TBS TELEVISION
Global Privacy Policy
The Japan Edit (UK Event)

TOKYO BROADCASTING SYSTEM TELEVISION, INC. (“TBS,” “we” or “our”) processes the personal information of users and counterparties (collectively, “Users”) of our services and products, specifically event titled ‘The Japan Edit by Tokyo Broadcasting System’ in the UK (collectively, our “Services”), and Users are also referred to as “Data Subjects” (unless specified otherwise), as follows.

1. - Who does this Global Privacy Policy apply to?

   This Global Privacy Policy applies to Users who are based outside of Japan.

2. - Which rules shall apply in the case of conflicting provisions?

   In the event of any conflicts between the provisions of this Global Privacy Policy and any service-specific privacy policy, the provisions of the service-specific privacy policy shall prevail.

3. - What personal information do we collect?

   We process the following personal information of Data Subjects:

   • Your name, e-mail address, mailing address, country of residence, gender, your affiliated organization’s name and its industry, your department, password, and your purchase history of and any other information we have obtained regarding our Services.
   • Online identifiers and device information (cookies, IP addresses, location information, browsing history, authentication information, other online identifiers, and other information obtained from your devices).
   • Other personal information required to fulfill the purposes of use specified in “4. How do we use personal information?” below.

4. - How do we use personal information?

   We process personal information for the following and other similar purposes permitted by applicable laws and regulations:

   • To provide our Services to Users;
   • To register Users for our Services and to verify Users’ identities;
   • To promote and advertise our Services;
   • To ensure the security and integrity of our Services, to debug, and to repair errors;
   • To respond to customer inquiries;
   • To address any breaches of TBS’s terms and conditions, policies, etc in relation to our Services; and
   • For any other purposes permitted under applicable laws and regulations.

5. - Legal bases for processing

   We process personal information in accordance with the legal bases under the applicable data protection regulations (such as those regarding Data Subjects’ consent, performance of contractual obligations, legitimate interests, and compliance with laws and regulations).
   The provision of personal information may be mandatory for various reasons, such as being a statutory or contractual requirement or being a necessary condition for entering into a contract. The provision of personal information, as outlined in “3. What personal information do we collect?” above, is a contractual requirement, and we may not be able to provide you with our Services if you do not provide such personal information.

6. - How long do we retain your personal information?

   In order to decide the appropriate retention period for personal information, we consider the following: the volume, nature and confidentiality of the personal information; the potential risk of damage caused by unjust use or disclosure of the personal information; the purposes for which we process the personal information, and whether TBS can fulfill those purposes by other means; and applicable legal requirements. If any Data Subject’s personal information collected by us is no longer necessary, we will delete or anonymize the personal information or, if such measures are impracticable (for example, if the personal information has been stored in back-up archives), we will safely retain the Data Subject’s personal information until its deletion becomes practicable and ensure that any new processing with respect to the Data Subject’s personal information will not be conducted.

7. - How do we collect personal information?

   We obtain Data Subjects’ personal information directly from the Data Subjects (including cases where personal information is automatically obtained). However, we may obtain Data Subjects’ personal information indirectly from third parties in the following cases:

   • When obtaining personal information from other TBS group companies and third parties (including processors);
   • When our customer is an organization, and we collect your personal information from such affiliated organizations;
   • When obtaining personal information from website traffic analysis service providers, such as Google LLC; and
   • Any other cases where personal information is lawfully obtained from third parties.

8. - With whom do we share personal information?

   We may share personal information, as outlined in “3. What personal information do we collect?” above, with third parties in the following cases:

   • Sharing of personal information with TBS group companies to fulfill the purposes stated in “4. How do we use personal information?” above;
   • Sharing of personal information with processors (meaning service providers that provide services necessary for the business activities of TBS, including distributors of products and services, IT companies that support our websites, online services and other business systems, payment service providers that process Users’ payments for our Services, advertising service providers, website traffic analysis service providers such as Google LLC, attorneys, accountants, financial advisors, and the like) to fulfill the purposes stated in “4. How do we use personal information?” above;
   • Sharing of personal information with third parties (controllers) as necessary for operating our Services;
   • Sharing of personal information associated with the corporate sale, merger, acquisition, or other transfer of all or part of our assets;
   • Sharing of personal information that is required by applicable laws or orders of governmental agencies and the like;
   • Sharing of personal information with third parties as (i) necessary for the protection of the life, body or property of TBS, Data Subjects, or third parties and (ii) permitted by applicable data protection regulations; and
   • Sharing of personal information that is otherwise permitted under applicable data protection regulations.

9. - How do we handle cross-border transfers of personal information?

   We may transfer personal information to foreign countries and jurisdictions, including the following, in order to fulfill the purposes stated in “4. How do we use personal information?” above:

   • United States
   • Japan

   Upon transferring personal information to any of these countries or regions, TBS takes appropriate protection measures required by local data protection regulations.

10. - How do we implement safety management measures?

    We will take necessary and appropriate measures, such as countermeasures against unauthorized access and computer viruses, to prevent the loss, destruction, falsification, leakage and the like of personal information.
    We will exercise necessary and appropriate supervision of our employees, contractors, etc. to protect personal information.

