FOODTRIP Services
Privacy Policy

１．User Information to be collected and sources of such information

In this Policy, “User Information” means information relating to the identification of the User (as defined in the Terms of Use “FOODTRIP Services Terms of Use,” and people those who agree to this Policy and download a catalog), action history in communication services, and other information generated or accumulated in relation to the User or their terminals, including smartphones and PCs, which OTANI TRADING CO LTD. (hereinafter referred to as the “Company”) collects based on the Policy. The User Information to be collected is as follows, depending on the collection method. The types of User Information collected by Company during the 12 months prior to the final revision of the Policy are the same as below.

• （１）Information provided directly by the User
  – Name, email address, telephone number, information on the organization to which the User belongs, password, credit card information used for payment, bank account information, and other information related to the payment
• （２） Information provided by other service provider when the User permits the linkage with such other service in the use of these Services
  The following information is obtained from said external service provider based on the content agreed upon at the time of such permission.
  – The ID and password used by the User in said external service, and other information that the User has authorized to be disclosed to such external service provider through privacy settings of the external service
• （３） Information obtained by the Company when the User uses these Services
  – Information on terminals, logs, and action history as well as that related to the status of use of the Company sites, and information on cookies and anonymous IDs

２．Purpose of and legal basis for use

２.1 The User Information shall be used for the provision of the FOODTRIP services (hereinafter referred to as the “Services”) as set forth in 2.2.

２.2 The specific purposes of use of the User Information relating to the provision of the Services are as follows. The purpose of use of the User Information collected or used in the 12 months prior to the final revision of the Policy is also the same as the following:

• （１）To provide, maintain, protect, and improve the Services, including accepting registrations for the Services, providing information to other Users, verifying identities, and calculating usage fees;
• （２）To provide information and respond to inquiries regarding the Services;
• （３）To respond to acts that violate the terms, conditions, or policies of the Services (hereinafter referred to as “Terms of Use”);
• （４）To notify changes in the Terms of Use of the Services;
• （５）To create statistical data in relation to the Services, processed into a form that does not identify individuals;
• （６）To provide services for the Users of the Services and information on campaigns: and
• （７）To Provide the download history of catalogs to the Users who published the catalogs.

２.3 The Company obtains and uses the User Information described in item (1) of the preceding paragraph with the consent of the User. For the purposes of preceding items (1)–(4), the Company uses the User Information in order to perform the contractual obligations between the Company and the Users. For the purposes of the preceding items (5) and (6), the Company uses the User Information as the legal basis to ensure our legitimate interests in conducting our business such as understanding the use of the Services, making suggestions to the Users or improving the Services for the Users.

３．Provision to third parties

３.1 The Company shall not provide personal information (“Personal Information” as defined in the Act on the Protection of Personal Information (Act No. 57 of 2003, hereinafter referred to as the “Personal Information Protection Act”) and other applicable laws and regulations concerning the Users) among the User Information, to a third party without obtaining prior consent from the User, unless disclosure is permitted under the Personal Information Protection Act or other laws and regulations; provided, however, that this shall not apply to the following cases. The User is deemed to have consented to the disclosure to other Users of information voluntarily disclosed to allow other Users to view information (for example, name or email address of the User’s contact person).

• （１）Cases in which the Company entrusts with all or part of the handling of Personal Information within the scope necessary for achieving the purpose of use;
• （２）Cases in which the Personal Information is provided in connection with the succession of business as a result of a merger or other similar event;
• （３）Cases in which it is necessary to cooperate with a national government organ, local government, or person entrusted thereby to execute affairs prescribed by laws and regulations, and in which obtaining the User’s consent may interfere with the execution of the relevant affairs; or
• （４）Other cases permitted under the Personal Information Protection Act or other applicable laws and regulations.

３.2 The Company has not provided any personal data to any third party in the 12 months prior to the last revision date of the Policy.

３.3 The Company has not sold Personal Information, including that of minors under 16 years of age, and has not sold Personal Information in the 12 months prior to the last revision date of the Policy.

４．Disclosure of Personal Information

The Company shall, when requested by the User to disclose Personal Information, disclose the same to the User without delay after confirming that such disclosure is requested by the User themselves (or notify the User if such Personal Information does not exist); provided, however, that this shall not apply if the Company is not obliged to disclose such information pursuant to the Personal Information Protection Act or other laws and regulations. Please note that disclosure of Personal Information incurs a handling fee of 1,000 yen (tax excluded) per disclosure request.

