Privacy and Cookie Policy for Mobile App

1. Introduction

PRIVACY AND COOKIE POLICY

This Privacy and Cookie Policy applies to the services of Nikkei Asia Mobile Apps. Capitalized terms used but not defined in this policy have the meaning given to those terms in the Terms of Use.


- Nikkei Asia Terms of Use for iOS App


- Nikkei Asia Terms of Use for Google Play App


Nikkei Inc. (“Nikkei”) will handle personal information in accordance with this policy.

(For clarity, our main Terms of Use, Privacy Policy and Cookie Policy apply in relation to your use of Nikkei Asia Services other than our Mobile Apps.---To be added on January 01, 2023)

Notice: This Privacy and Cookie Policy will be updated as described below. These changes will go into effect on January 01, 2023.

2. Personal information we collect

3. How we use your personal information

Nikkei will use your personal information for the following purposes, but will not use a method that is likely to foment or prompt unlawful or unjust act:


(1) To provide the Mobile Apps Service and personalize content available through the Service (“Content”) and to make Content relevant to you


(2) To improve, maintain and/or personalize the Service and other services of Nikkei Asia (“Ancillary Service”) and help us to develop new services and products


(3) To monitor compliance with our policies, terms, contracts and agreements, and to take appropriate action if they are breached


(4) To deliver information regarding renewal of periodical subscriptions and to communicate changes (in terms and conditions or Subscription types, etc.) and/or offers for Service and/or Ancillary Service


(5) For sales and marketing of Nikkei Asia


(6) For advertising, such as to:


- understand the effectiveness of the advertising which Nikkei serves to you and others, and to deliver relevant, personalized advertising (unless you opt out); and


- serve you with online advertisements that we believe are relevant to you and your interest (as described in clause 4, item 2, unless you opt out)


(7) For any other reasons required to provide the Service and/or Ancillary Service in relation with the above (1) - (6)

4. Who we provide your personal information to

(1) Nikkei will provide your personal information to a third party only when we have a lawful basis for doing so.


(2) Nikkei will provide personal information to some third parties to facilitate the running of our business or to provide specific services you have requested. Generally, Nikkei will provide personal information to:


- Service providers

Nikkei engages service providers who help to support its business and improve its products. These service providers include, for example, providers of online surveys etc. They can only use your personal information under Nikkei’s instruction.


- Advertising partners (for online advertisements)

Nikkei and its advertising partners serve you with online advertisements that we believe are relevant to you and your interests using cookies (and similar technologies).


- Organization where you work or study (for corporate subscriptions)

If you access our services through a corporate subscription of the organization where you work or study, Nikkei may provide your organization with your personal information.


- Social media platforms and other IT platforms

Personal information will be shared with social media platforms and other IT platforms where you use components of our Service provided by a social media platform or other IT platforms. Nikkei also shares your personal information with social media platforms and other IT platform partners for the following reasons:


- To prevent existing Users from being targeted with subscription offerings on social media platforms or other IT platforms


- To create lookalike audiences for the purposes of targeted advertising on social media platforms or other IT platforms


- To encourage Users to get the most out of their subscription


- Other users

The Service is publicly accessible, and anyone who accesses the Service will be able to see anything you post on the Service.


- Nikkei group

Nikkei will jointly use your personal information with Nikkei group companies as stipulated in clause 9.


When we provide your personal information to a third party in a country or jurisdiction outside of Japan as stipulated in this (2), we will do so after obtaining your consent providing you with general information on the personal information protection system in the country or jurisdiction, excluding the following cases:

- In case Japanese laws and regulations approve that the country or jurisdiction has a personal information protection system equivalent to that of Japan; or

- In case the third party has a system for taking continuous action equivalent to the obligation of a Japanese business operator handling personal information. In the second case above, Nikkei will take proper measure for securing the continuous equivalent action of the third party.


