Privacy Policy

JAPAN HOUSE SÃO PAULO

Updated on: November 5th, 2024.

Japan House São Paulo, located at Paulista Avenue, No. 52, second floor, in the city of São Paulo, State of São Paulo, registered before federal tax authorities under number CNPJ/MF 28.876.877/0001-60 (“Japan House São Paulo” or “JHSP”), is committed to safeguarding your privacy and protecting your Personal Data by adopting the best practices in security, transparency, and privacy when accessing and processing your Personal Data.

This Privacy Policy explains in detail how we treat your Personal Data and includes information about how Japan House São Paulo collects, uses, processes, stores, and shares Personal Data during the time you have a relationship with the company. A relationship with JHSP is established when you access and use our website or visit our spaces where you can have access to events, exhibits, workshops, articles, news, images, videos, infographics, podcasts, audio files, lives, experiences, surveys, and general content created to propagate elements of genuine Japanese culture to society.

This Privacy Policy is divided as follows:

How we collect your Personal Data
Types of Personal Data we process and for what purposes
Cookies and similar technologies
Sharing Personal Data with third parties
International transfer of Personal Data
Security and storage of Personal Data
Rights of Personal Data holders
Contact information and updates to this Policy

HOW WE COLLECT YOUR PERSONAL DATA

In order to offer content and experiences in our space, keep our website running, and have a continuous relationship with you, we may collect information and personal data.

This collection of data may happen in different situations and the type of personal data and collection methods will depend on the nature of your relationship with us.

We describe below the main situations in which we collect Personal Data.

Mailing: You can choose to provide some Personal Data, such as your name and e-mail address, to improve your experience at Japan House São Paulo by asking to be included in our mailing list.
- Events: We may collect your Personal Data when you voluntarily register for events promoted by Japan House São Paulo such as lectures, cultural events, guided visits, workshops, etc.
- Website navigation: We may also collect your Personal Data automatically by recording your interactions on our website. You can find more information in Item 3 of this Privacy Policy.

TYPES OF PERSONAL DATA WE PROCESS AND FOR WHAT PURPOSES

As part of our activities, we need to process Personal Data for certain purposes, such as registering you in our mailing list, promoting events, conducting satisfaction surveys, and continuously improving our relationship with you.

We have listed below some situations in which we may process your Personal Data in the context of your relationship with us:

PURPOSE	TYPE OF DATA USED
Sending institutional and marketing content	Contact Data: name and e-mail.
Event registration management	Registration Data: name, e-mail address, Brazilian tax-payer number (CPF), phone number.
Guided tours through institutions	Registration Data: name, e-mail address, phone number, name of institution, pictures.
Organization of activities, workshops, etc.	Registration Data: name, ID and tax-payer number (CPF), consent from legal guardian (when applicable), pictures.
Running satisfaction surveys and assessment of profiles, habits, and needs for possible Japan House São Paulo strategies.	Contact Data: name, e-mail, cell phone number, personal preferences.
Analyzing performance, trends, and number of visits, verifying browsing habits on the JHSP website, evaluating statistics related to the number of visits and use of the website, and assessing JHSP visitors.	Registration Data: name, gender, e-mail address. Navigation Data: IP number, date, time, access content and duration. Data about access device: model, manufacturer, operational system, service
	provider, browser type, connection type and speed.
Verifying the path that took you to the JHSP website, checking browsing habits on the website, improving website performance, and measuring number of visits.	Navigation Data: IP number, date, time, content accessed and duration of access. Data about access device: model, IMEI, manufacturer, operational system, service provider, browser type, connection type and speed.
Keeping records of visits to the website to fulfill legal requirements such as the Brazilian Internet Civil Framework.	Navigation Data: IP number, date, time, geographic location, browser type, content accessed and duration of access.
Resolution of inquiries or complaints	Contact Data: name, tax-payer number (CPF), e-mail.

Japan House São Paulo may also process Personal Data, whenever necessary, to meet applicable legal requirements, including in regard to the drafting of financial or regulatory reports, reports about adverse events and tax obligations among others, or for the purpose of exercising regular rights in judicial, administrative, or arbitration proceedings.

COOKIES AND SIMILAR TECHNOLOGIES

Japan House São Paulo may collect browsing information or Personal Data in an automated way through the use of cookies. Cookies are small files that may or may not be added to your device and allow the storage and recognition of your browsing data.

We use cookies to improve your experience when you browse through our website and to understand which content, products, or services can best serve you. This may mean an improvement to our authentication security or a way to customize offers and messages.

When you browse through our website, a few types of cookies may be used:

Essential cookies: Essential cookies are used to activate website security to aid in the monitoring or detection of malicious activities or activities that are not permitted by our Terms and Conditions, as well as to protect your information from non-authorized third parties. Essential cookies cannot be disabled or rejected because they are needed to ensure the adequate operation of the website, and they do not collect data for marketing purposes.

