SUSHIRO GH SINGAPORE PTE. LTD. PRIVACY POLICY

1. ABOUT THIS PRIVACY POLICY

1.1 This Privacy Policy describes how we may collect, use, disclose, process and manage your personal data when you:

1.1.1 Visit our official websites (including our social network services’ accounts) (“Website”);

1.1.2 download and use our Sushiro mobile application (“App”); and/or

1.1.3 provide us with your personal data, from you in one of our SUSHIRO restaurants operated by us, on our online services, or by telephone or fax, regardless of the medium through this such personal data is provided and also by collecting in accordance with paragraph 3 and 4.

2.1 By providing us with personal data, you agree to the terms of this Privacy Policy and you consent to our collection, use, disclosure and processing of personal data on these terms.
DO NOT provide any personal data to us if you do not accept this Privacy Policy. However, if you do not provide sufficient information to us, we may not be able to provide sufficient services to you.

2. PERSONAL DATA

2.1 What is personal data.
In this Policy, “Personal Data” is data that can be used to identify a natural person. Examples of Personal Data include, but not limited to, name, address, gender, date of birth, password, credit card information, details of your order including menu preferences and preferred restaurants, your health condition such as allergies, your feedback to our services, nationality, bank account, contact details, identification numbers, photo identification card, financial information, IP address, geographical information of your computer or smart device, transactional information based on your activities on our website and applications, telephone numbers (including mobile number), email address, images, and any other information of a personal nature.

2.2 Voluntary provision of Personal Data.
We collect Personal Data that you voluntarily provide to us. What Personal Data we collect depends on the purposes for which the Personal Data is collected and what you have chosen to provide.

You can choose not to provide us with your Personal Data. You also have the right to withdraw your consent for us to continue collecting, using, disclosing, processing, and correcting (if it is inaccurate) your Personal Data, by contacting us in accordance with paragraph 11. However, if you do so, it may not be possible for us to fulfil the purposes for which we require the Personal Data, including processing your transactions or providing you with the products and services that you require.

2.3 Providing Personal Data belonging to others.
In certain circumstances, you may also provide us with your Personal Data of persons other than yourself. If you do so, you warrant that you have informed him/her of the purposes for which we are collecting his/her Personal Data and that he/she has consented to your disclosure of his/her Personal Data to us for those purposes. You agree to indemnify and hold us harmless from and against any and all claims by such individuals relating to our collection, use and disclosure of such Personal Data in accordance with the terms of this Privacy Policy.

2.4 Accuracy and completeness of Personal Data.
You are responsible for ensuring that all personal data that you provide to us is true, accurate and complete. You are responsible for informing us of any changes to your personal data.

3. COLLECTION OF PERSONAL DATA

3.1 Personal Data you provide.
We collect your Personal Data that is relevant to our relationship with you. We may collect your Personal Data directly or indirectly through various channels, such as when:

3.1.1 you provide us with your Personal Data for whatever reasons;

3.1.2 you authorise us to obtain your Personal Data from a third party;

3.1.3 you register for a user account on our Website and/or App;

3.1.4 you download or use our Website and/or App and services, including to make reservations or to place food orders;

3.1.5 you transact with us, contact us or request that we contact you through various communication channels, for example, through social media platforms, messenger platforms, face-to-face meetings, telephone calls, emails, fax and letters;

3.1.6 you request to be included in an email or our mailing list;

3.1.7 your images are captured via CCTV cameras while you are within our premises;

3.1.8 your images are captured via photographs or videos taken by us or our representatives when you attend events organised by us;

3.1.9 when you participate in competitions, contests or games organised by us;

3.1.10 when you attend events or functions organised by us; and/or

3.1.11 we seek information about you and receive your Personal Data in connection with your relationship with us, for example, if you are an investor or shareholder of Sushiro Global Holdings Ltd. such as our parent company.

4.1 Personal data provided by others.

4.1.1 from our business partners such as third parties providing advertising, marketing and promotional services to us;

4.1.2 from your family members or friends who provide your Personal Data to us on your behalf; and/or

4.1.3 from public agencies or other public sources.

4.2 Automated Data Collection Technologies.
Our Website and/or App may contain certain technologies that collect data in the manner described in this Privacy Policy (see below). You should not use our Website and/or App if you do not agree to having your data collected through such means. Alternatively, you should disable these technologies where it is possible to do so.

4.2.1 Cookies (or browser cookies).
Cookies are small text files which are set by a website or application operator so that your browser or device may be recognised. We may make use of cookies on our Website and/or App to store and track information such as the number of users and their frequency of use, profiles of users and their online preferences. Cookies do not capture information which would personally identify you, but the information collected may be used to assist us in analysing the usage of our Website and/or App and to improve your online experience with us. You can disable the cookies by changing the setting on your browser. However, this may affect the functionality of the Website and/or App.

4.2.2 Third Party Use of Cookies and other Tracking Technologies.
Some content or applications on the Website and/or App, including advertisements, are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website and/or App. The information they collect may be associated with your Personal Data or they may collect information, including Personal Data, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

4.2.3 Flash cookies.
Certain features of our Website and/or App may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website and/or App. In contrast to normal cookies, these cookies are not created and saved by the web browser but are governed by the Adobe Flash plug-in. These can contain more information than normal cookies and cannot be deleted, disabled, turn off, rejected or opted out via the browser; this is only possible using tools such as the Adobe Flash Player website. You can also obtain more information about these cookies on their website.

