NIPPON CLUB DATA PROTECTION AND PRIVACY POLICY

1. Introduction

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

Nippon Club is registered as a data controller with the Information Commissioner's Office under registration Z4608412.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (“UK GDPR”).

Key terms used in this policy:

We, us, our	Nippon Club
Personal data	Any information relating to an identified or identifiable individual
Special category personal data	Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic data Biometric data (where used for identification purposes) Data concerning health, sex life or sexual orientation

2. What information do we collect?

We collect and process personal data, including special categories of personal data, about you when you interact with us by becoming a member or patient, through our websites or otherwise. The personal data we process may include:

• your and your family members' name;
• your and your family members' date of birth;
• your and your family members' gender;
• your and your family members' nationality
• your and your family members' home or work address, email address and/or phone number(s);
• details of your current employment, including your position/job title and the name of your employer;
• copies of your identity documents;
• financial information, such as bank account or card payment details;
• your Nippon Club membership number and registered account information;
• your marital status and, if applicable, the name of your spouse and other family members eligible to share Nippon Club primary membership (in the event family membership rather than individual membership is applied for)
• your image (e.g. through the use of CCTV)
• information related to the browser, device and operating system you use to access our website;
• your Internet Protocol (IP) address;
• information relating to how you use our websites;
• any other information you provide or which is provided to us on your behalf.

Certain personal data we collect is treated as a special category personal data to which additional protections apply under data protection law:

Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, eg:

We collect and process personal data, including special categories of personal data, about you when you interact with us by becoming a member or patient, through our websites or otherwise. The personal data we process may include:

• we have your explicit consent;
• the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
• the processing is necessary to establish, exercise or defend legal claims.

3. Where do we obtain this information?

We obtain the information we process from:

• you or your family directly (e.g. via online forms, in person, by telephone, email or otherwise);
• new applicants (where your name and contact details are provided as a referee to support an individual membership application);
• the company for whom you or your family work;
• those acting on your behalf;
• third parties that introduce you to us; and
• search engine and web analytics services providers.

4. How do we use this information and what is the legal basis for this use?

We process the personal data listed in paragraph 2 above for the following purposes:

• to verify your identity, in accordance with our legitimate interests and/or our legal obligations;
• to deliver our products and services, including to determine your eligibility for individual or family membership to the Nippon Club (including assessment of which category/level of membership is applicable) and to administer such membership, in accordance with our legitimate interests, to perform a contract to which you are a party, at your request prior to entering into a contract, and/or with your consent;
• to assess your eligibility as a non-member guest or family member of a Nippon Club member, in accordance with our legitimate interests, at your request prior to entering into a contract, and/or with your consent;
• for managing and planning club activities and services for members and non-members, such as seminars, dining events and functions, in accordance with our legitimate interests;
• to record your attendance at Nippon Club Annual General Meetings, in accordance with our legitimate interests;
• for marketing and reporting purposes, including provision of our bimonthly newsletter: "Big Ben" where you have provided your consent to receive these communications and/or in accordance with our legitimate interests;
• to provide you with information about competitions and events, including in connection with Nippon Club's recreational activity groups where you have provided your consent and/or in accordance with our legitimate interests;
• to enable us to maintain our records and manage our relationship with you, in accordance with our legitimate interests and/or our legal obligations;
• to investigate any complaints received from you or from others, in accordance with our legitimate interests and legal obligations;
• to enable us to comply with applicable law and regulation, in accordance with our legitimate interests and/or our legal obligations;
• to identify, assess and manage risk on an ongoing basis within the Nippon Club, in accordance with our legitimate interests;
• to prevent, detect, investigate and report suspected or actual financial and other crime, in accordance with our legal obligations and our legitimate interests;
• to investigate and handle legal, compliance and regulatory issues, including litigation, in accordance with our legal obligations and our legitimate interests;
• to monitor the use of our websites and to help us check, improve and protect our content, services and websites, both online and offline, in accordance with our legitimate interests;
• to monitor the use of our office and to help us keep our office building, staff and information safe and secure, in accordance with our legitimate interests and/or to protect the vital interests of you and others;
• to invite you to take part in surveys, where you have consented and/or in accordance with our legitimate interests; and
• to assess and process any job application, and for subsequent employment, legal and administrative purposes including confirming your right to work, as necessary to take steps at your request prior to entering into a contract or to perform a contract (in which case we will be unable to progress your application without it), and/or in accordance with our legitimate interests.

