Data Protection Policy
This Data Protection Policy (the “Policy”) applies to the collection, use and disclosure of an individual’s Personal Data (hereinafter defined) arising from service offerings including, but not limited to, events, trainings and programs offered by Shinnyo‑en, and all entities of Shinnyo‑en around the world (collectively referred to as “Shinnyo‑en”).
1.1 This Policy statement provides information on the obligations and policies of Shinnyo‑en in respect of an individual’s Personal Data. Shinnyo‑en undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations.
1.2 Shinnyo‑en’s officers, management, and members of staff shall use reasonable endeavors to respect the confidentiality of and keep safe any and all Personal Data collected and/or stored and/or disclosed and/or used for, or on behalf of, Shinnyo‑en. Shinnyo‑en shall use reasonable endeavors to ensure that all collection and/or storage and/or disclosure and/or usage of Personal Data by Shinnyo‑en shall be done in an appropriate manner and in accordance with the Act and this Policy.
1.3 By interacting with us, registering as a member with us, submitting information to us, or signing up for service on the website shinnyoen.org, you agree and consent to Shinnyo‑en as well as to its respective representatives and/or agents ("Representatives") (collectively referred to herein as "Shinnyo‑en", "us", "we" or "our") collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to Shinnyo‑en’s authorized service providers and relevant third parties in the manner set forth in this Privacy Statement.
1.4 This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.
1.5 For the purposes of this Policy, in line with the provisions under the Protection of Personal Information Act (No. 37 of 2021) in Japan (the “Act”), “Personal Data” shall mean data, whether true or not, about an individual who can be identified — from that data; or from that data and other information which an organization has or is likely to have access. Such Personal Data shall also refer to that which is already in the possession of Shinnyo‑en or that which shall be collected by Shinnyo‑en in future.
2. Contacting the Data Protection Officer
2.1 Where you legitimately request access to and/or correction of Personal Data relating to you, such Personal Data which is in the possession and control of Shinnyo‑en, Shinnyo‑en shall provide and/or correct that data within 30 days and in a manner in accordance with its standard procedures as stated hereinafter.
2.2 In accordance with the Act, Shinnyo‑en has established a process for receiving and responding to any query or complaint that may arise with respect to the application of this Act. To ensure that Shinnyo‑en receives your complaints and enquiries, please send the same via email to the Data Protection Officer (the “DPO”) of Shinnyo‑en at the following email address: firstname.lastname@example.org.
2.3 Please note that if your personal data has been provided to us by a third party (e.g. via a referral), you should contact that individual to make such queries, complaints, and access and correction requests to Shinnyo‑en on your behalf.
2.4 Should you not wish Shinnyo‑en to use your Personal Data for any of the purposes listed in Clauses 3.2 to 3.4, or not to receive materials or communications from Shinnyo‑en, you may opt out by sending a clearly worded email to the DPO via the email address provided in Clause 2.2. Your request shall be processed within 30 days. Please note however that this may affect our ability to attend to your needs with respect to the details that we have previously requested you to submit.
3. Statement of Website activities
Types of Personal Data Collected:
3.1 As part of its day-to-day activity, Shinnyo‑en may collect from you, through various means, including via our websites, events, and any forms used by Shinnyo‑en from time to time, including but not limited to, the following Personal Data:
- Name (first and surname);
- Email address;
- Location where you access to the Website (City, Country or Region).
Purpose of Collection of Personal Data
3.2 The above Personal Data mentioned in Clause 3.1 is collected for the purposes of delivering the newsletter and conducting analysis for service optimization or other related purposes; to provide you with any services which you may require; to conduct market research and analysis; to notify you of any changes to our policies or services which may affect you; to respond to queries and feedback; for identification and center; maintaining and updating your membership details; and informing you of new developments, services, promotions of Shinnyo‑en and other third parties which we are associated with.
Disclosure of Personal Data
3.3 In order to carry out the functions described above, Shinnyo‑en may, from time to time, disclose your Personal Data between Shinnyo‑en’s entities.
3.4 Without derogating from any of the above, Shinnyo‑en may also disclose your Personal Data to the following third parties:
- Regulators and law enforcement officials;
- Third party service providers and consultants including web hosting and membership portal vendors; and
- Any agent or subcontractor acting on Shinnyo‑en’s behalf for the provision of Shinnyo‑en’s services.