11. - Regarding the use of Google Analytics

    We may use Google Analytics for analytical and marketing purposes.
    With Google Analytics, customer information is collected using cookies, etc. For more information about how Google Analytics collects and uses information when a Data Subject uses our websites, please visit http://www.google.com/policies/privacy/partners.
    To opt out of Google Analytics, please visit https://tools.google.com/dlpage/gaoptout.

12. - Links to other websites

    Our website may contain links to other websites. If you click on any of these links, you should be aware that they may have their own privacy policy for which we do not accept any responsibility or liability. We encourage you to read the privacy notice of every website you visit.

13. - Data Subjects’ rights

    TBS respects the rights held by Data Subjects under the applicable data protection regulations of each country or region. For example, to the extent granted under the applicable data protection regulations of each country or region, Data Subjects may have rights such as the following: right to access; right to rectification; right to erasure; right to restriction of processing; right to objection to processing; right to withdraw consent (this may be granted if the Data Subject has given consent regarding certain types of processing activities; however, the Data Subject’s withdrawal of consent does not affect the lawfulness of processing conducted based on the Data Subject’s consent before such withdrawal); right to data portability; and right not to be subject to automated decision-making. The Act on the Protection of Personal Information of Japan (the “APPI”) grants the right to request the following in relation to Retained Personal Information (as defined in Article 16, Paragraph 4 of the APPI): notification of the purpose of use; disclosure; correction, addition or deletion of content; suspension of use or erasure; suspension of third-party provision; and disclosure of records of third-party provision (meaning records of third-party provision as prescribed in Article 37, Paragraph 2 of the APPI).
    Any Data Subject wishing to exercise the Data Subject’s rights granted under the data protection regulations of the country or region in question may contact us using the contact details provided in “13. Contact details” below.

14. - Contact details

    For questions and inquiries regarding this Global Privacy Policy, please contact us at:

    TBS Personal Information Management Office
    E-mail: privacy@gr.tbs.co.jp
    Address: 5-3-6 Akasaka, Minato-ku, Tokyo 107-8006, Japan

15. - How will you know if this Global Privacy Policy changes?

    If we intend to amend this Global Privacy Policy, we may amend all or part of, or make additions to, this Global Privacy Policy by publishing those amendments or additions on our websites, or by giving notice via any other method that we deem appropriate. In such cases, the post-amendment version of this Global Privacy Policy will be applied from either the date stated in such notice or the date upon which any of our Services are used or any of our websites are accessed for the first time following such notice, whichever is earlier.

Annex for residents of the United Kingdom (“UK”)

This Annex shall be applied to Users who are in the UK (or if UK data protection law applies).

Legal basis for processing
TBS processes the personal information of Data Subjects for the following purposes, based on the corresponding legal bases:

1. 1. Cross-border transfer of personal information

   When we transfer personal information to countries or regions outside the UK, such transfers will be:

   1. For transfers to Japan and other countries with adequacy decisions, based on such adequacy decisions (for adequacy decisions regarding Japan, click here;)
   2. For transfers to countries without adequacy decisions, we will implement appropriate safeguards by concluding standard contractual clauses approved by the European Commission (GDPR Article 46(2)(c) and 46(5)) and the UK Addendum to such clauses approved by the UK government; or
   3. In exceptional cases, transfers may be based on specific situations under UK GDPR Article 49.

   If you would like further information about how we legitimize the transfer of User’s personal data or if you would like to see a copy of the relevant documents, please contact us at the details above in Section 13 “Contact details.”

2. 2. Regarding cookies, etc.

   Cookies and other technologies are used on the websites of our Services. A cookie is a technology used to identify the browser used to access a website. (If you prefer to avoid the use of cookies, you may reject cookies for the website in question or change the settings in your internet browser so that cookies are rejected, deleted, or deactivated. Detailed information on the cookies used on our website can be viewed by clicking the gear icon on the lower-left side of the page, where you can also configure your cookie preferences.)

3. 3. Data Subjects’ rights

   Subject to applicable law, you have the following rights over your personal information:

   • The right to obtain confirmation as to whether or not we process your personal information, and, where that is the case, the right to access your personal information and certain information about how we process your personal information;
   • The right to have incomplete or inaccurate personal information corrected;
   • The right to require us to delete your personal information in some circumstances;
   • The right to restrict the use of your personal information;
   • The right to ask us to stop processing your personal information;
   • The right to request that we “port” the personal information you have provided to us in a structured, commonly used and machine-readable format to you or a third party (where this is possible); and
   • The right to withdraw any consent you have provided at any time. Withdrawal of consent does not affect the lawfulness of prior processing of personal information based on that consent.

   If you wish to exercise any of the rights set out above, please contact us at the details above in Section 13 “Contact details.”

   
   

   You also have the right to lodge complaints about our practices with respect to your personal information with the relevant supervisory authority.

   • If you are in the UK, you can contact the UK Information Commissioner’s Office here.

4. 4. Representatives

   The contact details of TBS’s representatives are as follows:

   • Representative in the UK:
     Name: DataRep
     Address: 107-111 Fleet Street, London, EC4A 2AB, United Kingdom
     Registered in Ireland (number 616588)
     E-mail: datarequest@datarep.com
     Website: https://www.datarep.com/data-request