Privacy Policy
Welcome to the Nippon Kaiji Kyokai's privacy notice for General Data Protection Regulation (GDPR) (EEA).
Nippon Kaiji Kyokai respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you use ClassNK Academy including your visit to our website regarding ClassNK Academy (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy notice is also prepared to comply with the Act on the Protection of Personal Information (APPI) (Japan). Special and unique provisions applicable to your personal data that is governed by APPI are set forth in Section 10 below.
This privacy notice aims to give you information on how Nippon Kaiji Kyokai collects and processes your personal data through your use of ClassNK Academy and this website, including any data you may provide through this website when you contact us.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Nippon Kaiji Kyokai is the controller and responsible for your personal data (collectively referred to as "Company", "we", "us" or "our" in this privacy notice).
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact below.
Our full details are:
Full name of company: Nippon Kaiji Kyokai
Department: Human Resources Development Centre
Representative: Hiroaki Sakashita (President)
Email address: nkacademy@classnk.or.jp
Postal address: 4-7, Kioi-cho, Chiyoda-ku, Tokyo, 102-8567, Japan
Telephone number: +81-3-5226-2188
You have the right to make a complaint at any time to the supervisory authority in your country for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the authority so please contact us in the first instance.
This version was last updated on 14 November 2024.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, last name, date of birth, gender, industry, company name, department, responsibilities, title and years of experience.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| (1) To provide, operate and improve services relating to ClassNK Academy ("Services") (2) To Manage user's usage history on the website (3) To Provide users with information on events, etc. (4) To conduct research, examination, analysis, or development for the purpose of improving the Services (5) To perform necessary items for providing the Services, including identity authentication, contact, billing, support work incidental to the Services, and responses to opinions and requests (6) To complete other business procedures relating to the Services |
(a) Identity Data (b) Contact Data (c) Technical Data |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated) |
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We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below for the purposes set out in the table in Section 4 above.
• Our group companies and subsidiaries.
• Service providers based in Japan who provide IT and system administration services.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We and some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission, including Japan.
• Where we use certain service providers, we may use specific contracts or other measures approved by the European Commission which give personal data the same protection it has in Europe.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
The outline of our security measures is as follows.
• Formulation of basic policy
In order to ensure the proper handling of personal data, a basic policy has been formulated regarding compliance with relevant laws, regulations and guidelines and contact for questions and complaints handling.
• Discipline for the handling of personal data
Internal rules on the handling of personal data have been formulated for each stage of the collection, use, storage, provision, deletion and disposal of personal data, including handling methods, responsible persons, and their duties.
• Organisational security control measures
A person responsible for the handling of personal data has been appointed, employees who handle personal data and the scope of personal data handled by such employees have been clarified, and a system for reporting to the person responsible in the event that a fact or indication of a breach of the applicable law and regulations on the handling of personal data is detected.
Regular self-inspections of the handling of personal data are carried out, as well as audits by other departments and external parties.
• Personnel security control measures
Regular training is provided to employees on matters to be noted concerning the handling of personal data.
The confidentiality of personal data is provided in the employment rules.
• Physical security control measures
In areas where personal data is handled, access control for employees and restrictions on equipment and other items they may bring in are in place, and measures are taken to prevent unauthorised persons from viewing personal data.
Measures are taken to prevent theft or loss of equipment, electronic media and documents that handle personal data, and measures are also taken to ensure that personal data is not easily revealed when such equipment, electronic media, etc. are carried, including when moving within the business premises.
• Technical security control measures
Access controls are implemented to limit the scope of persons in charge and the personal data databases, etc. handled.
A mechanism is in place to protect information systems handling personal data from unauthorised external access and unauthorised software.
• Grasping the external environment
We handle personal data not only in Japan but also in our overseas offices and subsidiaries, and implement safety management measures based on an understanding of the systems for the protection of personal data in the countries where the overseas offices and subsidiaries are located and personal data is processed. For information on the countries where our overseas offices are located, see the Service Network page.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see Request erasure in YOUR LEGAL RIGHTS below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under applicable data protection laws in relation to your personal data. Please refer to “9. Glossary” below to find out more about these rights for your information:.
• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Personal data may be shared with our group companies and subsidiaries.
a) Shared personal data
1） Personal data such as name, address, telephone number, e-mail address and usage data on our website
b) Scope of shared users
Ship Data Center Co., Ltd. and/or our subsidiaries
c) Purpose of use for shared users
1）To provide, operate and improve the Services smoothly
2）To promote sales
3）To execute business and operations being carried out
4）To perform other operations incidental and related to the business and operations of us
d) Names, etc. of the parties responsible for the management of personal date to be shared
We will be responsible for the management of personal data to be shared. For the address and name of the representative of us, please refer to Section 1 above.
Our subsidiaries with which personal data is shared include companies located in China, Singapore, Malaysia, Indonesia, New Zealand, UAE, Qatar, Greece, Poland, the Netherlands, Belgium, Chile and Brazil. For information on the personal data protection legislation of relevant foreign countries, with the exception of the EU and the UK, which are foreign countries with the personal data protection system that is recognised as being of a similar standard to Japan in protecting the rights and interests of individuals under the APPI, see the website of the Personal Information Protection Commission of Japan at: https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/#gaikoku). For information on measures taken by our subsidiaries to protect personal data, please contact us.