Legal
Privacy Policy
This policy explains what personal data we collect when you subscribe to updates or apply to Brand Finland to Japan, why we collect it, and what rights you have over it.
1. Who we are
The data controller is Tetra Tokyo K.K., registered at [registered address, Tokyo, Japan]. You can reach us about anything in this policy at [privacy contact email].
Brand Finland to Japan is run together with Sisu Factory ([legal entity name and address, Finland]). [Decide: are Tetra Tokyo and Sisu Factory joint controllers under Art. 26 GDPR, or is Sisu Factory a separate controller receiving data from us? If joint, a joint-controller arrangement has to exist and its essence has to be summarised here.]
[Art. 27 GDPR: as a controller established outside the EU offering services to people in the EU, Tetra Tokyo may need a designated EU representative. Confirm with counsel whether the Art. 27(2) exemption applies; if not, name the representative here — Sisu Factory may be able to act in that role.]
2. What we collect
If you subscribe to updates. Your work email address, and the fact and time of your consent.
If you apply to the program. Your first and last name, job title, company, work email address, a description of the product you want to sell in Japan, your company or product URL, your reasons for applying, and the track you selected.
Automatically, when you visit the site. Your IP address, the pages you view, and an identifier stored by HubSpot's tracking cookie. [List any analytics you actually run. If you add none, say so.]
We do not ask for special-category data, and we ask you not to include any in the free-text fields.
3. Why we use it, and on what legal basis
| Purpose | Data | Legal basis |
|---|---|---|
| Sending program updates and newsletters | Work email | Your consent — Art. 6(1)(a) |
| Assessing your application and contacting you about it | All application fields | Steps taken at your request before entering a contract — Art. 6(1)(b) |
| Introducing selected companies to Japanese partners, consumers or investors | Company name, product description, URL | Your consent, obtained separately before any introduction is made |
| Understanding how the site is used and improving it | Usage data, cookie identifier | Your consent for non-essential cookies |
| Meeting our legal and accounting obligations | Contract and billing records | Legal obligation — Art. 6(1)(c) |
Consent is never a condition of applying. You can withdraw it at any time, and doing so does not affect anything we did before you withdrew it.
4. Who we share it with
- HubSpot — our CRM and email platform, acting as our processor under a data processing agreement. Submissions from this site go directly to HubSpot. [State the region your portal is hosted in: EU or US.]
- Sisu Factory — our program partner in Finland, who sees application data in order to run the selection and the program with us.
- Japanese partners, monitors, media and investors — only for companies selected into the program, only the information needed for that specific introduction, and only after we have your consent for it. [Confirm this matches how the monitor and pre-sales activities actually work.]
- Our hosting provider — [name and country].
We do not sell your data, and we do not share it for anyone else's marketing.
5. Sending data outside the EEA
Tetra Tokyo is in Japan, so running this program means your data is transferred from the EEA to Japan. The European Commission has decided that Japan provides an adequate level of data protection, so this transfer needs no additional safeguard. Should that decision ever be withdrawn, we would move to Standard Contractual Clauses.
[If the HubSpot portal is US-hosted, add: HubSpot, Inc. is certified under the EU–US Data Privacy Framework, and describe that transfer here.]
6. How long we keep it
- Newsletter subscribers — until you unsubscribe, and for [suggested: 24 months] after your last engagement, after which we delete the record.
- Applications that are not selected — [suggested: 24 months] from the decision, so we can contact you about a later intake, then deleted.
- Participating companies — for the duration of the program and [suggested: 7 years] afterwards for contractual and accounting records.
7. Your rights
Under the GDPR you can ask us to give you a copy of your data, correct it, delete it, restrict or object to how we use it, or send it to another provider in a portable format. Where we rely on consent, you can withdraw it at any time — every email we send has an unsubscribe link.
Write to [privacy contact email] and we will respond within one month.
If you are not satisfied, you can complain to your national supervisory authority. In Finland that is the Office of the Data Protection Ombudsman (Tietosuojavaltuutetun toimisto, tietosuoja.fi). Because we are established in Japan, you may also contact the Personal Information Protection Commission (ppc.go.jp).
8. Cookies
We use HubSpot's tracking cookie (hubspotutk) to connect a form submission
to the visit it came from. [If this cookie is set before the visitor
consents, a cookie banner is required. Decide whether to add one or to load HubSpot
tracking only after consent.]
The videos and fonts on this site are served from [state whether fonts are self-hosted or loaded from Google Fonts — the latter sends the visitor's IP to Google and has been challenged in the EU].
9. Changes to this policy
If we change how we handle your data, we will update this page and change the date below. If the change is significant and we hold your contact details, we will tell you directly.
10. Contact
Tetra Tokyo K.K.
[registered address]
[privacy contact email]
Last updated
[date this version is published]