プライバシーポリシー

プライバシーポリシー詳細版（英語）

駿台海外校ではEU一般データ保護規則（GDPR：General Data Protection Regulation）に準拠した、EU圏内向けの詳細なプライバシーポリシーを定めています。

I. Name and address of the controller

The controller for purposes of the General Data Protection Regulation and other national data protection laws of the Member States and other provisions of data protection law is:

Sundai International Education Centre Co., Ltd.

2-5-4, Kanda-Surugadai, Chiyoda-ku, Tokyo

kaigai@sundai-kaigai.jp

Ⅱ. Name and address of the controller’s data protection officer

Hiroshi Oyabu

2-5-4, Kanda-Surugadai, Chiyoda-ku, Tokyo

kaigai@sundai-kaigai.jp

Ⅲ. General information on data processing

1. Scope of the processing of personal data

Personal data will only be processed by us to the extent necessary for the purpose of providing a functional website and our contents and services.

2. Legal basis for the processing of personal data

Insofar as we obtain the consent of the data subject for the processing of personal data, Article 6 (1)(a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis for the processing.

In case the processing of personal data is necessary for the performance of a contract to which the data subject is a party, Article 6 (1)(b) GDPR serves as the legal basis for the processing. This also applies to processing operations necessary in order to take steps prior to entering into a contract.

Insofar as the processing of personal data is necessary for compliance with a legal obligation to which our company is subject, Article 6 (1)(c) GDPR serves as the legal basis for the processing.

If processing is necessary in order to protect the vital interests of the data subject or of another natural person, Article 6 (1)(d) GDPR serves as the legal basis for the processing.

If processing is necessary for the purposes of a legitimate interest pursued by our company or by a third party and if the interests, fundamental rights and freedoms of the data subject do not override such interests, Article 6 (1)(f) GDPR serves as the legal basis for the processing.

3. Data erasure and storage period

The personal data of the data subject will be erased or blocked once it is no longer necessary for the purpose for which it was collected. Storage may also take place if this has been provided for by the European or national legislator in EU regulations, laws or other regulations to which the controller is subject. The data will also be blocked or erased if a storage period prescribed by the above-mentioned provisions expires unless there is a need for further storage of the data in order to conclude or implement a contract.

Ⅳ. Rights of the data subject

1. Right of access

You have the right to obtain from the controller confirmation as to whether or not your personal data is being processed by the controller.

Where that is the case, you have the right of access to the following information:

ⅰ. the purposes of the processing;

ⅱ. the categories of personal data concerned;

ⅲ. the recipients or categories of recipient to whom your personal data have been or will be disclosed

ⅳ. the envisaged period for which your personal data will be stored, or, if not possible, the criteria used to determine that period;

ⅴ. the existence of the right to request from the controller rectification or erasure of your personal data, the right to request from the controller restriction of processing or the right to object to such processing;

ⅵ. the right to lodge a complaint with a supervisory authority;

ⅶ. where the personal data are not collected from the data subject, any available information as to their source;

ⅷ. the existence of automated decision-making, including profiling, referred to in Article 22 (1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

You have the right of access to information as to whether your personal data is transferred to third countries or international organisations. In this context, you may request to be informed of the appropriate safeguards pursuant to Article 46 GDPR relating to the transfer.

This right of access can be restricted in so far as it is likely to render impossible or seriously impair the achievement of research purposes or statistical purposes and the restriction is necessary for the achievement of research purposes or statistical purposes.

2. Right to rectification

You have the right to obtain from the controller the rectification and/or the completion of inaccurate or incomplete personal data concerning you. The controller must provide the rectification without undue delay.

Your right of rectification can be restricted to the extent that it is likely to render impossible or seriously impair the achievement of research purposes or statistical purposes and the restriction is necessary for the achievement of research purposes or statistical purposes.

3. Right to restriction of processing

You have the right to obtain from the controller restriction of processing your personal data where one of the following applies:

• you contest the accuracy of your personal data for a period enabling the controller to verify the accuracy of the personal data;
• the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
• the controller no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
• you have objected to processing pursuant to Article 21 (1) GDPR pending the verification on whether the legitimate grounds of the controller override your interests, rights and freedoms.