(3) Nikkei may also provide your personal information to relevant third parties to:


- comply with applicable laws, court orders or other valid legal processes;


- enforce or apply the Terms of Use, any subscription contract/agreement or any of our other rights;


- protect and defend Nikkei's rights, assets and properties, including to protect against misuse or unauthorized use of the Services; and


- protect the safety, asset or property of you or the public.

5. Controlling your personal information

Regrettably, there is no function to disable the cookies used on our Mobile Apps. Please consider using our Website instead and disabling cookies used there in accordance with its Cookie Policy.

This Privacy and Cookie Policy applies to the services of Nikkei Asia Mobile Apps. Capitalized terms used but not defined in this policy have the meaning given to those terms in the Terms of Use.


- Nikkei Asia Terms of Use for iOS App


- Nikkei Asia Terms of Use for Google


Play AppNikkei Inc. (“Nikkei”) will handle personal information in accordance with this policy.

Nikkei may collect the following personal information when you access our Mobile Apps:


- Usage of the Mobile Apps --- such as a history of pages viewed on the Mobile App


- Access environment --- such as IP address and the type of device you are using to access the Mobile Apps


- Engagement with advertisements --- such as advertisement viewing history


This information will be collected by using cookies mainly to improve the performance of the Service and to make advertising more relevant.


In detail, IT platform(s) may send data known as cookies to your device when you use our Mobile Apps Service. This data will be saved in the memory of your device. Cookies are used for purposes like monitoring the performance of our Mobile Apps.


We use the following third party cookie(s). See the links below for information on how the third party cookie(s) is/are used on our Mobile Apps.


Google Inc.

[Google Analytics]

Purpose: Traffic Analysis

Security and privacy in Universal


[Google Analytics for Firebase]

Purpose: Traffic Analysis

Privacy and Security in Firebase


AppsFlyer Ltd.

[AppsFlyer]

https://www.appsflyer.com/

Purpose: Ad Delivery

Services Privacy Policy


When you sign up for a subscription for the services of Nikkei Asia through our Mobile Apps, we will not collect any personal information. We will notify you beforehand if we collect any personal information unexplained herein.

6. Security

We have appropriate technical and administrative security measures in place to help ensure that your personal information is protected against unauthorized or accidental access, use, alteration or loss.

7. Transfer of personal information

As the internet is a global environment, collecting and processing personal information may involve international transmission of such information, including outside of Japan. Therefore, by communicating electronically with Nikkei, you acknowledge and agree to your personal information being processed in this way.

8. Children under 16

Nikkei does not intentionally collect any information on children under 16 years of age. Nikkei will undertake to delete any such information if notified by a parent or guardian.

9. Joint use by Nikkei group companies

Nikkei will jointly use your personal information with Nikkei group companies.


(1) The range of personal information that will be jointly used will be identical to the range stipulated in clause 2, "Personal information we collect."


(2) Nikkei group companies listed here will jointly use your personal information.


(3) The purpose of joint use will be the same as stipulated in clause 3, "How we use your personal information."


(4) Nikkei will be responsible for the management of joint use.

10. Point of contact for personal information/personal data enquiries

For inquiries about your personal information (or personal data) as specified by the Personal Information Protection Law in Japan or any other laws and regulations applicable, please contact us.


Nikkei Inc.

Head Office: 1-3-7 Otemachi, Chiyoda-ku, Tokyo 100-8066, Japan

12. Miscellaneous

(1) Nikkei may also handle your personal information in ways other than stated above when Nikkei, as a Japanese company, is required to comply with the Personal Information Protection Law in Japan or other laws and/or regulations where applicable.


(2) Nikkei may change this Privacy Policy at any time. Nikkei will publish the revised Privacy Policy before it becomes effective and will state its effective date.

13. Handling personal data of EEA and the U.K. residents

This clause applies only to the handling of personal data of users residing in the European Economic Area (EEA) and the United Kingdom (U.K.), in addition to clauses 1 through 12.


