Wejo Privacy Notice for Japan

Wejo Japan K.K. ("Wejo") is committed to protecting your personal information.

This Privacy Policy defines how Wejo collects and uses personal information via the following sources (collectively referred to as Sources):

·               Any website, page or form of or provided by Wejo that links to this Policy (Websites);

·               Social media in Japan or Wejo content on other websites in Japan;

·               Software, mobile device and TV applications in Japan (Apps);

·               Information collected through contacts by emails or other means between you and Wejo

This Privacy Policy is issued by Wejo Japan K.K.

Wejo Japan KK

Address: c/o Baker & McKenzie (Gaikokuho Joint Enterprise), Ark Hills Sengokuyama Mori Tower 28F, 1-9-10 Roppongi, Minato-ku,

Representative Director: https://www.wejo.com/about

Wejo Group means the parent company of Wejo Japan K.K. and all its subsidiaries including the following companies:

Wejo Limited

Address: ABC Building, 21-23 Quay Street, Manchester, England, M3 4AE

Legal representative: https://www.wejo.com/about

Wejo EU France

Address: Lot 41 66 Avenue des Champs-Elysées 75008 Paris

Legal representative: https://www.wejo.com/about

Wejo Inc

Address: 1013 Centre Road, Suite 403-B, Wilmington, DE 19805 Representative Director: https://www.wejo.com/about

Wejo Data Services Inc

Address: 1013 Centre Road, Suite 403-B, in the city of Wilmington, County of New Castle, Delaware 19805

Legal representative: https://www.wejo.com/about

Wejo California Corp

Address: 818 West Seventh Street, Suite 930, Los Angeles, CA 90017

Legal representative: https://www.wejo.com/about

Our Approach to Privacy

The privacy and security of your personal information is very important to us. We want to assure you that your information will be properly managed and protected whilst in our hands.‍

The information we collect and how we collect it.

Information you provide to Wejo

We may receive personal information about you, when you contact Wejo for example by doing any of the following:

·       Requesting or obtaining a quote

·       Purchasing a Wejo product from us or from one of our partners

·       Using the Websites and Apps

·       Entering Wejo competitions

·       Participating in Wejo events or webinars

·       Using live chat

·       Creating an account on a Wejo App

·       Telephoning, texting, writing by post or email, or communicating via online channels, such as online chat, to Wejo

·      Applying for a position at Wejo on the Careers website

This information may include:

·               Basic personal details such as your name, address, e-mail address, telephone number, date of birth or age, gender, job role, employer name, job history;

·               Your marketing preferences.

Information we collect through Cookies and similar technologies

We collect information through "Cookies" and other similar technologies (e.g. pixel tags or links), to remember you when you visit the Websites so we can improve your online experience to suit your needs. These help us understand how you and others use our Websites, view our products and respond to our advertising, so we can tailor direct marketing and enhance our overall product and service offering. This also saves you from re-inputting information when you return to the Websites.

When you receive direct marketing from us via email, we may use technology e.g. pixel tags or links to determine your use of and interest in our direct marketing.

When you visit one of our Websites, we may record your device information including hardware and software used, general location, when and how you interact with our Websites and your registration and log-in activity when you use our online platforms. This information is retained and used to note your interest in our Websites, improve customer use experience, determine pricing and/or offer you available discounts.

To find out more about Cookies and related technologies please read our separate Cookie Policy at https://www.wejo.com/privacy/terms-privacy-cookies.

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How we use information to help you

We may use information for:

(a)            providing you contracted services or products and addressing your inquiries;

(b)            research or statistical purposes (which we consider is in our legitimate interest), including to analyse how people use our Websites, view our products, respond to our advertising and to improve our understanding of what customers need to develop or improve our service or products, to improve customer use experience, to determine prices or discounts of our service or products, to conduct effective marketing activities;

(c)            conducting training for our employees or sub-contractors, to improve or develop our products or services and their delivery, to improve customer use experience for example by recording telephone calls;

(d)            marketing purposes including to send you marketing emails or mail or to conduct tele-marketing with regard to our service, products or any campaigns or events, to provide you with advertising that we believe may be relevant for you;

(e)            anti-fraud purposes

(f)             recruiting and sourcing job candidates for open positions at Wejo  

How we use and share your information within the Wejo Group

We may jointly use the information about you which is specified in "the information we collect and how we collect it" section with the Wejo Group. The Wejo Group may use this information to support the activities described in this policy.

Information will be transferred to the Wejo Group through secure electronic means.

The transfer of information from Wejo to the Wejo Group will be done on the basis of agreements executed in accordance with the Personal Information Protection Act.

Wejo remains responsible for such joint usage and you can contact us with regard to joint usage at the address shown below.

How we share your information outside of Wejo

We may entrust the processing of your personal information to third parties, only if strictly necessary and subject to the execution of an agreement ensuring that we monitor how your personal information will be processed and that said third parties will respect all applicable provisions of the Personal Information Protection Act.

To the extent permitted by law, your information may be disclosed when we believe in good faith that the disclosure is:

·      required by law;

·      in the event of a merger, business transfer, or other related transaction; or

·      as otherwise permitted under applicable data privacy laws.

‍‍Data retention

For regulatory, reporting and financial reasons we may retain the personal data provided to us in accordance with regulatory requirements. However, you can ask us to delete your personal data at any time, see 'Your Rights' below for details.

Data transfers outside of Japan

Your information may be transferred by Wejo to the Wejo Group under a joint usage arrangement or to service providers in countries outside of Japan, including the UK and the European Economic Area (EEA). In all cases, agreements will be put in place meeting the requirements of the Personal Information Protection Act.