Where processing of your personal data has been restricted, such personal data can, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

If the restriction on processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.

Your right to restriction of processing can be restricted to the extent that it is likely to render impossible or seriously impair the achievement of research purposes or statistical purposes and the restriction is necessary for the achievement of research purposes or statistical purposes.

4. Right to erasure

a) Duty to erase

You have the right to obtain from the controller the erasure of your personal data without undue delay and the controller has the obligation to erase this data without undue delay where one of the following grounds applies:

ⅰ. your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

ⅱ. you withdraw your consent on which the processing is based according to Article 6 (1)(a), or Article 9 (2)(a) GDPR, and where there is no other legal ground for the processing;

ⅲ. You object to the processing pursuant to Article 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21 (2) GDPR.

ⅳ. Your personal data have been unlawfully processed;

ⅴ. Your personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;

ⅵ. Your personal data have been collected in relation to the offer of information society services referred to in Article 8 (1) GDPR.

b) Information to third parties

Where the controller has made your personal data public and is obliged pursuant to Article 17 (1) GDPR to erase this personal data, the controller, taking account of available technology and the cost of implementation, must take reasonable steps, including technical measures, to inform controllers which are processing this personal data, that you, as data subject, have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

c) Exceptions

The right to erasure does not apply insofar as the processing is necessary

ⅰ. for exercising the right of freedom of expression and information;

ⅱ. for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

ⅲ. for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9 (2) as well as Article 9 (3) GDPR;

ⅳ. for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89 (1) GDPR in so far as the right referred to in section a) is likely to render impossible or seriously impair the achievement of the objectives of that processing; or

ⅴ. for the establishment, exercise or defence of legal claims.

5. Right to information

If you have asserted the right of rectification, erasure or restriction of processing vis-à-vis the controller, the controller is obliged to notify all recipients to whom your personal data has been disclosed of this rectification, erasure or restriction of processing, unless this proves impossible or involves a disproportionate effort. You have the right to be informed by the controller about those recipients.

6. Right to data portability

You have the right to receive your personal data, which you have provided to a controller, in a structured, commonly used and machine-readable format. Furthermore, you have the right to transmit those data to another controller without hindrance from the controller to which the personal data has been provided, where

ⅰ. the processing is based on consent pursuant to Article 6 (1)(a) GDPR or Article 9 (2)(a) GDPR or on a contract pursuant to Article 6 (1)(b) GDPR; or

ⅱ. the processing is carried out by automated means.

In asserting this right, you also have the right to have the personal data transmitted directly from one controller to another, where technically feasible. This shall not adversely affect the rights and freedoms of others.

The right to data portability does not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

7. 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 which is based on point (e) or (f) of Article 6 (1) GDPR, including profiling based on those provisions.

The controller does no longer process your personal data unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.

Where your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.

Where you object to processing for direct marketing purposes, your personal data can no longer be processed for such purposes.

In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you can exercise your right to object by automated means using technical specifications.

Where personal data is processed for scientific or historical research purposes or statistical purposes pursuant to Article 89 (1) GDPR, you have, on grounds relating to your particular situation, the right to object to processing of your personal data.

Your right of objection can be restricted to the extent that it is likely to render impossible or seriously impair the achievement of research purposes or statistical purposes and the restriction is necessary for the achievement of research purposes or statistical purposes.

8. Right to withdraw of consent to processing personal data

You have the right to withdraw your consent to processing personal data at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

9. Automated individual decision-making, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision:

ⅰ. is necessary for entering into, or performance of, a contract between you and the data controller

ⅱ. is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or

ⅲ. is based on your explicit consent.

However, these decisions must not be based on special categories of personal data referred to in Article 9 (1) GDPR, unless point (a) or (g) of Article 9 (2) GDPR applies and suitable measures to safeguard your rights and freedoms and legitimate interests are in place.

In the cases referred to in section 1 and 3, the data controller has to implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.