(1) Handling of personal data


We always process personal data on a lawful basis, such as:


- Your consent


This is when you have given us explicit permission to process your personal data for a given purpose.


- Legitimate business purposes


This is when we have a legitimate interest, as a business, to process personal data. For example, when we are aware of copyright infringements, it is in our legitimate interests as a business to identify those responsible. We take due care to balance our interests against your right to privacy.


- Contractual necessity


This is when we have to process personal data to meet our contractual obligations. For example, if you subscribe to the Print Edition, we would need to process your delivery address to fulfil your subscription.


- Legal obligation


This is when we have to process personal data in order to comply with the law. For example, we process and retain customer invoice data to comply with financial regulations.


(2) Cross border transfers


Personal data may be transferred to countries or jurisdictions outside your residence area such as Japan and the U.S. Please note that such countries or jurisdictions may not have the same data protection laws as your residence area and would not afford many of the rights conferred upon you in your residence area. We will put in place reasonable safeguards to protect information that is transferred in this way.


(3) Your rights


You have the right to access your personal data, request to delete your personal data, request to limit and/or object to the processing of your personal data, and request data portability with regards to your personal data. When Nikkei receives a request based on the rights specified above, Nikkei shall respond to such requests without undue delay.


You also have the right to withdraw your consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before withdrawal of the consent.


You can contact us to exercise the above rights which cannot be exercised in the way as stipulated in clause 5. We will keep improving our services so that more preferences can be configured.


You can lodge a complaint with your local data protection authority if you have a complaint regarding Nikkei’s processing of your personal data.


(4) Retention of personal data


Nikkei will retain personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

14. Handling personal information of California residents

This clause applies only to the handling of personal information of users residing in California, in addition to clauses 1 through 12.


The California Consumer Privacy Act (CCPA) may provide you with additional rights regarding the use of your personal information. These rights include:


- The right to access the personal information we process about you;


- The right to know what personal information is collected about you and if any information is sold or disclosed, and if so, to whom;


- The right to request the deletion of your personal information, if applicable;


- The right to opt-out from the sale of your personal information, if applicable; and


- The right to not be discriminated against for exercising any of the rights above.


You can contact us and exercise any applicable rights which cannot be exercised at Your Account as stipulated in clause 5 or by configuring cookie preferences. When you contact us and exercise such rights, you may be required to submit proof of your identity and/or address, if we are unable to confirm your identity or cannot verify that you are a California resident. When Nikkei receives a request based on the rights specified above, Nikkei shall respond to such requests without undue delay. You may also designate an authorized agent to make a request on your behalf, subject to proof of identity and authorization.


We do not sell your personal information.


From January 01, 2023:

This clause applies only to the handling of personal information of users residing in California, in addition to clauses 1 through 12. The terms in this clause shall be interpreted in accordance with the California Consumer Privacy Act of 2018 and California Privacy Rights Act of 2020 (collectively, “CPRA”).


CPRA may provide you with additional rights regarding the use of your personal information. These rights include:

- The right to know (i.e. “the right to access”) what personal information about you was over the past twelve (12) months collected or used and if any information was sold, disclosed or shared, and if so, to whom;

(Once Nikkei receives and confirms your verifiable consumer request, Nikkei will disclose to you:

- The categories of personal information Nikkei collected about you;

- The categories of sources for the personal information Nikkei collected about you;

- Our business or commercial purpose for collecting, selling or sharing your personal information;

- The categories of third parties to whom Nikkei discloses, sells or shares your personal information; and

- The specific pieces of personal information Nikkei collected about you (i.e. a data portability request).)


- The right to request the deletion of your personal information, if applicable;(Nikkei will instruct any third parties, including service providers and/or contractors, to whom Nikkei has disclosed your personal information, to delete your information, if applicable.)


