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This website is owned and maintained by Sasuga Communications K. K. (\u201cthe Company\u201d). Please read these terms of use (\u201cthe Terms\u201d) carefully. These Terms apply to your use of the website identified as sasugacommunications.com (\u201cthe Website\u201d). These Terms should be read in conjunction with the Company\u00a0Privacy Policy. We reserve the right to vary or alter these Terms from time to time and any change made to these Terms will take effect immediately when posted on the Website with a date of last update attached. By using this Website, you agree to be bound by these Terms. Please note that these Terms do not apply to training, coaching, or other products and services provided by the Company to its clients. Any training, coaching, or other products and services are subject to the terms agreed in writing between clients and and the Company.<\/p>\n
WEBSITE PRIVACY<\/b><\/p>\n
This Website has content and tools that you can view and access without the necessity of providing any personal information. Where you voluntarily provide personal details, the Company will only use that information for the purpose for which it was intended and to communicate with you. Any personal information you submit is stored securely by the Company or the Company\u2019s contracted service provider and will not be disclosed to any third parties, except as required or permitted by relevant laws in Japan. Please read the Company\u2019s Privacy Policy (below).<\/p>\n
USE OF COOKIES\u00a0<\/b><\/p>\n
The Company uses cookies to collect data about users who visit this Website. We use that data to compile statistics about how the Website is used such as what pages have been accessed, what documents are downloaded, and what tabs are opened.\u00a0 Gathering this information about Website usage helps the Company understand what users find useful and also helps us to update the user experience of the Website. Please read the Company\u2019s Cookies Policy (below).<\/p>\n
WEBSITE GOVERNING LAW<\/b><\/p>\n
The Company is based in Tokyo, Japan. These Terms are governed by and construed by the laws of Japan, exclusive of its choice of law . Website users agree that any disputes or proceedings between the Company and you concerning these Terms and\/or the Website shall be brought exclusively in a court of competent jurisdiction sitting in Tokyo, Japan, and you hereby consent to the personal jurisdiction and venue of such court.<\/p>\n
WEBSITE INTELLECTUAL PROPERTY<\/b><\/p>\n
This Website and content are subject to copyright \u00a9 2025 by Sasuga Communications K. K. All rights are reserved except as expressly stated. By using this Website, you agree not to copy, amend, reproduce, republish or distribute any of its content without permission in writing from Sasuga Communications K. K.. Permission may be requested by contacting the Company via email to: info@sasugacommunications.com.<\/p>\n
Last updated: April 23, 2025<\/b><\/p>\n\u00a0<\/h2>\n
SASUGA COMMUNICATIONS K. K. PRIVACY POLICY<\/b><\/h2>\n
\u00a0<\/b><\/p>\n
HOW WE USE YOUR DATA<\/b><\/p>\n
General<\/b><\/p>\n
Sasuga Communications K. K. (\u201cSASUGA\u201d or \u201cWe\/Our\u201d) and trusted partners acting on our behalf, use your personal data:<\/p>\n
– to provide products and services to you;<\/p>\n
– to make a tailored website available to you (subject to our Terms of Use (above);<\/p>\n
– to verify your identity;<\/p>\n
– for crime and fraud prevention, detection and related purposes;<\/p>\n
– with your agreement, to contact you electronically about promotional offers, products, and services which we think may interest you;<\/p>\n
– for market research purposes – to better understand your needs;<\/p>\n
– to enable us to manage customer service interactions with you; and<\/p>\n
– where we have a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute)<\/p>\n
Newsletter and Marketing<\/b><\/p>\n
Promotional communications<\/p>\n
SASUGA uses your personal data for electronic marketing purposes (with your consent) and to update you on topics of interest related to communication and personal development.\u00a0 SASUGA aims to update you about products and services which are of interest and relevant to you as an individual. You have the right to opt out of receiving promotional communications at any time, by:<\/p>\n
1.\u00a0 changing marketing preferences via email to info@sasugacommunications.com;<\/p>\n
2. making use of the simple \u201cunsubscribe\u201d link in emails; and\/or<\/p>\n
3. contacting SASUGA via the contact channels set out in this Policy.<\/p>\n
Newsletter<\/p>\n
Where you have signed up for SASUGA\u2019s newsletter, we may collect data directly from you, as well as analyzing your browsing activity, online activity, and your responses to marketing communications. The results of this analysis, together with other demographic data, allow us to ensure that we contact you with information on products and services that are relevant to you. To do so, we use software and other technology.<\/p>\n
Web Banner Advertising<\/p>\n
