Privacy Policy

1. About this Policy

This Privacy Policy (“Policy”) is to ensure that you (“User” or “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 “RICOH360 Tours” (“Service”), a service provided by RICOH and the related websites managed by RICOH (“Website”).

“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.

Some terms of this Policy are applicable to users of the Service whose personal data is protected by the General Data Protection Regulation (“European Users of the Service”).

2. Management of Personal Data

RICOH implements appropriate safety management measures to 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.

3. Acquisition and Purposes of Use of Personal Data

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

(1)

  • Type of acquired information: RICOH collects your email address, name, phone number and other personal information when you create your Account for using the Service.
  • Purpose of use: The email address, name, phone number and other personal information is needed to identify and allocate users to specific Service accounts.
  • Legal Basis (only for European Users of the Service): Processing is necessary for the performance of the contract, Art. 6 (1) (b) GDPR.
  • Duration: Personal Data will be processed for the duration of the contractual relationship between you and RICOH.

(2)

  • Type of acquired information: Ricoh collects email address, name, address, phone number and other personal information of your contact information shared on the Service.
  • Purpose of use: The email address, name, address, phone number and other personal data of your contact information is needed to share the data with other users of the Service.
  • Legal Basis (only for European Users of the Service): Processing is necessary for the performance of the contract, Art. 6 (1) (b) GDPR.
  • Duration: Personal Data will be processed for the duration of the contractual relationship between you and RICOH.

(3)

  • Type of acquired information: Ricoh collects the User Name chosen by each user. If you choose your real name, it includes personal data. Instead of using your real name, you are free to choose a pseudonym as User Name as well.
  • Purpose of use: The User Name is needed to identify and allocate users to specific Service accounts. We further process your User Name in connection with your public 360-degree photos or videos to display it publicly as your User Account. It is necessary to provide the Service.
  • Legal Basis (only for European Users of the Service): Processing is necessary for the performance of the contract, Art. 6 (1) (b) GDPR.
  • Duration: Personal Data will be processed for the duration of the contractual relationship between you and RICOH.

(4)

  • Type of acquired information: RICOH automatically collects your IP Address, device profile and other personal data when using the Service.
  • Purpose of use: The IP address, device profile and other personal data is needed to provide the Website to you. This information is collected to administer the Website under your terms and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
  • Legal Basis (only for European Users of the Service): Processing is necessary for the performance of the contract, Art. 6 (1) (b) GDPR.
  • Duration: Personal Data will be processed for the duration of the contractual relationship between you and RICOH.

(5)

  • Type of acquired information: Ricoh collects and stores your 360-degree photos or videos, location, and other information related to the photos uploaded and shared on the Service.
  • Purpose of use: The collection of your photos, location and other information related to the photos that is necessary to provide the Services, e.g. for you to upload and share its photos with other users of the Service. Each of your photos and videos contain its own Universally Unique Identifier (UUID), which allows the system to identify the respective photos. When you share your photo with third parties, the system requires the UUID to allocate the photo and to display it to the third person using the URL. Thus, we process your photo UUID in connection with your 360-degree photos or videos to convert it into a URL to give you the opportunity to share your 360-degree photos or videos with others. Please note that for technical reasons due to the nature of the composition of the respective URL, your photos and videos can be shared with third parties who merely try out UUIDs taking into account the conversion logic to compose a URL.
  • Legal Basis (only for European Users of the Service): Processing is necessary for the performance of the contract, Art. 6 (1) (b) GDPR.
  • Duration: Personal Data will be processed for the duration of the contractual relationship between you and RICOH. When you delete your 360-degree photos or videos from the Service, RICOH will no longer process such content.

(6)

  • Type of acquired information: RICOH collects your contact form, chat history, email address and other personal information when you send a support request.
  • Purpose of use: This information is collected to administer the Website under your terms and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
  • Legal Basis (only for European Users of the Service): Processing is necessary for the performance of the contract, Art. 6 (1) (b) GDPR. Processing is necessary for the performance of the contract (Art. 6 (1) (f) GDPR), particularly in order to improve the Service and its functionality.
  • Duration: Personal Data will be processed for the duration of the contractual relationship between you and RICOH.