- The right to request correction;(If Nikkei retains inaccurate personal information about you, you have the right to request us to correct such inaccurate personal information, taking into account the nature of the personal information and the purposes for which the personal information is processed. Upon receiving and confirming your verified consumer request, Nikkei will use commercially reasonable efforts to correct the inaccurate personal information indicated by you in accordance with the laws and regulations.)


- The right to not be discriminated against for exercising any of the rights provided by CPRA; and


- The right to opt-out from the sale or sharing of your personal information, if applicable.


Cookies are used in our Mobile Apps as clause 2 describes. If you exercise the right to opt-out of the cookies (“Do Not Sell or Share My Personal Information”), please follow the instruction of clause 5. Regrettably, there is no function to disable the cookies used on our Mobile Apps. Our Content is fully available also on our Website.


You can contact us and exercise any applicable rights other than the opting-out of the cookies. Only you as a natural person or a person registered with the California Secretary of State that you authorize to act on its behalf, or a person who has power of attorney or is acting as a conservator for you, may make a verified consumer request related to your personal information. You may also make a verified consumer request on behalf of your minor child. When Nikkei receives a request based on the rights specified above, Nikkei shall respond to such requests without undue delay. You may also designate an authorized agent to make a request on your behalf, subject to proof of identity and authorization.


You may only make a verifiable consumer request with:

- Sufficient information that allows us to reasonably verify that you are the person about whom Nikkei collected personal information or an authorized representative thereof; and

- Description of your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.


Please note that the above rights are not absolute, and Nikkei may be entitled to refuse requests, wholly or partly, where exceptions under applicable law apply.

If your requests are manifestly unfounded or excessive, in particular because of their repetitive character, Nikkei may:

- Charge a reasonable fee taking in account the administrative costs of providing the information or taking the action requested; or

- Refuse to act on the request and notify you of the reason for refusing the request.


Nikkei may deny your deletion request if retaining the information is necessary for us, our service provider(s) or our contractor(s) to:

- Complete the transaction for which Nikkei collected the personal information, fulfill the terms of a warranty or product recall made pursuant to federal law of U.S., or provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;

- Help ensure the security and integrity of consumers' personal information to the extent that its use is reasonably necessary and proportionate to its purpose;

- Debug products to identify and repair errors that impair existing intended functionality;

- Exercise free speech, ensure the rights of another consumer to exercise their free speech rights, or exercise other rights provided for by law;

- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);

- Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent thereto;

- Perform internal and lawful uses reasonably aligned with consumer expectations based on your relationship with us and that are compatible with the context in the which you provided such information; or

- Comply with legal obligations.


Nikkei will not discriminate against you for exercising any of your CPRA rights. Unless permitted by the CPRA, Nikkei will not:

- Deny you goods or services;

- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;

- Provide you a different level or quality of goods or services; or

- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.


In relation to your use of our Mobile Apps,

- We do not sell your personal information.

- Clause 2 outlines the categories of personal information Nikkei has collected about you and sources of the collection in relation to the services of Nikkei Asia in the preceding twelve (12) months.

- Clauses 2 and 4 outline our possible sharing of your personal information in the preceding twelve (12) months and the categories of third parties to whom the information was shared.

- Clauses 4 and 9 outline the categories of personal information that Nikkei has disclosed for a business purpose to third parties in the preceding twelve (12) months and the categories of third parties to whom the information was disclosed.

- Nikkei does not collect sensitive personal information.(For clarity, clause 14 of our main Privacy Policy applies in relation to your use of our Services other than our Mobile Apps.)


Nikkei does not have any actual knowledge that Nikkei sells or shares the personal information of consumers under 16 years of age.


Nikkei will retain personal information for the period necessary to fulfill the purposes outlined in this Privacy and Cookie Policy, unless a longer retention period is required or permitted by law.

Our criteria for determining the retention period include, without limitation: (i) the duration you receive services from us; and (ii) the existence of legal obligations to which Nikkei is subject.