We do not use web banner advertising. We may use \u2018cookies\u2019 placed on your computer or other devices (see further information on the use of cookies in our Cookie Policy (below).\u00a0You can remove or disable cookies at any time – see below for further information.<\/p>\n
Sharing data with third parties<\/b><\/p>\n
Our service providers and suppliers<\/p>\n
In order to make certain products and services available to you, we may need to share your personal data with some of our service partners.\u00a0These include administration support personnel, IT, IP attorneys, accountants and other legal service providers who are trusted partners of SASUGA (\u201cservice providers\u201d).<\/p>\n
SASUGA only allows its service providers to handle your personal data when we have confirmed that they apply appropriate data protection and security controls. We review our agreements with service providers from time to time to ensure that these agreements also impose contractual obligations on service providers relating to data protection and security, which means they can only use your data to provide products and services to SASUGA and to you, and for no other purposes.<\/p>\n
Other third parties<\/p>\n
Aside from our service providers, SASUGA will not disclose your personal data to any third party, except as set out below.\u00a0We will never sell or rent our customer data to other organizations for marketing purposes.<\/p>\n
We may share your data with:<\/p>\n
– our carefully selected partners who provide SASUGA branded products and services, if we have your consent to do so;<\/p>\n
– credit reference agencies where necessary for payments;<\/p>\n
– governmental bodies, regulators, law enforcement agencies, courts\/tribunals and insurers where we are required to do so: –<\/p>\n
– to comply with our legal obligations;<\/p>\n
– to exercise our legal rights (for example in court cases);<\/p>\n
– for the prevention, detection, investigation of crime or prosecution of offenders; and<\/p>\n
– for the protection of our employees and customers.<\/p>\n
International transfers<\/b><\/p>\n
As SASUGA is located outside of the European Economic Area (EEA), in order to deliver products and services to you, it will be necessary for SASUGA to share your data outside of the EEA.\u00a0This will typically occur when service providers are located outside the EEA or if you are based outside the EEA, for example in Japan.\u00a0These transfers are subject to special rules under data protection laws.<\/p>\n
If this happens, we will ensure that the transfer will be compliant with data protection law and all personal data will be secure. Our standard practice is to use \u2018standard data protection clauses\u2019 which have been approved by the European Commission for such transfers.<\/p>\n
HOW LONG DO WE KEEP YOUR DATA?<\/b><\/p>\n
We will not retain your data for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of data, however the longest we will normally hold any personal data is ten (10) years.<\/p>\n
\u00a0<\/b><\/p>\n
WHAT PERSONAL DATA DO WE COLLECT?<\/b><\/p>\n
SASUGA may collect the following information about you:<\/p>\n
– your name and gender;<\/p>\n
– your contact details: postal address including billing and delivery addresses, telephone numbers (including mobile numbers) and e-mail address;<\/p>\n
– products and services purchased by you;<\/p>\n
– your online browsing activities on the SASUGA website;<\/p>\n
– when you make a purchase, your payment details;<\/p>\n
– your communication, marketing preferences and your reactions and responses to our communication;<\/p>\n
– your interests, preferences, feedback and survey responses;<\/p>\n
– your location;<\/p>\n
– your correspondence and communications with SASUGA; and<\/p>\n
– other publicly available personal data, including any which you have shared via a public platform (such as a LinkedIn page or public Facebook page, or other social media).<\/p>\n
Our website is not intended for children and we do not knowingly collect data relating to children.<\/p>\n
This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this Policy. Some of the above personal data is collected directly, for example when you participate in SASUGA training, coaching, webinars, retreats, or other events. Other personal data is collected indirectly, for example your web browsing activity. We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources.<\/p>\n
We also receive personal data from trusted third parties who provide products and services to our customers under the SASUGA brand, such as SASUGA\u2019s Bank (The Bank of Tokyo-Mitsubishi UFJ) and SASUGA\u2019s tax and accountancy service provider (name available upon request to info@sasugacommunications.com). SASUGA\u2019s Bank will share with us details of payments made using your bank account, which we may use to analyze client behavior and improve our products and services.<\/p>\n
HOW WE PROTECT YOUR DATA
<\/b><\/p>\n
SASUGA is committed to keeping your personal data safe and secure.<\/p>\n
Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.<\/p>\n
We use regular Malware Scanning.<\/p>\n
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive\/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.<\/p>\n
