Privacy Policy

GR PHOTO FESTIVAL

Last modified: October 1, 2026

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 may also collect: (i) your consent to receive promotional emails from Ricoh Imaging; and (ii) where you are under the applicable age of digital consent in your country, confirmation of parental or guardian consent. We will then collect additional personal information for the winner only, including their address, telephone number.

We do not intentionally 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). While your entry (photograph) may incidentally contain images of individuals, we do not process such images for the purpose of uniquely identifying any natural person, and accordingly such images are not treated as biometric data under applicable data protection laws.
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:

PurposePersonal Information we collectLegal 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, emailPerformance of a contract
Contest Statistics
Creation of statistical data		name, gender, age, country or city of your residence, photographing device model nameLegitimate interest (improving our contests and products)
Sending questionnaires about the Contestsname, email addressLegitimate interest (improving our contests), subject to your right to object
Newsletter to announce the next Contestname, email addressConsent
Announcement of Award-Winning Works
Archival recording and publication of award-winning works		name, country or city of your residence, entry, photographing device model namePerformance of a contract
Providing information about our products (for those who wish to receive it only)name, email address, Instagram accountConsent
Promotion of the Contest and photography culturename, entry (photograph), photographing device model nameLegitimate interest (see details below)
Internal business usename, entry (photograph)Legitimate interest (see details below)
Product developmentvoluntary questionnaire responsesLegitimate interest (see details below)

In addition to the purposes listed in the table above, we may use your entry (photograph), its title, and your name for the following specific purposes:

  • Promotion of the Contest and photography culture: We may feature winning and selected entries, together with the photographer's name, on our websites, social media channels, printed promotional materials, and at exhibitions held at our facilities, for the purpose of promoting the Contest and contributing to photography culture. Legal basis: Legitimate interest (promotion of the Contest and photography culture), subject to your right to object (see Article 8).
  • Internal business use: We may use entries in internal presentation materials and on internal websites for the purpose of sharing the results of the Contest within the Ricoh group. Legal basis: Legitimate interest (internal reporting and knowledge sharing).
  • Where we wish to use your entry for purposes beyond those described above (for example, in product advertising or commercial campaigns), we will seek your separate consent before doing so.
  • Product development: The contents of any voluntary answers you provide in our questionnaires may be used as a reference when developing our products. Legal basis: Legitimate interest (product improvement), subject to your right to object (see Article 8).
  • 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: We share your entry (photograph) and an anonymized identification number (which cannot be used to identify you) with the contest judges for the sole purpose of judging and selecting winning entries. The judges do not receive your name, email address, or any other directly identifying information. The judges are located in Japan, the United States, Canada, France, the People's Republic of China, the Philippines, and Singapore. The judges act as data processors on our behalf and are bound by data processing agreements and confidentiality obligations in accordance with Article 28 of the GDPR.
  • 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. Your Personal Information may be transferred to the following countries outside the EEA: Japan, the United States, Canada, France (within the EEA), the People's Republic of China, the Philippines, and Singapore. The transfers are made for the purposes described in this Policy, including in particular the judging of contest entries. Whenever we transfer your Personal Information outside the EEA, we ensure that at least one of the following safeguards is implemented:
  • Adequacy decisions: We transfer your Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information by the European Commission. This currently includes Japan (Commission Implementing Decision (EU) 2019/419 of 23 January 2019) and Canada (Commission Decision 2002/2/EC of 20 December 2001, for transfers subject to the Personal Information Protection and Electronic Documents Act (PIPEDA)).
  • Standard Contractual Clauses (SCCs): Where we transfer your Personal Information to countries that have not received an adequacy decision (currently including the People's Republic of China, the Philippines, and Singapore), we use the standard contractual clauses approved by the European Commission (Commission Implementing Decision (EU) 2021/914 of 4 June 2021), supplemented where necessary by additional safeguards identified through a transfer impact assessment.
  • EU-US Data Privacy Framework: Where we transfer your Personal Information to recipients in the United States, we may rely on the EU-US Data Privacy Framework (DPF), as recognized by the European Commission's adequacy decision of 10 July 2023, where the recipient is certified under the DPF. Where the recipient is not DPF-certified, we use Standard Contractual Clauses as described above.
  • 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.

As a general guide:

  • Non-winning entry data (including your entry photograph and associated personal data): retained until 6 months after the announcement of the Contest results, after which it will be securely deleted.
  • Winning entry data: Your entry (photograph), name, country or city of residence, and photographing device model name will be published on our website and may be retained indefinitely for the purpose of archival recording and publication of award-winning works, as described in Article 3 of this Policy. This is because the recognition of winning the Contest serves as a lasting professional credential for photographers. You may request removal at any time by exercising your right to erasure (see Article 8).
  • Winner contact data (address and telephone number): retained for 3 years after the conclusion of the Contest for administrative purposes, after which it will be securely deleted.
  • Marketing consent records: retained for as long as you remain subscribed, and for 5 years thereafter for compliance record-keeping purposes.
  • Statistical data: retained in anonymized form indefinitely.
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/2025/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 policyPurpose of useCountry
Ricoh Imaging Americas CorporationJudging of the entryUnited States of America
Ricoh Imaging Canada Inc.Judging of the entryCanada
Ricoh Imaging Europe S.A.S.Judging of the entryFrance
Ricoh Imaging China Co., Ltd.Judging of the entryPRC. China
Individual judges (photographers and photography professionals) commissioned for the Contest. For the names of the judges, please refer to the entry guidelines published on the Contest website. Judging of the entryJapan, United States of America, Canada, France, People's Republic of China, Philippines, Singapore


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 AND MINORS
If you are under the age of 16 (or such lower age as may apply in your country of residence under applicable data protection laws, but in no event under the age of 13), you must obtain the consent of your parent or legal guardian before entering the Contest and submitting your Personal Information to us. By entering the Contest, you confirm that you have obtained such consent where required.

We do not knowingly collect Personal Information from children under the age of 13 without verified parental consent.

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





Our representative in the European Union for the purposes of Article 27 of the GDPR is:

Ricoh Imaging Europe S.A.S.
Email: info@eu.ricoh-imaging.com
Address: 7-9 avenue Robert Schuman 94150 Rungis, France

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