Odakyu Electric Railway Co., Ltd. (hereinafter, the “Company”) sets forth the following Privacy Policy (hereinafter, this “Policy”) regarding the handling of information identifying customers and personal information of individual customers by which customers may be identified (hereinafter, “Personal Information”) obtained by the Company in the platform services, and various service contents provided at such platform (hereinafter, the “Services”), by the “EMot” application (hereinafter, the “App”) and the “EMot Online Ticket” website (hereinafter, the “Website”) operated and provided by the Company, and shall ensure that various measures are implemented in accordance with this Policy. Provided, however, that this Policy shall not be applicable to the handling of Personal Information of customers obtained by the parties allied with the Company in the Services (meaning the companies allied with the Company in relation to the Services, including but not limited to sellers of tickets and other things sold in the Services, settlement agency companies and allied transportation business operators.)
This Policy is comprised of Chapters 1 through 5, and each Chapter shall be applicable to the following customers.
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Chapter 1 |
All customers |
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Chapter 2 |
Customers residing in Japan |
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Chapter 3 |
Customers residing in the People’s Republic of China (hereinafter, “Mainland China”) |
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Chapter 4 |
Customers residing in the U.S.A. |
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Chapter 5 |
Customers residing in European Economic Area (EEA), U.K., and Switzerland |
In the event of any conflict between the contents of Chapter 1 and Chapters 2 through 5, the contents of Chapters 2 through 5 shall prevail.
Chapter 1 Handling of Personal Information of All Customers
Article 1 Business Operators Handling Personal Information
The Company (Please refer to here for the address and the name of representative. The language of indication may be changed by the header of the page to where you are transited.)
Article 2 Purposes of Use of Personal Information
The Company shall use Personal Information obtained through the Services for the following purposes.
(1) Provision and operation of the Services
(2) Responding to inquiries from customers (including identifying the customer)
(3) Making contact related to the maintenance, new functions, renewal information related to the Services and other provision of the Services
(4) Improving the Services, evaluating the impact of the Services, or reviewing business strategies (including implementing questionnaires for the purposes above)
(5) Sending advertisements regarding products, services or campaign of the Company or third parties (including implementing questionnaires for the purposes above)
(6) Claiming usage fees to customers for charged individual services
(7) Preventing and taking measures towards unauthorized use of the Services and the individual services
(8) Compliance with laws and regulations
(9) Preparing statistics information
Article 3 Types and Obtainment Method of Personal Information
The Company shall acquire by the following methods the following types of Personal Information upon the customer’s use of the Services. The purpose of use of each Personal Information is as follows.
[Information Obtained Commonly in the Services]
[1] Information related to customers (country/region of residence, email address, year of birth, sex)
- Obtainment Method: The customer shall input information when the customer creates an account for the Services or renews account information; provided, however, that when creating an account using the ID of a third party service, an email shall be received from such third party service. Credit card information shall be obtained and handled by the settlement agency company, and shall not be directly handled by the Company.
- Purpose of Use (please refer to Article 2)
(1) Provision and operation of the Services
(2) Responding to inquiries from customers (including identifying the customer)
(3) Making contact related to the maintenance, new functions, renewal information related to the Services and other provision of the Services
(4) Improving the Services, evaluating the impact of the Services, or reviewing business strategies (including implementing questionnaires for the purposes above)
(5) Sending advertisements regarding products, services or campaign of the Company or third parties (including implementing questionnaires for the purposes above)
(6) Making claims and settlements in charged individual services
(7) Preventing and taking measures towards unauthorized use of the Services and the individual services
(8) Compliance with laws and regulations
(9) Preparing statistics information
[2] Credit card information
- Obtainment Method: The customer shall input information when the customer creates an account for the Services or renews account information; provided, however, that when creating an account using the ID of a third party service, an email shall be received from such third party service.
Credit card information shall be obtained and handled by the settlement agency company, and shall not be directly handled by the Company.
