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Privacy Policy: Special Provisions for the GDPR

The Japan Racing Association (the “JRA,” “we,” “us,” or “our”) understands the importance of the personal data of data subjects (“you” or “your”) in European Union member countries and the three EEA/EFTA states (Iceland, Liechtenstein, and Norway) (collectively, the “EU”) and acknowledge our responsibility to comply with the EU General Data Protection Regulation (the “GDPR”) and fully protect personal data. Accordingly, we have established the following provisions to provide security, instill trust, and raise the awareness of all of our officers and staff and will continue to protect your personal data.

1. Categories of personal data

We will collect and process the following personal data in the ordinary course of our business:

  • (1) Data acquired from applicants for JRA Individual Owner Registration (Non-Residents of Japan)
  • (2) Data acquired from applicants for the new and short-term JRA jockey licensing system
  • (3) Data acquired from owners, handlers, jockeys, applicants, and stablemen of starters
  • (4) Data acquired from jockeys who participate in World All-Star Jockeys (“WASJ”)
  • (5) Data acquired from guests invited by the JRA
  • (6) Data of users of JRA Seat Reservation, including the user’s name and gender
  • (7) Data of JRA website (the “Website”) visitors, including internet domain names, online identifiers (cookies, IP address, etc.), browsing information on the Website

To learn more about our use of cookies and similar technology, please review our “Cookie Policy”.

2. Purposes and legal basis for processing personal data

We will handle personal data for the following purposes and upon the following legal bases:

• To conduct our business and pursue our legitimate interests, as necessary, in particular:

① Optimizing the quality and content of our websites;

② Providing, implementing, and operating our various policies and services, such as horse racing, horse owner registration, launching and operating the new and short-term jockey license system for foreign jockeys, international racing, WASJ, guest invitation, and JRA seat reservation; and

③ Responding to inquiries and questions regarding the JRA.

• To fulfil obligations under a contract or take steps in relation to a contract, in particular:

① Contacting, cooperating, negotiating, performing, billing, brokering, and serving as intermediaries in relation to a contract; and

② Selling tickets for watching races at racetracks and hosting visitors.

• Where you provide consent for the purpose of communicating with us, in particular:

① Providing information that may be of interest to you (where your consent is required in accordance with applicable law); and

② Analyzing the browsing history of website visitors (where your consent is required in accordance with applicable law).

• For purposes that are required by law, in particular:

① Where necessary to retain or acquire personal data to fulfill legal obligations imposed on us; and

② Responding to requests by the government or law enforcement authorities conducting an investigation.

3. Recipients of personal data

We will process your personal data via the following recipients:

  • (1) Service providers
    We will consign the handling of personal data after concluding a memorandum for business support with various service providers. These service providers include providers that assist with the Website and IT infrastructure, providers that handle the distribution of seats at each racetrack facility, providers that process payments, and providers of marketing support.
  • (2) Business Partners
    We provide personal data to partner companies. Our partner companies include companies that manage accommodations for the jockeys participating in WASJ or for invited guests of the JRA.
  • (3) Government and Law Enforcement Agencies
    We provide personal data to the government and law enforcement agencies. For example, we provide personal data to the relevant authorities for the purpose of applying for certificates of eligibility.

4. Sources of personal data

We will collect personal data directly from you. However, in some cases, your personal data is provided by service providers and business partners

5. Transfers to recipients in third countries

In the course of our business, we will need to transfer your personal data to countries outside of the EU, including countries that are not recognized by the European Commission as providing an adequate level of data protection. Please be advised that we only transfer personal data to these countries when we are able to implement suitable safeguards to assure the protection of your personal data, such as standard data protection clauses under Article 46.2 of the GDPR.
For further information and to obtain a copy of the documents used to protect your personal data, please contact us by email or postal mail at the following addresses:

International Department of the Japan Racing Association
JRA Head Office, Roppongi Hills Gate Tower, 11-1, Roppongi 6-chome, Minato-ku, Tokyo 106-8401, Japan
inter@jra.go.jp

6. Storage period

We will store your personal data for as long as necessary for the purposes described above. The criteria used to determine our storage periods include: (i) whether we have an ongoing relationship with you; (ii) whether there is any legal obligation to which we are subject; and (iii) whether such retention is needed in order to perform a contract to which you are party. However, as a general rule, personal data related to the new and short-term JRA jockey licensing system for foreign jockeys will be retained for 30 years.

7. Your rights

You have the right to ask us for a copy of your personal data; to correct, delete, or restrict (or stop any active) processing of your personal data; and to obtain the personal data you have provided to us for a contract or with your consent in a structured, machine-readable format (the right of data portability). In addition, you can object to the processing of your personal data under certain conditions (for further information, see “Your right to object to processing”).
These rights may be limited, for example, if the fulfilment of your request would reveal personal data about another person, where it would infringe upon the rights of a third party (including our rights), or if you ask us to delete information that we are required by law to retain or have legitimate compelling interests in retaining. Relevant exemptions are included in the GDPR and local EU laws on privacy.

8. Your right to object to processing

You have the right at any time to object to the processing of your personal data based on our legitimate interests, including “profiling” (analyzing or predicting your behavior based on your information). When we process your personal data for direct marketing purposes, you have an absolute right to opt out of direct marketing or the profiling we carry out for direct marketing.

9. Withdrawing consent

Wherever we rely on your consent, you have the right to withdraw that consent at any time. Such withdrawal does not affect the lawfulness of any processing performed pursuant to the consent given prior to the withdrawal.

10. Mandatory personal data

Mandatory personal data is indicated on the relevant forms that you complete. Where provision of personal data is mandatory, we are not able to provide our services to you if the relevant information is not provided.

11. Your right to complain to a supervisory authority

You have the right to lodge a complaint with a supervisory authority, including with the supervisory authority of the EU Member State of your habitual residence or place of work or of the place where the alleged infringement of the GDPR took place.

12. Minors

We do not knowingly collect and process information of minors under sixteen (16) without the permission and consent of their parent(s). If we discover that we have directly collected and processed the personal data of a minor under sixteen (16) or the equivalent minimum age of the jurisdiction concerned, we will take steps to delete the information as soon as possible. If you become aware that a minor under sixteen (16) has directly provided us with personal data, please contact us immediately at the contact address specified in this privacy policy.

13. Review

We reserve the right to amend this privacy policy at any time. The revised privacy policy will be available on our Website.

14. Contact details

For any inquiries about your personal information, you may contact us by email or postal mail at the following addresses:

International Department of the Japan Racing Association
JRA Head Office, Roppongi Hills Gate Tower, 11-1, Roppongi 6-chome, Minato-ku, Tokyo 106-8401, Japan
inter@jra.go.jp