3.5 Shinnyo‑en may disclose your Personal Data to the abovementioned parties also in the occurrence of any of the following events:
- To the extent that Shinnyo‑en is required to do so by the law;
- In connection with any legal proceedings or prospective legal proceedings;
- To establish, exercise or defend Shinnyo‑en’s legal rights;
- To any person and/or entity for the purpose of processing such information on Shinnyo‑en’s behalf;
- To third parties who provide services to Shinnyo‑en or on its behalf;
- With your consent; and
- For the purposes of disaster recovery.
Optional Provision of Personal Data
3.6 Under certain circumstances, telephone calls made to any of Shinnyo‑en’s temples/ centers to order and/or service hotlines and/or inquiry telephone numbers are recorded for the purposes of quality control, appraisal, as well as staff management and development. In such an event, by agreeing to this Policy, you hereby give your consent for the collection, use and disclosure of such Personal Data for the purposes of our records, following up with your enquiry and/or transaction, and for quality control and training purposes.
4. Transfer of Personal Data Overseas
Your Personal Data will be processed by Shinnyo‑en, its affiliates, agents and third parties providing services to Shinnyo‑en in Japan, in jurisdictions outside of Japan, as well as the country which you are residing in. In this event Shinnyo‑en will comply with the terms of the Act.
5. Accuracy of Personal Data
Where possible, Shinnyo‑en will validate data provided using generally accepted activities and guidelines. In some instances, Shinnyo‑en is able to validate the data provided against pre-existing data held by Shinnyo‑en. In some cases, Shinnyo‑en is required to see original documentation before we may use the Personal Data such as with Personal Identifiers and/or proof of address. To assist in ensuring the accuracy of your Personal Data in the possession of Shinnyo‑en, please inform us of any updates of any parts of your Personal Data by sending a clearly worded email to the DPO at the email address provided at Section 2.2.
6. Protection of Personal Data
Shinnyo‑en uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside Shinnyo‑en, other than to you or as described in this Policy. However, Shinnyo‑en cannot ensure or warrant the security of any information you transmit to Shinnyo‑en and you do so entirely at your own risk. In particular, Shinnyo‑en does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any of Shinnyo‑en’s physical, technical, or managerial safeguards.
7. Access and Correction of Personal Data
7.1 In accordance with Clause 2.1 of this Policy, you have the right to:a) check whether Shinnyo‑en holds any Personal Data relating to you and, if so, obtain copies of such data; andb) require Shinnyo‑en to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used.
7.2 Shinnyo‑en reserves the right to charge a reasonable administrative fee in order to meet your requests under Clause 7.1(a). Upon payment of the requisite fee under Clause 7.1(a) and/or receipt of your request under Clause 7.1(b), your request shall be processed within 30 days.
7.3 If you wish to verify the details you have submitted to Shinnyo‑en or if you wish to check on the manner in which Shinnyo‑en uses and processes your personal data, Shinnyo‑en’s security procedures mean that Shinnyo‑en may request proof of identity before we reveal information. This proof of identity will take the form of full details of name, membership number and relevant identification number. You must therefore keep this information safe as you will be responsible for any action which Shinnyo‑en takes in response to a request from someone using your membership details. We would strongly recommend when you login to your online account in our websites that you do not use the browser's password memory function as that would permit other people using your terminal to access your personal information.
8. Storage and Retention of Personal Data
Shinnyo‑en will delete, as reasonably possible, or otherwise anonymize any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of Shinnyo‑en and where the Personal Data is deleted from Shinnyo‑en’s electronic, manual, and other filing systems in accordance with Shinnyo‑en’s internal procedures and/or other agreements.
9. Change Policy
Shinnyo‑en reserves the right to alter any of the clauses contained herein in compliance with local legislation, and for any other purpose deemed reasonably necessary by Shinnyo‑en. You should look at these terms regularly. If you do not agree to the modified terms, you should inform us as soon as possible of the terms to which you do not consent. Pending such notice, if there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.
10. Governing Law
This Policy is governed by and shall be construed in accordance with the laws of Japan. You hereby submit to the non-exclusive jurisdiction of the Japan courts.
11.1 This Policy only applies to the collection and use of Personal Data by Shinnyo‑en. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. Shinnyo‑en does not share your Personal Data with third party websites. Shinnyo‑en is not responsible for the privacy and conducts activities of these third-party websites, so you should read their own privacy policies before disclosure of any Personal Data to these websites.
11.2 Shinnyo‑en will not sell your personal information to any third party without your permission, but we cannot be responsible or held liable for the actions of third-party sites which you may have linked or been directed to Shinnyo‑en’s website.
11.3 In cases where personal data of a minor is involved, Shinnyo‑en will seek the relevant consent from the minor’s parent/guardian.