Advertising cookies: Advertising cookies are used to direct content and advertising to you based on information regarding your interaction with our website or third-party websites. These cookies may be disabled through the settings on your browsers.

Performance Cookies: The purpose of this type of cookie is to understand website performance, measure website visits, check browsing habits, and understand the path that took you to the website (e.g. through links on other websites, search engines, or directly through the web address). Performance cookies allow us to store your preferences and customize your experience when you use the website, and they can collect Personal Data for marketing purposes. These cookies may be disabled through the settings on your browsers. However, by deciding to disable these cookies, you acknowledge that it is possible the website will not perform all its functionalities.

You can manage how cookies are used during browsing and clear cookies and browsing data through your browser settings. You will find more explanations on how to proceed by clicking on the links below. To find information related to other browsers, please visit the browser developer’s website

Firefox Chrome Safari Internet Explorer Edge

The Website may contain links to third-party websites, which are not subject to the provisions of this Privacy Policy. We recommend that you review the third-party privacy policies before interacting with their websites. The existence of these links does not imply our endorsement or sponsorship of third-party websites, and by clicking on the links you acknowledge that you are subject to the respective websites’ terms and conditions and privacy policies.

SHARING PERSONAL DATA WITH THIRD PARTIES

The Personal Data collected may be shared with the following third parties:

The Ministry of Foreign Affairs of Japan (MOFA): Japanese government agency and author of the project Japan House. As author of the project, MOFA coordinates the budget and defines the project’s main guidelines.
1. JTB Group: Japanese Corporation that operates as a travel agency in Japan and worldwide. JTB was the corporation chosen by MOFA to implement and manage the Japan House project in Brazil.
2. Quickly Travel Agência de Viagens e Turismo: Brazilian Corporation belonging to JTB Group that operates as a travel agency in Brazil and worldwide. Quickly Travel was the corporation chosen by JTB to assist in the management of the Japan House project in Brazil.
3. Vendors and partners: we rely on vendors and partners who may process Personal Data. The information is shared only for the purposes of the provided services. We always seek to evaluate our vendors and partners and establish with them contractual obligations of Personal Data protection to minimize risks for the data holders. Among these vendors and partners are advertising agencies, law firms, data hosting servers, and companies that assist us with the management of our websites and development of our operations.
4. Public Authorities: we may share your Personal Data with public authorities to comply with current legislation. Should a judge or legally authorized individual request that we share certain Personal Data to, for example, conduct an investigation, we are required to comply. We are opposed to any abuse of power and, if we see that a given order is abusive, we will always defend the privacy and protection of the data of Personal Data holders.

INTERNATIONAL TRANSFER OF PERSONAL DATA

Japan House São Paulo is an initiative by the Japanese Government. Therefore, Japan House São Paulo may, if necessary, transfer Personal Data collected in Brazil to Japan. In addition, some of our technology vendors may have servers in other countries.

You can find below more details about international transfer of data:

Country of destination of Personal Data	How and why are Personal Data transferred internationally?	For how long are the data transferred?	Responsibility of the entities involved in the transfer and adopted security measures
Japan	Personal Data may be shared with Japanese institutions that are responsible for managing Japan House São Paulo so they can store the data in servers in Japan and provide performance reports about the projects and initiatives promoted by Japan House São Paulo. The transfer can be made through systems and databases that are shared between the relevant organizations or through managerial reports and audits.	While the project Japan House São Paulo is happening, the data will be kept by the responsible and supporting entities	Japan House São Paulo is responsible for protecting the transferred Personal Data. JTB Group and MOFA are responsible for guaranteeing compliance with local Japanese legislation and adopting the necessary security measures to protect the data received. All transfers occur through secure channels that have restricted access controls and continuously monitor
			the security of the servers.
U.S.A. and Russia	The international transfer of Personal Data occurs because some of our technology vendors may store data in servers outside of Brazil as part of the necessary structure to provide the contracted services. These transfers are made to ensure the efficiency of the systems and the technology tools that are essential to the activities of Japan House São Paulo. .	For the time during which the contract between Japan House São Paulo and its vendors remains in effect, which will be equivalent to the time required to fulfill the purposes provided for in the contract.	Japan House is responsible for ensuring the protection of the transferred Personal Data. Technology vendors are responsible for ensuring that local legislation of the countries of destination of the data be complied with and for implementing robust security measures which include, for example, the use of cryptography, running frequent security tests, use of firewalls, and implementing tools to detect and prevent intrusions (IDS/IPS), among other security practices that protect Personal Data.

The Brazilian National Data Protection Authority (ANPD) has not yet issued a decision regarding compliance requirements for the recipient countries. However, to ensure the same level of protection for your Personal Data, we have formalized appropriate instruments with the data processing agents involved in the international data transfer, in accordance with the mechanisms provided in Article 33 of the LGPD (Brazilian General Personal Data Protection Law) and Resolution CD/ANPD No. 19/2024.

