Privacy Policy

1. Controller

The controller of personal data relating to this site (ryueiculture.com) and its membership is the Ryūei Culture Association. The system is operated and maintained by our partner Edo Tokugawa Design Co., Ltd. ("ETD"). For rights requests and inquiries, contact info@ryueiculture.com.

2. Joint Use Within the Tokugawa Sōke Group

We may use your personal data jointly with the following four organisations (together, the "Tokugawa Sōke Group"). Such joint use follows the "joint use" framework under Japan's APPI (Art. 27(5)(iii)), disclosed as follows:

• Organisations sharing the data: Ryūei Culture Association / Edo Tokugawa Design Co., Ltd. / Tokugawa Memorial Foundation / Office of the Tokugawa Main House (Sōke)
• Data items shared: name, email, phone number, affiliation, membership category, content of inquiries and applications, (for Samurai-Lineage Members, family-lineage information provided voluntarily), and payment/membership-status information
• Purposes of joint use: membership management and guidance, event invitations, operation of research and cultural activities, mutual introductions and inquiry handling
• Party responsible for management: Ryūei Culture Association (info@ryueiculture.com)

We do not provide data to third parties outside the Tokugawa Sōke Group except as required by law or with your consent.

3. Personal Data We Collect

• Name, email, phone number, affiliation/title (on inquiry or application)
• Membership category, interests and message content
• For Samurai-Lineage Members, family-lineage information provided voluntarily
• Payment-related information (processed by Stripe; we and the Group do not retain card numbers or payment credentials)
• Account information (login email, authentication data)
• Access logs (IP address, browser information, cookies, etc.)

4. Purposes and Legal Bases

We use your personal data for the following purposes, on the following legal bases (GDPR Art. 6):

• Membership application, review, management and service delivery — performance of a contract / steps at your request
• Billing and payment of fees — performance of a contract
• Newsletters, announcements and event invitations — consent or legitimate interests
• Responding to inquiries — steps at your request
• Compliance with legal obligations (accounting, tax, etc.) — legal obligation
• Service improvement and statistical analysis (anonymised/aggregated) — legitimate interests

5. Processors

We and the Group entrust processing of personal data to the following services, under appropriate data-processing agreements (DPAs):

• Supabase (database and authentication)
• Stripe (payment processing; card data is handled directly by Stripe in compliance with PCI-DSS and is not retained by us)
• Netlify (site hosting and form intake)

6. International Data Transfers

Some processors may process personal data on servers outside Japan (e.g. the US or EU). For such transfers, we confirm an adequate level of protection or apply appropriate safeguards such as Standard Contractual Clauses (SCCs). Personal data of EEA/UK residents is transferred in accordance with Chapter V of the GDPR.

7. Retention

We retain personal data only for as long as necessary for the stated purposes or as required by law, after which it is appropriately deleted or anonymised. Member data is deleted after the periods required by law (e.g. accounting, tax) following withdrawal.

8. Security

We apply appropriate technical and organisational measures — access control, encryption in transit, authentication and least-privilege access — to prevent leakage, loss or damage of personal data.

9. Your Rights (Data Subjects)

You may exercise the following rights regarding your personal data (APPI; GDPR Arts. 15–22):

• Right of access (disclosure)
• Right to rectification, addition and erasure (including the "right to be forgotten")
• Right to suspension of use / restriction of processing
• Right to data portability
• Right to object to processing, and to opt out of direct marketing
• Right to withdraw consent at any time for consent-based processing (without affecting the lawfulness of prior processing)
• Right to lodge a complaint with a supervisory authority (Japan: Personal Information Protection Commission; EEA: your local data-protection authority)

To exercise these rights, contact info@ryueiculture.com. We will respond in accordance with law after verifying your identity.

10. Cookies & Analytics

This site may use cookies and similar technologies to provide features and understand usage. You can disable cookies in your browser settings, though some features may then be unavailable.

11. Minors

Where we collect information about minors in connection with children's programs (e.g. Ryūei Narai), we do so on the basis of parental consent and to the minimum extent necessary.

12. Changes to this Policy

We may revise this policy in response to changes in law or our services. Material changes will be announced on this page.

13. Contact

Tokugawa Sōke Group — Personal Data Contact (responsible party: Ryūei Culture Association)
Email: info@ryueiculture.com / info@edotokugawa.com