If you have your habitual residence in the European Economic Area, this Chapter VIII shall prevail against Chapters I to VII above with respect to our processing of personal data and data subject rights.
Summary of PRIVACY NOTICE
This summary Privacy Notice (“Summary Notice”) will provide you with a summary of the accompanied, detailed Privacy Notice (hereafter “Full Notice”, together "Summary and Full Notice") on the data processing activities of Vision Inc., located at SHINJUKU EASTSIDE SQUARE 8F 6-27-30 Shinjuku, Shinjuku-ku, Tokyo 160-0022, Japan ("Vision", „our“, "we" or "us") with respect to individually identifiable information ("Personal Data") about users of our site ( https://townwifi.com/ ) ("Website").
Scope of applicability
This Summary and Full Notice applies to you if you are a user of our Website.
Processing of your Personal Data (categories of Personal Data)
We process the following of your Personal Data collected during your visit of our Website: your full name, your date of birth, your gender, your country, your postal address including your street and number, city, zip code, phone number, e-mail address, your IP-address, host name, user agent, browser identification, referrer, the date/time of your access to the Website, and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you. For more details see 1. of the Full Notice or click
here.
Processing purposes
We process your Personal Data for the following purposes: providing WiFi router rental services, billing and collecting fees for our services, granting prizes and conducting campaigns, introducing goods or services of us or our business partners, managing and administrating your account, get in contact with you concerning your queries, security and fraud prevention, conducting market research and/or analysis for statistical, profiling or other purposes for us to review, develop and improve the quality of our products and service. For more details see 2. of the Full Notice or click here.
Legal justifications for the processing of your Personal Data
One of the key privacy law requirements is that any processing of Personal Data has to have a legal justification. We generally use the following legal justifications: (1) You have given your consent to the processing (Art. 6(1)(a) GDPR; “Consent Justification”), (2) the processing is necessary for (a) the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (Art. 6(1)(b) GDPR; “Contract Performance Justification”) (b) compliance with a legal obligation (Art. 6(1)(c) GDPR; “Legal Obligation Justification”) and (c) realizing a legitimate interest (Art. 6(1)(f) GDPR; “Legitimate Interest Justification”). For more details and the matching of purposes and corresponding legal justifications see 3. of the Full Notice or click here.
Data transfers and recipients and legal justification for such transfers
We transfer your Personal Data to our service providers, and, in accordance with applicable law, other governmental authorities, courts, external advisors, and similar third parties, some of the aforementioned recipients located in jurisdictions outside the EU. For more details see 4. of the Full Notice or click here.
Retention periods for and deletion of your Personal Data
Your Personal Data will be deleted once they are not any longer needed for the purposes motivating their original collection or as required by applicable law. For more details see 5. of the Full Notice or click here.
Your statutory rights
You have a number of rights with regard to the processing of your Personal Data, each as per the conditions defined in applicable law, such as the right to have access to your Personal Data, to have them corrected, erased or handed over. Please refer any of your questions to [email protected]. For more details see 6. of the Full Notice or click here.
Changes of this Summary and Full Notice as well as further notices
This Summary and Full Notice are subject to change. You will be notified adequately of any such changes. Further, you will be notified adequately through further relevant privacy notices (e.g. for specific purposes) in case such is not covered by this Summary and the Full Notice.
・How to contact us
If you wish to exercise your data subject rights or if you have any other questions concerning this Summary and Full Notice, please address your request to us, who can be contacted at:
Vision Group Personal Information Contact,
SHINJUKU EASTSIDE SQUARE 8F 6-27-30 Shinjuku, Shinjuku-ku, Tokyo 160-0022, Japan,
Email: [email protected]
Tel: 03-5325-0200.
The reception time for all counters is from 9 AM to 5 PM on weekdays except for national holidays in Japan.
・Full Notice
We are delighted about your interest in our Website. Your privacy is important to us. Hereafter, we provide you with detailed information on dealing with your personal data on this Website.
This Full Notice is applicable for the Website only. Other Vision websites may be governed by other privacy policies. Please also note that parts of the Website may contain links to such other Vision websites or third party websites which may be governed by other privacy policies.
This Website uses cookies. For further information please read our cookie policy - which you will find here.
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Categories of Personal Data
We process the following Personal Data about you (hereinafter jointly "Your Data"):
- (i) your full name, your date of birth, your gender, your country, your postal address including your street and number, city, zip code, phone number, e-mail address (hereinafter jointly "Contact Data");
- (ii)your IP-address, host name, user agent, browser identification, referrer, and the date/time of your access to the Website (hereinafter jointly "Technical Data"); and
- (iii) any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you (hereinafter jointly "Form Data").
