What does this notice cover?

This Privacy Notice (the “Privacy Notice”) describes how Authlete, Inc. and its affiliates (“Authlete,” “we,” “our” or “us”) collect, use, and share information in connection with your use of our websites (including www.authlete.com), services, and applications (collectively, the “Services”). It also describes your data protection rights, including a right to object to some of the processing that we carry out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section below.

This Privacy Notice does not apply to information our customers may process when using our Services.

We recommend that you read this Privacy Notice in full to ensure you are fully informed. If you have any questions about this Privacy Notice or Authlete’s data collection, use, and disclosure practices, please contact us from our contact page.

1. Information we collect

We may collect and receive information about users of our Services (“users,” “you,” or “your”) from various sources, including: (i) information you provide through your user account on the Services (your “Account”) if you register for the Services; (ii) your use of the Services; and (iii) from third-party websites, services, and partners.

1a. Information you provide:

The personal information that you are asked to provide and the reasons why you are asked to provide it will be made clear to you at the point we ask you to provide your personal information.

1. Account Registration. When you register for an Account, we may ask for your contact information, including items such as name, and email address.
2. Communication. If you contact us directly, we may receive additional information about you, such as your name, email address, phone number, the contents of the message and attachments you may send us, and any other information you may choose to provide. We may also receive a confirmation when you open an email from us.

1b. Information We Collect When You Use Our Services.

1. Cookies and Other Tracking Technologies. As is true of most websites, we gather certain information automatically and store it in log files. In addition, when you use our Services, we may collect certain information automatically from your device. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, landing page, and referring URL. To collect this information, a cookie may be set on your computer or device when you visit our Services. Cookies contain a small amount of information that allows our web servers to recognize you. We store information that we collect through cookies, log files, and/or clear gifs to record your preferences. We may also automatically collect information about your use of features of our Services, about the functionality of our Services, frequency of visits, and other information related to your interactions with the Services. We may track your use across different websites and services. In some countries, including countries in the European Economic Area (“EEA”), the information referenced above in this paragraph may be considered the personal information under applicable data protection laws.
2. Usage of our Services. When you use our Services, we may collect information about your engagement with and utilization of our Services, such as access logs, and configuration of our Services. However, we do not store parameters in each request body to our Services.

2. How we use the information, and what is the legal basis for this use?

We use the information we collect for the following purposes and legal bases:

• To fulfill a contract, or take steps linked to a contract: this is relevant where you subscribe for our Services. This includes to:
  • process your user account, transactions, and subscription, including verifying your identity, taking payments and communicating with you;
  • communicate with you, either directly or through one of our partners, including for customer service.
• As required by Authlete to conduct our business and pursue our legitimate interests, in particular to:
  • provide, operate and maintain our Services;
  • communicate with you to provide our Services, such as responding to your queries;
  • provide you with updates and other information relating to the Service;
  • improve personalize and expand our Services;
  • understand and analyze how you use our Services;
  • develop new products, services, features, and functionality;
  • develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business;
  • protect the security and safety of our Services and our customers, and detect and prevent illegal activities;
  • protect your vital interests or those of another person;
• Where you give us consent:
  • for marketing and promotional purposes where we send you direct marketing in relation to our relevant products and services, or other products and services provided by us;
  • for placing cookies and using similar technologies in accordance with our Cookies Policy and the information provided to you when those technologies are used;
  • on other occasions where we ask you for consent, we will use the data for the purpose which we explain at the time.
• For purposes which are required by law:
  • For compliance purposes as may be required by applicable laws and regulations or requested by any judicial process or governmental agency, including requests by government or law enforcement authorities conducting an investigation.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract 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).

Relying on our legitimate interests

We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this Privacy Notice.

Withdrawing consent or otherwise objecting to direct marketing

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.

