Circular E recognizes the importance of protecting personal information and is committed to handling it appropriately.
This Privacy and Cookie Policy (the “Policy”) describes how we collect, use, and manage personal data and cookie information through our website (https://www.cir-e.com/) and related services.
We comply with the Act on the Protection of Personal Information of Japan and other applicable laws and regulations.
This Policy applies to all users of our website and governs the handling of personal data we obtain.
1.Introduction
This Policy explains how Circular E handles personal data and cookies obtained through its website and related services.
It applies to all users of our website and services, both domestic and international.
2. Types of Personal Data Collected
We may collect and use the following categories of personal data:
(1) Information collected through inquiries:
- Name
- Email address
- Company name, department, position
- Phone number
- Inquiry content
- Any other information you voluntarily provide
Purpose:
Responding to inquiries, sending materials, providing service information, business communications
(2) Information automatically collected from your device when using our services (including cookies):
- IP address
- Device, browser, and OS information
- Cookie information
- Access logs, browsing history, usage logs
- Referrer URLs
Purpose:
Analyzing site usage, service improvement, traffic measurement, security management, marketing optimization
(3) Information collected through your event applications and surveys:
- Event or seminar registration details (name, email, company, etc.)
- Survey responses
- Campaign or promotion participation details
Purpose:
Event management, participant administration, survey analysis, promotional campaign operations
(4) Information collected at the time of membership registration:
- Registration information (name, email, phone number, company name, company address, password, etc.)
- payment-related information
Purpose:
Providing the service, improving the service, managing members, analyzing survey results, carrying out promotional activities
3. Purposes of Use of Personal Data
We use the collected personal data for the following purposes:
(1) Service provision and management:
- Operating, improving, and providing our website and services
- Communication necessary for service provision
- Contract execution, invoicing, payment, and transaction management
(2) Responding to inquiries and providing information:
- Addressing customer feedback, requests, and inquiries
- Sending materials, conducting meetings, business negotiations
- Follow-ups and communications related to inquiries
(3) Marketing activities and analysis:
- Informing about events, seminars, and campaigns
- Conducting surveys and requesting feedback for service improvement
- Analyzing website access, preparing statistical data, planning marketing activities
- Providing service recommendations and delivering advertisements based on usage patterns
4. Use of Cookies
We use cookies to enhance the user experience, analyze website usage, and optimize marketing activities.
(1) Overview and Purpose of Cookies
Cookies are small text files stored on a user’s device (PC, smartphone, tablet, etc.) by websites.
They help identify returning users and analyze usage patterns to improve site performance.
We use cookies for:
- Proper display and functionality of the website
- Analysis of site usage and improvement of services
- Optimizing marketing activities and advertisement delivery
(2) Types of Cookies Used
- Functional Cookies:
For maintaining basic website functions and user settings
- Analytical Cookies:
Used by tools such as Google Analytics for analyzing site visits and usage patterns
- Marketing Cookies:
Used for advertisement delivery, retargeting, and content optimization
(3) Cookie Management and Disabling
Users can manage or disable cookies through their browser settings.
Please note that disabling cookies may affect the functionality of certain website features.
For cookie management instructions, please refer to your browser’s help section.
(4) Third-Party Cookies and Advertising
We may use cookies provided by the following third-party services for analytics and advertising purposes:
- Google Analytics
- Google Ads (remarketing)
- Meta Ads (Facebook, Instagram)
- LinkedIn Ads
- Stripe Payment
These third-party cookies are managed in accordance with the respective service providers' privacy policies.
To opt-out of these cookies, please refer to the opt-out options provided by each service provider.
5. Provision of Personal Data to Third Parties
We will not disclose or provide personal data to third parties without prior consent, except in the following cases:
(1) Legal compliance
When required by law or upon formal request from governmental agencies or judicial authorities
(2) Protection of life, body, or property
When necessary to protect the life, body, or property of the individual or a third party and obtaining consent is difficult
(3) Outsourcing to contractors
When outsourcing part of our operations to external contractors (e.g., website operation, system management, email distribution, event operation, payment processing, analytics)
In such cases, we will ensure proper contractual agreements and supervisory measures are in place.
(4) Provision of statistical data
We may provide statistical data that does not identify individuals, such as aggregated analytics results.
(5) Business succession or restructuring
In the case of business transfer, merger, or organizational restructuring, personal data may be transferred within the necessary scope under appropriate handling in accordance with this Policy.
