Privacy Policy

This Privacy Policy describes how your personal information is collected, used, and shared when you visit http://www.tsunagupro.com (the “Site”).

PERSONAL INFORMATION WE COLLECT

1. Device Information

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”

We collect Device Information using the following technologies:

- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

- “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

Further information on conditions of use and data protection can be found at
https://marketingplatform.google.com/about/analytics/terms/us/ and https://policies.google.com/privacy?hl=en-US.

Google Analytics

Our platform uses the web analysis service Google Analytics, from Google LLC, 1600 Amphitheatre Parkway Mountain View, California 94043, USA, for the purpose of analysing and continuously optimising our website. Google Analytics uses cookies which allow website use to be analysed. Pseudonymised user profiles are created for this purpose. We use Google Analytics only with activated IP anonymisation.

You can prevent cookies from being stored by configuring the operating system settings on your browser or mobile device accordingly. However, please bear in mind that, in this case, you may not be able to make full use all of the functions on our platform. You can also prevent the data produced by the cookie and information relating to your use of our website (including your IP address) being collected by Google and being processed by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout.

2. Booking Information

Additionally when you make an inquiry through the Site, we collect certain information from you.

We refer to this information as “Booking Information.”

Below is the list of information we collect from you:

• • Name and surname
• • Gender
• • Age group
• • Telephone number
• • E-mail address
• • The restaurant where you make your reservation
• • Date and time of reservation
• • The number of guests
• • Special preferences

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Booking Information.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We use the Booking Information that we collect generally to fulfill any inquiry placed through the Site (including processing your booking information, arranging your restaurant booking, and providing you booking confirmations). Additionally, we use this Booking Information to:

• • To accept your inquiry about our Japanese restaurant concierge service
• • To provide our Japanese restaurant concierge service (including suggestion of restaurants and making reservations on behalf of you)
• • To Communicate with you
  (We may use your personal information to contact you with newsletters,promotional e-mails, marketing and other information that may be of interest to you. You may opt out of receiving any or all, of these communications from us by sending email to info@tsunagupro.com)
• • To respond to your requests/inquires
• • To verify your eligibility to use the service
• • To identify you
• • To conduct a survey and analysis related to our service
• • To improve our service
• • To carry out other works incidental to the above

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

For what other purposes do we process your data?

We possibly process your data for additional purposes.
These include the following:

• passing on your personal data to third parties if we are legally obliged to do so;
• assertion of legal claims and defence in legal disputes;
• compliance with legal requirements for data retention due to tax legislation, etc.

What is the legal basis of data processing?

• When processing your personal data, we rely on local data protection law and use your personal data only for the fulfilment of our services.
• In this context, we refer in detail to the following legal foundations:

Consent

Since you have given us your consent to process personal data for the above-mentioned purposes, such consent guarantees the lawfulness of such processing. By registering with your information, you expressly consent to the processing of your data as described in this Privacy Policy by crossing the box before submitting the inquiry form: When we process your data, this is because you have expressly permitted and requested us to do so when you use our platform. Your consent thus represents the most important legal basis for the processing of your personal data by us.

Fulfilment of our contractual obligations towards you

At the same time, the processing serves to make the platform available within the scope of performance under our contract with you. Accordingly, in most cases the processing is justified not only with your consent, but also because it is necessary to fulfil our contract with you. For example, if you use The Service, we need to process the booking Information to make the reservation and secure your seating.

Our legitimate interests

There are also cases in which we would be entitled to process your data without your consent if this is necessary to protect our legitimate interests (or those of third parties). In this respect, the purposes described above, for which we process your data, in many cases also represent legitimate interests. This means that we may process the data necessary to ensure the security of our IT systems in any case, even if you have not given or withdrawn your consent to such processing. This also refers to the prevention of abuse of our platform or the personalization of advertising for your interests (referred to as direct marketing).

Statutory requirements

In addition, we are required by law to provide certain information to the law enforcement or tax authorities upon request in individual cases.

SHARING YOUR PERSONAL INFORMATION

We share your personal information with third parties for the above purpose.

To whom do we transmit your data?

We treat your personal data with care and confidentiality and pass such data on to third parties only to the extent described below and no further. We only transmit data to public authorities if there is a legal obligation to do so as a result of a request for information from the competent authority.

Beyond statutory obligations to public authorities, we will only share your information with partnering restaurants when we make a reservation on behalf of you, with our third-party providers who assist us in providing the platform, or within the Smilewave International HongKong Limited, outsourced contractors

We use Google Analytics to help us understand how our customers use the Site--you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/.
You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

DO NOT TRACK

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

DATA RETENTION

When you make an inquiry and restaurant booking through the Site/our service, we will maintain your booking Information for our records unless and until you ask us to delete this information.

Do I have to provide data? What happens if I do not provide my data or no longer provide it?

You are not legally obliged to provide us with the personal data specified in this Privacy Policy. In particular, the contractual relationship that you have entered with us by agreeing to our terms and conditions means that you are under no obligation to provide your personal data. However, the transmission of the contract information you send to us is a basic prerequisite for the conclusion of a contract with us. Moreover, you may not use the platform or may use it only to a limited extent if you do not provide us with certain data or if you object to the use of such data.

CHANGES

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at info@tsunagupro.com or by mail using the details provided below:

Smilewave International HongKong Limited.

Flat 02, 9/F, Catic Plaza, 8 Causeway Road, Causewaybay, Hong Kong, Hong Kong, , Hong Kong