GDPR Privacy Policy

1 Personal Data that we collect from Customers

The Personal Data that we collect from Customers is listed below. We respect the privacy rights of individuals and comply with the GDPR and other laws and regulations relating to data protection and privacy.

1. (1) Name
2. (2) Affiliation
3. (3) Position
4. (4) Email address
5. (5) Telephone number
6. (6) Cookie identifier
7. (7) Browsing history of our website

2 Purpose and Manner of Use of Personal Data that We Collect

We process the Personal Data that we collect in a manner that ensures its appropriate security, based on the following purposes and legal basis on which we perform such processing. We may obtain your consent with respect to your Personal Data; provided that, except for the cases where the legal basis is stated as "consent" as below, the legal basis for processing will be "processing is necessary to pursue legitimate interests" or "processing is necessary to perform a contract" despite obtaining consent.
You have the right to withdraw your consent at any time in a manner separately specified by our Company at the time of obtaining consent. However, the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
For more information on the use and configuration of cookie identifiers, please visit [Cookies Policy].

1. (1) To respond to enquiries from Customers
   Categories of Personal Data: Section 1 (1), (2), (3), (4) and (5)
   Legal Basis: processing is necessary to pursue legitimate interests (responding appropriately to enquiries to provide more suitable products, services, etc.)
2. (2) To provide information on our products and services
   Categories of Personal Data: Section 1 (1), (2), (3), (4), (5), (6) and (7)
   Legal Basis:
   
   1. a.direct marketing by e-mail or other means where consent is deemed necessary: consent
   2. b.if the above does not apply: processing is necessary to pursue legitimate interests (to inform Customers about our products, services, and market strategies)
3. (3) To provide our products and services
   Categories of Personal Data: Section 1 (1), (2), (3), (4) and (5)
   Legal Basis: processing is necessary to perform the contract

3 Transfer of Personal Data outside the EEA

When transferring Personal Data outside the European Economic Area (EEA), unless otherwise notified to the Customer separately, we will ensure adequate level of data protection by relying on an adequacy decision in the countries where it is recognized, or that the recipient enters into standard data protection clauses with us that have been approved by the European Commission. If you would like to obtain a copy of the documents relating to these safeguards, please contact us by using the contact details set forth in Section 8 of this Privacy Policy.

4 Sources of Personal Data

We collect Customers’ Personal Data directly from the Customers or indirectly through third parties, including:

1. (1) 21st floor, Shinjuku Monolith, 2-3-1 Nishi-Shinjuku, Shinjuku-ku, Tokyo 163-0919
   Website: https://cloudcircus.jp/
2. (2) Companies providing data processing and hosting services

5 Sharing of Personal Data

We may share your Personal Data with third parties operating the following categories of businesses for purposes set out in this Privacy Policy, in accordance with the GDPR. In addition, such sharing also includes the transfer of your Personal Data outside of the EU and EEA to Japan.

1. (1) Our group companies [Offices]
2. (2) Cloud services for managing your information

6 Retention Period for Personal Data

We will retain your Personal Data that we collect only for as long as it is necessary to achieve the purposes of use set out above. The specific period of retention will be determined by taking into account the purpose for which the Personal Data is to be used, the nature of the Personal Data and the legal or business need to retain the Personal Data.

7 Legal Rights of Customers

You have the following rights in relation to the Personal Data that we collect and process. If you wish to exercise any of the following rights, please contact us by using the contact details set forth in Section 8 of this Privacy Policy. You may also object to our processing of your Personal Data to the data protection supervisory authority of the Member State where you reside, work or where the GDPR violation occurred.

1. (1) Obtaining Information on Data Processing
   You have the right to obtain from us all necessary information regarding our data processing activities relevant to you.
2. (2) Access to Personal Data
   You have the right to receive confirmation from us as to whether or not Personal Data relating to you has been processed, and if so, you have the right to access such Personal Data and certain related information.
3. (3) Correction or Deletion of Personal Data
   You have the right to have inaccurate Personal Data relating to you corrected without undue delay or to have incomplete Personal Data made complete. You also have the right to have Personal Data relating to you erased without undue delay if certain requirements are met.
4. (4) Restrictions on Processing of Personal Data
   You have the right to have the processing of your Personal Data restricted if certain requirements are met.
5. (5) Objections to Processing of Personal Data
   You have the right to object to the processing of Personal Data relating to you if certain requirements are met.
6. (6) Data Portability of Personal Data
   You have the right to receive Personal Data relating to you in a structured, commonly used and machine-readable format, and to transfer such data to another controller without hindrance from us, provided that certain requirements are met.
7. (7) Not to be Subject to Automated Decision-Making
   You have the right not to be the subject to decisions based solely on automated data processing (including profiling) that have legal effects or similarly significant effects on you, if certain requirements are met.

8 Contact Detail

If you have any questions about this Privacy Policy, or if wish to inquire about or make a request in relation to your rights as set out in Section 7 of this Privacy Policy, please contact us at the following address:

1. (1) SUNCALL CORPORATION
   14 Umezunishiura-cho, Ukyo-ku, Kyoto 615-8555, Japan
   Email address: kenichi_maezumi@suncall.co.jp
2. (2) LCA Studio Legale
   Via della Moscova 18, 20121 Milano, Italy
   Tel: +39 027788751
   Email address: milano@lcalex.it

9 Updates to this Privacy Policy

This Privacy Policy may be updated from time to time. Any substantive or material changes will be communicated to you via our website and, if necessary, via an email notification to you.