Privacy Policy

1. Collection of customers' personal data

1. Data for identity confirmation
   Name, age, date of birth, sex, occupation, address, postal code, country of residence, phone number, fax number, e-mail address, credit/debit card payment information, and social network information, etc.
2. Data concerning customer transactions
   Transaction details (information concerning products/services purchased or to be purchased by customers), purchase history, browsing history, service usage history, shops, location information, other online identifiers, and device information, etc.
3. Data concerning payment
   Bank account, payment, payment method information.
4. Personal data obtained or generated in relation to new product development, surveys, and research conducted by the Company
5. Other data
   Information concerning customers' suggestions, requests, and inquiries to the Company

2. Usages of personal data

Purposes of the Company using customers' personal data:

1. Delivery, provision, or after-sales services of the Company's products and invoicing for the Company's products and services.
2. Provision, promotion, advertising, and other marketing activities of the Company's products and services based on analyses of customers' browsing history and past behaviors.
3. Soliciting customers' opinions and suggestions regarding the Company's products and services and improvement of responses to customer inquiries.
4. Communicating changes in the Company's products and services, etc.
5. Implementation of marketing data analyses, surveys, and marketing initiatives concerning the Company's new product development and services.
6. Maintenance and management of the Company's products and services.
7. Provision of personal data to third parties as prescribed herein.
8. Implementation of campaigns, prize promotions, and questionnaire surveys.
   In principle, customers provide their personal data to the Company at their own discretion but are not obligated to provide it. However, the Company may not be able to carry out a customer contract where a pertinent customer refuses to provide the requested data. It may also hinder the Company's fulfillment of its statutory or regulatory obligations.
   When required or permitted to do so under law, the Company may process customers' personal data without obtaining the consent of or notifying customers.

Change of purposes:

Where it is necessary to use customers' personal data for any new purpose beyond the extent stated above, the new purpose of use will be notified to customers before starting the usage and the usage of personal data for such new purpose will commence only when customer consent is obtained.
Legal bases for the handling of personal data
The Company handles customers' personal data on one or more of the following legal bases:

1. When customers' provide consent
2. When necessary for taking action for fulfillment or execution of a contract
3. When necessary for the Company's fulfillment of statutory obligations
4. When necessary for the protection of any material interest of customers or other natural persons
5. When necessary for the performance of duties for public interest or for exercising any statutory authority granted to the Company
6. When necessary for the Company's or any third party's legitimate interest (such as to learn about customers' interests and concerns for marketing purposes, e.g., for the provision of personalized products and services), over which customers' interests and rights do not take precedence.

Collection of personally-linked data:

The Company may collect personally-linked data of customers from third parties or its group companies.
When using any such personally-linked data as personal data by combining it with customers' personal data held by the Company or its group companies, the Company will obtain consent from customers and handle such data in an appropriate manner in line with the "purposes of using customers' personal data by the Company" unless any other purposes are indicated.
The Company will not provide personally-linked data to any third party without the prior consent of a principal unless otherwise permitted or required by law.

3. Provision of personal data to third parties

4. Usage of cookies

5. Education

6. Rights of customers

1. Right of access to personal data
   Customers have the right to confirm whether their personal data is handled by the Company and to access their personal data and certain other information, if handled by the Company.
2. Right to correct personal data
   If customers' personal data held by the Company are incomplete, customers have the right to request correction of their own personal data without undue delay.
3. Right to delete personal data
   Under certain conditions, customers have the right to request deletion of their own personal data held by the Company without undue delay.
4. Right of personal data portability
   Under certain conditions, customers have the right to receive their own personal data provided to the Company's group in a structured, generally used, and machine-readable format and to transfer such data to a different administrator.
5. Objection to handling
   Under certain conditions, customers have the right to object to the Company's handling of their own personal data at any time.
6. Limitation of methods of using personal data
   Under certain conditions, customers have the right to limit the handling of their own personal data held by the Company.
7. Right to withdraw consent
   Customers have the right to withdraw their consent from the Company's handling of their own personal data if desired.
8. Right to refuse direct marketing
   The Company will not conduct any direct marketing actions to customers not wishing to receive information from the Company regarding its products and services (i.e., direct marketing). If you are not willing to receive direct marketing information, please contact us via the Company's services you use or the contact information provided in 10.
9. Automated decision making
   Customers have the right not to be subject to decision making based on automated processing, including but not limited to profiling that creates a legally-binding effect or other significant effect on customers.

* The rights listed above are not absolute rights and may not be applicable in certain situations. Also, exceptions under law may apply and customer requests may be declined in such cases.

* The Company group never makes decisions based on automated processing, including but not limited to profiling that creates a legally-binding effect on customers.

7. Security measures

1. Establishment of the basic policy
   This basic policy has been established in order to ensure appropriate handling of personal data and provide contact information for inquiries and complaints.
2. Development of disciplines concerning the handling of personal data
   Rules for the handling of personal data, including the appointment and duties of supervisor(s)/officer(s) in charge of personal data have been established.
3. Organizational security measures
   A supervisor in charge of handling personal data (personal data management supervisor) has been appointed.
4. Personnel security measures
   Provisions concerning personal data confidentiality are incorporated in employment regulations.
5. Physical security measures
   Employee access control to areas in which personal data are handled and restrictions on the bringing of devices into such areas have been implemented, along with measures to prevent personal data from being accessed by unauthorized individuals.
6. Technical security measures
   Access control measures have been implemented to limit officers with access and scope of accessible information.

8. Joint usage of personal data

1. Items of personal data to be used jointly
   Name, address, and phone number
2. Persons with whom personal data are jointly used
   TCI Holdings Co., Ltd. and its affiliates (inc. overseas subsidiaries)
3. Purposes of usage
   Notification of information about new products and services of the Company's group
4. The entity responsible for the management of jointly-used personal data
   TCI Holdings Co., Ltd.
   Address: 8F, T-PLUS Nihonbashi-kodemmacho,　16-12 Nihonbashi-kodemma-cho, Chuo-ku, Tokyo 103-0001
   Representative: Representative Director & President Naoyuki Asakawa

9. Request for retained personal data disclosure, etc.

1. If such disclosure may risk or harm the life, body, properties, and other rights and interests of the principle and/or third parties.
2. If such disclosure may substantially hinder proper execution of the Company's business operations.
3. If such disclosure would constitute a breach of laws and regulations.
   The Company will also respond to any request for correction to, addition to, or deletion of retained personal data or for suspension/erasure of personal data usage or provision to third parties from a principal or his/her proxy through appropriate investigation in compliance with laws and regulations.

10. Contact for this privacy policy or customers' personal data

11. Retention period

12. Duties of customers