Notice on How We Process Your Personal Data

We, International Operation Inc. (”Johren Platform"), provide services and products for your use or purchase, we take privacy very seriously and undertake to process your personal data in compliance with applicable laws including the EU General Data Protection Regulation (“GDPR”).
Below is our notice on how we process your personal data.

We may change, add to, or delete any part of this notice from time to time. You can obtain the latest version of this notice on the following URL:

URL: https://www.johren.net/privacy-policy/

1. Personal Data

Personal data under this notice (“Personal Data”) means any information to identify a person with following items.

Data Subject Category Examples
Customers Identification information on websites IP address, Cookie
Customer name Registered name
Customer contact information Registered email address
Behavior monitoring information Purchase history and action history
Bank account, credit card information Payment information
Third Parties Individuals’ name Name in contracts etc.
Contact information Email address, telephone number in contracts etc.
Bank account, credit card information Bank account in contracts etc.
Address Physical address in contracts etc.
Employees Employees’ name Name on resume etc.
Image of employee Image on resume etc.
Contact information Email address and telephone number on resume etc.
Information on employee’s family Family information on resume
Evaluation information Job assignment information and its evaluation related information on resume etc.
Bank account information Bank account
Address information Address on resume etc.
Special category Medical check data

2. Use of Personal Data and Disclosure to Third Parties, Purpose of Data Processing

We use the collected Personal Data for the following purposes.

Data Subject Purposes
Customers Use of the services, improvement of service and usage, response to inquiries, prevention of fraud, and distribution of advertisement
Third Parties (e.g. Business partners, Service providers etc.) Fulfillment of contractual obligations and maintaining contact information
Employees Fulfillment of contractual obligations, maintaining emergency contact information, and taxation

3. Disclosure of Personal Data with Third Parties

We will disclose Personal Data with the following third parties

Business Partners: Contractors, service providers, other business partners, including the followings:

  • Platform service providers
  • Cloud service providers
  • Data center contractors
  • Business operation support contractors
  • Developers
  • Shipping companies
  • Publishing companies
  • Service monitoring companies
  • Fraud monitoring companies
  • Payment and settlement companies
  • Auditing firms

4. Legal Basis to Use Personal Data

We will handle and use Personal Data to the extent applicable to the followings.

Legal Basis Explanations/Examples
Fulfillment of contractual obligations To fulfill our contractual obligations by and between you and us: Membership management,
purchase of service/item, response to inquiries etc.
Legitimate interests To use Personal Data in order to conduct our business with legitimate reasons: site improvements, prevention of fraud etc.
Compliance with legal obligations To use Personal Data in order to comply with the legal requirements: Judicial/governmental orders, tax procedures etc.
Consent We may ask consent by Data Subject for a use of Personal Data.
Consent by Data Subject will be obtained by certain methods including check-box etc.
The consent by Data Subject will be a legal base for our processing your Personal Data. You can withdraw your consent anytime: Marketing activities, email magazines

Upon your consent when your consent is regulatory required, we use cookies and similar technologies to compile information about the usage of our websites.
When you visit our websites, we or an authorized third party may place a cookie on your browser.
Cookies collect information, including your Personal Data, about your online activities over time and across your different sites.
Cookies allow us to track overall usage, determine your browsing preferences and improve and customize your browsing experience.
We may use both session cookies expiring once you close your browser and persistent cookies staying on your device until they expire or you delete them to improve our service. For more information about how we use cookies, please read our cookie policy.

If you fail to provide your Personal Data, we might be unable to maintain our relationship with you or provide our services or products to you to the extent that such Personal Data are necessary to maintain the relationship or to provide the services or products.

5. CHILD DATA (How we handle child data)

We do not knowingly collect or solicit Personal Data from anyone under the age of 16 or knowingly allow such persons to access to in order to use the service or purchase products.

6. RETENTION (How long we retain your Personal Data)

We will retain your Personal Data only as long as we are entitled or required under applicable laws or it is necessary in relation to the purposes.
This is usually 7 years after you close your account, or your last contact in case of non- accountholders. Upon the lapse of the retention period, we will either delete or anonymize your data.

7. TRANSFERS TO NON-EEA COUNTRIES

As a majority part of our services in our commercial operations are provided by us in Japan and other countries such as the U.S., your data are processed or stored in the servers or storage devices hosted in Japan and such other countries. In this context, we may transfer your Personal Data to such other countries, where the GDPR is not in force. Your Personal Data are protected by our data transfer agreements with our counterparts.
These agreements impose contractual obligations on our counterparts to process your Personal Data in accordance with the GDPR.

8. YOUR RIGHTS (what legal right you can exercise on your Personal Data)

According to the GDPR, where you have given your consent to process your Personal Data, you may withdraw your consent or explicit consent at any time.
You also have the right to object at any time the processing your data for direct marketing purposes.
Additionally, provided that the applicable statutory conditions are met, you have the legal rights to request us the followings:

  • information on what Personal Data we have about you
  • correction of your personal data if inaccurate or incomplete
  • erasure of your Personal Data if we have no lawful ground to process them
  • suspension of using your Personal Data during our way of processing them is being contested
  • obtaining your Personal Data in a computer-readable format

9. Safety Control Measures

We take the security and confidentiality of Personal Data.
We take technical, administrative and physical security measures to prevent Personal Data from fraudulent accesses and improper uses.
We conduct periodical review of the security measures to consider implementation of new technologies or methodologies.
While we will spend best effort for security measures, there are no perfect/iron wall measures.
Our companies’ current security measures to prevent from fraudulent physical accesses and fraudulent electrical accesses are as follows: Personal Data is to be stored in a securely locked location, Personal Data is to be restricted and accessed only by the personnel in charge, Personal Data is to be accessible only with unique password of personnel in charge, Personal Data which needs special protection, we will apply industry standard encryption technology for such special protection, Personal Data is to be processed in accordance with a documented security policy to be complied by all of our personnel.

10. INQUIRY

For further information and inquiry, contact: Our Data Protection Organization provides support with any data privacy related questions, comments, concerns or complaints or in case you wish to exercise any of your data privacy related rights in connection with us.
Our Data Privacy Organization will be contacted by email.
Our Data Protection Organization will always use best efforts to address and settle any requests or complaints you bring through the email address below: