This Data Protection Policy (the "Policy") applies to the collection, use and disclosure of an individual's Personal Data (as defined below) arising from service offered by Shinnyo-en ( "Shinnyo-en").

1.1 This Policy provides information on the obligations and policies of Shinnyo-en in respect of Personal Data on the website "stream.shinnyo.tv" (the "Website") operated by Shinnyo-en. Shinnyo-en undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations.

1.2 Shinnyo-en's officers, management, and members of staff shall use reasonable endeavors to respect the confidentiality of and keep safe any and all Personal Data collected, stored, disclosed and/or used for, or on behalf of, Shinnyo-en. Shinnyo-en shall use reasonable endeavors to ensure that all collection, storage, disclosure and/or usage of Personal Data by Shinnyo-en shall be done in an appropriate manner and in accordance with the Protection of Personal Information Act (No. 37 of 2021) in Japan (the "Act") and this Policy.

1.3 By logging in for service on the Website, you agree and consent to Shinnyo-en collecting, using, disclosing and sharing your Personal Data, and disclosing such Personal Data to Shinnyo-en's authorized service providers and relevant third parties in the manner set forth in this Policy.

1.4 This Policy does not replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.

1.5 For the purposes of this Policy, in line with the provisions under the Act, "Personal Data" shall mean data, whether true or not, about an individual who can be identified — from that data; or from that data and other information which an organization has or is likely to have access. Such Personal Data shall also refer to that which is already in the possession of " or that which shall be collected by Shinnyo-en in future.

2.1 Where you legitimately request access to, correction, deletion, suspension of use, and/or cancellation to provide third party of Personal Data relating to you, such Personal Data which is in the possession and control of Shinnyo-en, Shinnyo-en shall provide, correct, delete, suspend to use, and/or cancel to provide third party that data within 30 days and in a manner in accordance with its standard procedures as stated hereinafter.

2.2 In accordance with the Act, Shinnyo-en has established a process for receiving and responding to any query or complaint that may arise with respect to the application of this Policy. To ensure that Shinnyo-en receives your complaints and enquiries, please send the same via email to the Data Protection Officer (the "DPO") of Shinnyo-en at the following email address:

dpo_international@shinnyo.net.

2.3 Please note that if your personal data has been provided to us by a third party (e.g. via a referral), you should contact such third party to make such queries, complaints, and access and correction requests to Shinnyo-en.

2.4 Should you not wish Shinnyo-en to use your Personal Data for any of the purposes listed in Clauses 3.2, you may opt out by sending a clearly worded email to the DPO via the email address provided in Clause 2.2. After Shinnyo-en confirms that the request has been done by yourself, your request shall be processed within 30 days. Please note however that this may affect our ability to attend to your needs with respect to the details that we have previously requested you to submit.

Your Personal Data may be processed by Shinnyo-en, its affiliates, or third parties providing services to Shinnyo-en in or outside Japan. In this event Shinnyo-en shall comply with the terms of the relevant local act applicable to it, and if necessary require your consent.

Shinnyo-en may validate data provided using generally accepted activities and guidelines. In some instances, Shinnyo-en is able to validate the data provided against pre-existing data held by Shinnyo-en. Also, Shinnyo-en may be required to confirm original documentation before we may use the Personal Data such as with Personal Identifiers and/or proof of address. To ensure the accuracy of your Personal Data in the possession of Shinnyo-en or in case of any updates of any parts of your Personal Data, please complete the procedures based on Clause 7 below.

Shinnyo-en uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside Shinnyo-en, other than to you or as described in this Policy. However, Shinnyo-en cannot ensure or warrant the security of any information you transmit to Shinnyo-en and you do so entirely at your own risk. In particular, Shinnyo-en does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any of Shinnyo-en's physical, technical, or managerial safeguards.

7.1 In accordance with Clause 2.1 of this Policy, you have the right to:
a) check whether Shinnyo-en holds any Personal Data relating to you and, if so, obtain copies of such data; and
b) require Shinnyo-en to correct, delete, or suspend to use any Personal Data relating to you which is inaccurate for the purpose for which it is being used.

7.2 Shinnyo-en reserves the right to charge a reasonable administrative fee in order to meet your requests under Clause 7.1(a). Upon payment of the requisite fee under Clause 7.1(a) and/or receipt of your request under Clause 7.1(b), your request shall be processed within 30 days.

7.3 If you wish to verify the details you have submitted to Shinnyo-en or if you wish to check on the manner in which Shinnyo-en uses and processes your personal data, Shinnyo-en's security procedures mean that Shinnyo-en may request proof of identity before we reveal information. This proof of identity will take the form of full details of name, membership number and relevant identification number. You are therefore responsible for properly managing the ID, etc. used for login. We would strongly recommend when you login to your online account in the Websites that you do not use the browser's password memory function as that would permit other people using your terminal to access your Personal Data.

Shinnyo-en will delete, as reasonably possible, or otherwise anonymize any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of Shinnyo-en and where the Personal Data is deleted from Shinnyo-en's electronic, manual, and other filing systems in accordance with Shinnyo-en's internal procedures and/or other agreements.

Shinnyo-en reserves the right to alter any of the clauses contained herein in compliance with local legislation, and for any other purpose deemed reasonably necessary by Shinnyo-en. You should look at these terms regularly. If you do not agree to the modified terms, you should inform us as soon as possible of the terms to which you do not consent. Pending such notice, if there is any inconsistency between these terms and the revised terms, the revised terms will prevail to the extent of the inconsistency.

This Policy is governed by and shall be construed in accordance with the laws of Japan. You hereby submit to the non-exclusive jurisdiction of the Japan courts.

11.1 This Policy only applies to the collection and use of Personal Data by Shinnyo-en on the Website. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. Shinnyo-en does not share your Personal Data with third party websites. Shinnyo-en is not responsible for the privacy and activities of these third-party websites, so you should read their own privacy policies on such third parties' websites before disclosure of any Personal Data to these third parties' websites.

11.2 Shinnyo-en will not sell or transfer your Personal Data to any third party without your permission.

11.3 In cases where Personal Data of a minor is involved, Shinnyo-en shall seek the relevant consent from the minor's parent/guardian, and shall treat such Personal Data as having given parent/guardian's consent. If it becomes clear that there is no consent from the parent/guardian, Shinnyo-en shall not use the Personal Data for any purpose other than contacting parent/guardian and any other related purposes.