We implement a variety of security measures when a user places an order enters, submits, or accesses their information to maintain the safety of your personal information.<\/p>\n
All transactions are processed through a gateway provider and are not stored or processed on our servers.<\/p>\n
WHAT YOU CAN DO TO HELP PROTECT YOUR DATA<\/b><\/p>\n
SASUGA will never ask you to confirm any bank account or credit card details via email.\u00a0 If you receive an email claiming to be from SASUGA asking you to do so, please ignore it and do not respond. If you are using a computing device in a public location, we recommend that you always log out and close the website browser when you complete an online session.<\/p>\n
YOUR RIGHTS<\/b><\/p>\n
You have the following rights:<\/b><\/p>\n
– the right to ask for a copy of personal data that we hold about you (the right of access);<\/p>\n
– the right (in certain circumstances) to request that we delete personal data held on you; where we no longer have any legal reason to retain it (\u201cthe right of erasure or to be forgotten\u201d);<\/p>\n
– the right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you (\u201cthe right of rectification\u201d);<\/p>\n
– the right to opt out of any marketing communications that we may send you and to object to us using\/holding your personal data if we have no legitimate reasons to do so (\u201cthe right to object\u201d);<\/p>\n
– the right (in certain circumstances) to ask us to \u2018restrict processing of data\u2019; which means that we would need to secure and retain the data for your benefit but not otherwise use it (\u201cthe right to restrict processing\u201d); and<\/p>\n
– the right (in certain circumstances) to ask us to supply you with some of the personal data we hold about you and provide a copy of the data in such a format to another organization (\u201cthe right to data portability\u201d).<\/p>\n
If you wish to exercise any of the above rights, please contact us via info@sasugacommunications.com.<\/p>\n
LEGAL BASIS FOR USING DATA<\/b><\/p>\n
We are required to set out the legal basis for our \u2018processing\u2019 of personal data.<\/p>\n
GENERAL<\/b><\/p>\n
SASUGA collects and uses customers\u2019 personal data because is it necessary for:<\/p>\n
– the pursuit of our legitimate interests (as set out below);<\/p>\n
– the purposes of complying with our duties and exercising our rights under a contract for the sale of products and services to a customer; or<\/p>\n
– complying with our legal obligations.<\/p>\n
In general, we only rely on consent as a legal basis for processing personal data in relation to sending direct marketing communications to customers via email or text message.<\/p>\n
Customers have the right to withdraw consent at any time.\u00a0Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.<\/p>\n
Our legitimate interests<\/b><\/p>\n
The normal legal basis for processing customer data, is that it is necessary for the legitimate interests of SASUGA, including:-<\/p>\n
– selling and supplying products and services to our customers;<\/p>\n
– protecting customers, employees, and other individuals and maintaining their safety, health and welfare;<\/p>\n
– promoting, marketing, and advertising our products and services;<\/p>\n
– sending promotional communications which are relevant and tailored to individual customers;<\/p>\n
– improving products and services and developing new products and services;<\/p>\n
– complying with our legal and regulatory obligations in Japan and the United Kingdom, where applicable;<\/p>\n
– preventing, investigating, and detecting crime, fraud or anti-social behavior and prosecuting offenders, including working with law enforcement agencies;<\/p>\n
– handling customer contacts, queries, complaints or disputes;<\/p>\n
– protecting SASUGA, its employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to SASUGA;<\/p>\n
– effectively handling any legal claims or regulatory enforcement actions taken against SASUGA; and<\/p>\n
– fulfilling our duties to our customers, colleagues, and other stakeholders.<\/p>\n
COOKIES<\/b><\/p>\n
Our website uses cookies to collect information.\u00a0This includes information about browsing behavior by people who access our website.\u00a0This includes information about pages viewed and the general customer journey around our website. Detailed information is set out in our Cookies Policy (below).<\/p>\n
DATA PROTECTION OFFICER<\/b><\/p>\n
SASUGA has appointed a Data Protection Officer to ensure we protect the personal data of our customers (and others) and comply with data protection legislation.<\/p>\n
If you have any questions about how SASUGA uses your personal data that are not answered here, or if you want to exercise your rights regarding your personal data, please contact our Data Protection Officer\u2019s team by<\/p>\n
– phone: +81-80-5021-3365;<\/p>\n
– e-mail: info@sasugacommunications.com; or<\/p>\n
– write to: Data Protection Officer, Sasuga Communications K. K., 6F Nishi-Shinjuku Mizuma Building, 3-3-13 Nishi-Shinjuku, Shinjuku-ku, Tokyo 106-0023, Japan<\/p>\n