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The legal mumbo jumbo required is all on this page: JBLC.LLC as a registered LLC, JLBC's Web and client PRIVACY POLICY WebSite and Client Data Usage Privacy Policy 1.      Introduction JLBC.LLC was first legally registered in Suginami-ku, Tokyo, Japan. Upon expiry, JLBC.LLC was registered as an entity in the United States in the State of Ohio on August 2022. 1  JLBC, LLC, our internet and specific JLBC, LLC website-based services providers are committed to safeguarding the privacy of our website visitors. 1.2  This policy applies where we are acting as a data controller with respect to the personal data of our website visitors; in other words, where we determine the purposes and means of the processing of that personal data. 1.3  We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.  1.4  In this policy, "we", "us" and "our" refer to Associates of JLBC, LLC. For more information about us, see Section 13. 2.  Credit 2.1  This document was created using a template from SEQ Legal (https://seqlegal.com/free-legal-documents/privacy-policy). 
 3.  How we use your personal data 3.1  In this Section 3 we have set out: (a)  the general categories of personal data that we may process; (b)  in the case of personal data that we did not obtain directly from you, the source and specific categories of that data; (c)  the purposes for which we may process personal data; and (d)  the legal bases of the processing. 3.2  We may process data about your use of our website and services ("usage data"). This will only be for internal site use and client marketing analytics. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services. 3.3  We may process your website user account data ("account data"). The account data may include your name and email address. The source of the account data is JLBC, LLC. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is proper administration of our website and business or performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. 3.4  We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent to our proper administration of our website and business. 3.5  We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details.   The source of the transaction data is you and/or our payment services provider(s). The transaction data may be processed for the purpose of supplying the purchased goods and/or services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or JLBC, LLC and our associates taking steps, at your request, to enter into such a contract; providing that, if you are not the person contracting with us, the legal basis for this processing is our legitimate interests, namely the proper administration of our website and business. 3.6  We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent. 3.7  We may process inquiry and/or survey data you have entered at this site or from JLBC, LLC emailed questionnaires. This data may include name, email address, voluntary inquiry questions and comments, answers to surveys, existing and future, including but not limited to your organization, job title, job description, what service and expertise you need or desire to get from our organization, your experience relevant to survey topic, your specified areas of interest and your language skills.   The source of this data is from you, by email or form entry on emails and site surveys. This data may be processed for JBLC. LLC's internal use; business analysis, tailoring JLBC, LLC services to meet client and market requirements.   The legal basis for this processing is specified above in this paragraph or the performance of services between you and us and/or taking steps, at your request, to enter into services with us. 3.8  We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others. 3.9  We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks. 3.10  In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. 3.11  Please do not supply any other person's personal data to us, unless we prompt you to do so. By you supplying another person €™s data to us, you consent to full responsibility in doing so and applying all usage claims of this stated policy to that data where relevant. 
 4.      Providing your personal data to others 4.1  We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. 4.2  Your personal data held in our website databases at our facilities (as specified in section 3.7 of this Policy) and stored on the servers of our web hosting services providers and at our facilities. 4.3  We may disclose your name, email, service related requests (contact and communicated information you supply) to our contracted services suppliers or subcontractors only if that information is absolutely necessary to accommodate your requests regarding JLBC, LLC Services directly related to delivering you services required or requested. Your information will remain confidential to the general public. 4.4  In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. 
 5.      International transfers of your personal data 5.1  In this Section 5, we provide information about the circumstances in which your personal data may be transferred between countries outside the European Economic Area (EEA). 5.2  The hosting facilities for our website are situated in the United States of America and payment services provided in Japan. The European Commission has made an "adequacy decision" with respect to Japanese and U.S. data protection laws. Transfers within all countries will be protected by appropriate safeguards, including the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain here or at this URL:   https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en 5.3  payment services providers web hosting services we utilize are situated in Japan and/or the United States. The European Commission has made an "adequacy decision" with respect to data protection laws of each of these countries. Transfers within all countries will be protected by appropriate safeguards, including the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain hereor at this URL:   https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en 5.4  You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others. We strongly suggest all web users protect their internet sessions with products and tools including VPNs and encryption. 