3. How we share information:

We may share the information we collect in various ways, including the following:

• Vendors and Service Providers. We may share information with third-party vendors and service providers that provide services on our behalfs, such as helping to provide our Services, for promotional and/or marketing purposes, and to provide you with information relevant to you such as product announcements, software updates, special offers, or other information.
• Aggregate Information. Where legally permissible, we may use and share information about users with our partners in an aggregated or de-identified form that can’t reasonably be used to identify you.
• Third-Party Partners. We also share information about users with third-party partners in order to receive additional publicly available information about you.
• Analytics. We use analytics providers, such as Google Analytics. Google Analytics uses cookies to collect non-identifying information. Google provides some additional privacy options regarding its Analytics cookies at http://www.google.com/policies/privacy/partners/.
• Business Transfers. Information may be disclosed and otherwise transferred to any potential acquirer, successor, or assignee as part of any proposed merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
• As Required by Law and Similar Disclosures. We may also share information to (i) satisfy any applicable law, regulation, legal process, or governmental request; (ii) enforce this Privacy Policy Notice and our Terms of Service, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security, or technical issues; (iv) respond to your requests; or (v) protect our legitimate interests, rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.
• With Your Consent. We may share information with your consent.

International Data transfers

Authlete is a global business. We may transfer personal information to countries other than the country in which the data was originally collected. These countries may not have the same data protection laws as the country in which you initially provided the information. In particular, your personal information may be transferred from a place in the EEA to a place outside the EEA that is not subject to an adequacy decision by the EU Commission , in which case such transfer is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification, or our internal binding corporate rules. A copy of the relevant mechanism can be provided for your review upon request. When we transfer your personal information to other countries, we will protect that information as described in this Privacy Notice.

4. Security

Authlete is committed to protecting your information. To do so, we employ a variety of security technologies and measures designed to protect information from unauthorized access, use, or disclosure. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. However, please bear in mind that the Internet cannot be guaranteed to be 100% secure.

5. Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements).

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in the future.

Where we process personal data in connection with performing a contract with you, we keep the data for 6 years from your last interaction with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. What rights do I have?

In accordance with applicable laws, you may have rights in relation to your personal information. Such rights include:

If you are a registered user, you may access certain information associated with your Account by contacting from our website. If you terminate your Account, any public activity on your Account prior to deletion may remain stored on our servers and may remain accessible to the public.

7. Your data protection rights under the general data protection regulation (GDPR)

If you are a resident of the EEA, you have the following data protection rights:

• If you wish to access (ask for a copy of your personal information), correct, update, or request deletion of your personal information, you can do so at any time by contacting from our website.
• In addition, you can object to the processing of your personal information, ask us to restrict the processing of your personal information, or request the portability of your personal information. Again, you can exercise these rights by contacting from our website.
• Opting Out: You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. To opt-out of other forms of marketing, please contact us by contacting from our website.
• Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• Right to complain: You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

Your rights may be limited. To protect your privacy and security, we may also take reasonable steps to verify your identity before updating or removing your information. The information you provide us may be archived or stored periodically by us according to backup processes conducted in the ordinary course of business for disaster recovery purposes. Your ability to access and correct your information may be temporarily limited where access and correction could: inhibit Authlete’s ability to comply with a legal obligation; inhibit Authlete’s ability to investigate, make or defend legal claims; result in disclosure of personal information about a third party; or result in breach of a contract or disclosure of trade secrets or other proprietary business information belonging to Authlete or a third party. Relevant exemptions are included in applicable data protection laws. We will inform you of the relevant exemptions we rely upon when responding to any request you make.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

8. Your choice

You may unsubscribe from receiving certain promotional emails from us. If you wish to do so, simply follow the instructions found at the end of the email. Even if you unsubscribe, we may still contact you for informational, transactional, account-related, or similar purposes.

Many browsers have an option for disabling cookies, which may prevent your browser from accepting new cookies or enable selective use of cookies. Please note that, if you choose not to accept cookies, some features and the personalization of our Services may no longer work for you. You will continue to receive advertising material but it will not be tailored to your interests.

9. Changes to this privacy notice

This Privacy Notice may be modified from time to time, so please review it frequently. Changes to this Privacy Notice will be posted on our websites. If we materially change the ways in which we use or share personal information previously collected from you through our Services, we will notify you through our Services, by email, or other communication.

10. Which Authlete entity is my data controller and with which affiliates might my data be shared?

The data controllers for your information are listed below:

Authlete, Inc.
FINOLAB, Otematchi Bldg 4F,
Otematchi 1-6-1, Chiyoda-ku, Tokyo, 100-0004, Japan

11. Contact us

If you have any questions or concerns about this Privacy Notice, please feel free to contact us from here.