Privacy Policy

GR PHOTO FESTIVAL

Last modified: October 21, 2022

INTRODUCTION:


Ricoh Imaging Company, Ltd. and our subsidiaries and affiliates ("Ricoh" or "we") respect your privacy and commit to protecting it through our compliance with the practices described in this Privacy Policy (“Policy”).

This Policy describes our practices for collecting, using, maintaining, protecting, and disclosing the personal data we may collect from you or that you may provide when you enter the GR PHOTO FESTIVAL (the “Contest”). This notice applies to the personal data collected through the Contest, regardless of the country where you are located.

Please read this Policy carefully to understand our policies and practices for processing and storing your personal data. This notice may change from time to time (see below), so please check the notice periodically for updates.

1. INFORMATION WE COLLECT.
Personal Information” means information that identifies you or another person as an individual such as your name, mailing address, email address, telephone number, IP address, location or any other identifier by which you or any other individual may be contacted online or offline.

Personal information we may collect may include your name, gender, age, country or city of your residence, email address, Instagram account, entry, photographing device model name. We will then collect additional personal information for the winner only, including their address, telephone number.

We do not collect any “Special Categories” of Personal Information about you (such as race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, information about your health, and genetic and biometric data.)
2. HOW WE COLLECT YOUR INFORMATION.
We may collect information when you enter the Contest or you are selected as winner.
3. WHY WE COLLECT YOUR PERSONAL INFORMATION.
We process your Personal Information only for fair, lawful and legitimate reasons in order to conduct the Contest and provide information about our products to those who wish to receive such information. The table below listing the categories of Personal Information we collect, the purpose for processing such Personal Information, and on what legal basis:
Purpose Personal Information we collect Legal Basis
Notification of results to winners
Provision of information related to the Contest
Inquiries about entry
name, gender, age, country or city of your residence, email Performance of a contract
Contest Statistics
Sending questionnaires about the Contests
Creation of statistical data
Newsletter to announce the next Contest
name, gender, age, country or city of your residence, email address, Instagram account, entry, photographing device model name, address, telephone number
Announcement of Award-Winning Works
Archival recording and publication of award-winning works
name, country or city of your residence, entry, photographing device model name Performance of a contract
Providing information about our products (for those who wish to receive it only) name, email address, Instagram account Performance of a contract

In addition to the above, we may use your entry, its title and your name to enrich the advertising purpose and the work culture in general.
In addition, we may use your entry, its title and your name in any medium for our business purposes. This includes, for example, presentation materials, internal websites, exhibitions of works at the facility.
In addition, the contents of the voluntary answers in the questionnaire may be used as a reference when developing our products.
The names of the winners will also be posted on the contest-related websites, printed materials, and other materials when introducing the winning works. In addition, it may be used to confirm the identity of the person making a request such as correction of personal information such as a change of address.
4. DISCLOSURE OF YOUR INFORMATION
We disclose your Personal Information to the following categories of recipients to the extent necessary to administer the Contest and provide information about our products to those who wish to receive it:
  • Judges: to judge the entry works.
  • Business Partners or Affiliates: other companies affiliated with us, including affiliates, subsidiaries, distributors, advisors, partners and consultants who are bound by confidentiality obligations and security measures.
  • Business Transfers: to a buyer or successor in the event of a merger, reorganization, dissolution, or other sale or transfer of some or all of our business or assets.
  • Law Enforcement: to third-parties such as law enforcement, government entities, courts, or other third parties as required or allowed by applicable law when requested. To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • Controller Interest: If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Ricoh, customers, users or others such as fraud agencies.
5. INTERNATIONAL TRANSFERS.
We are located outside of the European Economic Area (EEA). As a result, when you are an entrant from the EEA and provide Personal Information to us, that Personal Information is transferred outside of the EEA in order for us to be able to receive and access it.

We use external third parties that are based outside the EEA that process your Personal Information in order to carry out activities specified in this Policy. This includes currently third parties in the following countries: Japan and the United States. Whenever we transfer your Personal Information to one of these third parties, we ensure that at least one of the following safeguards are implemented:
  • We will only transfer your Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Information the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal Information shared between the Europe and the US.
  • Please email us to Contact information listed in Article 15 of this Policy if you want further information on the specific mechanism used by us when transferring your Personal Information out of the EEA.
6. YOUR CHOICES AND OPTING OUT
We may periodically send you who wish to receive it email messages describing news, information, updates related to the Contest.