- Purpose of Use (please refer to Article 2)
(2) Responding to inquiries from customers (including identifying the customer)
(6) Making claims and settlements in charged individual services
(7) Preventing and taking measures towards unauthorized use of the Services and the individual services
(8) Compliance with laws and regulations
(9) Preparing statistics information
[3] Information related to the location and movements of customers (destination, station name and history of other inputted information, movement route information)
- Obtainment Method: These information shall be obtained based upon the destination and departure / arrival location information inputted by the customer in the case of using the functions of route search service
- Purpose of Use (please refer to Article 2):
(1) Provision and operation of the Services
(2) Responding to inquiries from customers (including identifying the customer)
(3) Making contact related to the maintenance, new functions, renewal information related to the Services and other provision of the Services
(4) Improving the Services, evaluating the impact of the Services, or reviewing business strategies (including implementing questionnaires for the purposes above)
(5) Sending advertisements regarding products, services or campaign of the Company or third parties (including implementing questionnaires for the purposes above)
(6) Making claims and settlements in charged individual services
(7) Preventing and taking measures towards unauthorized use of the Services and the individual services
(8) Compliance with laws and regulations
(9) Preparing statistics information
[4]Other information related to the status of use of the Services (including information related to the access source such as IP address and other matters)
- Obtainment Method: Automatically obtained upon the use of the Services
- Purpose of Use (please refer to Article 2):
(1) Provision and operation of the Services
(2) Responding to inquiries from customers (including identifying the customer)
(3) Making contact related to the maintenance, new functions, renewal information related to the Services and other provision of the Services
(4) Improving the Services, evaluating the impact of the Services, or reviewing business strategies (including implementing questionnaires for the purposes above)
(5) Sending advertisements regarding products, services or campaign of the Company or third parties (including implementing questionnaires for the purposes above)
(6) Making claims and settlements in charged individual services
(7) Preventing and taking measures towards unauthorized use of the Services and the individual services
(8) Compliance with laws and regulations
(9) Preparing statistics information
[Information Obtained by the App]
[1] Action history on the App obtained through the Software Development Kit (SDK)
- Obtainment Method: Automatically obtained upon the customer’s use of the App. Please refer to Article 4 for details.
- Purpose of Use (please refer to Article 2):
(4) Improving the Services, evaluating the impact of the Services, or reviewing business strategies (including implementing questionnaires for the purposes above)
(5) Sending advertisements regarding products, services or campaign of the Company or third parties (including implementing questionnaires for the purposes above)
(8) Compliance with laws and regulations
(9) Preparing statistics information
[2] GPS information
- Obtainment Method: If the customer himself/herself permits the obtainment of GPS information, location information shall be obtained when viewing services showing information on the map, and when purchasing and using electronic tickets.
- Purpose of Use (please refer to Article 2):
(1) Provision and operation of the Services
(2) Responding to inquiries from customers (including identifying the customer)
(3) Making contact related to the maintenance, new functions, renewal information related to the Services and other provision of the Services
(4) Improving the Services, evaluating the impact of the Services, or reviewing business strategies (including implementing questionnaires for the purposes above)
(5) Sending advertisements regarding products, services or campaign of the Company or third parties (including implementing questionnaires for the purposes above)
(7) Preventing and taking measures towards unauthorized use of the Services and the individual services
(9) Preparing statistics information
[Information Obtained at the Website]
[1] Action history on the Website obtained through Cookie
- Obtainment Method: Automatically obtained when the customer accesses the Website; provided, however, that the obtainment of information using other than strictly necessary Cookie shall be limited only to the case where the customer gives individual consent. Please see Article 4 for details.
- Purpose of Use (please refer to Article 2):
(1) Provision and operation of the Services
(4) Improving the Services, evaluating the impact of the Services, or reviewing business strategies (including implementing questionnaires for the purposes above)
(5) Sending advertisements regarding products, services or campaign of the Company or third parties (including implementing questionnaires for the purposes above)
(6) Making claims and settlements in charged individual services
(7) Preventing and taking measures towards unauthorized use of the Services and the individual services
(8) Compliance with laws and regulations
(9) Preparing statistics information
Article 4 Cookie and Similar Technologies
The Company uses the functions of Cookie to analyze access to the pages viewed by customers and to measure the effectiveness of advertisements through the Services. Cookie enhances the convenience of customers by storing identifiers and other information transmitted and received by the customer between the browser and the server as text files on the customer’s smartphone, computer, or digital tablet when the customer uses the website. The Company uses Cookies to analyze customer behavior on the Website in order to enhance the convenience of the Service. Cookie may also be used for such purposes as showing the most appropriate advertisements on websites other than the Company’s. The receipt of Cookie may be rejected by changing the settings of the customer’s browser. However, please acknowledge that if you reject the use of Cookie, the Services may not correctly function or the response speed may slow down. The Company may also acquire information through the Software Development Kit (SDK) of a third party equipped within the App and use it for such purposes as analyzing the actions of customers and showing advertisements within the App. Please refer here for the details of the information which a third party acquires through the Website or the App.
