Privacy

Privacy Policy

Personal Information Protection Policy

ICPA International Protocol Co., Ltd. (the “Company”) sets out the following policy on the handling of personal information at The Elegance Academy Tokyo (the “Academy”), which it operates, and undertakes to observe it. In the event of any discrepancy, the Japanese version shall prevail.

1. Compliance with Laws

The Company complies with the Act on the Protection of Personal Information and other relevant laws, guidelines and this Policy in acquiring, using and otherwise handling personal information.

2. Protection of Your Rights and Interests

  1. On request, we will stop sending newsletters and other communications.
  2. We may entrust all or part of the handling of personal information to third parties within the scope of the purposes of use. We select contractors judged to handle personal information appropriately and supervise them as necessary.

3. Purposes of Use

We acquire and use personal information for the following purposes:

  1. providing and operating the Academy’s programmes and events;
  2. invoicing and confirming payment of fees;
  3. improving our programmes and events and developing new services;
  4. informing you of programmes, events and new services organised or co-organised by the Academy (including newsletters);
  5. recording course content and improving quality;
  6. the Academy’s publicity activities; and
  7. understanding website usage and improving our services (including cookies and analytics; see Section 9).

4. Use within the Purposes

We will not handle personal information beyond the scope necessary to achieve the purposes of use without your prior consent, except where required by law, where necessary to protect a person’s life, body or property and it is difficult to obtain consent, or as otherwise permitted by law.

5. Proper Acquisition

We do not acquire personal information by deception or other improper means.

6. Information We Collect

  1. name (including phonetic reading);
  2. email address, telephone number and address;
  3. occupation and date of birth (for certain programmes);
  4. social media accounts (optional);
  5. information necessary for the safe running of programmes and events, such as food allergies (acquired with your consent);
  6. connection data when using our website (IP address, device information, cookie identifiers, etc.); and
  7. images, video and audio recorded during programmes and events.

Credit card payments are processed through our payment provider, Stripe. Card details are managed by Stripe and are not held by the Company.

7. Photography during Programmes and Events

We may photograph or film programmes and events for record and publicity purposes. When such images are used on our website, social media or brochures, we will either render faces unidentifiable or obtain prior consent. If you do not wish to be photographed, please let us know in advance.

For programmes where consent to photography or publication of interviews is a condition, a separate consent form will be signed, which takes precedence over this Policy.

8. Retention

We retain personal information only for as long as necessary for the purposes of use, and delete it without delay thereafter, unless retention is required by law or you have consented.

9. Cookies and Analytics

Our website uses cookies and analytics by Google Analytics and HubSpot to understand usage and improve our services. These collect information such as pages viewed, referrers, browsing environment and IP address, which does not directly identify individuals.

You can disable cookies in your browser settings. To opt out of Google Analytics, you may use the opt-out browser add-on provided by Google.

10. Security Measures

We endeavour to keep personal information accurate and up to date, and take necessary measures — including access control, limiting the persons who handle data and securing information systems — to prevent unauthorised access, alteration, leakage, loss or damage.

11. Supervision of Staff

We supervise and train our staff as necessary to ensure the secure handling of personal information.

12. Supervision of Contractors

We may entrust all or part of the handling of personal information to contractors for registration, payment, email delivery and other operations, within the purposes of use. We select appropriate contractors, set out security and confidentiality obligations in contracts, and supervise them as necessary.

13. Contractors Located Overseas

We use services of overseas providers — including Google LLC (USA), HubSpot, Inc. (USA) and Stripe, Inc. (USA) — for website analytics, management of applications and enquiries, and payment processing, and part of your personal information may be handled by them. We use these providers after confirming that they maintain an appropriate level of personal information protection. Information on the data protection systems of the relevant countries is available on request.

14. Provision to Third Parties

We will not provide personal information to third parties without your consent, except:

  1. where required by law;
  2. where necessary to protect a person’s life, body or property and it is difficult to obtain your consent;
  3. where especially necessary for improving public health or promoting the sound development of children and it is difficult to obtain your consent; or
  4. where necessary to cooperate with a national or local government body, or its contractor, in carrying out duties prescribed by law.

15. Requests for Disclosure

If you wish us to notify you of the purposes of use, or to disclose, correct, add to, delete, stop using or stop providing to third parties your personal information, we will respond in accordance with the law after verifying your identity. Please contact us at the email address below. If you prefer to make a request in writing, please email us and we will provide a postal address.

Contact: contact@elegance-in.com

16. Enquiries and Complaints

We will respond promptly and appropriately to enquiries and complaints regarding the handling of personal information.

The Elegance Academy Tokyo (operated by ICPA International Protocol Co., Ltd.)
Email: contact@elegance-in.com
Hours: weekdays 9:00–18:00 (JST)

17. Response to Data Breaches

In the event of a leak or other incident involving personal information, we will take appropriate action, including promptly notifying the persons concerned.

18. Continuous Improvement

We continually review and improve our handling of personal information. Any changes to this Policy will be published on the Academy’s website.

Established October 2026
ICPA International Protocol Co., Ltd. — operating The Elegance Academy Tokyo

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Established 2016