You can “opt-out” of receiving emails from us at any time by following the instructions included in your email or by sending a reply stating your request, and we will make the requested changes. Whether you opt-out of receiving emails or not, we reserve the right to email or otherwise contact you with respect to important information, notices or changes relating to the Contest.
7. DATA RETENTION
We will only retain your Personal Information 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 Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
8. YOUR LEGAL RIGHTS
Subject to the statutory requirements, the fulfillment of which must be assessed on a case-by-case basis, you have certain legal rights under applicable data protection laws including the following:
  • Right to Access: You can request a copy and review the Personal Information we process about you.
  • Right to Rectification: You can request to amend or update your Personal Information that is inaccurate or incomplete.
  • Right to Erasure: You can request that we delete your Personal Information where there is no good reason to continue processing it or if it was collected unlawfully. We may not always be able to comply with your erasure request for specific legal reasons, which will be notified to you.
  • Right to Restrict: You can request that we temporarily or permanently stop processing all or some of your Personal Information if: (a) you want us to establish the accuracy of the Personal Information; (b) where the use is unlawful but you do not want it erased; (c) where you need us to hold it for legal purposes; or (d) you have objected to the use of your Personal Information but we need to verify if we have overriding legitimate reasons for processing the Personal Information.
  • Right to Object: You can object to us processing your Personal Information on grounds relating to your particular situation. You have the right to object to your Personal Information being processed for direct marketing purposes.
  • Right to Data Transfer: You can request a copy of and transfer your Personal Information in electronic format to you or a third-party. This right only applies to automated information that you consented to us processing or where we used the Personal Information to perform a contract with you.
  • Right Not to Be Subject to Automated Decision Making: You have the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
  • Withdraw Consent: Where you provided your consent for us to process your Personal Information, you have the right to withdraw your consent. (This does not affect the lawfulness of processing your Personal Information prior to the withdrawal of your consent.)

    You may email us to Contact information listed in Article 15 of this Policy to exercise any of your legal rights. If you are ever not satisfied with our response or believe that your Personal Information is being processed unlawfully, you may contact or lodge a complaint with the competent supervisory authority or seek other remedies under applicable law.
9. CALIFORNIA RIGHTS
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit [https://www.ricoh-imaging.com/en/grphotofestival/2022/privacypolicy_cr.html].
10. CONSENT TO THE PROVISION OF PERSONAL DATA OUTSIDE JAPAN. [ONLY FOR JAPANESE RESIDENT]
We may provide Personal Data provided by you to service providers, judges and business partners or affiliates outside Japan in order to achieve the purposes of use described in this Policy. The list of the parties outside Japan and their purposes of use are shown in the list at the list below. We may review and update the list from time to time.

List
Name of the Parties and its privacy policy Purpose of use Country
Ricoh Imaging Americas Corporation Judging of the entry United States of America
Ricoh Imaging Canada Inc. Judging of the entry Canada
Ricoh Imaging Europe S.A.S. Judging of the entry France
Ricoh Imaging China Co., Ltd. Judging of the entry PRC. China
Judge shown in the entry guideline Judging of the entry as shown in the entry guideline

With respect to Personal Data Protection System of the Country, please refer to the “Investigation of systems related to the protection of personal information in foreign countries“ on the website of Personal Information Protection Commission.

Each Party have taken all steps to address The OECD’s Eight Principles set forth in OECD Guidelines on the Protection of Privacy and Transborder Flows of Personal Data.
11. DATA SECURITY
We have put in place appropriate security measures to prevent your Personal Information from accidentally being lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Website. Any transmission of personal data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Service.
12. CHILDREN UNDER THE AGE OF 13
We do not knowingly collect Personal Information from children under the age of 13. If you are under the age of 13, you should not submit Personal Information to us. If we learn that we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any Personal Information from or about a child under 13, please email us to Contact information listed in Article 15 of this Policy.
13. CHANGES TO OUR PRIVACY POLICY
We may modify or amend this Policy from time to time. The date this Policy was last revised is identified at the top of the page and the terms of this Policy are effective as of that date.
14. CONTROLLING TEXT
The governing language of this Policy is English. Only the original English language version of this Policy has the effect of a policy, and any translation of the Policy has no contractual or any other effect.
15. CONTACT INFORMATION
Ricoh Imaging Company, Ltd. is the data controller for the purposes of the Personal Information processed under this Policy. To ask questions or comment about this Policy and our privacy practices, contact us at:
Ricoh Imaging Company, Ltd. GR PHOTO FESTIVAL Management Office
Email: zjc_gr_photofestival@jp.ricoh.com
Address: 1-3-6, Nakamagome, Ohta-ku, Tokyo, 143-8555 Japan

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