Privacy & Cookies Policy Statement

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Privacy & Cookies Policy Statement

The purpose of 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 propose to 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 or telephone), for example to request our news 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 38455063 - 000 and registered office address at 1401 Chung Wai Commercial Building, 447-9 Lockhart Road, 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 you have expressly agreed that we can do so or where we have a legal basis to do so. The grounds on which we may collect and use personal data about you include the following:

  • where there exists a contract between Walk Japan and you to provide you with our services;
  • it satisfies our legitimate interests (which is 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.

The personal data we collect

We collect and/or request information from you through our website and other interactions. These include but are not limited to when you:

submit, make, manage or confirm a booking;

contact us (via the Website, by email or telephone), for example to request our brochure, news and updates;

provide us with information about an accident, illness or incident that occurred in connection with your tour;

participate in our promotions; or

participate in social media connected with us.

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.

The information we collect is determined by our actual operational needs and includes but is not limited to:

Name

Address

Telephone numbers

Email address

Nationality and passport details

Gender

Date of birth

Details of a travel group (number of persons, itinerary, dates)

Type of tour and dates

Medical conditions

Dietary requirements

Payment information

Other travel-related details.

Some of the information we require is mandatory. Without it, we will be unable to provide our products or services.

Sensitive personal data

In the course of providing services to you, we may collect sensitive personal data or 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 such sensitive personal data where you have given your explicit consent, or it is necessary to protect your vital interests or those of other people, like our tour participants or tour guides, or where you have deliberately made it public. If you do not allow us to collect or process sensitive personal data or any 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 your booking; (b) confirming your booking; (c) contacting you and responding to your enquiries; (d) arranging your tour, including making arrangements with our tour leaders, guides, hotels and other contractors and providers; (e) personalising your customer experience; (f) optimising the Website and keeping the Website safe and secure; and (g) for any other purposes that you would reasonably expect.

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 will never provide personal data regarding you to third parties for direct marketing purposes.

Minors

Our Website 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 for 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. 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 respectively 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

We may disclose personal data relating to you to third parties in certain circumstances including (but not limited to) the following:

  • any of our group or affiliated companies;
  • our third party service providers, such as our agents, vendors, contractors or those we engage to host and maintain the Website, our IT systems and to assist us with marketing campaigns;
  • 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; and/or
  • relevant government bodies (including immigration, customs and border control agencies), 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.

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 such steps as are reasonable 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 so 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.

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;
  • request access to personal data relating to you;
  • object to the processing of personal data relating to you;
  • ask for personal data relating to you to be rectified where there are inaccuracies;
  • ask for personal data relating to you to be erased;
  • ask for personal data relating to you to be transmitted;
  • ask for processing of personal data relating to you to be restricted;
  • lodge a complaint with our supervisory authority.

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 Information Commissioner’s Office at https://ico.org.uk/concerns/ or the relevant authority in your country or territory of work or residence.

Variations to this PCPS

We review and amend our PPCS from time to time. Any changes we make to this policy in the future will be posted on this page and, where appropriate, 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

The Website can use cookies. Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer's hard drive.

The table below lists the cookies we collect and what information they store.

COOKIE name

COOKIE Description

None (as of February 2019)

None (as of February 2019)

By using the Website after accepting the cookie notice that appears when you first visit the Website, or by browsing the Website, after having been presented with this notice, you agree to the placement of cookies on your computer in accordance with the terms of this PCPS.

Cookies allow us to do multiple things to enhance and improve your browsing experience on our Website. If you wish to turn off cookies, please adjust your browser settings.

You do not have to accept cookies, but without accepting them you may experience reduced functionality on the Website. If you wish to reject the cookies then please read the information that came with your browser software to see how you can turn off the automatic download feature. For more information about cookies, including how to set your internet browser to reject cookies, please go to www.allaboutcookies.org.

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.

Global Enquiries

Address: 1401 Chung Wai Commercial Building, 447-9 Lockhart Road, Hong Kong SAR.

Email: customerservice@walkjapan.com

EU Representative

Rickert Rechtsanwaltsgesellschaft mbH

Kaiserplatz 7-9, 53113 Bonn, Germany

Email: datenschutz@rickert.net

Last updated: April 2019

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