1. Explanation of Privacy Policy for Europe
Tokyo International Law Office (“TKI”) is committed to protecting your privacy in compliance with applicable data protection laws i.e. the Act on the Protection of Personal Information of Japan, the EU General Data Protection Regulation (“GDPR”) and the UK Data Protection Act (“UK DPA”) and other laws, regulations and standards concerning the handling of personal information. This Privacy Policy for Europe (hereinafter referred to as “Privacy Policy for Europe”) explains how TKI may process Personal Data (as defined below) of data subjects which are protected under the GDPR and the UK DPA.
This Privacy Policy for Europe applies to our processing of the Personal Data of data subjects resident in the European Economic Area (“EEA”) and the UK. This Privacy Policy for Europe shall apply together with TKI’s Privacy Policy, but the former shall prevail over the latter in respect of those data subjects to the extent that these policies contradict.
We may revise this Privacy Policy for Europe and will post the updated Privacy Policy for Europe from time to time on this page. You are thus expected to check this page to review our revisions of any changes we make in this Privacy Policy for Europe.
Our website may contain links to and from third-party websites. These third-party websites and any services that may be accessible through them have their own privacy policies. We are not responsible for these third-parties’ data protection activities. We encourage you to be aware of this when you leave this website and to read the privacy policies applicable to these third-party websites.
2. Purposes and legal basis of our processing of your Personal Data
We may process the following categories of your personal information (together “Personal Data”):
- Personal Data which our (potential) clients and related parties provided to us in the course of our professional services and/or our promotional activities, including:
- Contact information including name, title, e-mail address, phone number, fax number, company name, address, department and position, signature;
- Date and time of visits to our premises;
- Your communication with us;
- Personal information relevant to any dispute, grievance, investigation, arbitration, or other legal advice we have been asked to provide to our client; and
- Financial and payment data, including your bank account and other data necessary for processing payments, including credit/debit card numbers, security code numbers and other related billing information.
- Sensitive personal information: In the course of our professional services, we may represent you and/or your organization in legal matters that require us to collect and use sensitive personal information relating to you (i.e., information about your racial or ethnic origin, political opinions, religious beliefs, trade union activities, physical or mental health, sexual life and sexual orientation or details of criminal offences, Personal information collected through this website, including cookies, access logs, web beacons (also known as pixels), your preferences in receiving marketing information from us, your communication preferences and information about how you use our websites(s), including the services you viewed or searched for, page response times, download errors, length of visits and page interaction information (such as scrolling, clicks, and mouse-overs), the Internet Protocol (IP) address, browser type and version, device type, time zone setting, browser plug-in types and versions, operating system and platform.
We use such Personal Data for the following purposes:
| Categories of Personal Data | Purposes of Use |
|---|---|
| Personal Data which our (potential) clients and related parties provided to us in the course of our professional services and/or our promotional activities | ･ To perform the professional services you required; ･ To investigate and confirm the status of conflicts of interest, etc.; and ･ To send you research materials, publications, articles, or notices of seminars and other events that might be of your interest. |
| Personal Data collected through this website | ･ To create usage statistics, analyze visitors’ interest and conducting other marketing analysis; ･ To operate, further optimize and develop the website; and ･ To recognize, prevent and investigate attacks. |
For the above purposes, we process your Personal Data on the following legal bases:
a. Contractual performance:
We need to process your Personal Data to perform the contract we enter into with you and/or the legal service you required.
b. Legal Obligation:
We need to comply with a legal obligation under applicable laws. Specifically, based on the rules provided by the Japan Federation of Bar Associations, or other authorities, we are required to confirm certain identification matters (also known as the “Know Your Client (KYC)” procedures) when you seek our legal advice for the first time. Your kind understanding would be appreciated in this regard.
c. Legitimate Interests:
The use of your Personal Data is necessary for legitimate interests pursued by us or a third-party, and your interests and fundamental rights do not override those interests.
d. Consent:
You have given consent for us to process your Personal Data. However, even if we obtain consent from you, we may process your Personal Data based on other legal bases (e.g., legal obligation or vital interests) if required. The withdrawal of your consent shall not affect the lawfulness of processing performed based on the consent before your withdrawal. After your withdrawal of consent, we may still process your Personal Data if other legal bases apply.
3. Cookies
Cookies are small text files that may be stored on your computer when you visit a website. Cookies are generally used to provide site visitors with additional functionality within the site. Cookies cannot access, read or modify any other data on your device(s).
This website uses Google Analytics, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043 United States (“Google”). Google Analytics uses cookies to help the website analyze how users use the site. We use cookies on the basis of our overriding legitimate interest to cost-efficiently generate easy-to-use website access statistics.
The information about your use of the website (including your IP address and the URLs of the accessed pages) generated by the cookie will be transmitted to and stored in Google’s servers. We do not store any of your Personal Data collected by Google Analytics.
This website uses an IP anonymization feature provided by Google Analytics. Your IP address will therefore be truncated/anonymized by Google as soon as it receives it. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage to us. Google will not associate your IP address with any other data held by Google.
You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of this website. You can also prevent Google’s collection and use of your data by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en-GB.
Further information concerning Google’s terms of use and privacy statement can be found at https://www.google.com/analytics/terms/gb.html or at https://policies.google.com/?hl=en&gl=uk.
4. Transferring of your Personal Data
We may share your Personal Data with the following categories of recipients.
a. Service providers such as external professional advisors and IT-related service providers; and
b. Any parties relevant to the performance of the professional services you requested such as competent authorities, law enforcement agencies or courts, to the extent necessary for us to provide our legal services or comply with applicable laws or regulations.
Some of the recipients referred to above are located in countries outside, or process Personal Data outside of the EEA or UK. The level of data protection in any such country may not be equivalent to that in the EEA or UK. However, we only transfer your Personal Data to countries where the EU Commission or the UK government, as appropriate, has decided that they have an adequate level of data protection (e.g., Japan) or we take measures to ensure that all recipients provide an adequate level of data protection. We do this, e.g., by entering into appropriate data transfer agreements based on Standard Contractual Clauses (2010/87/EC and/or 2004/915/EC). These are accessible upon request (see the contact details in Section 7 below).
5. Retention period of Personal Data
We will retain the Personal Data that we collect for as long as it is necessary for the purposes set forth in this Privacy Policy for Europe, unless otherwise required by applicable laws or necessary for potential legal claims, where Personal Data is needed to raise or defend against the claim not yet time-barred.
6. Your rights regarding to your Personal Data
You have a number of legal rights in regard to the Personal Data we retain. These rights may depend on where you are located and which data protection laws will apply to the relationship between you and us, but would typically include:
a. The right to access:
you can ask us for a copy of part or all of your Personal Data which we process for the purposes set out above;
b. The right to rectification:
you can ask us at any time to correct your Personal Data if it is incorrect or incomplete;
c. The right to erasure:
you can ask us to delete your Personal Data we process, if this does not otherwise violate our obligations under applicable laws or a natural person’s vital interests;
d. The right to restriction of processing:
you can ask us to limit the processing of your Personal Data;
e. The right to objection of use:
you can ask us to stop the processing of your Personal Data, if the processing is not based on our legitimate interests and there is no other lawful basis that we can rely on to continue processing your Personal Data;
f. The right to data portability:
you can ask us to transfer your Personal Data we process to another processor;
g. The right to withdraw consent:
you can withdraw your given consent to the processing of your Personal Data. We will, upon your request, restrain from any future process of your Personal Data, unless the processing can be continued based on another legal basis (e.g., our legitimate interests, legal obligations, a natural person’s vital interests or public interest);
h. The right to complaint:
you can lodge complaints with competent supervisory authorities at any time if you believe our processing of your Personal Data violates your rights or applicable laws and regulations.
You can exercise your rights by contacting us in accordance with Section 7.
7. Contact Details
You may contact TKI at:
Tokyo International Law Office
P.O. BOX 571, ARK Mori Building 24F 1-12-32 Akasaka, Minato-ku, Tokyo 107-6024 Japan
Attention: Dai Iwasaki
Telephone: +81 (0)3-6843-2847
E-mail: privacy@tkilaw.com