PRIVACY POLICY

Published: December.15.2022
Last updated: December.15.2022

We, Japan Othello Association, respect your privacy.
We process your personal data as the “controller” or “business” in accordance with applicable data protection laws, including the General Data Protection Regulation of the European Union (the “GDPR”) and the California Consumer Privacy Act (the “CCPA”).
This is our privacy policy on how we process and protect your personal data. We may revise this privacy policy from time to time. You can obtain the latest version of this policy on our site.

1. RESPONSIBLE CONTROLLER
We, Japan Othello Association, an association registered in Japan, issue this privacy policy. When we process the following personal data, we are the data controller and are responsible for protecting your rights regarding personal data.

2. HOW WE PROCESS YOUR PERSONAL DATA
As we provide you with our services, we collect, use, store, generate or disclose to third-parties (hereinafter collectively referred to as “process”) your personal data for the following purposes:

1) To manage the Othello competition, we host
i. Categories of your personal data we process: your name, age, residential address, telephone number, gender and nationality.
ii. Lawful basis:
1) hosting a competition and publishing your results in competition on our website or various publication media on the ground that it is necessary for the performance of our contract with you; and
2) gathering information for maintaining and improving service quality and detecting and preventing fraud against you on the ground that it is necessary for the purposes of our legitimate interest pursued.
iii. Period for which we store your personal data: Until you withdraw your registration in our association or for the duration to show that we treated you fairly.
iv. Recipients we disclose your personal data to: our web hosting providers and the companies which cosponsor the competition.

2) To issue press releases announcing the competition on news media.
i. Categories of your personal data we process: winners’ name and competition pictures (which may include your facial images). For the avoidance of doubt, these pictures are not used to identify you.
ii. Lawful basis: your consent. You can withdraw your consent at any time. Your withdrawal of consent does not affect the lawfulness of our processing of your personal data based on consent before its withdrawal.
iii. Period for which we store your personal data: for the duration we publish the press release on our website, or until you withdraw your consent.
iv. Recipients we disclose your personal data to: the media in which we issue press releases.

3) To analyze your use of our website in order to generate insight that is useful for improving our services, products, and marketing:
i. Categories of your personal data we process: your interactions with our website collected, including your browsing history on our website together with IP address and other information about your terminal device.
ii. Lawful basis: your consent. You can withdraw your consent at any time Your withdrawal of consent does not affect the lawfulness of our processing of your personal data based on consent before its withdrawal.
iii. Period for which we store your personal data log data is deleted after 26 months.
iv. Recipients we disclose your personal data to: our contractors that assist us in analyzing web traffic data.

4) To protect your privacy and security, integrity, and availability of our website:
i. Categories of your personal data we process: your browsing history on our website collected by web access logging, including your IP address, type and version of your web browser, web browser plugins, operating system, and other information about your terminal device and technologies you use when accessing our website.
ii. Lawful basis: the processing is necessary for the purpose of our legitimate interest, i.e. protecting your privacy and our website from fraudulent or unlawful access by monitoring web access traffic.
iii. Period for which we store your personal data:- for as long as is necessary to achieve our purpose.
iv. Recipients we disclose your personal data to: our contractors that assist us in monitoring web access traffic.

5) To respond to your inquiry:
i. Categories of your personal data we process: Your name, e-mail address, ID and the content of your inquiry.
The personal information above is required to respond to your inquiries. If you do not provide them, it prevents us from giving you as appropriate and precise information as we can.
ii. Lawful basis: the processing is necessary for the performance of a contract to which the data subject is a party.
iii. Period for which we store your personal data: For as long as your questionnaire is active and for a reasonable time thereafter according to our standard procedures or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
iv. Recipients we disclose your personal data to: none.

3. SENSITIVE PERSONAL DATA
We do not collect and/or use sensitive categories of your personal data as defined in Articles 9 or 10 of GDPR on our website.

4. TRANSFER TO NON-EU COUNTRIES
We do not transfer your personal data to any entities located in any third countries outside of the European Economic Area (EEA) or Japan. In the event that we transfer your data to an entity located outside the EEA or Japan, we protect your rights with personal data by virtue of a data transfer contract with the relevant recipient in accordance with the GDPR, which imposes on such recipients contractual obligations to ensure an adequate level of data protection equivalent to those laid down by the GDPR. When the recipients are located in Japan, your personal data is protected under the Act on the Protection of Personal Information of Japan. The European Commission has decided that Japan ensure an adequate level of data protection (the “Adequacy Decisions”) and that personal data can be lawfully transferred to Japan without requiring any specific authorization.

5. YOUR LEGAL RIGHTS
Provided that certain conditions are met, you have legal rights to request from us the following:
 Revocation of a previously given consent to our processing of your personal data
 Access to your personal data and to certain supplementary information covered by this policy;
 Rectification of your personal data if inaccurate or incomplete;
 Erasure of your personal data in certain circumstances;
 Suspension of using your personal data in certain circumstances;
 Stopping processing your personal data in certain circumstances; and
 Obtaining your personal data in a structured, commonly used, and machine-readable format.
If you wish to exercise your rights, please contact us.