Article 5 Provision of Personal Information to Third Parties
1. The Company may provide Personal Information of customers to the Company’s group companies and business operators providing external services to the extent required for attaining the purposes of use set forth in this Policy.
2. Other than the preceding paragraph, the Company may provide Personal Information of customers to third parties in the case that it falls under the following.
(1) The customer gives consent;
(2) It is based upon laws and regulations;
(3) It is necessary for the protection of the life or body of a person or for the protection of property, and it is difficult to obtain the customer’s consent;
(4) It is particularly necessary for the enhancement of public sanitation or the promotion of healthy development of children, and it is difficult to obtain the customer’s consent;
(5) It is necessary to cooperate with the performance of affairs set forth in laws and regulations by a governmental agency or local municipality, or a party entrusted thereby, and there is a likelihood that there will be an interference with the performance of such affairs by obtaining the customer’s consent;
(6) Providing upon business succession by merger or other reasons;
(7) In the case of providing Personal Information to academic research agencies and other parties and the party provided is required to handle such Personal Information for the purposes of academic research (including the case where a part of the purpose is academic research purposes, and excluding the case where there is a likelihood of undue infringement of an individual’s rights and interests);
(8) There exists a justifiable reason such as contacting customers in an emergency.
Article 6 Entrustment of the Handling of Personal Information
1. The Company may entrust the affairs accompanying the handling of Personal Information to service providers, and along with that, the Company may provide Personal Information of customers to such service providers. The service providers above include data hosting providers, Google which is the provider of Google Analytics, Val Laboratory Corporation and MTI Ltd. which are the parties entrusted with development and maintenance work related to the Services as well as the parties re-entrusted by such parties.
2. The Company shall perform such provision by taking procedures required in light of related laws and regulations.
Article 7 Transfer of Personal Information to Outside the Country
1. The Company may provide Personal Information of customers to outside the customer’s country of residence, for the purposes of use set forth in this Policy. Personal Information above may be processed by the Company or the service providers outside of the customer’s country of residence.
2. The Company shall take appropriate measures so that it meets the data protection rules applicable to the provision and processing referred to in the preceding paragraph.
Article 8 Rights Related to Personal Information
1. Customers shall be entitled to claim such matters as the reproduction, correction, amendment and deletion of Personal Information held by the Company in accordance with applicable laws and regulations. In the case that you make such claim, please contact the inquiry window set forth in Article 12.
2. In the event that the Company is subjected to the claim referred to in the preceding paragraph, it shall identify the customer (including confirming that the agent has authority if the claim is made through an agent) pursuant to the procedures set forth by the Company, and if it cannot be confirmed that it is a claim made by the customer himself/herself, the Company may refuse to respond to such claim.
Article 9 Information Management and Security Measures
The Company will manage personal data appropriately and strictly and will take thorough security measures to prevent divulgation, loss, unauthorized access, destruction or falsification of information.
Article 10 Period of Preservation
The Company shall preserve Personal Information for a period of seven (7) years after the customer’s final use of the Services; provided, however, that the Company shall not be obliged to retain Personal Information.
Article 11 Changes to this Privacy Policy
1. The Company shall be entitled to change this Policy from time to time by displaying notices and other matters on the Services or notifying to the customer’s email address.
2. To the extent permitted under applicable laws and regulations, the changed Policy shall become effective from the time that the changed Privacy Policy is displayed on the Website, and customers shall be deemed to have consented to the changed Policy.
Article 12 Inquiry Window
Please submit your inquiries related to this Policy to the following window.
<Inquiry Window>
Email address: support@emot.jp
Person responsible for EMot customer support
Management Strategy Department, Odakyu Electric Railway Co., Ltd.