5. With whom and where will we share your personal data?

We may share your personal data with:

• Our staff, including members of our Board;
• our professional advisors, such as our auditors, external legal and financial advisors and insurers;
• your employer;
• our suppliers, business partners and sub-contractors;
• online service providers;
• search engine and web analytics services providers;
• HM Revenue & Customs, regulators and other authorities, including law enforcement bodies;
• your advisors and/or other entities linked with you.

Our website may, from time to time, contain links to and from the websites of third parties such as our sponsors. If you follow a link to any of these third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these third party privacy policies before you submit any personal information to such websites.

6. How long will you keep my personal data?

We will not keep your personal data for any purpose(s) for longer than is necessary and we will only retain the relevant personal information that is necessary in relation to the purpose for which it was collected.

We will retain information relating to recruitment for employment positions for so long as it takes to process your application and, if it is unsuccessful, for an additional period of no greater than 6 months. If your application is successful, we will retain your personal data in accordance with our staff privacy policy.

We will retain information relating to the following activities as follows.

Type of Personal Data	Storage time period
Membership information	6 years after lapse of membership.
Web browsing information	26 months last access.

We will retain your data for a short time beyond the specified retention period, to allow for information to be reviewed and any deletion to take place.

7. Where is my personal data stored?

We store personal data within the UK. Any transfer of personal data outside the EEA will only be conducted with your explicit consent, or with other appropriate safeguards in place.

8. What are my rights in relation to my personal data?

You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by withholding your email address when you complete your membership form or unsubscribing from any communication we send you.

Where you have consented to us using your personal data, you can withdraw that consent at any time by contacting us.

If the information we hold about you is inaccurate or incomplete, please notify us and ask us to correct or supplement it.

You also have the right, with some exceptions, to ask us to provide a copy of any personal data we hold about you.

Where you have provided personal data to us and it is processed by automated means, you may be able to request that we provide it to you in a structured, machine readable format. If you have a complaint about how we have handled your personal data, you may be able to ask us to restrict how we use your personal data while your complaint is resolved.

In some circumstances you can ask us to erase your personal data if you withdraw your consent, it is no longer necessary for us to use your personal data, you object to the use of your personal data and we don't have a good reason to continue to use it, or we haven't handled your personal data in accordance with our obligations.

9. Personal data of children

We will only collect and process the personal data of individuals under the age of 20 with consent from a parent or legal guardian.

10. Keeping your personal data secure

We have appropriate security measures to prevent personal data from being lost accidentally, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

11. How to complain

Please contact us if you have any queries or concerns about our use of your personal data. We hope we will be able to resolve any issues you may have.

You may also have the right to lodge a complaint with the Information Commissioner (the UK data protection regulator).

12. Changes to this privacy policy

This privacy notice was published in July 2024.

We may change this privacy notice from time to time—when we do we will inform you via our website or other means of contact such as email.

13. Updating your personal data

We take reasonable steps to ensure your personal data remains accurate and up to date. To help us with this, please let us know if any of the personal data you have provided to us has changed, eg your surname or address.

14. How to contact us

For further information or to raise a concern, please contact:

Data protection:
Nippon Club
725A Salisbury House,
29 Finsbury Circus
London
EC2M 5QQ

If you are dissatisfied with our response, you can contact the Information Commissioner's Office:
https://ico.org.uk/