If you have any questions or concerns about our Privacy and Cookie Policy and information practices, please contact us.

1. Introduction

PRIVACY AND COOKIE POLICY (Revised on April 01, 2022
as follows.)

Mobile Apps version: established on October 22, 2020

Revised on December 23, 2020

Revised on April 01, 2022

To be revised on January 01, 2023

11. EU Representative (from April 01, 2022)

PLANIT // LEGAL Rechtsanwaltsgesellschaft mbH

Jungfernstieg 1, 20095 Hamburg, Germany

mail@planit.legal

11. EU Representative
(from April 01, 2022)

Privacy and Cookie Policy for Mobile App

1. Introduction

PRIVACY AND COOKIE POLICY

This Privacy and Cookie Policy applies to the services of Nikkei Asia Mobile Apps. Capitalized terms used but not defined in this policy have the meaning given to those terms in the Terms of Use.


- Nikkei Asia Terms of Use for iOS App


- Nikkei Asia Terms of Use for Google Play App


Nikkei Inc. (“Nikkei”) will handle personal information in accordance with this policy.

(For clarity, our main Terms of Use, Privacy Policy and Cookie Policy apply in relation to your use of Nikkei Asia Services other than our Mobile Apps.)

2. Personal information we collect

3. How we use your personal information

Nikkei will use your personal information for the following purposes, but will not use a method that is likely to foment or prompt unlawful or unjust act:


(1) To provide the Mobile Apps Service and personalize content available through the Service (“Content”) and to make Content relevant to you


(2) To improve, maintain and/or personalize the Service and other services of Nikkei Asia (“Ancillary Service”) and help us to develop new services and products


(3) To monitor compliance with our policies, terms, contracts and agreements, and to take appropriate action if they are breached


(4) To deliver information regarding renewal of periodical subscriptions and to communicate changes (in terms and conditions or Subscription types, etc.) and/or offers for Service and/or Ancillary Service


(5) For sales and marketing of Nikkei Asia


(6) For advertising, such as to:


- understand the effectiveness of the advertising which Nikkei serves to you and others, and to deliver relevant, personalized advertising (unless you opt out); and


- serve you with online advertisements that we believe are relevant to you and your interest (as described in clause 4, item 2, unless you opt out)


(7) For any other reasons required to provide the Service and/or Ancillary Service in relation with the above (1) - (6)

4. Who we provide your personal information to

(1) Nikkei will provide your personal information to a third party only when we have a lawful basis for doing so.


(2) Nikkei will provide personal information to some third parties to facilitate the running of our business or to provide specific services you have requested. Generally, Nikkei will provide personal information to:


- Service providers

Nikkei engages service providers who help to support its business and improve its products. These service providers include, for example, providers of online surveys etc. They can only use your personal information under Nikkei’s instruction.


- Advertising partners (for online advertisements)

Nikkei and its advertising partners serve you with online advertisements that we believe are relevant to you and your interests using cookies (and similar technologies).


- Organization where you work or study (for corporate subscriptions)

If you access our services through a corporate subscription of the organization where you work or study, Nikkei may provide your organization with your personal information.


- Social media platforms and other IT platforms

Personal information will be shared with social media platforms and other IT platforms where you use components of our Service provided by a social media platform or other IT platforms. Nikkei also shares your personal information with social media platforms and other IT platform partners for the following reasons:


- To prevent existing Users from being targeted with subscription offerings on social media platforms or other IT platforms


- To create lookalike audiences for the purposes of targeted advertising on social media platforms or other IT platforms


- To encourage Users to get the most out of their subscription


- Other users

The Service is publicly accessible, and anyone who accesses the Service will be able to see anything you post on the Service.


- Nikkei group

Nikkei will jointly use your personal information with Nikkei group companies as stipulated in clause 9.