Chapter 4 Handling of Personal Information of Customers Residing in California, U.S.A.
The provisions of Chapter 4 shall be applicable to the handling of Personal Information of customers residing in California, U.S.A. as special provisions to Chapter 1 in accordance with the California Consumer Privacy Act and the legal systems related thereto (hereinafter, the “CCPA”).
Article 1 Application
1. This Chapter shall be applicable to the handling of Personal Information of customers using the Website from California, U.S.A. The App is not provided towards California, and this Chapter shall not be applicable to the handling of Personal Information of customers in the case that customers residing in California use the App in Japan.
2. Customers under the age of eighteen (18) must obtain the consent of parents in the case of using the Website. If a parent learns that a child under the age of eighteen (18) has used the Website, please contact the inquiry window referred to in Article 12 of Chapter 1.
Article 2 Purposes of Use of Personal Information
The categories and purposes of use of Personal Information obtained or to be obtained by the Company are as described in Article 3 of Chapter 1.
Article 3 Sales, Sharing and Disclosure of Personal Information
1. The Company does not sell Personal Information.
2. The Company may share Personal Information described in the following chart.
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Categories of Personal Information |
Parties with whom Personal Information may be Shared |
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Action history on the Website obtained through Cookie |
Personal Information may be shared with advertisement related business operators which issue targeting Cookie, and cross context action advertisement shall be implemented through ad network. |
3. The Company may disclose Personal Information described in the following chart for business related purposes.
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Categories of Personal Information |
Parties to whom Personal Information may be Disclosed |
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Information related to customers (country/region of residence, email address, year of birth, sex) |
Service providers, governmental agencies or local municipalities or parties entrusted thereby, business successors by merger or other reasons |
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Credit card information |
Service providers, governmental agencies or local municipalities or parties entrusted thereby, business successors by merger or other reasons |
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Information related to the location and movement of customers (destination, station name and history of other inputted information, movement route information) |
Service providers, governmental agencies or local municipalities or parties entrusted thereby, business successors by merger or other reasons |
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Other information related to the status of use of the Services (including information related to the access source such as IP address) |
Service providers, governmental agencies or local municipalities or parties entrusted thereby, business successors by merger or other reasons |
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Action history on the Website obtained through Cookie |
Service providers, governmental agencies or local municipalities or parties entrusted thereby, business successors by merger or other reasons, advertisement related business operators |
4. The provisions of Article 5 of Chapter 1 shall not be applicable to the handling of Personal Information subject to application of this Chapter.
Article 4 California Consumer Rights
1. The consumers of California have the following rights.
(1) Right to Know
Right to request information as to what information is being collected, used, disclosed and sold by the Company.
(2) Right to Delete
Right to request deletion of Personal Information held by the Company.
(3) Right to Correct
Right to request correction of Personal Information in the case that Personal Information held by the Company is incorrect.
(4) “Do Not Sell or Share My Personal Information”
Right to request suspension of the sharing of Personal Information with third parties (opt-out) for the purposes of sales or cross context action advertisements.
(5) “Limit the Use and Disclosure of Sensitive Personal Information”
Right to request restriction of the use of sensitive information within a statutory scope; provided, however, that the Company uses information falling under sensitive information within a statutory scope.
2. Please contact the “inquiry window” set forth in Article 12 of Chapter 1 or refer to “Do Not Sell or Share My Personal Information” upon exercising the rights above.
3. The Company shall not handle or disclose sensitive information of customers for purposes other than the certain purposes permitted under the CCPA. The Company shall not acquire or handle sensitive information of customers for the purposes of inferring the customer’s characteristics.
Article 5 Prohibition of Discrimination
The Company shall not perform discriminatory handling of customers who exercised the rights under the preceding Article; provided, however, that all or a part of the Services may not be provided due to the deletion or correction of Personal Information.
Article 6 Notice Related to Monetary Incentives
The Company does not provide monetary incentives provided in the CCPA.
Chapter 5 Handling of Personal Information of Customers Residing in EEA, U.K. and Switzerland
The provisions of Chapter 5 shall be applicable to the handling of Personal Information of customers residing in the EEA (European Economic Area) region, U.K. and Switzerland (hereinafter, “Europe”) as special provisions to Chapter 1 in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 2018 of the U.K. (UK GDPR), the Federal Act on Data Protection of 19 June 1992 of Switzerland (FADP) and the legal systems related thereto.
