PRIVACY AND COOKIE POLICY
This website (www.sthjapan.com) (“Site”) is operated by STH Japan K.K. (“we”, “us”, “our”).
We are committed to safeguarding your privacy and ask that you read this privacy policy carefully as it contains important information on:
- The personal information we collect from you;
- What we do with your personal information; and
- Whom your personal information will be shared with.
1. WHO WE ARE
1.1 STH Japan K.K. is a company incorporated under Japanese law (its registered office: Arco Tower 7F, 1-8-1 Shimomeguro, Meguro-ku, Tokyo, 153-0064, Japan, Representative Director: Brendan Patrick Delahunty).
1.2 We are the Data Controller in relation to the personal information that you submit to us or that we collect from you via this Site and also in relation to the personal information that you submit to us or that we collect from you in relation to any of our travel and/or hospitality products.
2. INFORMATION THAT WE COLLECT FROM YOU
We will collect and process the following personal information about you:
2.1 Personal information you provide to us. This is personal information about you which you provide to us by filling in forms on the Site or by corresponding with us by phone, email or otherwise. For instance, if you submit your information on the Contact Us or Register page of the Site, you will be asked to provide certain personal information about yourself including your name and contact details and we will collect and keep this information. Also, if you choose to subscribe to our newsletters and updates, we may collect your contact information and possibly also some information about your preferences.
2.2 Personal information we collect about you. We use temporary cookies on the Site. Many websites, not only our Site, use cookies whenever a user visits their website in order to track online traffic flows. A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer from a website’s computer and is temporarily stored on your device’s hard drive. Information supplied by cookies can help us to analyse the profile of our visitors to the Site and help us to provide you with a better user experience. Please see below a short explanation regarding the type of cookies that this Site uses: –
- Necessary Cookies – Necessary Cookies are essential in enabling you to browse the Site and to use its features properly. One of the functions of Necessary Cookies are to keep a record of the options that you have selected and the input that you have given on a given page of the Site while enabling you to move on to the other pages of the Site. Disabling Necessary Cookies will in most cases disable the essential functionalities of the website and thus by continuing to use this Site, you indicate your consent to the use of Necessary Cookies.
- Preferences Cookies – Preference Cookies enable the Site to remember choices you made during past visits, such as user names and passwords. Preference Cookies will likely make your use of the Site more efficient if you intend to visit multiple times (which we hope you will!).
- Statistics Cookies – These cookies collect information about how you use the Site. Statistics Cookies collect your data such as which pages you visited and what links you clicked on during your visit. These cookies include cookies from third-party analytics services (such as Google Analytics as explained below) to the extent they are used by us.
- Marketing Cookies – Marketing Cookies track your general online activity. These cookies are used by advertisers to tailor the types of advertising that you see. Information collected by Marketing Cookies will be shared with other organizations and advertisers.
This Site uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the Site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content. They also allow you to see our ads as you browse other websites or search on Google for terms related to our products or services.
For more information on Google Analytics cookies, see the Google Analytics Home Page.
You can manage the cookies that this Site applies to your visit by either: –
- Selecting the appropriate tick box on the pop-up box that should have been displayed on your browser when you first visited the Site to indicate which cookies you consent for the Site to apply to your visit.
- Go to “All About Cookies” through the following the link (https://www.allaboutcookies.org/) and selecting (or deselecting) the appropriate cookie types that you consent to (and withdraw consent from), which are applied to your browsing or use of the Site.
You also have the opportunity to set your devices to accept all cookies, to notify you when a cookie is issued, or to not apply cookies at any time. You can stop the application of cookies by adjusting the settings of cookies (for details see your browser Help option for how to do this or alternatively visit (https://www.aboutcookies.org). Please be aware that disabling cookies may affect the functionality of this Site and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionalities and features of this Site.