10. Right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or place of the alleged infringement in case you consider that the processing of your personal data infringes the provisions of the GDPR.

The supervisory authority with which the complaint has been lodged informs the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to Article 78 GDPR.

Ⅴ. Provision of the website and creation of log files / Hosting

1. Description and scope of data processing

Any time our website is accessed, our system automatically collects data and information from the computer system of the accessing computer.

The following data are collected:

• Information about the browser (browser type and version, rendering engine, user agent, status code, HTTP version, and HTTP method)
• IP address of the User
• Date and time of access
• Websites from which the User’s system accesses our website
• Websites the User’s system accesses from our website

This data is stored in the log files of our system. This data is stored separately from all personal data provided by a user.

2. Purpose of data processing

The system has to temporarily store the IP address to transfer the website to the User’s computer. To that end, the User’s IP address must be retained for the duration of the session.

The storage in log files is done to ensure the website functions properly. In addition, the data is used to optimise the website and to generally ensure the security of our information technology systems. In this connection, data is not analysed for marketing purposes.

Our legitimate interest in data processing in accordance with Article 6 (1)(f) GDPR stems from these purposes.

3. Legal basis for data processing

Article 6 (1)(f) GDPR provides the legal basis for the temporary storage of data and log files.

4. Storage period

The data will be erased once it is no longer necessary for the purpose for which it was collected. When data is collected to allow us to provide our website, this occurs when the relevant session ends.

When data is stored in log files, this data is erased after seven days at the latest.

5. Option to object and have data deleted

The collection of data for the provision of the website and the storage of the data in log files is mandatory for the operation of the website. Therefore the User is not entitled to raise an objection in this context.

Ⅵ. Use of cookies

1. Description and scope of data processing

Cookies are text files that are stored in the internet browser or by the internet browser on the user’s computer system. When a user accesses a website, a cookie may be stored on the user’s operating system. These cookies can contain a characteristic string of characters that enables the browser to be uniquely identified when the website is accessed again. We use two kind of cookie: Technically necessary / session cookies and analytical cookies.

The user data collected in this way is pseudonymised by way of technical precautions. Therefore, it is no longer possible to connect the data to the user accessing the website. The data is not stored together with other personal data of the users.

2. Purpose of the data processing

The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. We use the following technically necessary cookies: “Cookie_notice_accepted” to track the user’s consent

The purpose for using analytical cookies is to help us analyze the use and performance of our website and services. For the Google Analytics cookies (“_ga_94T9VPD2GG” and ”_ga” please see below at section X.

3. Legal basis for data processing

The legal basis for storing technically necessary cookies is § 25 (2) Telecommunications and Telemedia Data Protection Act (Telekommunikation-Telemedien-Datenschutzgesetz – “TTDSG”). Legal basis for storing analytical cookies the processing of personal data by way of using technically necessary cookies is Article 6 (1)(a) GDPR.

4. Duration of storage, possibility of objection and deletion

Cookies are stored on the user’s computer and their data transmitted to our site by the user. Therefore, you as a user also have full control over the use of cookies. You can opt-out of the use of cookies by clicking on following link;

Cookieを無効化する

You can also change the settings in your internet browser to deactivate or restrict the transmission of cookies in general. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If you use a Safari browser version 12.1 or higher, cookies are automatically deleted after seven days. This also applies to opt-out cookies, which are set to prevent tracking measures.

Ⅶ. Newsletters via Email and LINE

1. Description and scope of data processing

Our website gives the opportunity to subscribe to a free newsletter via email or line. While registering for the newsletter, the following data entered into the input mask is transferred to us:

• Email address (only for email newsletters)
• Name
• Telephone/Mobile phone number (only for LINE newsletters)
• IP address of the accessing computer
• Date and time of registration

The data collected will not be passed on to third parties. The data collected is used exclusively for sending the newsletter.

2. Purpose of data processing

The purpose of collecting the User’s name and email address or phone number is to send the newsletter.

The collection of other personal data while registering for the newsletter is necessary in order to prevent misuse of the services or the email address used.