When we provide your personal information to a third party in a country or jurisdiction outside of Japan as stipulated in this (2), we will do so after obtaining your consent providing you with general information on the personal information protection system in the country or jurisdiction, excluding the following cases:

- In case Japanese laws and regulations approve that the country or jurisdiction has a personal information protection system equivalent to that of Japan; or

- In case the third party has a system for taking continuous action equivalent to the obligation of a Japanese business operator handling personal information. In the second case above, Nikkei will take proper measure for securing the continuous equivalent action of the third party.


(3) Nikkei may also provide your personal information to relevant third parties to:


- comply with applicable laws, court orders or other valid legal processes;


- enforce or apply the Terms of Use, any subscription contract/agreement or any of our other rights;


- protect and defend Nikkei's rights, assets and properties, including to protect against misuse or unauthorized use of the Services; and


- protect the safety, asset or property of you or the public.

5. Controlling your personal information

Regrettably, there is no function to disable the cookies used on our Mobile Apps. Please consider using our Website instead and disabling cookies used there in accordance with its Cookie Policy.

This Privacy and Cookie Policy applies to the services of Nikkei Asia Mobile Apps. Capitalized terms used but not defined in this policy have the meaning given to those terms in the Terms of Use.


- Nikkei Asia Terms of Use for iOS App


- Nikkei Asia Terms of Use for Google


Play AppNikkei Inc. (“Nikkei”) will handle personal information in accordance with this policy.

Nikkei may collect the following personal information when you access our Mobile Apps:


- Usage of the Mobile Apps --- such as a history of pages viewed on the Mobile App


- Access environment --- such as IP address and the type of device you are using to access the Mobile Apps


- Engagement with advertisements --- such as advertisement viewing history


This information will be collected by using cookies mainly to improve the performance of the Service and to make advertising more relevant.


In detail, IT platform(s) may send data known as cookies to your device when you use our Mobile Apps Service. This data will be saved in the memory of your device. Cookies are used for purposes like monitoring the performance of our Mobile Apps.


We use the following third party cookie(s). See the links below for information on how the third party cookie(s) is/are used on our Mobile Apps.


Google Inc.

[Google Analytics]

Purpose: Traffic Analysis

Security and privacy in Universal Analytics


[Google Analytics for Firebase]

Purpose: Traffic Analysis

Privacy and Security in Firebase


AppsFlyer Ltd.

[AppsFlyer]

https://www.appsflyer.com/

Purpose: Ad Delivery

Services Privacy Policy


When you sign up for a subscription for the services of Nikkei Asia through our Mobile Apps, we will not collect any personal information. We will notify you beforehand if we collect any personal information unexplained herein.

6. Security

We have appropriate technical and administrative security measures in place to help ensure that your personal information is protected against unauthorized or accidental access, use, alteration or loss.

7. Transfer of personal information

As the internet is a global environment, collecting and processing personal information may involve international transmission of such information, including outside of Japan. Therefore, by communicating electronically with Nikkei, you acknowledge and agree to your personal information being processed in this way.

8. Children under 16

Nikkei does not intentionally collect any information on children under 16 years of age. Nikkei will undertake to delete any such information if notified by a parent or guardian.

9. Joint use by Nikkei group companies

Nikkei will jointly use your personal information with Nikkei group companies.


(1) The range of personal information that will be jointly used will be identical to the range stipulated in clause 2, "Personal information we collect."


(2) Nikkei group companies listed here will jointly use your personal information.


(3) The purpose of joint use will be the same as stipulated in clause 3, "How we use your personal information."


(4) Nikkei will be responsible for the management of joint use.

10. Point of contact for personal information/personal data enquiries

For inquiries about your personal information (or personal data) as specified by the Personal Information Protection Law in Japan or any other laws and regulations applicable, please contact us.


Nikkei Inc.