2.3 Personal information we receive from other sources. We may obtain your personal information from other sources. For instance, if you have submitted personal information to any of our or our group companies’, we may obtain information about you from them and combine it with personal information that we collect via this Site. We may also work with third parties such as payment service providers, credit reference agencies, list brokers and advertising networks, and we may receive your personal information from them and combine it with personal information that we collect directly from you. In such case, to the extent your consent is required under applicable laws, we will obtain your prior consent in the format admitted by such applicable laws before receiving and using such information within the scope of purpose of use described in 3. below. We also collect and use the information available thorough variety of publicly available third-party sources (such as Linked In) and general information which can be researched on the internet in order to reach out to businesses who we think will be interested in our Site and services. We will only collect corporate contact details (such as business email addresses) when carrying out such research.
2.4 Where you submit personal information to us about another person, such as personal information about your guests for a product that you have purchased, you must only do so where you have their consent. We will use that information in accordance with this Privacy and Cookie Policy.
2.5 “Special categories” of particularly sensitive personal information require higher levels of protection. Special categories of data include details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document for collecting such data.
We will process the following special categories of personal information, on the basis of your explicit written consent:
- Dietary requirement/food allergies; and
- Special access/assistance you may require.
3. USE OF PERSONAL INFORMATION
3.1 Personal information you provide to us. We will use this information for the following purposes:
- To provide you with the information, products and services you have requested to us;
- To carry out our obligations arising from any contracts entered into between you and us;
- To provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- If you are a business contact, to provide you with information about our goods and services which we think will be of interest and relevance to you;
- To prepare customer lists and/or materials to manage our relationship with you or your business;
- To notify you about changes to our services;
- To develop and carry out marketing activities (see marketing section below for more information);
- To study how our customers use products and services from us and other organisations;
- To improve and manage our brands, products and services, and consider our new services, etc;
- To manage how we work with other companies that provide services to us and our customers;
- To detect, investigate, report, and seek to prevent fraud and other crimes;
- To obey laws and regulations that apply to us;
- To respond to complaints and seek to resolve them;
- To exercise our rights set out in agreements or contracts; and
- To make processes more efficient and maintain high standards.
3.2 Personal information we collect from you. We may use the personal information that we collect from you for some or all of the following purposes:
- To improve the Site and its features as well as how we engage with you;
- To make improvements to the quality of the Site so we can present it in the best possible manner for you;
- As part of our efforts to maintain the safety and security of the Site;
- To make suggestions and recommendations to users of our Site about products or services that may interest them.
3.3 Personal information we receive from other sources. We may combine the information you provide to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
3.4 Marketing. When you sign up to receive STH Japan news and information or use the Site and/or when you purchase our travel and/or hospitality products, we will use your personal information to create a profile by analyzing your browsing history and/or purchase history, etc. we hold. This is necessary for the purposes of our legitimate interests in ensuring we have accurate information about you. We create a profile for you based on your preferences in order to provide you with the best experience and to send you personalised marketing communications and newsletters. This is necessary for the purposes of our legitimate interests in ensuring that we provide you a personalised experience and provide you with the most relevant products.
If you have given us your consent to send you marketing communications (including by email, text, SMS, social media, on-screen message/push notification) or if we are permitted by law to send such communications without obtaining your consent, we use the information that you have provided to us or which we have collected about you (for instance from publicly available third party sources such as Linked In and general information researched on the internet) for sending you personalised marketing messages about our products or services, events, and promotions.
4. LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION
4.1 We will only process your personal information where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your personal information. In almost every case the legal basis will be one of the following:
- Consent: For example, where you have provided your consent to receive certain marketing from us. You can withdraw your consent at any time, including by clicking on the “unsubscribe” link at the bottom of any marketing email we send you.
- Our legitimate business interests: Where it is necessary for us to understand our customers, promote our services and operate effectively as a leading sports travel and hospitality provider offering premium spectator experiences at global sporting events, provided in each case that this is done in a legitimate way which does not unduly affect your privacy and other rights. For example, we will rely on this legal basis when we market to corporate contacts and when we conduct certain market analysis to understand our customers in sufficient detail so we can create new services and improve the profile of our business.
- Performance of a contract with you (or in order to take steps prior to entering into a contract with you): For example, where you have purchased a product or service from us and we need to use your contact details and payment information in order to process your order.
- Compliance with law: Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation.
