Privacy Policy
White Ship, Inc. ("White Ship", "the Company", "us", "we", "our") recognizes the critical importance of protecting personal information (“Personal Data”: information relating to an individual by which a specific individual can be identified; the same applies throughout) and is committed to complying with the Act on the Protection of Personal Information ("APPI") and protecting personal data in accordance with this Privacy Policy ("Policy").
This Policy applies to Personal Data collected in connection with the Company's website egaku.co (the "Site") and EGAKU gallery and online program sessions (the "Open Sessions").
1. Collection of personal data
The Company collects personal data through lawful and fair means, without deception or other improper methods.
2. Use of personal data
2.1 The Company will use customers' personal data only to the extent necessary for the conduct of its business, and only for the following purposes:
1. Responding to inquiries and questions directed to the Company
2. Providing and operating the Open Sessions (including booking management, session administration, and payment processing)
3. Providing information about EGAKU programs and related exhibitions, events, seminars, and other programs organized or participated in by the Company
4. Compiling aggregated data for internal reporting purposes, including demographic breakdowns (age, gender, etc.)
5. Improving existing services and developing new services, including the creation and use of anonymized information (see Section 2.2)
6. Photography and video recording at gallery sessions and other programs for use in public communications and marketing. Participants will be notified of any photography or video recording in their booking confirmation email and again at the start of the session. Participants who prefer not to be photographed or recorded should notify a staff member.
Where the Company has separately specified additional purposes at the time of collection, personal data will also be used for those stated purposes.
2.2 Anonymized Information
In accordance with Article 43 and subsequent provisions of the APPI, the Company may create and use anonymized information derived from collected personal data through appropriate processing.
Anonymized information may be used for the following purposes:
1. Improving and enhancing existing services and developing new services
2. Research, analysis, and study in the fields of learning, human development, and organizational development
3. Analysis using AI-assisted text analysis, data mining, and related methods
The Company will publish on the Site the categories of information included in any anonymized information it creates, and will not attempt to re-identify any individual from such anonymized information.
3. Security Management
To ensure the proper handling of personal data, the Company has established basic policies covering compliance with applicable laws, regulations, and guidelines, and the handling of inquiries and complaints, and has put in place internal rules for the handling of personal data. The Company designates a person responsible for personal data management and maintains a reporting structure for notifying that person of data incidents, violations, and any indicators thereof.
In the event of a significant incident involving the leakage, loss, or damage of personal data, the Company will promptly report to the Personal Information Protection Commission and notify affected individuals in accordance with APPI Article 26 and applicable guidelines issued by the Personal Information Protection Commission.
Where a breach involves the personal data of customers residing in the EEA or the United Kingdom, the Company will notify the relevant data protection authority and, where required, affected individuals, in accordance with applicable data protection law.
4. Disclosure of Personal Data to Third Parties
4.1 The Company will not disclose personal data to any third party without the prior consent of the individual, except as required or permitted by the APPI or other applicable laws and regulations.
In the course of its business operations, the Company may share personal data with the following service providers acting as data processors on its behalf. The Company maintains appropriate oversight of these processors in accordance with the APPI.
・ Wix.com Ltd. — Booking and membership management (Israel, United States)
・ Zoom Video Communications, Inc. — Online sessions (United States)
・ Stripe, Inc. — Payment processing (United States)
・ Google LLC — Email and file management (United States)
・ Dropbox, Inc. — File management and data storage (United States)
The processors listed above are located in countries whose personal data protection frameworks differ from Japan's APPI. The Company has taken appropriate contractual measures to ensure the protection of personal data transferred to these processors. For information on data protection frameworks in foreign jurisdictions, please refer to the Personal Information Protection Commission's Foreign Legal System Survey: https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/#gaikoku
4.2 Cookies
This Site uses cookies to maintain website functionality and improve our services. The types of cookies we use are as follows:
• Essential cookies: Required for core website functions such as maintaining login sessions and enabling bookings. These cookies are active by default and do not require your prior consent.
• Functional cookies: Used to save your preferences, such as language settings.
• Analytics cookies: Used for access analysis to help us improve our services (including Wix Analytics).