(7)

  • Type of acquired information: RICOH collects your credit card number (4 digits below) and credit card brand when you pay your fees for using stripe’s payment service.
  • Purpose of use: The credit card number (4 digits below) and credit card brand is needed to identify and allocate users to specific Service accounts.
  • Legal Basis (only for European Users of the Service): Processing is necessary for the performance of the contract, Art. 6 (1) (b) GDPR.
  • Duration: Personal Data will be processed for the duration of the contractual relationship between you and RICOH.

4. Provision of Personal Data to a Third Party

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

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

(2a) [only for European Users of the Service]

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 Europe. 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.
  • RICOH transfers Personal Data to its processor, mailing service providers, in the United States of America, who conduct the mailing service for the Services on RICOH’s behalf. 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.
  • RICOH transfers Personal Data to its processor, support service providers, in the United States of America, who conduct the support communication service for the Services on RICOH’s behalf. 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.
  • RICOH transfers Personal Data to its processor, analysis service providers, in the United States of America, who conduct the analysis service for the Services on RICOH’s behalf. 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.
  • Amazon Web Services, Inc. has certified itself under the EU-US-Privacy Shield and therefore the transfer of Personal Data to mailing service providers, support service providers and analysis service providers in the United States of America is conducted under an adequate level of protection in accordance with the GDPR.

(2b) [for the other Users]

Provision to business contractors, business partners, etc. with appropriate supervision from RICOH to fulfil a purpose of use. You hereby consent to international transfers for the following uses:

  • RICOH transfers Personal Data to its processor and hosting provider, Amazon Web Services, Inc., in Europe.
  • RICOH transfers Personal Data to its processor, mailing service providers, in the United States of America, who conducts the mailing service for the Services on RICOH’s behalf.
  • RICOH transfers Personal Data to its processor, support service providers, in the United States of America, who conducts the support communication service for the Services on RICOH’s behalf.
  • RICOH transfers Personal Data to its processor, analysis service providers, in the United States of America, who conducts the analysis service for the Services on RICOH’s behalf.

(3) If the Personal Data is required for the protection of a person’s life.

(4) If provision of the Personal Data is requested according to a law or regulation.

Payment Processing Information. For online payments, RICOH use the payment services of Stripe. RICOH do not process, record or maintain your credit card or bank account information or other related information necessary to complete your payments. For more information on how payments are handled, or to understand the data security and privacy afforded such information, please see https://stripe.com/us/privacy.

Social Networking Sites. The Service enable you to post content to a social network site or other online community (e.g., Facebook, and each, an “SNS”) through the “share” function. If you choose to do this, RICOH will provide information to such SNSs in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of each SNS that you post content to, and that it is your responsibility to review the terms of use and privacy policy of the third party provider of such SNSs. We will not be responsible or liable for: (a) the availability or accuracy of any SNS; (b) the content, products or services on or availability of any SNS; or (c) your use of any such SNS.

5. Inquiries and Procedures Relating to Enforcement of the Data Subject’s Rights

(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.

[Only for European Users of the Service] As far as RICOH processes Personal Data on the basis of RICOH’s legitimate interest (Art.6 (1) lit. f GDPR), you may object to processing (Art.21 (1) GDPR) at any time. You may find a detailed description of RICOH’s processing activities and the legal basis in section 3 of this Policy. If you object to such processing, RICOH asks you to state the grounds of your objection in order for RICOH to examine the processing of your Personal Data and decide whether to adjust the processing accordingly.

[Only for European Users of the Service] Processing of Personal Data may involve direct marketing activities as described above. If you do not want to have your activity on RICOH’s Services processed for direct marketing activities, you can object to any data processing free of charge at any time via e-mail (Art.21 (2) GDPR).

(2) When you wish to submit a request regarding the usage of your Personal Data for the Service, please contact at: privacy@ricoh360tours.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 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 Facebook, Inc. and Twitter, Inc. The registered content for these services is not managed by RICOH. Please contact the issuer for inquiries.

