At White Ship, Inc. ("White Ship", "our company", "us", "our", "we") we place great importance on the protection of personal data ("Personal Data") refers to information that could identify you as an individual), in addition to complying with all laws, regulations, ordinances and guidelines related to the protection of personal information ("privacy laws") we will strive to protect personal information as outlined in the following privacy policy ("Policy").
This Policy explains how we will use any personal information which we collect about you when you use our website (our “Site”) or correspond with us. By using our Site you are accepting and consenting to the practices described in this Policy.

1. Legal obligations

1.1 We collect and process your Personal Data in accordance with applicable laws that regulate data protection and privacy. For persons from the European Economic Area (“EEA Persons”) this includes, without limitation from 25 May 2018 the EU General Data Protection Regulation (2016/679).
1.2 Legal Basis for Processing Personal Information (EEA Persons Only)
If you are from the European Economic Area, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.
However, we will normally collect and use Personal Information from you where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms. Typically, our legitimate interests include improving, maintaining, providing, and enhancing our technology, products, and services; ensuring the security of the Services and our Sites; and for our marketing activities.
If you are a registered user, we may need the Personal Information to perform a contract with you. In some limited cases, we may also have a legal obligation to collect Personal Information from you.
If we ask you to provide Personal Information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not, as well as of the possible consequences if you do not provide your Personal Information.
Where required by law, we will collect Personal Information only where we have your consent to do so.
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided in 11. Contact.

2. Information we collect from you

2.1 We may collect the following information from you: first name(s) and last name, email address, postal address, phone number, date of birth, gender, company name/affiliation, IP address, location data and information regarding your use of our Site and EGAKU sessions you have signed up for and related data.

  • Identity Data may include your first name, last name, title, date of birth , company affiliation, and gender.
  • Contact Data may include your address, email address and telephone numbers.
  • Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
  • Profile Data may include your username and password, program registration data or orders, your interests, preferences, feedback.
  • Usage Data may include information about how you use our Site, products and services.
  • Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.

2.2 Such personal information is referred to in this Policy as “Personal Data”.
2.3 If you choose not to provide Personal Data, we may not be able to comply with a request for information or provide you with our Services.
2.4 We may collect the information you give in various ways, you may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:

  • exchange business cards with our company staff;
  • sign our guest book or mailing list form at our studio;
  • fill in forms on our site;
  • register for our services;
  • create an account on our Site and when you administer your account;
  • subscribe to our service or publications;
  • request resources or marketing be sent to you;
  • correspond with us with queries, comments, complaints or problems regarding the Site: or
  • browse our Site (please see ‘Cookies’ section below).


3. How we may use your Personal Data we gather

3.1 We will only use your Personal Data when legally permitted. The most common uses of your Personal Data are:

  • Where we need to perform the contract between us;
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

3.2 Purposes for processing your Personal Data
Set out below is a description of the ways we intend to use your Personal Data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
We may process your Personal Data for more than one lawful ground, depending on the specific purpose for which we are using your data.

Purpose/Activity Type of data Lawful basis for processing
To open an online account to register for one of our programs (a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
Performance of a contract with you
To process and, where required, deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications 
(a) Performance of a contract with you
(b) Necessary for our legitimate interests to recover debts owed to us
To run programs, talks, events which you have registered for. (a) Identity
(b) Contact
Necessary for our legitimate interests as a business to be able to contact you regarding this service and track attendance.
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
 (a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise
(b) Necessary to comply with a legal obligation
To deliver relevant content and event information to you and measure and understand the effectiveness of our advertising (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy
To use data analytics to improve our Site, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage
Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy


4. Disclosure of Your Information

We will not sell or lease your personal information to third parties. We will not disclose Personal Data to third parties without you knowing about it. The exceptions are:

  • Where we need assistance of third party data processors, acting under our instructions, who assist us in the performance of a contract we enter with you (e.g. payment processor, suppliers and sub-contractor);analytics and search engine providers that assist us in the improvement and optimization of our Site by analyzing how the Site is used and the path users take before making a purchase;
  • in the event that we sell or buy any business or assets, in which case we will disclose your Personal Data to the prospective seller or buyer of such business or assets;
  • if our company or substantially all of our assets are acquired by a third party, in which case Personal Data held by us about our customers will be one of the transferred assets; and
  • if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply our terms of and other agreements; or to protect our rights, property, or safety or that of our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.