５．Rights of the User

５.1 If the Company is requested by the User: (1) to correct any Personal Information in accordance with the provisions of the Personal Information Protection Act on the grounds that the Personal Information is not accurate; or (2) to suspend use of any Personal Information in accordance with the provisions of the Personal Information Protection Act or other relevant laws and regulations on the grounds that the Personal Information is being handled beyond the scope of the purpose of use publicly announced in advance or that the Personal Information has been used by deception, other illegal or wrongful means, the Company shall conduct necessary research without delay after confirming that the request is made by the User themselves, and, based on the results thereof, correct or suspend the use of the used Personal Information, and notify the User to that effect. If the Company decides not to make a correction or suspend use of the User’s website based on reasonable grounds, the Company will notify the User thereof.

５.2 When the Company is requested by the User to delete their Personal Information, if there are grounds under the Personal Information Protection Act or other related laws and regulations, or if the Company deems it necessary to accept such request, it shall delete the Personal Information after confirming that such request is made by the User and notify the User to that effect.

５.3 If the Company has no obligation of corrections or suspension of use, under the Personal Information Protection Act or other laws and regulations, the provisions of the preceding two items shall not apply.

５.4 In addition to the rights set forth in the preceding paragraph and 5.1 and 5.2, Users who reside in or are located in the EEA or the UK shall have the following rights with respect to Personal Information if the User satisfies the requirements under the General Data Protection Regulation or the UK General Data Protection Regulation (UK GDPR), which have been incorporated into UK law pursuant to the EU GDPR and the EU Withdrawal Act 2018 and amended by the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019.

Right to withdraw consent

The User may withdraw their consent at any time even if the Company will handle their Personal Information with their consent; provided, however, that this revocation does not affect the use of the Personal Information that the User has agreed to in the past.

Right to restrict the handling of Personal Information

The User can ask to restrict the handling of their Personal Information in certain cases.

Right to data portability

The User may receive the Personal Information they have provided to the Company in accessible electronic form and transmit it to third parties.

Right to file a complaint

Depending on the situation, the User may file a complaint about the handling of their Personal Information.

５.5 In addition to the rights set forth in the preceding paragraph and 5.1 and 5.2, Users who reside or are located in California shall have the following rights with respect to Personal Information if the User satisfies the requirements under the California Consumer Privacy Act.

Right to request the disclosure of information regarding the handling of Personal Information

The User may request disclosure up to twice in a 12-month period of the following User’s Personal Information that the Company has collected in the previous 12 months:

– Types of Personal Information about the User the Company has collected;
– Acquisition methods pertaining to the Personal Information;
– Purposes of use in relation to the collection of the Personal Information;
– Types of third parties to whom the Personal Information was disclosed; and
– Types of the User’s Personal Information disclosed by the Company to a third party.

Right to opt out of sale of Personal Information

The User may ask the Company to stop selling their Personal Information and not to sell such information in the future.

Right not to be discriminated against

The User has the right not to be treated unfairly or in a manner that discriminates against other Users when exercising or having exercised the above rights.

６．Retention period

The Company will retain the User’s information for the period necessary for the purpose of use or the period provided by applicable laws and regulations.

７．Use of cookies and tracking technology

The Company may collect User Information using Cookies or similar tracking systems in order to improve the convenience of the Services, enhance the Services, and provide appropriate information to Users.

８．Security and transfer of Personal Information to third countries

８.1 The Company strives to handle Personal Information at a high level of information security in order to prevent unauthorized access to and leakage of the Personal Information of the Users, and to maintain the accuracy of the Personal Information it holds.

８.2 If the Company obtains Personal Information from within the EEA or the UK, the information it obtains may be transferred to companies located in countries outside the EEA or the UK from Japan. The Company shall transfer the Personal Information to a company located outside the EEA and UK only if the country where the company is located has been recognized by the European Commission as providing an adequate level of protection for personal data, or if the Standard Contractual Clause (SCC) are adopted and implemented between the Company and the recipient company.

９．Changes to the Policy

The Company may change the Policy if necessary to comply with legal revisions or for its business needs. The Company notifies the Users of the changes by email.

10．Contact for inquiries

Please contact the Personal Information Protection Manager below for any comments, questions, complaints, or other inquiries about the handling of User Information.

Address: 463 Ouyachi, Higashi-ku, Niigata City, Niigata 950-0814

To the Personal Information Protection Manager of OTANI TRADING CO LTD.

Email： info@foodtrip-lp