Privacy Policy on the Handling of Personal Information

HANAYASHIKI CO., LTD. the “Company,” “we,” or “us”) wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect through:

• Websites operated by us from which you are accessing this Privacy Policy (the “Websites”);
• Software applications made available by us for use on or through computers and mobile devices (the “Apps”);
• Our social media pages on which we post a link to this Privacy Policy (collectively, our “Social Media Pages”);
• HTML-formatted email messages that we send to you that link to this Privacy Policy or other communications with you; and
• Offline business interactions you have with us.

Collectively, we refer to the Websites, Apps, Social Media Pages, emails, and offline business interactions as the “Services.”

 

1. PERSONAL INFORMATION

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The Services collect Personal Information, including:

• Name
• Age, Date of birth
• Gender
• Postal address (including billing and shipping addresses)
• Telephone number
• Email address
• IP address (we may also derive your approximate location from your IP address)
• Payment card data
• Profile picture
• Username
• Social media account ID
• Usage Information
• Location Information

 

2. Collection of Personal Information

• We and our service providers collect Personal Information in a variety of ways, including:

• Through the Services.

  • We collect Personal Information through the Services, for example, when you sign up for a newsletter, register an account to access the Services, attend one of our events, place an order over the phone, contact customer service, or make a purchase.

• From Other Sources.

  • We receive your Personal Information from other sources, for example, from publicly available databases and our joint marketing partners, when they share the information with us.
  • If you connect your social media account to your Services account, you will share certain Personal Information from your social media account with us, for example, your name, email address, photo, list of social media contacts, and any other information that may be or you make accessible to us when you connect your social media account to your Services account. We refer to this as “social sharing.”

We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

 

3. Use of Personal Information

We and our service providers use Personal Information for the following purposes:

• Providing the functionality of the Services and fulfilling your requests.

  • To provide the Services’ functionality to you, such as arranging access to your registered account, and providing you with related customer service.
  • To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about our Services.
  • To complete your transactions, verify your information, and provide you with related customer service.
  • To send administrative information to you, such as changes to our terms, conditions, and policies.
  • To allow you to send messages to another person through the Services if you choose to do so.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

• Providing you with our newsletter and/or other marketing materials and facilitating social sharing.

  • To send you marketing related emails, with information about our services, new products and other news about our company.
  • To facilitate social sharing functionality that you choose to use.

We will engage in this activity with your consent or where we have a legitimate interest.

• Analyzing Personal Information for business reporting and providing personalized services.

  • To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.
  • To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
  • To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.

We will provide personalized services based on our legitimate interests, and with your consent to the extent required by applicable law.

• Allowing you to participate in sweepstakes, contests or other promotions.

  • We may offer you the opportunity to participate in a sweepstakes, contest or other promotion.
  • Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information. Please read those additional rules before choosing to participate.

We use this information to manage our contractual relationship with you.

• Aggregating and/or anonymizing Personal Information.

  • We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.

• Accomplishing our business purposes.

  • For data analysis, for example, to improve the efficiency of our Services;
  • For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
  • For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
  • For developing new products and services;
  • For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures;
  • For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
  • For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
  • For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.

 

4. Disclosure of Personal Information

4-1 Disclosure of Personal Information

We disclose Personal Information:

• To our third party service providers, to facilitate services they provide to us.

  • These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.

• By using the Services, you may elect to disclose Personal Information.

  • On message boards, chat, profile pages, blogs, and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
  • Through your social sharing activity. When you connect your Services account to your social media account, you will share information with your friends associated with your social media account, with other users, and with your social media account provider. By doing so, you authorize us to facilitate this sharing of information, and you understand that the use of shared information will be governed by the social media provider’s privacy policy.

4-2. Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:

• To comply with applicable law and regulations.

  • This may include laws outside your country of residence.

• To cooperate with public and government authorities.

  • To respond to a request or to provide information we believe is necessary or appropriate.
  • These can include authorities outside your country of residence.

• To cooperate with law enforcement.

  • For example, when we respond to law enforcement requests and orders or provide information we believe is important.

• For other legal reasons.

  • To enforce our terms and conditions; and
  • To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.

• In connection with a sale or business transaction.