5. DISCLOSURE OF YOUR PERSONAL INFORMATION
5.1 We may share your information with the sports rights holder and others
As STH Japan envisage offering services to individuals in the EU and thus engaging with the processing of such individual’s personal data, STH Japan is subject to the EU General Data Protection Regulations (the “GDPR”) as well as to the provisions of Japanese laws.
Because STH Japan offers hospitality and travel products delivered by us and third party partners in relation to various sporting events, we may be required to share your personal information with third party providers, event organisers, venue operators of the events you have purchased a hospitality product, travel product and/or any other product in relation to, to any suppliers we are working together with to deliver a given product including to any accommodation/travel providers such as hotels and airline companies.
Your personal information will be used by us and those third parties for the purposes of:
- Administering and allocating your ticket to your requested event and/or hospitality packages;
- The prevention of crime and for supporter security purposes;
- The regulation of unauthorised aftermarket ticket sales;
- For market research and analytical purposes necessary to develop and improve the customer experience at future events; and
- Where you have provided your consent, to send you marketing communications.
Your personal data may also be shared with selected IT providers, such as third party cloud platform providers, in order to administer the above purposes. We or the other parties may contact you directly where this is necessary to fulfil your booking.
In carrying out the above purposes, we or our third party partners may need to transfer your personal data to third parties in foreign countries (including countries which may not have data protection laws providing the same level of protection as those in Japan or the European Economic Area). Where such a transfer occurs, we will take steps which are reasonably necessary to ensure that appropriate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this Privacy & Cookie Policy. In these cases, we may rely on approved data transfer mechanisms (such as the EU “Standard Contractual Clauses”) to ensure your information is subject to appropriate safeguards in the recipient country. You may contact us for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.
5.2 We may also, to the extent necessary to achieve the purposes of use, share your personal information with the following personnel. Such personnel include third parties in foreign countries (please see 5.4 below for more information):
- Any member of our other group companies, which means our subsidiaries, our ultimate holding company and its subsidiaries;
- Other third parties selected by us including:
- Suppliers and sub-contractors whom disclosure is necessary for the performance of any contract we enter into with them or you (this may include payment service providers, service contractors, and marketing fulfilment partners) or any other data processor who undertakes any data processing on our behalf;
- Analytics and search engine providers that assist us in the improvement and optimisation of our Site;
- Credit reference agencies for the purpose of assessing your credit score where this is required for us to enter into a contract with you.
5.3 We may also disclose your personal information:
- To any successor or prospective successor of the business of STH Japan, or any successor of the Site (and in each case the successor shall be entitled to use your personal information for the same purposes for which we are entitled to use that information);
- To third parties where necessary in order to enforce or apply the Sites terms of use or our terms and conditions of supply;
- To advertisers, advertising networks and other third parties chosen by us; or
- To third parties in order to protect the rights, property, or safety of STH Japan, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
The above recipients include third parties in foreign countries (please see 5.4 below for more information).
5.4 Provision of Personal Information to Third Party in Foreign Country
The destinations to which your personal information may be transferred include the following countries/areas:
- United Kingdom and EEA member countries (for example, Germany, France, Sweden, Iceland and Norway);
- The countries/areas recognized by European Commission as providing adequate protection (for example, Israel and Switzerland)
- Participating Countries of APEC Cross Border Privacy Rules (for example, Unites States, Canada, Korea, Taiwan, Singapore and Australia*)
*For more information about participating countries of APEC CBPR, please see this site (Personal Information Protection Commission)(Japanese only)
For the information about personal data protection system of each country to which your personal information may be transferred, please see this site (Personal Information Protection Commission)(Japanese only)
Each recipient of personal information complies with local laws and regulations related to personal data protection.
5.5 Other than as expressly set out in this Privacy and Cookie Policy or as otherwise required or permitted by law, we will not share, sell or distribute any of the personal information you provide to us without your consent.
6. STORING PERSONAL INFORMATION
6.1 We collect personal information from wherever users are situated, but our Site‘s servers are situated in Japan. Thus, the personal information that we collect through our Site will therefore first be transferred to Japan from any other country in which you may be located and will be subject to EU and Japanese data protection laws rather than the laws of the country in which you are resident.
