Privacy Policy

We take our commitment to protecting the security and privacy of our website users very seriously. We strive to protect your online privacy while providing an enjoyable website experience that provides information relevant and useful to you. The purpose of this Privacy Policy is to inform you of our website (the “Website”)  personal information practices. 

The present Privacy Policy is an information notice provided to any entity having to do with the website, the “Website”) of DOCOMO Digital Ltd., – a company registered in England and Wales with the registered office to 1 King William Street, London, EC4N 7AF, England (hereinafter, the “Company”).

This information only applies to the above-mentioned Company’s Website and does not concern either the websites that may be visited by a user via an external link nor those services provided by the Company – in this regard, please refer to the specific privacy policies of such services, in order to know how the Company processes personal data of users who subscribe to its services.

Certain services or information offered on the website may be subject to a different privacy policy. In such instances, a separate privacy policy will be posted. 

“You” in this Privacy Statement means you as an individual.

“We” or “us” in this Privacy Statement means, in relation to your personal data, the Data Controller, namely DOCOMO Digital Ltd.

The Data Protection Officer (“DPO”) designated by the Data Controller, pursuant to Articles 37, 38 and 39, GDPR/UK GDPR, is appointed and you may contact the DPO at the e-mail address [email protected] or via registered post at the address into 1 King William Street, London, EC4N 7AF, England.

What information is collected?

When you browse our website, we process your IP address, Google Analytics ID, internet browser and device type, location data and your use of the app and our website, including which pages you visited, how you got to our website, the time and length of your visit and your language preferences.

When you visit our Website we may collect personal data either:

  1. directly where you are asked to provide data. If you fill in any forms on the Website you may need to provide your name, contact information and the name of your organization and/or
  2. indirectly, such as using cookies (as described below) or to track your use of certain pages of the Website (e.g. your internet protocol address) and other technical means to monitor your use of the Website.

We do not seek to collect sensitive data through the Website.

Why will personal data be used?

We use this data for our legitimate interests (pursuant the applicable laws) of making sure our website works properly, including debugging, to be able to deliver you content and for DDOS mitigation on our website, and improving our website and performing statistical analyses for optimizing our website. We also use this information to provide you with information tailored to your needs based on your preferences, with your prior consent. Please refer to the Cookie Policy for more information

We also use your personal data to answer your questions, comments/complaints and respond to your queries and (support) requests and to assess your interest in partnering with us. As such, this data is used by us to establish (future) contract with you and for our legitimate interests in following up with you.

You can sign up for our newsletter or download content using your name and e-mail address via the sign-up form on our website. When you fill out this form, you indicate your consent to receive our newsletter and information about our products and services. You can at any time unsubscribe from receiving these e-mails by following the instructions provided in any of the newsletters or by clicking here (valid link to be added).

How do we share Personal Information?

We may share and disclose Personal Information for any of the purposes listed in this Privacy Policy with:

  1. The subsidiaries belonging to our DOCOMO Digital family in accordance to an intracompany data sharing agreement we have in place
  2. Contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them
  3. Our business partners, in compliance with the relevant contract in place and as agreed by both parties.

We may also disclose your Personal Information:

  • To comply with any court order, law, or legal process, including responding to any government or regulatory request;
  • To enforce or apply our Terms of Use, Terms and Conditions or any other agreement or understanding may have with you; and
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our company, our customers, or others.

This includes exchanging information with other companies and organizations for the purposes of fraud protection.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

Your rights as a data subject

In relation to the processing of your personal data:

  • Right to be informed – you have the right to be informed about the collection and use of their personal data. This is a key transparency requirement under the UK GDPR (Art. 13 & 14).
  • Right of access to your Personal Information – you have a right to know if we are processing your Personal Information and for what purposes free of charge.
  • Right to have inaccurate Personal Information corrected – you have the right to ask us to correct information about you that is inaccurate, incomplete or out-of-date.
  • Right to have your Personal Information erased – in some circumstances you have the right to ask us to delete certain information about you. This right is not absolute and can only be exercised in accordance with applicable laws.
  • Right to restrict processing of your Personal Information – in certain circumstances, you have the right to restrict or object to certain uses of information we hold about you.
  • Right to data portability – in certain circumstances you have the right to request to receive a copy of your Personal Information in a commonly used electronic format or have it transferred to another third party where it is technically feasible. Certain fees may apply.
  • Right to object to the processing of your Personal Information – wherever we use legitimate interest as the ground to the processing your Personal Information you can object to our use of it.
  • Right not to be subject to a decision based solely on automated processing – none of our activities constitute decisions based solely on automated processing.

In the event that you wish to make a complaint about how your personal data is being processed by the Data Controller, or how your complaint has been handled, you have the right to lodge a complaint directly with the data protection authority and the DPO.

As an alternative, you may contact the DPO at the e-mail address [email protected]

Is Personal Data Transferred to Another country?

The website is located on a server in the European Economic Area.

Personal data collected from you is stored in data centers as well as cloud networks which are located or hosted in the European Economic Area.

When your personal data is transferred to parties located outside of the European Economic Area we shall take appropriate measures to ensure such third party will provide adequate security of such personal data and respect your rights to privacy.

We take all steps reasonably necessary to ensure that your personal data is treated securely.

Security Measures

We use the appropriate organizational, technical and administrative measures to maintain the security of your Personal Information and to protect against the destruction, loss, alteration, unauthorized disclosure, or access to Personal Information under our control.

All our tools and equipment are password protected. In certain cases, some information treated is encrypted.

We also take preventive measures to restrict access to Personal Information. We do apply the following principles:

i) Need to know: we do not share all information with everyone in the organization. The access to functions and information must be necessary only for the conduct of the End-user’s assigned job duties

ii) Least privilege: access to functions and information must be granted only to the extent necessary for the conduct of the End-user’s assigned job duties

iii) Segregation of duties: To avoid conflict of interest and the risk of error or fraud, access to functions and data which are required to perform a critical task shall be separated and assigned to different persons.

How long is personal data retained?

We will keep your personal data only as long as it is reasonably necessary for the purposes described in this Privacy Statement. We do consider many factors in order to determine the correct retention period to be applied.

We retain Personal Information and transactional data for those periods required to comply with all retention and reporting obligations under applicable laws, including without limitation commercial, tax and anti-money laundering laws and regulations

Personal Information provided to us for marketing purposes may be retained until you opt out or until we become aware that any such data is inaccurate provided you do not have other ongoing relationships with us.

If you leave us your personal information will be deleted from the website as soon as possible and within a few weeks of your departure.

Where we consider there to be a risk that we may need to defend or bring legal claims, we may retain your personal information as necessary for our legitimate interests in ensuring that we can properly bring or defend legal claims. We may also need to share this information with our insurers or legal advisers. How long we keep this information will depend on the nature of the claim and how long we consider there to be a risk that we will need to defend or bring a claim.