5. PURPOSES FOR COLLECTION, USE OR DISCLOSURE OF PERSONAL DATA

5.1 Personal data of customers.
We collect, use, disclose and process your Personal Data for purposes connected or relevant to our business, to make your relationship with us. Such purposes would include:

5.1.1 To contact customers who have made reservations at our restaurants and outlets to update them of the status of their reservation;

5.1.2 To process your payment or credit facilities in relation to our services;

5.1.3 To check your credit, payment and/ or status in relation to our services;

5.1.4 To respond to feedback and enquiries from customers, confirm and record these feedbacks and improve our business;

5.1.5 To make announcements of discounts, benefits and campaigns;

5.1.6 To contact customers who are on our waiting list at our restaurants and outlets;

5.1.7 To contact customers and confirm their orders if they order takeaway at our restaurants and outlets;

5.1.8 To deal with the winners of the prizes and campaigns, notifications on recruitment, provisions of goods and rewards; and planning and/or organizing events amongst others;

5.1.9 To conduct feedback and survey for our goods and services, and respond to enquiries from customers;

5.1.10 To carry out market research, and product development which may be targeted at every age, gender, family and geographical area;

5.1.11 To provide confirmation and services of registration for all kinds of membership services; and/or

5.1.12 To communicate regarding business transactions, arrange delivery of goods to related parties, and to send out invoices in relation to business transactions.

5.2 Use permitted under applicable laws.
We may also collect, use, disclose and process your Personal Data for other purposes, without your knowledge or consent, where this is required or permitted by law.

5.3 Contacting you.
When we contact or send you information, we may do so by post, e-mail, SMS, telephone, direct message through a social network service or such other means provided by you. If you do not wish to receive any communication or information from us, or wish to restrict the manner by which we may contact or send you information, you may contact us in accordance with paragraph 11.

6. JOINT COLLECTION, USE OR DISCLOSURE OF PERSONAL DATA

6.1 Scope of our joint business partners
We may use your Personal Data in cooperation with the affiliated companies including the following joint business partners:
Sushiro Global Holdings, Akindo Sushiro Co., Ltd., and Sushiro Creative Dining Co., Ltd.

6.2 International data transfer
We may transfer your Personal Data outside Republic of Singapore in accordance with the “Personal Data Protection Act 2012” and relevant laws in Republic of Singapore.

6.3 Purposes for use

6.3.1 Personal Data of customers and business associates (hereinafter referred to as “clients”)

6.3.1.1 To conduct marketing activity for the purpose of sales promotion of goods and services

6.3.1.2 With respect to goods and services of our group companies, to respond to enquiries from clients and convey or hand over to a relevant group company.

6.3.1.3 For other purposes, to perform business transactions with clients properly and smoothly.

7. Voice Recording and Video Recording

7.1. We may record telephone calls with you in order to know the content of your enquiries accurately and deal with them accordingly.

7.2. We may record your images and videos by surveillance camera when you visit our premises including restaurants and use these images and videos for crime prevention and safety purposes.

8. SECURITY AND RETENTION OF PERSONAL DATA

8.1. Unauthorised access.
While precautions will be taken to ensure that the Personal Data you provide is protected against unauthorised or unintended access, we cannot be held responsible for unauthorised or unintended access that is beyond our control.

8.2. Protection of Personal Data
We will take reasonable precautions to safeguard your Personal Data. While reasonable precautions will be taken to ensure that the information you provide is protected against unauthorised or unintended access, we cannot be held responsible for unauthorised or unintended access that is beyond our control.

8.3. Period of retention.
We keep your Personal Data only for so long as we need the Personal Data to fulfil the purposes we collected it for, and to satisfy our business and/or legal purposes, including audit, accounting or reporting requirements. How long we keep your Personal Data depends on the nature of the data, for example:

8.3.1. we will keep your Personal Data for at least the duration of the limitation period for bringing claims if the Personal Data may be required to commence or defend legal proceedings; and

8.3.2. the Personal Data collected for use for a limited purpose will generally not be retained for more than five (5) year after completion of the purpose.

8.3.3. we will delete your Personal Data and remove from our system as soon as possible on your request basis.

8.3.4. Regardless of the above some information may be retained for longer, for example where we are required to do so by law, or need to retain it for the purposes of litigation.

9.1. YOUR RIGHTS

9.1.1. Disclosure, correction and deletion of personal data
If we are requested by you or the person who has the right to do so, to notify the purposes for use of the Personal Data which we retain, disclose such Personal Data, correct its content, add or delete, suspend the use, remove or suspend the provision of your Personal Data to third parties, we will deal with your request in writing after confirming the content of your request. For procedure, please contact us at Personal Data Protection Department below.

9.2. Limitations. We may be permitted under applicable laws to refuse a request.

10. HOW TO REQUEST OF DISCLOSURES

10.1. Please fill out the necessary information in our application form.

10.2. We will verify you in accordance with your Personal Data which we retain.

10.3. In case that an enquiry is made by your proxy, we will verify him/her with power of attorney or certification of registered seal.

10.4. The application of disclosure is accepted by mail to the address below.

10.5. If you want us to inform you of the purposes of use or disclose such Personal Data, we ask you to pay 10 Singapore Dollars plus shipping cost for registered mail per request.

10.6. We will use your Personal Data on Personal Data Disclosure Application Form in order for us to verify you and your proxy, or to respond to requests of disclosure of such Personal Data

11. PERSONAL DATA PROTECTION OFFICER

SUSHIRO GH SINGAPORE PTE. LTD.:
Representative of General Affairs Department
70 Shenton Way #17-04/05 Eon Shenton, Singapore 079118
Email address:info@sushiro.com.sg or Telephone number 6970 2296

12. GOVERNING LAW

This Privacy Policy is governed by the laws of the Republic of Singapore. You agree to submit to the exclusive jurisdiction of the Courts of the Republic of Singapore in any dispute relating to this Privacy Policy.