Non-essential cookies are used only where you have not opted out through your browser settings. Most browsers allow you to refuse or delete cookies through their settings. Please note that disabling certain cookies may affect the functionality of this Site.
5. Access, Correction, and Deletion
5.1 Where an individual submits a request for notification, disclosure, correction, suspension of use, deletion, or other action regarding personal data held by the Company, the Company will respond in accordance with applicable laws and regulations. Requests will not be processed where the identity of the requester cannot be verified.
Customers residing in the EEA or the United Kingdom have, in addition to the above, the right to data portability (GDPR Article 20), the right to object to processing (Article 21), and the right not to be subject to automated individual decision-making (Article 22). To exercise any of these rights, please contact us using the details in Section 6.
5.2 Notice to Customers Residing in the EEA or the United Kingdom
The EGAKU Booking Site is primarily intended for participants based in Japan. The Company does not actively solicit or market its services to residents of the EEA or the United Kingdom. However, in respect of participants who enrolled while residing in Japan and have since relocated, or participants attending English-language sessions online from the EEA or the United Kingdom, the Company is committed to handling personal data in a manner consistent with the principles of the GDPR and UK GDPR, as set out below.
Data Controller:
White Ship, Inc., Terasawa Building 6F, 1-7-17 Moto-Akasaka, Minato-ku, Tokyo
Legal basis for processing:
• Booking management, service delivery, and payment processing → Performance of a contract (GDPR Article 6(1)(b))
• Booking confirmations, change notifications, and other transactional emails → Performance of a contract (Article 6(1)(b))
• Analysis and technical development for service improvement → Legitimate interests (Article 6(1)(f)) ¹
• Use of photography and video for communications and marketing → Legitimate interests (Article 6(1)(f)) ²
¹ Legitimate interest: the ongoing improvement of the EGAKU program and the prevention of misuse.
² Legitimate interest: promoting awareness of the EGAKU program. Participants will be informed before the session begins and may notify a staff member if they prefer not to be photographed or recorded.
Retention of Personal Data:
(a) During active enrollment, personal data will be retained to the extent necessary for service delivery.
(b) Following the end of enrollment, personal data will be retained for the period required under applicable tax, corporate, or other legislation (up to a maximum of seven years), after which it will be securely deleted or anonymized.
Transfers of Personal Data to third countries: Personal data collected through the EGAKU program is hosted in Japan and is subject to Japanese law. Transfers of personal data from the EEA or the United Kingdom to Japan are made in reliance on the adequacy decisions relating to Japan issued by the European Commission and the UK Government respectively.
Where the Company shares personal data with service providers located outside Japan, it takes appropriate steps to ensure that personal data continues to receive an adequate level of protection. For further information on the safeguards applicable to any particular transfer, please contact us at egaku@whiteship.net.
Withdrawal of consent: Where processing is based on consent you may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal. To withdraw consent in respect of cookies, please adjust your browser settings.
Your rights: In addition to the rights set out in Section 5, customers residing in the EEA or the United Kingdom have the right to data portability (GDPR Article 20) and the right to object to processing (Article 21). To exercise any of these rights, please contact us using the details in Section 6.
Right to lodge a complaint: Customers residing in the EEA or the United Kingdom have the right to lodge a complaint with the data protection supervisory authority in their country of residence. Customers in the United Kingdom may also contact the Information Commissioner's Office (ICO) at https://ico.org.uk.
6. Contact
For requests regarding personal data held by the Company, or for inquiries regarding the Company's handling of personal data, please contact us at:
White Ship, Inc.
Terasawa Building 6F, 1-7-17 Moto-Akasaka, Minato-ku, Tokyo 107-0051
Email: info@whiteship.net Tel: 03-6434-9785
Program related enquiries: egaku@whiteship.net
7. Revisions to this Policy
The Company may revise this Policy in response to changes in applicable laws and regulations or changes to the Company's business operations. Any revisions will be published on this website.
Established: June 1, 2006
Revised: June 3, 2014
Revised: January 20, 2022
Revised: July 1, 2026
Representative Director: Kimi Hasebe