6. Management and Security of Personal Data
We take the following measures to ensure the safe management of personal data:
(1) Organizational measures
- Appointing a personal data protection officer
- Monitoring and recording data handling practices
(2) Personnel measures
- Providing training and awareness programs on data protection
- Restricting access to personal data to authorized personnel only
(3) Physical measures
- Restricting access to devices and storage containing personal data
- Managing entry and exit in controlled areas and implementing theft prevention measures
(4) Technical measures
- Encrypting communications via SSL/TLS
- Access control, logging, and monitoring
- Using antivirus software and firewalls
(5) Supervision of contractors
- Concluding confidentiality agreements with contractors
- Regularly verifying management conditions and providing necessary guidance
7. Data Subject Rights and How to Exercise Them
Data subjects have the following rights regarding their personal data held by us:
- Request for access
- Request for correction, addition, or deletion
- Request for suspension of use or erasure
- Withdrawal of consent
- Data portability
- Filing complaints with supervisory authorities
To exercise your rights, please contact us at the contact information below.
We may require identity verification for your protection.
8. Handling of Data from Individuals Under 16
We require individuals under the age of 16 to obtain parental or guardian consent before providing personal data.
If it becomes evident that personal data was provided without such consent, we will promptly delete the information.
9. Handling of External Links
Our website may contain links to external sites.
We are not responsible for the privacy practices or content of linked third-party websites.
Please review the privacy policies of external sites before using them.
10. Changes to this Privacy and Cookie Policy
We may revise this Policy as necessary due to changes in laws, regulations, or our services.
Revisions will take effect upon publication on our website.
Significant changes will be notified through appropriate means.
We encourage users to regularly review this Policy.
11. Contact Information
For inquiries regarding this Policy or your personal data, please contact:
Circular E
Email: info@cir-e.com
Annex: the General Data Protection Regulation
If you are located in the European Economic Area (“EEA”) or the United Kingdom (the "UK"), not only the Policy but also this Annex (“Annex”) applies to the processing of your personal data. This Annex covers both the EU and the UK’s General Data Protection Regulation (“GDPR”). In the event of any discrepancies or conflicts between the Policy and this Annex, this Annex shall prevail.
1.Legal Basis
Legal basis of the processing of personal data listed in 2. Types of Personal Data Collected in the Policy is as follows:
| Types of Personal Data Collected | Legal basis |
|---|---|
| (1) Information collected through inquiries. | Processing is necessary to pursue legitimate interests, such as responding to inquiries, requests, and complaints in order to provide better products and services. |
| (2) Information automatically collected from your device when using our services (including cookies). |
Direct marketing requiring consent via electronical means: consent In cases not covered above: processing is necessary to pursue legitimate interests, such as informing customers about our products, services, and market strategies. |
| (3) Information collected through your event applications and surveys. |
Direct marketing requiring consent via electronical means: consent In cases not covered above: processing is necessary to pursue legitimate interests, such as informing customers about our products, services, and market strategies. |
| (4) Information collected at the time of membership registration. |
Direct marketing requiring consent via electronical means: consent In cases not covered above: for contract execution (to provide the service). |
For the details of balancing test on legitimate interest, please contact us at the contact details set out in 11. Contact Information in the Policy.
2. Transfer of Personal Data to Other Countries
When we transfer personal data outside the EEA or the UK, we will rely on adequacy decisions for countries where such decisions have been made (GDPR Article 45) or implement appropriate safeguards by entering into appropriate standard contractual clauses (GDPR Article 46(2)(c) and (5)) with the importer for the other countries, except in cases where we have notified you otherwise.
3. Retention Period for Personal Data
We retain your personal data for as long as necessary to fulfill the aforementioned purposes for processing your personal data. 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 unauthorized 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.
4. Your Rights
The GDPR gives you certain rights regarding your personal data. You may ask us to take the following action regarding your personal data obtained and processed by us as long as you meet requirements under the GDPR:
- Restriction on processing of your personal data
You have the right to have us restrict the processing of personal data concerning you.
- Objection to processing your personal data
You have the right to object to our reliance on our legitimate interests as the legal basis of our processing of personal data concerning you that impacts your rights as well as the right to object to direct marketing.
- Not to be subject to automated decision-making
If certain conditions are satisfied, you have the right not to be subject to solely data-based, automated decision-making (including profiling) that produces any legal or similar material effect on you.
5. Our Identity Information
Rotterdam Office: [Circular E] at Maasboulevard 100, 3063 NS Rotterdam The Netherlands. This is the representative of YEJapan LLC.
Tokyo Head Office: YEJapan LLC at UCF635 Win Aoyama Bild2-2-15, Minamiaoyama, Minato ku Tokyo 107-0062, Japan.