 6.      Retaining and deleting personal data 6.1  This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data. 6.2  Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. 6.3  We will retain your personal data as follows: (a)  [usage data will be retained for a minimum period of less than 1 year following the date of collection, and for a maximum period of more than one year following that date]; (b)  [account data will be retained for a minimum period of less than one year following the date of closure of the relevant account, and for a maximum period permissible by Japanese and US laws following that date]; (c)  [publication data will be retained for a minimum period of one day following the date when the relevant publication ceases to be published on our website or through our services, and for a maximum period required by US and Japanese law following that date]; (d)  [enquiry data will be retained for a minimum period of one month following the date of the enquiry, and for a maximum period according to applicable governing law of Japan and the US following that date]; (e)  [transaction data will be retained for a minimum period of less than one month following the date of the transaction, and for a maximum period according to applicable governing law of Japan and the US following that date]; (f)  [notification data will be retained for a minimum period of one week or less following the date that we are instructed to cease sending the notifications, and for a maximum period of 30 days following that date (providing that we will retain notification data insofar as necessary to fulfill any request you make to actively suppress notifications). We will strive to satisfy your removal request as soon as we receive it.]; and (g)   [General business analytics data pertaining to your non-personal inquiries and communications with JLBC, LLC operations and service will be retained for a minimum period of one month following inquiry submission and for a maximum period permitted by applicable governance in the countries where our host servers reside.] 6.4  Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. 
 7.  Your rights 7.1  In this Section 7, we have listed the rights that you have under data protection law. 7.2  Your principal rights under data protection law are: (a)  the right to access - you can ask for copies of your personal data; (b)  the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data; (c)  the right to erasure - you can ask us to erase your personal data; (d)  the right to restrict processing - you can ask use to restrict the processing of your personal data; (e)  the right to object to processing - you can object to the processing of your personal data; (f)  the right to data portability - you can ask that we transfer your personal data to another organization or to you; (g)  the right to complain to a supervisory authority - you can complain about our processing of your personal data; and (h)  the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent. 7.3  These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/. 7.4  You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below. 
 8.  About cookies 8.1  A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. 8.2  Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. 8.3  Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies. 
 9.  Cookies that we use 9.1  When appropriate, we use cookies for the following purposes: (a)  [authentication and status - we use cookies to identify you when you visit our website and as you navigate our website, and to determine if you are logged into the website]  (b)  [personalization - we use cookies to store information about your preferences and to personalise the website for you] (c)  [security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally]; (d)  [advertising - we use cookies to help us to display services (including on-line payment) that will be convenient to you]; (e)  [analysis - we use cookies to help us to analyse the use and performance of our website and services]; and (f)  [cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally]. 
 10.  Cookies used by our service providers 10.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website. 10.2  We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google's use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google's privacy policy at https://policies.google.com/privacy.] 10.3  When payment services are accepted that include credit card companies listed for payment processing, please review the privacy policies of these services provided at their sites. 11.  Managing cookies 11.1  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links: (a)  https://support.google.com/chrome/answer/95647 (Chrome); (b)  https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox); (c)  https://help.opera.com/en/latest/security-and-privacy/ (Opera); (d)  https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies(Internet Explorer); (e)  https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac(Safari); and (f)  https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge). 11.2  Blocking all cookies will have a negative impact upon the usability of many websites. 11.3  If you block cookies, you will not be able to use all the features on our website. 
 12.  Amendments 12.1  We may update this policy from time to time by publishing a new version on our website. 12.2  You should check this page occasionally to ensure you are happy with any changes to this policy. 12.3  We may notify you of significant changes to this policy by email. 
 13.  Our details 13.1  This website and all content we have created to make available, distribute or give access to for the public is owned, operated and copyrighted© by Todd Judge. 13.2  Registered as JLBC in Japan as an LLC in 2014, with Japanese mailing address and operations out of Kichijoji minamicho 5-chome 5-8 -103, Musashino-shi, Tokyo 180-0003 13.3  Our principal business addresses are below. JLBC consulting and training work is off-site at available or rented facilities. 13.4  Contact Todd Judge, dba JLBC: using this website contact form, by email, using toddbob@mac.com (USE THIS FOR FASTEST REPLY!) by telephone or post, to either of the postal addresses: In USA   Todd Judge 309 Wade Street Spring Valley, OH 45370 TEL: 01-937-212-2393 toddbob@mac.com In Japan Todd Judge Kichijoji minamicho 5-chome 5-8 -103 Musashino-shi, Tokyo 180-0003 TEL: +81 (090) 6958-2398 toddbob@mac.com 
 14.      Data protection officer 14.1  Data protection contact: please email Todd Judge at tjudge@jlbc.co

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