Updated 14 June 2019
Here, you can find out how we, HummingByrd Inc. (Level 20 Marunouchi Trust Tower – Main.
1-8-3 Marunouchi, Chiyoda-ku Tokyo 100-0005 Japan), safeguard your information and how we use it to improve our products and services for the benefit of all our customers and website users.
The nature of our business means that, from time to time, we’ll require some personal details from our customers and website users.
The data we collect could just be a name and an email address, but depending on your level of engagement with HummingByrd, it could be much more than that.
The personal information you’ve shared with us, along with data on how you use our websites – what you search for and what preferences you select, for example – help us to better understand our customers as a group and as individuals. This in turn helps us to provide a range of products and services that meet your needs.
HOW WE PROTECT YOUR DATA
When you share your personal information with any company, you have a right to expect that information to be treated with total confidentiality.
Your privacy is extremely important to us. We’re committed to protecting any personal information you’ve given us, and we comply with all relevant data protection laws, including the Personal Data Protection Act (“PDPA”).
This means that:
- We take full responsibility for the information we hold about you
- We will protect your privacy at all times
- We will never sell your personal information.
- what information we collect about you
- how we collect and use this information
- how we safeguard the information you’ve provided
- your rights in relation to the information we hold about you
- how to report abuse.
At HummingByrd, we know that you care how your personal information is used and we appreciate that you trust us to do that carefully and sensibly.
WHAT INFORMATION DOES HUMMINGBYRD COLLECT ABOUT ME?
Personal information that we collect may include your name, contact details (phone numbers, email address and addresses), your date of birth, course information, your personal interests and data about the pages you visit and your other activity on our site, as well as any other personal information relating to you that you supply to us.
Some of our sites may also collect other information that you supply to us, such as information relating to your education, skills or job experience, where relevant in the context of the site or the services provided through the site. Except where stated otherwise on the site at the time such personal information is submitted, it is only processed for the purposes for which you have submitted it to us.
HOW DOES HUMMINGBYRD COLLECT MY PERSONAL INFORMATION?
We collect your information in two ways:
- Personal information you choose to disclose. You may, for example, provide us with your information when you post something on our site, when you register for any features on our site that require registration, when you contact us (online or offline).
We collect information about you that is not personal information. For example, we may collect data relating to your activity on our websites (including the type of internet browser you use, your operating system, address of referring site, your IP address and other clickstream information) via tracking technologies such as cookies, or we may collect information from you in response to a survey, promotion or competition. We may use Google Analytic tools from time to time including Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager integration, or Google Analytics Demographics and Interest Reporting. We generally use this information to report statistics, analyse trends, administer our services, diagnose problems, advertise online, optimize our advertising and websites and target and improve the quality of our products and services.
Cookies allow your browser to utilise some of the features of our websites. We use both session ID cookies and persistent cookies, first party cookies (such as Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on someone’s past visits to our website, to report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our site. Third-party vendors, including Google, may show our ads on sites across the Internet. Most web browsers are set by default to accept cookies. If you reject cookies you will be unable to take advantage of some of the features of our websites. To the extent this information does not constitute personal information, the PDPA is not applicable and we may use this information for any lawful purpose.
We generally advise that you do not publish or communicate personal information, or at least limit the personal information that you publish or communicate, to the public via our services, such as in any forums, blogs or anywhere that user generated content can be uploaded (“Non-Confidential Information”). We cannot control any third party collection or use of your Non-Confidential Information that is publicly available.
We will inform you prior to collecting your personal information if it is requested on a voluntary basis and the consequences of not providing voluntary personal information.
In a separate automatic operation the web server will collect your IP address and browser type and details of the website, application or email communication you came from before entering our site. This information is used to:
- work out how many times our site has been visited
- record which parts of our site have been visited so we can improve the content and layout of the site
- understand the effectiveness of our email communications.
We may from time to time supply this data to third parties in an anonymised form for uses in connection with our site.
WHAT WILL HUMMINGBYRD DO WITH MY PERSONAL INFORMATION?
We use your personal information for a variety of business purposes which are in our legitimate interests (“Business Purposes”), and/or in order to enter into or perform a contract with you (“Contractual”), and/or with your consent (“Consent”), and/or compliance with our legal obligations (“Legal Reasons”). For example, we may use your personal information:
- to provide you with the relevant services through our applicable site for Contractual reasons
- to process your online purchases for Contractual reasons
- to inform you about and provide more information on products and services offered by us for our Business Purposes or with your Consent
- to invite you to participate in surveys, discussions and prize draws and ask for your views on our services via online surveys and discussion forums for our Business Purposes and/or with your Consent
- to improve the products and services offered to you for our Business Purposes
- for marketing for our Business Purposes and/or with your Consent
- for statistical or analytical purposes for our Business Purposes
- to detect, prevent or investigate security breaches or fraud for our Business Purposes and/or Legal Reasons
- to otherwise to better meet the needs and preferences of our customers for our Business Purposes.