Head Office: 1-3-7 Otemachi, Chiyoda-ku, Tokyo 100-8066, Japan

12. Miscellaneous

(1) Nikkei may also handle your personal information in ways other than stated above when Nikkei, as a Japanese company, is required to comply with the Personal Information Protection Law in Japan or other laws and/or regulations where applicable.


(2) Nikkei may change this Privacy Policy at any time. Nikkei will publish the revised Privacy Policy before it becomes effective and will state its effective date.

13. Handling personal data of EEA and the U.K. residents

This clause applies only to the handling of personal data of users residing in the European Economic Area (EEA) and the United Kingdom (U.K.), in addition to clauses 1 through 12.


(1) Handling of personal data


We always process personal data on a lawful basis, such as:


- Your consent


This is when you have given us explicit permission to process your personal data for a given purpose.


- Legitimate business purposes


This is when we have a legitimate interest, as a business, to process personal data. For example, when we are aware of copyright infringements, it is in our legitimate interests as a business to identify those responsible. We take due care to balance our interests against your right to privacy.


- Contractual necessity


This is when we have to process personal data to meet our contractual obligations. For example, if you subscribe to the Print Edition, we would need to process your delivery address to fulfil your subscription.


- Legal obligation


This is when we have to process personal data in order to comply with the law. For example, we process and retain customer invoice data to comply with financial regulations.


(2) Cross border transfers


Personal data may be transferred to countries or jurisdictions outside your residence area such as Japan and the U.S. Please note that such countries or jurisdictions may not have the same data protection laws as your residence area and would not afford many of the rights conferred upon you in your residence area. We will put in place reasonable safeguards to protect information that is transferred in this way.


(3) Your rights


You have the right to access your personal data, request to delete your personal data, request to limit and/or object to the processing of your personal data, and request data portability with regards to your personal data. When Nikkei receives a request based on the rights specified above, Nikkei shall respond to such requests without undue delay.


You also have the right to withdraw your consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before withdrawal of the consent.


You can contact us to exercise the above rights which cannot be exercised in the way as stipulated in clause 5. We will keep improving our services so that more preferences can be configured.


You can lodge a complaint with your local data protection authority if you have a complaint regarding Nikkei’s processing of your personal data.


(4) Retention of personal data


Nikkei will retain personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

14. Handling personal information of California residents

This clause applies only to the handling of personal information of users residing in California, in addition to clauses 1 through 12. The terms in this clause shall be interpreted in accordance with the California Consumer Privacy Act of 2018 and California Privacy Rights Act of 2020 (collectively, “CPRA”).


CPRA may provide you with additional rights regarding the use of your personal information. These rights include:


- The right to know (i.e. “the right to access”) what personal information about you was over the past twelve (12) months collected or used and if any information was sold, disclosed or shared, and if so, to whom;

(Once Nikkei receives and confirms your verifiable consumer request, Nikkei will disclose to you:

- The categories of personal information Nikkei collected about you;

- The categories of sources for the personal information Nikkei collected about you;

- Our business or commercial purpose for collecting, selling or sharing your personal information;

- The categories of third parties to whom Nikkei discloses, sells or shares your personal information; and

- The specific pieces of personal information Nikkei collected about you (i.e. a data portability request).)


- The right to request the deletion of your personal information, if applicable;

(Nikkei will instruct any third parties, including service providers and/or contractors, to whom Nikkei has disclosed your personal information, to delete your information, if applicable.)


- The right to request correction;

(If Nikkei retains inaccurate personal information about you, you have the right to request us to correct such inaccurate personal information, taking into account the nature of the personal information and the purposes for which the personal information is processed. Upon receiving and confirming your verified consumer request, Nikkei will use commercially reasonable efforts to correct the inaccurate personal information indicated by you in accordance with the laws and regulations.)


- The right to not be discriminated against for exercising any of the rights provided by CPRA; and


- The right to opt-out from the sale or sharing of your personal information, if applicable.