Article 1 Application
1. The Company provides the Website towards customers residing in Europe, and this Chapter shall be applicable to the handling of Personal Information of customers using the Website from Europe. The App is not provided towards Europe, and this Chapter shall not be applicable to the handling of Personal Information of customers in the case that customers residing in Europe use the App in Japan.
2. Customers under the age of eighteen (18) must obtain the consent of parents or a parental guardian in the case of using the Website. If a parent learns that a child under the age of eighteen (18) has used the Website, please contact the inquiry window referred to in Article 12 of Chapter 1.
Article 2 Purposes of Use and Legal Basis of Personal Information
The legal basis for the handling of Personal Information by the Company are as follows.
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Purposes of Use |
Legal Basis |
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(1) Provision and operation of the Services |
- Performance of contracts with the customer |
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(2) Responding to inquiries from customers (including identifying the customer) |
- Performance of contracts with the customer - Handling for the purposes of justifiable interests |
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(3) Making contact related to the maintenance, new functions, renewal information related to the Services and other provision of the Services |
- Performance of contracts with the customer - Handling for the purposes of justifiable interests |
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(4) Improving the Services, evaluating the impact of the Services, or reviewing business strategies (including implementing questionnaires for the purposes above) |
- Handling for the purposes of justifiable interests |
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(5) Sending products and services or campaign advertisements of the Company or third parties (including implementing questionnaires for the purposes above) |
- Consent (The Company may send advertisements to customers through Cookie of the Website if the customer gives individual consent. Customers may revoke their consent on the Website at any time.) |
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(6) Claiming usage fees to customers for charged individual services |
- Performance of contracts with the customer - Handling for the purposes of justifiable interests |
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(7) Preventing and taking measures towards unauthorized use of the Services and the individual services |
- Handling for the purposes of justifiable interests |
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(8) Compliance with laws and regulations |
- Compliance with legal obligations owed by the manager |
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(9) Preparing statistics information |
- Handling for the purposes of justifiable interests |
Article 3 Provision of Personal Information
1. Other than cases where the customer gives individual consent, the Company may provide Personal Information of customers to third parties in the following cases.
(1) Processors/service providers
The Company uses services provided by third parties upon the provision of the Services, and such third parties may handle Personal Information of customers on the Company’s behalf as the processors/service providers of the Company. Such third parties include parties entrusted with development and maintenance work related to the Services, data hosting providers, and Google which is the provider of Google Analytics.
(2) Business transfer
The Company may provide Personal Information of customers to the business successor along with business succession due to merger or other reasons.
(3) Requests of laws and regulations
In the event that there are requests based upon laws and regulations such as the case where there are inquiries from the governmental agencies or the court, the Company may provide Personal Information of customers to the agency which made such request.
2. The provisions of Article 5 of Chapter 1 shall not be applicable to the handling of Personal Information subject to application of this Chapter.
Article 4 Cross-Border Transfer of Personal Information
Personal Information of customers may be handled or preserved in a country other than EEA or the customer’s country of residence, or may be transferred to the countries above. Japan, where the Company is located, has received an adequacy decision by the European Commission and the U.K. government; however, recipients receiving Personal Information from the Company pursuant to the preceding Article include parties which are located in countries which have not received an adequacy decision. In such case, the Company shall take measures necessary for the handling, preservation and transfer above to meet the requirements of applicable laws and regulations, through such measures as the Standard Contractual Clauses approved by the European Commission. Please contact the inquiry window set forth in Article 12 of Chapter 1 if you have any inquiries or concerns regarding the measures above.
Article 5 Rights of Customers
1. The customer has the following rights regarding Personal Information held by the Company; provided, however that these rights may be restricted in certain cases such as where responding to the customer’s request infringes upon Personal Information of third parties.
(1) Right to claim for disclosure
(2) Right to claim for correction
(3) Right to claim for deletion
(4) Data portability right
(5) Right to request restriction of handling
(6) Right to raise an objection against the handling
(7) Right to revoke consent when consent is the legal base