6.2 We implement appropriate technological and operational security measures to protect your information as much as possible against any unauthorised access or unlawful use. Unfortunately, information transmitted via the internet cannot be completely secure and so we cannot guarantee the security of your data transmitted to our Site. Any transmission of data to us via the internet is at your own risk.
6.3 Our Site may, from time to time, contain links to and from the websites of our partner, networks, advertisers and affiliates. 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 information to these websites.
6.4 We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with us. If we have not been in contact with you for 3 years then your account may be classed as dormant or your personal information may be deleted in line with our data retention policy.
7. SECURITY CONTROL MEASURES
We implement the following safety control measures to ensure proper handling of your personal information.
- We have established a basic policy stipulating a compliance with relevant laws, regulations and guidelines, as well as the point of contact for questions and complaints on handling of personal information.
- We have established basic handling rules for acquiring, using, and storing, etc. of personal information.
- We have appointed a person in charge of the handling of personal information and have established a system for reporting and communicating from employees to such person in charge.
- Clauses concerning the confidentiality of personal information are stipulated in our employment regulation.
- We take measures to ensure that any person, other than the data subject and the employee who is authorised to handle the personal information, is not able to easily access the personal information.
- We have introduced a mechanism for protecting any equipment used for handling personal data from unauthorized access and/or from unauthorized software.
- We have implemented security control measures with the understanding of the system for personal data protection in Japan, where the personal information is stored.
8. YOUR RIGHTS
We are committed to ensure that your rights under applicable laws are protected. You will find below a table summarizing your different rights:
| Right of access | You can request access to your personal information. You may also request rectification of inaccurate personal information, or to have incomplete personal information completed. You can request any available information as to the source of the personal information, and you may also request your personal information being processed by us. |
| Right to be forgotten | Your right to be forgotten entitles you to request the erasure of your personal information in cases where: (i) The data is no longer necessary in relation for the purposes of its collection or processing; (ii) You choose to withdraw your consent related to personal information; (iii) You object to the processing by automated means using technical specifications; (iv) your personal information has been unlawfully processed; (v) there is a legal obligation to erase your personal information; or (vi) erasure is required to ensure compliance with applicable laws. |
| Right to restriction of processing | You may request the restriction of processing in the cases where: (i) You contest the accuracy of the personal information; (ii) We no longer need the personal information, for the purposes of the processing; or (iii) You have an objection to processing for legitimate reasons. |
| Right to data portability | You can request the portability of your personal information and you have the right to have transmitted your personal information to another data controller without hindrance from us in a structured, commonly used, and machine-readable format, where the below applies: (a) The processing of your personal information was based on your consent or on a contract; and (b) The processing is carried out by automated means. You can also request us to transmit your personal information directly to a third party of your choice (where this is technically feasible). |
| Right to object to processing for the purposes of direct marketing | You may object (right to “opt-out”) to the processing of your personal information (notably for profiling or for marketing communications). When we process your personal information on the basis of your consent, you can withdraw your consent at any time. |
| Right not to be subject to automated decisions | You have the right not to be subjected to a decision based solely on automated processing, including automated profiling which produces legal effects concerning you or similarly significantly affects you. |
| Right to lodge a complaint to the competent Supervisory Authority | If you have a privacy-related complaint against us, you may make your complaint by email to privacy@sthjapan.com. If you are not satisfied with our response, you may then seek further recourse by contacting the competent supervisory authority or the competent court. |
We will handle any request to exercise your rights in accordance with applicable laws and any relevant legal exemptions. If you wish to exercise any of these rights, please contact us using the contact details below. We may need to request specific information from you to help us confirm your identity and to enable you to access your personal information (or to exercise any of your rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Generally, you will not have to pay a fee to access your personal information (or to exercise any of the above rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We will aim to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will endeavour to notify you and keep you updated.
9. CHANGES TO OUR PRIVACY AND COOKIE POLICY
We reserve the right to make changes to the Privacy and Cookie Policy from time to time. Any such changes to our Privacy and Cookie Policy will be posted to the Site and, where appropriate, we will notify through e-mail notification.
10. CONTACT US
If you have any requests or queries in relation to this Privacy and Cookie Policy, please contact us by sending an email to privacy@sthjapan.com.