5. International transfers

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (‘EEA’). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your Personal Data to us, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

6. Security

Rest assured we do everything possible to keep all personal information as secure as is humanly possible, but no method of transmission over the internet, or method of electronic storage, is 100% fail-safe. Although we do our best to protect your Personal Data and use industry standard procedures and security features to try to prevent any unauthorized access by a third party, we cannot guarantee the security of your data transmitted to our Site.

7. Links to other websites

Our Site may contain links to other websites of interest. However, once you have used these links to leave our Site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites because such websites are not governed by this Policy. You should exercise caution and look at the privacy statement applicable to the website in question.

8. Cookies

8.1 Like many websites, we use “cookies” to collect information. A cookie is a small data file that we transfer to your computer, laptop or mobile media device’s hard drive for record-keeping purposes.
8.2 We use session ID cookies to enable certain features of the Site, to better understand how you interact with the Site and to monitor aggregate usage by White Ship users and web traffic routing on the Site.
8.3 We also make use of persistent cookies which stay on your computer, laptop or mobile media device after you have gone offline. Persistent cookies can be found in your browser’s cookies folder and remain there after you have gone offline.
8.4 We do not link the information we store in cookies to any personally identifiable information provided by users.
8.5 We may collect personal information about how you use the Site including traffic data, location data, weblogs, other communication data, and the resources that you access or use.
8.6 You may refuse to accept cookies by activating the settings on your browser which allows you to refuse the setting of cookies. You can learn how to do this by accessing the ‘Help’ function on your browser. However, if you select this setting, you may be unable to access certain parts of the Site or discover that you have a reduced functionality whilst using the Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to the Site.
8.7 Please be aware that if you visit our Site after clicking a link on another website, you should note that we do not have any control over the cookies used by the operator of that website.

9. Your rights

9.1 In accordance with your legal rights under applicable law, you can request information about the Personal Data that we hold about you, what we use that Personal Data for and who it may be disclosed to.
9.2 You can also request that we:

  • correct Personal Data that we hold about you which is inaccurate or incomplete;
  • erase your Personal Data for marketing.

9.3 All of these requests may be forwarded on to a third party provider who is involved in the processing of your Personal Data.
9.4 If you would like to exercise any of the rights set out above, please write to our data protection contact at the email address in the ‘Contact’ section below. Where applicable law allows, we may request a fee to cover our administrative expenses in responding and may also require further information to verify your identity or locate the specific information you seek before we can respond in full.
9.5 If you wish to update your preferences or unsubscribe from newsletter communications, you can do so via the links found at the bottom of the relevant communication.
9.6 If you wish to exercise any of the rights set out above, please email us at You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
9.7 We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
9.8 We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Retention period

We will retain certain Personal Data in respect of financial transactions for as long as the law requires us to for tax or accounting purposes. In respect of the holding of Personal Data for direct marketing purposes, we will retain this data for a limited period in line with recommendations of competent regulatory authorities.

11. Contact

If you have further queries or requests relating to how we use Personal Data, please email us
If you have any questions about this Policy, you can contact us by post at any time:
White Ship, Inc.
6F Terasawa Building, 1-7-17 Moto-Akasaka
Minato-ku, Tokyo, Japan

12. Revisions to the Policy

We reserve the right to change this Policy at any time. Any changes we may make to our privacy policy in the future will be posted on this page. By continuing to use our Site you will be deemed to have accepted such changes.

Last update: May 25, 2018
Updated June 4, 2014
Created June 1, 2006
Kimi Hasebe
CEO, White Ship, Inc.