We will not allow unrelated third parties to use your personal information for marketing without your consent. Where we rely on your consent, you have the right to withdraw it at any time.
We also use personal information to identify types of user, audit how our sites are used and to help with the strategic development of our sites. When doing so, we remove any direct identifiers.
Participation in surveys and discussion forums is entirely voluntary. You may unsubscribe from being contacted for these purposes at any time. Survey information will be used for market research with the aim of improving our services.
We will show your username on any content you submit or post on our sites (including discussions, bulletin boards and forums).
WILL HUMMINGBYRD SHARE MY PERSONAL INFORMATION WITH ANYONE ELSE?
We will never sell your personal information. We may disclose and share your personal information with:
- our group companies
- any entity which acquires any part of our business
- our service providers (including, for example, credit reference agencies and payment processors, distributors/agents of our products, suppliers who develop or host our sites)
- third-party search engines that may index user profile pages and usernames as part of the URL of the user profile page by default if required or permitted by law
- relevant third parties (such as your employer, your school, your internet service provider, law enforcement agencies) if we reasonably believe you may be in breach of the law (e.g. if you have posted defamatory content on our sites) or if required to do so in accordance with applicable law
- other third parties with your consent.
EMAIL MARKETING AND OPT-OUT
We will not send you marketing emails if you have opted out of receiving them. Any marketing emails we send you will include an unsubscribe link at the end of the email.
The HummingByrd sites also provides contact details you may use if you want to contact us by email, post or telephone in order to unsubscribe.
HOW DOES HUMMINGBYRD KEEP MY PERSONAL INFORMATION SAFE?
We seek to protect the safety of all your personal information by implementing appropriate technical and organisational measures. For example, provided your browser accepts HTTPS (Hyper Text Transfer Protocol Secure) encryption, we seek to protect your payment information against unauthorised access through a secure server. Where we use third parties to process personal information, we require them to ensure the safety of your information.
Any personal information that you voluntarily post on a public area of our site, such as a bulletin board or discussion forum, or an interactive area requiring registration and/or subscription, may be collected and used by others. Please be careful what personal information you disclose in this way. You understand that we cannot control the actions of other users.
WILL HUMMINGBYRD SEND MY PERSONAL INFORMATION TO ANOTHER COUNTRY?
FOR HOW LONG WILL HUMMINGBYRD KEEP MY PERSONAL INFORMATION?
We will keep your personal information only for as long as necessary to fulfil the purposes for which we are processing your personal information unless the law permits or requires longer. For example, we might need to keep your personal data for quality assurance of the service we have provided, or we might need to keep it to defend future legal claims.
WHAT IF I AM UNDER 16 YEARS OLD?
WHAT RIGHTS DO I HAVE?
Subject to the exceptions set out in the PDPA and other applicable privacy laws, you may request to access, update or correct the personal information we hold about you. We will require you to verify your identity and to specify the information that you wish to access, update or correct. A fee may be charged for providing access however we will advise you of the likely cost in advance.
Subscribers or members of our websites will generally be able to access, update and correct their membership and contact details online.
We request that you keep your information as current as possible so that we may continue to improve our service to you.
In some regions, such as the EEA (European Economic Area), you may have certain rights in relation to your personal information, including the right to:
- request access to and obtain a copy of your personal information
- rectification of your personal information if it is no longer accurate or erasure of your personal information if our retention is no longer necessary for the purposes for which it was collected
- restrict or object to the processing of your personal information in certain circumstances
- data portability (if applicable).
If you wish to exercise any of your rights in relation to your personal information please send your request to us using the details set out in the “Contact HummingByrd” section below. We will consider and act upon any request in accordance with applicable data protection laws.
MISUSE OF PERSONAL INFORMATION
If you suspect any misuse, interference or loss, or unauthorised access, modification or disclosure in respect of your personal information, please let us know immediately.
You agree not to misuse any personal information available on our sites or to gather it or use robots or other automated scripts, codes or functionalities to do so.
CONTACT HUMMINGBYRD INC.
Attention: Data Protection Officer
Level 20 Marunouchi Trust Tower – Main.
1-8-3 Marunouchi, Chiyoda-ku
Tokyo 100-0005 Japan