1. Personal Data
In this Policy, Personal Data means any data relating to an identified or identifiable natural person (“Personal Data”). Grooves may acquire and process Personal Data, including the name, address, telephone number, gender, nationality, occupation, and email address of a natural person in the EEA.
2. Use of Personal Data
Grooves acquires and processes Personal Data for the following purposes:
- Providing services to relevant clients;
- Providing service information from Grooves;
- Analyzing and improving the provision of Grooves services to clients
- Investigating any complaints or queries data subjects may have
- Compliance with legal and regulatory obligations that Grooves has to discharge
- Defense of certain rights or interests; and
- Any other purposes necessary for the appropriate and smooth performance of services by Grooves.
Grooves relies on the following legal grounds to process Personal Data:
- The data subject’s consent expressly given to process his/her Personal Data in such manner. The data subject may withdraw his/her consent to this processing at any time; however, this will not affect the lawfulness of any processing carried out before withdrawal of the consent;
- Entering into a contract with a data subject or performing obligations under a contract with a data subject;
- Legitimate interests of Grooves or those of any third party recipients of data subject’s Personal Data, provided that such interests are not overridden by interest or fundamental rights and freedoms of the data subject; and
- Compliance with legal and regulatory obligations.
3. Disclosure to Third Parties
Grooves may supply or disclose Personal Data, without the data subjects’ prior consent, to group companies of Grooves and other third parties that are service assignees of Grooves. Grooves may also supply or disclose Personal Data to third parties when it is necessary for some other justifiable reason permitted by laws and regulations.
4. Cross-Border Transfer
Personal Data may be transferred to entities in countries or jurisdictions outside the EEA, such as Japan, if required for the purposes as described above. Please note that such countries or jurisdictions may not have the same data protection laws as the EEA and will not afford many of the rights conferred upon data subjects in the EEA. Grooves will ensure that any such international transfers are made subject to appropriate and suitable safeguards as required by the GDPR or other relevant laws. When doing so, Grooves will comply with applicable data protection requirements and take appropriate safeguards to ensure the security and integrity of Personal Data.
5. Retention of Personal Data
Grooves will retain Personal Data for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law.
6. Rights of Data Subject
Data subjects have the right to access, request correction of, request the limitation of processing of, and request the data portability of data subjects’ Personal Data retained by Grooves. When Grooves receives a request based on such right, Grooves will conduct any necessary investigation without delay and provide data subjects or nominated third parties with Personal Data or respond to such request without a delay.
Data subjects also have the right to lodge a complaint with the local data protection authority if data subjects have any complaint regarding processing of data subjects’ Personal Data by Grooves.
If data subjects fail to provide their Personal Data, there will not generally be any detrimental effects for data subjects. However, Grooves may need to collect data subjects’ Personal Data to process their instructions of perform the contract with data subjects. In such case, Grooves may have to cancel its engagement or contract data subject have with Grooves, and Grooves will notify data subjects thereof at that time.
For any questions about this Policy or your rights described in Section 6., please contact us at the following:
5-4-27, Minamiaoyama, Minato-ku Tokyo, 107-0062, Japan
Personal Data Consultation Service