automatically. You can adjust this and change your browser settings to reject all or some types of cookies, to accept or block each cookie individually, or that all cookies are removed as soon as you close your browser. Cookies that require your consent will only be placed on your device if you allowed this by pressing the accept button in the cookie information banner shown on your visit to our website.
Cookie table
The following information is included per type of cookie:
- The name of the cookie including the type of cookie (functional, analytical, tracking)
- The purpose for which the cookie is used
- The information that is collected
- The validity period of the cookie.
- Who places the cookie (we or a third party)
- Who can view the cookie information
See our Cookie table below for a full overview of the information we process per cookie.
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_ga, analytic cookie |
This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the site's analytics report. The cookies store information anonymously and assign a randomly generated number to identify unique visitors. |
calculate visitor numbers (by individual IP address, though IP address is not stored), session (date and time), campaign data and keep track of site usage for the site's analytics report. |
2 months |
third party: Google Analytics
Google privacy information: and http://www.google.com/intl/en/policies/privacy/ GDPR: https://www.google.com/about/company/user-consent-policy/ |
Google: the data of Google Analytics may be linked by Google to data collected via its other services, such as Search, YouTube, Maps and DoubleClick
Google privacy information: and http://www.google.com/intl/en/policies/privacy/ GDPR: https://www.google.com/about/company/user-consent-policy/ |
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_gid, analytic cookie |
This cookie is installed by Google Analytics. The cookie is used to store information about how visitors use a website and helps to create an associated analytics report. |
number of visitors, the source of those visitors, and the pages visited. Stored in an anonymous format. |
2 months |
third party: Google Analytics
Google privacy information: and http://www.google.com/intl/en/policies/privacy/ GDPR: https://www.google.com/about/company/user-consent-policy/ |
Google: the data of Google Analytics may be linked by Google to data collected via its other services, such as Search, YouTube, Maps and DoubleClick
Google privacy information: and http://www.google.com/intl/en/policies/privacy/ GDPR: https://www.google.com/about/company/user-consent-policy/ |
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_gat, analytic cookie |
This cookie is installed by Google Universal Analytics to throttle the request rate to limit the collection of data on high traffic sites. |
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2 months |
third party: Google Analytics
Google privacy information: and http://www.google.com/intl/en/policies/privacy/ GDPR: https://www.google.com/about/company/user-consent-policy/ |
Google: the data of Google Analytics may be linked by Google to data collected via its other services, such as Search, YouTube, Maps and DoubleClick
Google privacy information: and http://www.google.com/intl/en/policies/privacy/ GDPR: https://www.google.com/about/company/user-consent-policy/ |
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CONCRETE5, functional |
This cookie stores “Session”. It is used to save the state of all visiting users to keep track of form submission, login etc. It is a necessary session cookie. |
session (date and time)
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2 hours |
first party: Concrete5, Macareux, Admins |
https://marketplace.concretecms.com/marketplace/addons/gdpr/cookie-consent |
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CONCRETE5_LOGIN, functional |
Cookie flag if the user is logged into Concrete CMS or not. (ONLY for those accessing the Media area of the website) |
ip address
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2 weeks |
first party: Concrete5, Macareux, Admins |
https://marketplace.concretecms.com/marketplace/addons/gdpr/cookie-consent |
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ccmAuthUserHash, functional |
This cookie is to be used when the logged in user used the option “Stay signed in for 14 days” to keep her/his login state (ONLY for those accessing the Media area of the website)
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ip address
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2 weeks |
first party: Concrete5, Macareux, Admins |
https://marketplace.concretecms.com/marketplace/addons/gdpr/cookie-consent |
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cookieconsent_status, functional |
This cookie is added when the site visitor agrees to accept cookies & shows the user accepted cookie. |
ip address |
1 year |
first party: Concrete5, Macareux, Admins |
https://marketplace.concretecms.com/marketplace/addons/gdpr/cookie-consent |
| cookiefirst-consent, functional | This cookie saves your cookie preferences for this website. You can change these or withdraw your consent easily. |
Your cookie preferences set on the cookie banner for this website. |
1 year |
third party: CookieFirst |
https://cookiefirst.com/legal/cookie-declaration/ |
Contact us
If you have any comments, questions or concerns about the content of this PCPS, we encourage you to contact us by writing to us at our details below.
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Address of the data controller: Unit 59, Level 24, Lee Garden One, 33 Hysan Avenue, Causeway Bay, Hong Kong SAR. |
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Email: customerservice@walkjapan.com |
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Data Protection Officer |
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Llewelyn Thomas admin@walkjapan.com |
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EU Representative |
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Rickert Rechtsanwaltsgesellschaft mbH Kaiserplatz 7-9, 53113 Bonn, Germany |
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Email: datenschutz@rickert.net |
Last updated: November 2023