If you would like to learn more about our data transfer practices (including requesting copies of the safeguard measures, when applicable), please contact our Data Protection Officer listed at the end of this Policy. To exercise the rights of data holders provided under the LGPD, please refer to Item 7 of this Policy.

6. SECURITY AND STORAGE OF PERSONAL DATA

We are responsible for taking care of your Personal Data. Japan House São Paulo adopts all organizational and technical measures to protect your Personal Data against loss, unauthorized use, or other misuse, ensuring a level of security compatible with the activities we perform.

The Personal Data are stored in a secure operational environment that is not accessible to the public. We make an effort to protect the Personal Data we store by using measures such as (i) adopting a program of governance and privacy; (ii) creating a team that is responsible for the Protection of Personal Data and a Data Protection Officer; (iii) adding the principles Privacy by Design and Privacy by Default to our activities; (iv) creating policies of confidentiality with our employees; (v) restricting access to Personal Data based on the principles need-to-know and least privilege among others. In spite of all the aforementioned measures, we cannot guarantee total security.

The unauthorized use of accounts, hardware or software malfunction, and other factors may compromise the security of your Personal Data at any time. Therefore, we need your help to keep a secure environment for everyone. In addition to adopting good security practices regarding your Personal Data, we are available to help you should you identify or detect something that compromises your Personal Data. If that happens, please contact us via the e-mail address displayed at the end of this Privacy Policy.

Your Personal Data will be processed only for as long as necessary to fulfill the purposes for which it was collected, including compliance with any legal or contractual obligations, accountability, defense in administrative or judicial proceedings, or requests from the authorities.

All collected Personal Data will be excluded upon your request or when they are no longer necessary or relevant for Japan House São Paulo to provide its services. We may, however, keep Personal Data even after a request for exclusion if there are other reasons for keeping the data such as a legal requirement to do so or to ensure the rights of Japan House São Paulo. To determine the appropriate period of Personal Data retention, we consider the quantity, nature, and sensitivity of the Personal Data, the potential risks of unauthorized use or of sharing the Personal Data, the purpose of processing the Personal Data and whether we are able to fulfill these purposes through other means, and the applicable legal requirements.

7. RIGHTS OF PERSONAL DATA HOLDERS

When you provide your Personal Data to Japan House São Paulo, we will ensure your rights as provided under the applicable data protection legislation, namely:

Access: Being aware of the information and Personal Data processed by Japan House São Paulo.
Correction: Requesting a correction of Personal Data stored by Japan House.
Request for anonymization, blocking, or deletion: You may request the anonymization, blocking, or deletion of Personal Data that is excessive, unnecessary, or processed in non-compliance with the Brazilian General Data Protection Law (LGPD). In such cases, Japan House São Paulo will conduct an analysis to verify any excess or non-compliance in the processing of Personal Data and, if such non-compliance is confirmed, Japan House São Paulo will fulfill the request made.
Deletion of registration: You may request the deletion of a registration you created with Japan House. In such cases, some Personal Data may remain stored for the fulfillment of legal obligations or to safeguard the rights of Japan House São Paulo.
Withdrawal of consent: You may withdraw consent previously given for certain functionalities by using the opt-out tool when applicable.
Data portability: You may request the portability of your Personal Data to another provider of products or services in an interoperable format, such as a .txt file, where feasible.
Review of Automated Decisions: You may request a review of an exclusively automated decision that affects your interests.

For security reasons, when we receive your request, we may need to verify your identity before we fulfill your request. This verification may include a request for additional data to ensure you are correctly identified so we can prevent fraudulent activity and ensure the non-disclosure of Personal Data to unauthorized persons. In addition, when you appoint a third-party to make requests on your behalf, the appointed third-party must present a document, such as a power-of-attorney signed by you, to prove they are authorized to act on your behalf.

In some cases, we may have legitimate reason not to fulfill a request. These situations may include, for example, cases in which revealing specific information could break the confidentiality of business secrets of Japan House São Paulo or third parties, and in cases where requests for anonymization, blocking, or deletion cannot be fulfilled due to Japan House São Paulo’s obligation to store the data for legal or regulatory reasons or to guarantee the rights of Japan House São Paulo or third parties, including in any dispute of any nature. Moreover, some request may not be fulfilled immediately, but we are committed to responding to every request within reasonable time and always in accordance with applicable legislation.

To exercise any of these rights, you may contact us via the e-mail address displayed at the end of this Policy.

You also have the right to register complaints with the Brazilian National Data Protection Authority (ANPD) should you feel that your rights are not being respected.

8. CONTACT INFORMATION AND UPDATES TO THIS POLICY

If you have any questions regarding our Privacy Policy or about how we process your Personal Data, please contact us at:

Data Protection Officer: Carlos Roza

E-mail: [email protected].

Japan House São Paulo reserves the right to periodically and unilaterally modify this Privacy Policy and will promptly update the website with its newest version.

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