Cookies are used in our Mobile Apps as clause 2 describes. If you exercise the right to opt-out of the cookies (“Do Not Sell or Share My Personal Information”), please follow the instruction of clause 5. Regrettably, there is no function to disable the cookies used on our Mobile Apps. Our Content is fully available also on our Website.


You can contact us and exercise any applicable rights other than the opting-out of the cookies. Only you as a natural person or a person registered with the California Secretary of State that you authorize to act on its behalf, or a person who has power of attorney or is acting as a conservator for you, may make a verified consumer request related to your personal information. You may also make a verified consumer request on behalf of your minor child. When Nikkei receives a request based on the rights specified above, Nikkei shall respond to such requests without undue delay. You may also designate an authorized agent to make a request on your behalf, subject to proof of identity and authorization.


You may only make a verifiable consumer request with:

- Sufficient information that allows us to reasonably verify that you are the person about whom Nikkei collected personal information or an authorized representative thereof; and

- Description of your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.


Please note that the above rights are not absolute, and Nikkei may be entitled to refuse requests, wholly or partly, where exceptions under applicable law apply.

If your requests are manifestly unfounded or excessive, in particular because of their repetitive character, Nikkei may:

- Charge a reasonable fee taking in account the administrative costs of providing the information or taking the action requested; or

- Refuse to act on the request and notify you of the reason for refusing the request.


Nikkei may deny your deletion request if retaining the information is necessary for us, our service provider(s) or our contractor(s) to:

- Complete the transaction for which Nikkei collected the personal information, fulfill the terms of a warranty or product recall made pursuant to federal law of U.S., or provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;

- Help ensure the security and integrity of consumers' personal information to the extent that its use is reasonably necessary and proportionate to its purpose;

- Debug products to identify and repair errors that impair existing intended functionality;

- Exercise free speech, ensure the rights of another consumer to exercise their free speech rights, or exercise other rights provided for by law;

- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);

- Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent thereto;

- Perform internal and lawful uses reasonably aligned with consumer expectations based on your relationship with us and that are compatible with the context in the which you provided such information; or

- Comply with legal obligations.


Nikkei will not discriminate against you for exercising any of your CPRA rights. Unless permitted by the CPRA, Nikkei will not:

- Deny you goods or services;

- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;

- Provide you a different level or quality of goods or services; or

- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.


In relation to your use of our Mobile Apps,

- We do not sell your personal information.

- Clause 2 outlines the categories of personal information Nikkei has collected about you and sources of the collection in relation to the services of Nikkei Asia in the preceding twelve (12) months.

- Clauses 2 and 4 outline our possible sharing of your personal information in the preceding twelve (12) months and the categories of third parties to whom the information was shared.

- Clauses 4 and 9 outline the categories of personal information that Nikkei has disclosed for a business purpose to third parties in the preceding twelve (12) months and the categories of third parties to whom the information was disclosed.

- Nikkei does not collect sensitive personal information.

(For clarity, clause 14 of our main Privacy Policy applies in relation to your use of our Services other than our Mobile Apps.)


Nikkei does not have any actual knowledge that Nikkei sells or shares the personal information of consumers under 16 years of age.


Nikkei will retain personal information for the period necessary to fulfill the purposes outlined in this Privacy and Cookie Policy, unless a longer retention period is required or permitted by law.

Our criteria for determining the retention period include, without limitation: (i) the duration you receive services from us; and (ii) the existence of legal obligations to which Nikkei is subject.


If you have any questions or concerns about our Privacy and Cookie Policy and information practices, please contact us.

1. Introduction

Mobile Apps version: established on October 22, 2020

Revised on December 23, 2020

Revised on April 01, 2022

Revised on January 01, 2023

11. EU Representative

PLANIT // LEGAL Rechtsanwaltsgesellschaft mbH

Jungfernstieg 1, 20095 Hamburg, Germany

mail@planit.legal

11. EU Representative

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Nikkei Inc. No reproduction without permission.

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