Security

We are committed to protecting the confidentiality and security of the information that you provide to us and we put in place appropriate technical, physical and organisational security measures to protect against any unauthorised access or damage to, or disclosure or loss of, your information.

Policies: Wejo maintains policies that provide management direction and support for information security in accordance with business requirements and privacy and data protection Laws.

Organisation of Information Security: Wejo maintains a management framework to initiate and control the implementation and operation of information security with Wejo’s organisation and ensuring the security of teleworking and use of mobile devices.

Human Resources: Wejo maintains appropriate measures to ensure that employees and contractors understand, are aware of and fulfil their information security responsibilities, are suitable for the role for which they are considered, and the Wejo’s interests are protected as part of employment change or termination.

Asset Management: Wejo maintains appropriate measures to identify Wejo’s organisational assets and ensure the information receives the appropriate level of protection in accordance with its importance to Wejo, and to prevent the unauthorised disclosure, modification, removal, or destruction of information stored on media.

Access Control: Wejo ensures that access to information processing facilities is limited, mandating authorised user access only to prevent unauthorised access to systems, applications and services as well as making users accountable for safeguarding information.

Cryptography: Wejo maintains appropriate measures to ensure the proper and effective use of cryptography to protect the confidentiality, integrity, availability of information.

Physical & Environment Security: Wejo has appropriate measures in place to prevent unauthorised physical access, damage and interference to Wejo’s information and information processing facilities to prevent loss, damage, theft, or compromise of assets and prevent interruption to Wejo’s operations.

Operational Security: Wejo maintains appropriate measures to ensure there are correct and secure operations of information processing facilities through the protection of information against malware and loss of information, recording of events and the generation of evidence. Wejo ensures the integrity of operational systems, preventing the exploit of technical vulnerabilities and minimising the impact of audit activities.

Communications Security: Wejo maintains appropriate measures to ensure the protection of information in networks and to maintain the security of information transferred within the Wejo’s organisation and with any external entity.

Systems Acquisition, Development and Maintenance: Wejo maintains appropriate measures to ensure that information security is an integral part of information systems across the entire lifecycle including the requirements for services over public networks, ensuring that information security is designed and implemented within an information systems development lifecycle as well as certify that data used for testing is protected.

Supplier Relationships: Wejo ensures the protection of Wejo’s assets that are accessible by subcontractors or suppliers and maintains an agreed level of information security and service delivery in its subcontractors or supplier agreements.

Incident Management: Wejo has a consistent and effective approach to the management of information security incidents, including communications on security events and weaknesses.

Information Security aspects of Business Continuity Management: To ensure the availability of information processing facilities, Wejo embeds information security continuity in the Wejo’s business continuity management system.

Compliance: Wejo has the appropriate measures in place to avoid breaches of legal, statutory, regulatory, or contractual obligations related to information security and ensure that information security is implemented and operated in accordance with the organisation’s policies and procedures.

You should also be aware that communications over the internet, such as e-mails, are not secure unless they have been encrypted. The Websites may contain links to other third-party websites. These other websites will be subject to their own privacy policies which may differ from this Privacy Policy. You should carefully read the privacy policies of these websites before submitting any personal information.

Fraud prevention and detection

When requested by public authorities and in the conditions authorized under the Act for the Protection of Personal Information, we may share information about you with public bodies, such as the police for anti-fraud purposes.

Your Rights - How to find out what information we hold about you

You have the right to request a copy of all the personal information we hold about you in a subject access request. To do this, simply write to us at the address below. We will take all reasonable steps to confirm your identity before providing you with details of any personal information we may hold about you. Please note that depending on your request, a fee may be charged.

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Your Rights - How to request us to restrict or delete your information

You have the right to request that we stop processing (right to object, restrict us from using your data (but let us still keep it) and delete your personal information at any time. We make this as easy to do as possible. To do this, simply write to us at the address or email address below (see How to Contact us) with your request. We will take all reasonable steps to confirm your identity before deleting your personal information.

Although we will make every effort to remove your data from our systems when instructed to do, your data will be fully removed from all our systems no later than what is required by law. Actual processing timelines may vary upon the nature of the request.

Your Rights - How to request your information to be corrected

Information accuracy is very important to us at Wejo. If at any time you believe that we are holding inaccurate or incorrect information about you, please do not hesitate to let us know and we will make the required changes as soon as possible.

To do this, simply write to us at the address or email address below (see How to Contact us) with your request. We will take all reasonable steps to confirm your identity before updating your personal information.

‍‍Changes to this Privacy Policy

We may amend this Privacy Policy from time to time for example, to keep it up to date or to comply with legal requirements. You should regularly check this Privacy Policy for updates. If there will be any significant changes made to the use of your personal information in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website.

‍‍How to contact us

For all general enquiries regarding Wejo Japan K.K. please call us via the numbers and addresses on our Website - www.wejo.com

For any questions or concerns relating to this Privacy Policy or our data protection practices, or to make any requests or complaints relating to your data, please contact the Security, Risk and Compliance Team who can be contacted using the details below.

Head of Privacy

By email: privacy@wejo.com

By post: Wejo Japan K.K., c/o Baker & McKenzie (Gaikokuho Joint Enterprise), Ark Hills Sengokuyama Mori Tower 28F, 1-9-10 Roppongi, Minato-ku,

Wejo Japan Privacy Policy v1.0 (31 March 2022)

A Japanese version of this notice is available here