This Privacy Policy (“Policy”) is to ensure that you understand the type of information acquired, the use of this information and the purpose of this use, the methods used by Ricoh Company, Ltd. (“RICOH”) for handling your personal data in “RICOH THETA Smart Device Plug-in Service”, a service provided by RICOH.

“Personal Data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

For questions about this Policy or your Personal Data, please contact us: theta_alexa@jp.ricoh.com

RICOH implements appropriate safety management measures to comply with laws and regulations, guidelines and internal regulations of RICOH to prevent leaking, loss, destruction, etc. of Personal Data, and works to protect Personal Data retained by RICOH. RICOH also trains its employees on appropriate handling of Personal Data, etc. and works to fully ensure the protection of this information.

RICOH will acquire and use your Personal Data within the necessary scope for the purposes stated below.

List of Types of Acquired Information and Purposes of Use

RICOH will not provide Personal Data to third parties except in the following cases:

(1) If prior consent has been received from you,

(2) Provision to business contractors, business partners, etc. with appropriate supervision from RICOH to fulfil a purpose of use:

• RICOH transfers Personal Data to its processor and hosting provider, Amazon Web Services, Inc., in the United States of America. This is necessary for the provision of the platform and, thus, for the fulfilment of the Terms of Use, Art. 6 (1) lit. b GDPR.
• The transfer of Personal Data to Amazon Web Services, Inc. in the United States of America is conducted under an adequate level of data protection as compared to the GDPR, because Amazon Web Services, Inc. has certified itself under the EU-US-Privacy Shield.
• Personal Data will also be transferred to the RICOH processor and part of Ricoh group companies, Ricoh IT Solutions Co., Ltd. in Japan, who conducts the maintenance and support service for the Services on RICOH’s behalf. This is necessary for the provision of maintenance and to provide Services, Art. 6 (1) lit. b GDPR.
• The transfer of Personal Data to Ricoh IT Solutions Co., Ltd. In Japan is conducted under an adequate level of protection due to the Commission Implementing Decision C (2019) 304 of 23 January 2019 pursuant to Regulation (EU) 2016/679 and the corresponding decision taken by the Japanese Personal Information Protection Commission of 23 January 2019 (“Reciprocal Adequacy Decision”).

(3) If the Personal Data is required for the protection of a person’s life, Art. 6 (1) lit. d GDPR.

(4) If provision of the Personal Data is requested according to a law or regulation, Art.6 (1) lit. c GDPR.

(1) You have the following rights in relation to Personal Data relating to you that RICOH processes:

• The right to require free of charge (i) information whether your Personal Data is retained and (ii) access to and/or (iii) duplicates of the Personal Data retained. However, if the request affects the rights and freedoms of others or is manifestly unfounded or excessive, RICOH reserves the right to charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request;
• The right to request proper rectification, removal or restriction of your Personal Data;
• Where processing of your Personal Data is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, the right to receive the Personal Data concerning you in a structured, commonly used and machine-readable format or to have your Personal Data transmitted directly to another company, where technically feasible (data portability);
• Where the processing of your Personal Data is based on your consent, the right to withdraw your consent at any time without impact to data processing activities that have taken before such withdrawal or to any other existing legal justification of the processing activity in question;
• The right not to be subject any automatic individual decisions which produces legal effects on you or similarly significantly affects you; and
• The right to take legal actions in relation to any breach of your rights regarding the processing of the Personal Data, as well as to lodge complaints before the competent data protection regulators.

(2) When you wish to submit a request regarding the usage of your Personal Data for the Service, please contact at: theta_alexa@jp.ricoh.com. Persons making inquiries may be asked to confirm that they are the data subject or a legitimate agent of the data subject.

(3) Please be aware that requests may not be granted in cases in the following categories.

• If the requester cannot confirm that they are the data subject or a legitimate agent of the data subject.
• If disclosure of Personal Data held by RICOH violate other laws or regulations.
• In the case of requests being manifestly unfounded or excessive, in particular because of their repetitive character.
• In the case of a request for deletion or cessation of use of Personal Data held by RICOH if, to the extent that processing is necessary: -for exercising the right of freedom of expression and information; -for compliance with a legal obligation which requires processing by Union or Member State law to which RICOH is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in RICOH; -for reasons of public interest in the area of public health; -for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89 (1) GDPR in so far as the right for deletion is likely to render impossible or seriously impair the achievement of the objectives of that processing; or -for the establishment, exercise or defence of legal claims.
  • -for exercising the right of freedom of expression and information;
  • -for compliance with a legal obligation which requires processing by Union or Member State law to which RICOH is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in RICOH;
  • -for reasons of public interest in the area of public health;
  • -for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89 (1) GDPR in so far as the right for deletion is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
  • -for the establishment, exercise or defence of legal claims.

(4) This Service uses IDs provided by a party other than RICOH, namely Google LLC, Amazon.com, Inc. and Facebook, Inc. The registered content for these services is not managed by RICOH. Please contact the issuer for inquiries.

If you have any complaints and other inquiries relating to the handling of Personal Data, please contact us at theta_alexa@jp.ricoh.com, or by writing to us at the following address:
Ricoh Company, Ltd.
1-3-6 Nakamagome, Ohta-ku,Tokyo
143-8555 Japan

Ricoh Company, Ltd. is the data controller for the purposes of the Personal Data processed under this Policy.

RICOH may update this Policy in response to changes to or improvements of the purposes of use, improvement of safety, or according to revisions of related laws, regulations and rules. Therefore, RICOH recommends to periodically check this Policy on RICOH’s website.

Implemented: June 1 2019
Ricoh Company, Ltd.