6. COMPLAINT
If you are from EEA and UK, You can lodge complaints about our way of processing your personal data with the data protection supervisory authorities of your country of residence.

7. INQUIRY
For further information and inquiry, contact:
Email address　 info@othello.gr.jp

FOR OUR VISITORS FROM THE STATE OF CALIFORNIA

This section of our privacy policy explains how we collect, use, share, and protect personally identifiable information of California residents and any information related to it (“personal information”) and non-personal information.

1. RIGHT TO KNOW ABOUT PERSONAL INFORMATION COLLECTED, DISCLOSED, OR SOLD
a. The CCPA states that you have the right to request us to disclose what personal information we collect, use, disclose, and sell.
b. You can exercise your above-mentioned rights unless you have exercised the rights within the preceding 12 months. We endeavor to respond to you within 45 days of receiving a verifiable request from you. If you intend to exercise such rights, please refer to section 6.
c. We use your information (name, and email address) to verify your request. You may be asked to provide additional information so that we can verify your request.
d. The categories of personal information we collected, business or commercial purpose, sources, and category of third parties we shared within the preceding 12 months are as follows:

CATEGORY(as stipulated in CCPA 1798.140(o))

DETAIL

BUSINESS OR COMMERCIAL PURPOSE FOR PROCESSING

SOURCES OF COLLECTED PERSONAL INFORMATION

CATEGORY OF THIRD PARTIES WE SELL (stipulated in CCPA 1798.140(w))　OR DISCLOSE

Identifiers

name, age, residential address, telephone number, gender and nationality

To manage the Othello competition, we host

Direct from you

our web hosting providers and the companies which cosponsor the competition

categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

name, residential address, and telephone number

Protected classification characteristics under California or federal law

age, gender and nationality

Identifiers

Winners’ name

To issue a press release announcing the competition on our website or news media.

For the avoidance of doubt, visual information is not used to identify you.

Direct from you

The media in which we issue press releases

Visual Information

competition pictures (which may include your facial images)

Identifiers

Unique personal identifier (cookie(s)), Internet Protocol address

To analyze your use of our website and generate insight to improve our service and marketing

Your activity on our site

Our contractors that assist us in analyzing web traffic data

Identifiers

Internet or other electronic network activity information

Internet Protocol address

browsing history, information regarding a consumer’s interactions with an Internet website, application

To protect your privacy and security, integrity and availability of our website

Your activity on our site

Our contractors that assist us in monitoring web access traffic

Identifiers

Your name, e-mail address and ID

To respond to your inquiry

Directly from you via e-mail or telephone

None

e. Disclosure or Sale of Personal Information
(1) We do not have actual knowledge that we sell personal information about residents who we know are younger than 16 years old.
Under the CCPA, “sell” means disclosing by electronic or other means a consumer’s personal information to a third party for monetary or other valuable consideration.

2. RIGHT TO REQUEST DELETION OF PERSONAL INFORMATION
a. The CCPA states that you have the right to request us to delete your personal information collected by us.
b. You can exercise your above-mentioned right with your account with us unless you have exercised the rights within the preceding 12 months. We endeavor to respond to you within 45 days of receiving a verifiable request. If you intend to exercise such rights, please refer to section 6.
c. We use your information (name and email address) to verify your request. You may be asked to provide additional information so that we can verify your request.

3. RIGHT TO OPT-OUT OF THE SALES OF PERSONAL INFORMATION
a. The CCPA states that you have the right to opt-out of the sale of your personal information by us.
b. We do not sell your personal information and do not share information collected from cookies or email address with advertising agencies to manage our personalized advertising to those of you based on your preferences.

4. RIGHT TO NON-DISCRIMINATION FOR THE EXERCISE OF A CONSUMER’S PRIVACY RIGHT
a. The CCPA states that you have a right not to receive discriminatory treatment by us for the exercise of the privacy rights conferred by the CCPA.

5. AUTHORIZED AGENT
a. When you use an authorized agent to submit a request to know or a request to delete, we may require that you:
(1) Provide the authorized agent with written permission to do so; and
(2) Verify your own identity directly with us.
(3) Directly confirm with us that you provided the authorized agent with permission to submit the request
We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your own behalf.

6. CONTACT US
Please contact us by email if you have any questions or concerns about this privacy policy or the information we hold about you.
Email-address info@othello.gr.jp

7. CHILDREN’S PRIVACY
We do not collect and store personal information about Children (in this provision, we define Children as minors under 13 years of age) if this information is submitted by a Child without prior parental consent or by the parent or guardian of the Child.
If we discover that we’ve unintentionally collected information from a Child in a way that does not meet COPPA requirements, we will delete the information immediately.