3. Legal basis for data processing

Insofar as the consent of the data subject for the processing of personal data is obtained, Article 6 para. 1(a) GDPR serves as the legal basis for the processing of data after registration for the newsletter by the User.

4. Storage period

The data will be erased once it is longer necessary for the purpose for which it was collected. Therefore, the User’s email address is stored as long as the subscription to the newsletter is active.

The other personal data collected while registering for the newsletter is usually erased after a period of seven days.

5. Option to object and have data deleted

The User can unsubscribe from email newsletters at any time. A corresponding link for this purpose can be find in every email newsletter. To unsubscribe from our LINE newsletters, please block our Line number that we use for such newsletters ([XXX]). As a result, also the given consent to store personal data collected during the registration can be withdrawn.

Ⅷ. Contact via LINE/email/contact form

1. Description and scope of data processing

Users can contact us and the individual schools via LINE, contact form or the email addresses provided on our website. In case the User contacts the schools via LINE or email, the personal data transferred with the User’s LINE account or email will be stored. If Users contact a school via contact form, the data entered will be processed by us as processor on behalf of the individual school and forwarded to it.
The data will be used exclusively for processing the conversation.

2. Purpose of data processing

The legitimate interest necessary for processing this data stems from contacting us via LINE, contact form or email.

3. Legal basis for data processing

Insofar as the consent of the data subject for the processing of personal data is obtained, Article 6 (1)(a) GDPR serves as the legal basis for the processing of data. Article 6 (1)(f) GDPR serves as the legal basis for the processing of data transferred in the course of submitting a contact form or sending an email or LINE message. If the contact via contact form, LINE or email aims at the conclusion of a contract, Article 6 (1)(b) GDPR serves as an additional legal basis for the processing.

4. Storage Period

Due to limitations of LINE we store this data generally for a period of 1 years.

5. Option to object and have data deleted

The User has the right to withdraw his or her consent to the processing of personal data at any time. By way of contacting us or the individual school (in case the User contacted the individual school) via email or LINE, the User can object to the storage of his or her personal data at any time. In such a case, the conversation cannot be continued.

In this case, all personal data stored in the course of the contact will be erased.

Ⅸ. Google Analytics

1. Description and scope of data processing

We use the web analytics service Google Analytics to analyse and improve the use of our website. Google Analytics is a web analytics service provided by Google LLC. The responsible party for users in the EU/EEA and Switzerland is Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”). Google Analytics uses cookies that enable an analysis of your use of our websites. The information collected by means of the cookies about your use of this website is generally transferred to a Google server in the USA and stored there.

Google Analytics 4 has IP address anonymization enabled by default. Due to IP anonymization, your IP address will be truncated by Google within member states of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. According to Google, the IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

During your website visit, your user behavior is recorded in the form of “events”. Events can be:

• Page views
• First visit to the website
• Start of session
• Your “click path”, interaction with the website
• Scrolls (whenever a user scrolls to the bottom of the page (90%))
• clicks on external links
• internal search queries
• interaction with videos
• file downloads
• seen / clicked ads
• language setting

Google also records:

• Your approximate location (region)
• your IP address (in shortened form)
• technical information about your browser and the end devices you use (e.g. language setting, screen resolution)
• your internet service provider
• the referrer URL (via which website/advertising medium you came to this website)

2. Purpose of data processing

On behalf of the operator of this website, Google will use this information to pseudonymous use of the website and to compile reports on website activity. The reports provided by Google Analytics are used to analyze the performance of our website.

3. Recipients

Recipients of the data are/may be:

Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (as processor under Art. 28 DSGVO).

Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA

Alphabet Inc, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA It cannot be ruled out that US authorities may access the data stored by Google.

4. Third country transfer

Insofar as data is processed outside the EU/EEA and there is no level of data protection corresponding to the European standard, we have concluded EU standard contractual clauses with the service provider to establish an appropriate level of data protection. The parent company of Google Ireland, Google LLC, is based in California, USA. A transfer of data to the USA and access by US authorities to the data stored by Google cannot be ruled out. The USA is currently considered a third country from a data protection perspective. You do not have the same rights there as within the EU/EEA. You may not be entitled to any legal remedies against access by authorities.