6. Handling of Access Log Information on the Website

(1) SSL

Encryption technologies using SSL (Secure Sockets Layer) is used to prevent information theft etc. by a third-party during communication when you provide highly confidential information such as Personal Data via this Website.

It may not be possible to use these technologies depending on your computer environment. In this case, please be aware that you may not use this Service.

(2) Use of Cookies and Web Beacons

RICOH uses Cookies and other similar technologies (web beacons, Flash Cookies, etc.) to enhance the experience using the Services. Cookies are used to indirectly collect information, including Personal Data, from you.

Although most web browsers automatically accept Cookies, the decision of whether to accept or not is yours. You have the choice to accept or decline Cookies by way of consent. RICOH only drops strictly necessary Cookies (see below) without your consent. If you do not accept Cookies, RICOH will not be able to produce customized website content to you and you will receive only non-customized content.

There are different types of Cookies:

  1. Strictly necessary Cookies. These are Cookies that are required for the operation of the Services. They include, for example, Cookies that enable you to log into secure areas of the Services.
  2. Functionality Cookies. These are used to recognise you when you return to the Services. This enables RICOH to personalise its content for you, greet you by name and remember your preferences (for example, choice of language or region).
  3. Analytical cookies. They allow RICOH to recognise and count the number of users and to see how they move around the website when using it. This helps RICOH for its legitimate purposes to improve the way the website works, for example, by ensuring that you are finding what you are looking for easily.
  4. Targeting Cookies. These Cookies record your visit to the Services, the pages you have visited and the links you have followed.

This Website may use Cookies or web beacons for the following purposes:

  • To identify your browser or you and reduce the work required for authentication.
  • To assess usage of the Website and make improvements.
  • To make advance assessments of your use of services on which Personal Data will be registered and make improvements.

It may not be possible to use some of the features provided by this Website if your browser is set not to receive Cookies or is set not to display images while you use this Website.

The following list of cookies are those used on the website which we have identified:

(a)

  • Information on the cookies: “Google Analytics”, a cookie which is used when you use the web analytics service provided by Google Inc. (“Google”)
  • Purpose of the cookies: To assess usage of the Website and to make improvements by RICOH and Google
  • Types of the cookies: 3. Analytical cookies, 4. Targeting Cookies

(b)

  • Information on the cookies: “Stripe“, a cookie which is used when you use the payment service provided by Stripe
  • Purpose of the cookies: To process and complete your payment by Stripe
  • Types of the cookies: 1. Strictly necessary Cookies

(c)

  • Information on the cookies: A cookie which is used when you use ricoh360tours.com
  • Purpose of the cookies: To customize your user interface
  • Types of the cookies: 2. Functionality Cookies

(d)

  • Information on the cookies: “Zendesk“, a cookie which is used when you use helpdesk
  • Purpose of the cookies: To assess usage of the Website and make improvements
  • Types of the cookies: 3. Analytical cookies, 4. Targeting Cookies

(e)

  • Information on the cookies: “AWS”, a cookie which is used when you log in ricoh360tours.com
  • Purpose of the cookies: To administer your log in session in ricoh360tours.com
  • Types of the cookies: 1. Strictly necessary Cookies

(f)

  • Information on the cookies: “Google Maps”, a cookie which is used when you use the web analytics service provided by Google
  • Purpose of the cookies: To assess usage of the Website and to make improvements by Google
  • Types of the cookies: 3. Analytical cookies, 4. Targeting Cookies

(3) Use of Cookies and Web Beacons by Third Parties

Cookies and Web beacons in your browser may be used by third parties, including advertisers, to distribute advertisements optimized for each user. You can set their browser not to receive cookies. Refer to the help of your browser for details.

(4) Disabling of Cookies

The effect of disabling cookies depends on which cookies you disable, but in general the website may not operate properly if cookies are disabled. If you only disable third party cookies, you will not be prevented from using our Service. If you disable all cookies, you will be unable to use our Services. See below for details of how to disable cookies on commonly used browsers.