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Processing purposes
We process Your Data to the extent permitted or required under applicable law, for the following purposes:
- • to perform a contractual obligation under contracts between you and Vision or to take steps at your request prior to entering into a contract with us (hereinafter "Contract Purposes");
- • to provide the Website in an optimized way for you and to currently enhance the user experience of the Website (hereinafter "Quality Purposes");
- • to send you marketing materials, such as newsletters to provide you with the latest information about our products and services which might be of interest to you (hereinafter jointly "Marketing Purposes").
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Legal justification for the processing of Your Data
Generally, the provision of Your Data is voluntary. However, if you do not provide Your Data, the use of the Website may be different. Particularly, if you do not provide Contact Data, we do not provide our Wi-Fi router rental services to you.
Furthermore, We rely on the following legal justifications for the processing of Your Data:
YOUR DATA
Processing purposes |
Categories of Your Data involved |
Legal basis |
Contract Purposes |
Contact Data Form Data |
Contract Performance Justification |
Quality Purposes |
Technical Data |
Legitimate Interest Justification |
Marketing Purposes |
Contact Data Marketing Data Form Data |
Consent Justification |
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Data transfers and recipients and legal justification for such transfers
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4.1 Recipients
- (i)Third parties: We may transfer Your Data to governmental agencies and regulators, courts, and government authorities, all in accordance with applicable law based on Legal Obligation Justification and to external advisors acting as controllers (e.g., lawyers, accountants, auditors etc.) based on Legitimate Interest Justification.
- (ii)Service providers: We contract with third party service providers as part of our normal business operations to provide the Website and related services to you (i.e., cloud service providers, call center service providers, and logistic companies).
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4.2 Cross-Border Data Transfers
- (i)We may transfer Your Data outside of the country you are located. Some recipients of Your Data are also located in another country for which the European Commission has not issued a decision that this country ensures an adequate level of data protection as of the date of this Privacy Notice, namely: Japan.
- (ii)By way of entering into appropriate data transfer agreements based on Standard Contractual Clauses (2010/87/EU and/or 2004/915/EC) as referred to in Art. 46(5) GDPR, we have established that all recipients located outside the EEA will provide an adequate level of data protection for Your Data and that appropriate technical and organizational security measures are in place to protect Your Data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. Any onward transfer is subject to appropriate onward transfer requirements as required by applicable law. Such agreements are accessible upon request from [[email protected]].
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Retention periods for and deletion of Your Data
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5.1 Your Data processed for the purposes hereunder will be stored only to the extent necessary. If a judicial or disciplinary action is initiated, Your Data may be stored until the end of such action, including any potential periods for appeal, and will then be deleted or archived as permitted by applicable law.
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5.2 In principle, we will retain Your Data as long as required or permitted by applicable law. Afterwards, we will remove Your Data from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it.
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Your statutory rights
Under the conditions set out under applicable law (i.e., the GDPR), you have the following rights:
- 6.1 Right of access: You have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, to request access to the Personal Data. The access information includes – inter alia – the purposes of the processing, the categories of Personal Data concerned, and the recipients or categories of recipients to whom the Personal Data have been or will be disclosed.
You have the right to obtain a copy of the Personal Data undergoing processing. For additional copies requested by you, we may charge a reasonable fee based on administrative costs.
- 6.2 Right to rectification: You have the right to obtain from us the rectification of inaccurate Personal Data concerning you. Depending on the purposes of the processing, you have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.
- 6.3 Right to erasure (right to be forgotten): You have the right to ask us to erase your Personal Data.
- 6.4 Right to restriction of processing: You have the right to request the restriction of processing your Personal Data. In this case, the respective data will be marked and may only be processed by us for certain purposes.
- 6.5 Right to data portability: You have the right to receive the Personal Data concerning you which you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit those Personal Data to another entity without hindrance from us.
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6.6 Right to object:
You have the right to object, on grounds relating to your particular situation, at any time to the processing of your Personal Data by Us and We can be required to no longer process your Personal Data. In general, you have the right to object to our processing of your personal data for direct marketing purposes. If you have a right to object and you exercise this right, your Personal Data will no longer be
processed for such purposes by Us. Exercising this right will not incur any costs.
Such a right to object may not exist, in particular, if the processing of your Personal Data is necessary to take steps prior to entering into a contract or to perform a contract already concluded.
Please note that the aforementioned rights might be limited under the applicable national data protection law. We remain the universal point of contact for your execution of these rights.
Please refer any of your questions to [email protected].
In case of complaints you also have the right to lodge a complaint with the competent supervisory authority, in particular in the member state of your habitual residence or alleged infringement of the GDPR.