5. Storage period

The data sent by us and linked to cookies are automatically deleted after 2 months. Data whose retention period has been reached is automatically deleted once a month.

6. Legal basis

The legal basis for this data processing is your consent according to Art.6 Abs.1 S.1 lit.a DSGVO.

7. Option to withdraw consent and have data deleted

The User has the right to withdraw his or her consent to the processing of personal data at any time by clicking on the following link:

Cookieを無効化する

Ⅹ. Application

1. Description and scope of data processing

We allow Users to apply for a job on our website by providing personal data. The data will be entered into an input mask and transmitted to us and stored.

The following data is collected as part of the application process:

• Name (first and last name)
• Sex
• Date of birth
• Address
• E-mail address
• Phone number

Users will also provide information about graduate schools and major in university, CV and references.

Only authorized employees from the personnel department or employees involved in the application process will have access to your data.

2. Purpose of data processing

If Users apply to us via our web form, we will collect and process personal data for the purpose of handling the application procedure and implementing pre-contractual measures.

By submitting an application on our recruiting page, the User expresses his his/her interest in pursuing employment with us. In this context, we use and store the personal data provided to us exclusively for the purpose of your job search/application.

3. Legal basis for data processing

The legal basis for processing the personal data in this context is Article 6(1)(b) GDPR, the fulfilment of a contract. If the User consents to the storage beyond the end of the specific application procedure, legal basis is the User’s consent pursuant to Article 6(1)(a) GDPR.

4. Third country transfer

For processing applications, we use Google forms, a service by Google Ireland. Insofar as data is processed outside the EU/EEA and there is no level of data protection corresponding to the European standard, we have concluded EU standard contractual clauses with the service provider to establish an appropriate level of data protection. The parent company of Google Ireland, Google LLC, is based in California, USA. A transfer of data to the USA and access by US authorities to the data stored by Google cannot be ruled out. The USA is currently considered a third country from a data protection perspective. You do not have the same rights there as within the EU/EEA. You may not be entitled to any legal remedies against access by authorities.

5. Storage period

Personal data is stored exclusively for the purpose of filling the vacant position for which the Users has applied. In the event of an unsuccessful application, the personal data will be stored for a maximum period of two months after the decision to reject your application. This is done in order to comply with legal obligations or to defend against possible claims arising from legal regulations. We are then obliged to erase or anonymise your personal data. In this case, the data is only available to us as so-called metadata without direct personal reference for statistical evaluations (for example, proportion of women or men in applications, number of applications per period, etc.).

For the processing of personal data beyond the end of the specific application procedure, we ask for the User’s consent during the submission process. Only if the User give this consent, the personal data will be stored for a period of twelve months in order to contact the User later and continue the application process if the User is considered for another position.

If the User receives an offer of employment with us during the application process and accept this offer, we will store the personal data collected during the application process for the duration of the employment relationship, if applicable.

6. Option to object and have data deleted

The User can object to the processing of your personal data that we collect as part of the application process and assert his/her rights as a data subject as set in this Privacy Notice at any time. All you have to do is send us an informal e-mail to kaigai@sundai-kaigai.jp.

Ⅺ. Events

1. Description and scope of data processing

Users can sign up for our events on our website. The data will be entered into an input mask and transmitted to us and stored. In the input mask, we collect the following data from the user:

• Name (first and last name)
• E-mail address
• Address

2. Purpose of data processing

The data is only used for holding the event and will be deleted afterwards. Legal basis for storing this data is the user’s consent, Article 6(1)(a) GDPR.

3. Storage period

The data will be erased once it is longer necessary for the purpose for which it was collected. We adhere to the statutory retention periods.

4. Legal basis

The legal basis for this data processing is your consent according to Article 6 (1)(a) GDPR.

5. Option to withdraw consent and have data deleted

The User can withdraw his/her consent and assert his/her rights as a data subject as set in this Privacy Notice at any time. All you have to do is send us an informal e-mail to kaigai@sundai-kaigai.jp.