Disabling cookies on Internet Explorer:

  1. Select “Tools” and then choose “Internet Options”
  2. Click on the “privacy” tab
  3. Select the appropriate setting

Disabling cookies on Google Chrome:

  1. Select Settings and then choose Advanced
  2. Under "Privacy and security," click “Content settings”
  3. Select “Cookies”

Disabling cookies on Safari:

  1. Select Preferences and then choose Privacy
  2. Click on “Remove all Website Data”

Disabling cookies on Firefox:

  1. Select “Tools” in the menu and then choose “Options”
  2. Click on the “privacy” icon
  3. Find the “cookie” menu and select the relevant options

Disabling cookies on Opera 6.0:

  1. Select “Files” in the menu and then choose “Preferences”
  2. Privacy

(5) Use of Google Analytics

This Service uses Google Analytics, a web analytics service provided by Google Inc. (“Google”), 1600 Amphitheatre Parkway Mountain View, CA 94043, USA. Google Analytics uses Cookies, which – as explained above in detail – are text files placed on users’ computers, to help the website analyse how users use the website. The information generated by the Cookie about the use of the Service (including your IP address) will be transmitted to and stored by Google on servers in the United States of America. In case of activation of the IP anonymization, Google will truncate/anonymise the last octet of the IP address for Member States of the European Union and for other parties to the Agreement in the EEA. Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA. Google will use this information for the purpose of evaluating your use of the Service on RICOH’s behalf, compiling reports on Service activity for RICOH and providing RICOH with other services relating to Service activity and internet usage. Google will not associate your IP address with any other data held by Google. You may refuse the use of Cookies by selecting the appropriate settings on their browser. However, in that case, it may not be possible to use the full functionality of the Service. Furthermore, you can prevent Google’s collection and use of data (Cookies and IP address) by downloading and installing the browser plug-in available at https://tools.google.com/dlpage/gaoptout?hl=en-GB.

You can refuse the use of Google Analytics by clicking on the following link Disable Google Analytics. An opt-out Cookie will be set on your computer, which prevents the future collection of your Personal Data when visiting the website.

Further information concerning the terms and conditions of use and data privacy can be found at https://www.google.de/intl/en_uk/policies. Please note that on the website, Google Analytics code is supplemented by “anonymizeIp” to ensure an anonymized collection of IP addresses (so-called IP-masking).

In addition, you can prevent the collection of the data generated by the Cookie by Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available from the following link: https://tools.google.com/dlpage/gaoptout.

(6) Links to Websites Other than This Website

Links to the websites of companies related to RICOH or third-party companies (hereinafter "Websites Managed by Third Parties") are placed in some areas of the Website of this Service to improve convenience for you. Accessing these links may take you away from RICOH's Website. Although RICOH or RICOH THETA logo may be displayed on some parts of the Websites Managed by Third Parties, RICOH is not involved in the content posted on the Website Managed by a Third Party and does not accept responsibility for the website's handling of Personal Data.

Websites Managed by Third Parties may issue Cookies, gather data or gather Personal Data according to their own policies. This Policy does not apply to the handling of information on other, linked websites. Therefore, in the event that you access a Website Managed by a Third Party, RICOH recommends that you read the policies of the Website Managed by a Third Party relating to protection of Personal Data before providing Personal Data.

(7) Requests to Underage Users

In the event that Personal Data is provided to RICOH by underage users, RICOH request that this information is provided with the consent of a legal guardian. Personal Data therefore cannot be provided by such persons even with the consent of a legal guardian. If it becomes known to RICOH that Personal Data has been provided by underage users, the information and the underage user's account will be deleted immediately.

7. Contact for Inquiries Relating to Personal Data / Complaints

If you have any complaints and other inquiries relating to the handling of Personal Data, please contact us at privacy@ricoh360tours.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.

8. Amendments

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: October 11th, 2019
Ricoh Company, Ltd.

© Ricoh Company, Ltd. All Rights Reserved.