  • We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

 

5. OTHER INFORMATION

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:

• Browser and device information
• App usage data
• Information collected through cookies, pixel tags and other technologies
• Demographic information and other information provided by you that does not reveal your specific identity
• Information that has been aggregated in a manner such that it no longer reveals your specific identity

5-1. Collection of Other Information

We and our service providers may collect Other Information in a variety of ways, including:

• Your browser or device.

  • Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.

• Your use of the App.

  • When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.

• Cookies.

  • Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services. We may also use cookies or other technologies in online advertising to track responses to our ads. We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to https://allaboutcookies.org/how-to-manage-cookies. And, to the extent legally required, cookie settings on individual websites allow you to accept or reject cookies that are not strictly required for website functionality, either by the Site or by third parties (Analytics Partner (Google Analytics), Ad Tech Partner, or Social Media Partner). If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. You also may not receive advertising or other offers from us that are relevant to your interests and needs.

• Pixel tags and other similar technologies.

  • Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.

• Analytics.

  • We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to https://policies.google.com/technologies/partner-sites, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

• Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies.

  • We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also go to the Global Storage Settings Panel and follow the instructions (which may explain, for example, how to delete existing Flash LSOs (referred to as “information”), how to prevent Flash LSOs from being placed on your computer without your being asked, and how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications.

• Physical Location.

  • We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. Our Apps may collect device location data when they are running in the foreground or the background. We may use your device’s physical location to provide you with personalized location-based services and content. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.

5-2. Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

 

6. SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

 

7. CHOICES AND ACCESS

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. For details, please check the information for each service.

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.

 

8. How you can access, change, or delete your Personal Information

If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below. We will respond to your request consistent with applicable law.

In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

For requests for disclosure of personal information and notification of the purpose of use by the Company, a fee of 800 yen (including tax) will be charged per request.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).

 

9. RETENTION PERIOD

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

 

10. THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.

 

11. SENSITIVE INFORMATION

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.

 

12. JURISDICTION AND CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in Japan where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in Japan may be entitled to access your Personal Information.

 

13. THIRD PARTY PAYMENT SERVICE

We may use a third party payment service to process payments made through the Services. If you wish to make a payment through the Services, your Personal Information will be collected by such third party and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your Personal Information.

 

14. Additional Information Regarding the EEA (non-EEA)

Some non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available at https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission, to protect your Personal Information. You may obtain a copy of these measures by contacting us in accordance with the “Contact Us” section below.

 

15. UPDATES TO THIS PRIVACY POLICY

The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services.

 

16. CONTACTING US

HANAYASHIKI CO., LTD. (Representative: President Toyoshi Nishikawa, located at 2-28-1, Asakusa, Taito-ku, Tokyo, Japan 111-0032, is the company responsible for collection, use, and disclosure of your Personal Information under this Privacy Policy.

If you have any questions about this Privacy Policy or you have a complaint about our handling of personal information, please contact us at :

2-28-1, Asakusa, Taito-ku, Tokyo, Japan 111-0032

 

17. THIRD PARTY ADVERTISING

We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services.

You may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit https://optout.aboutads.info and https://optout.networkadvertising.org. You may download the AppChoices app at https://youradchoices.com/appchoices to opt out in mobile apps.

 

18. ADDITIONAL INFORMATION REGARDING THE EEA

You may also:

• Lodge a complaint with an EU/EEA data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available at https://ec.europa.eu/newsroom/article29/items/612080/en.

 

19. ADDITIONAL INFORMATION REGARDING CALIFORNIA

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following details regarding the categories of Personal Information that we collect, use, and disclose about California residents. This section does not apply to our job applicants, employees, contractors, owners, directors, or officers where the Personal Information we collect about those individuals relates to their current, former, or potential role with us.

19-1. Sources of Personal Information

We collect Personal Information from:

• Our interactions with you, such as when you interact with our websites or other online services we provide, give us feedback, participate in any of our polls, surveys, questionnaires, contests, sweepstakes or other promotions, link your social media account to your account with us, or contact customer support; and
• Publicly available online sources, joint business partners, and third-party advertising and market research partners.

19-2. Collection of Personal Information

We plan to collect, and have collected within the preceding 12 months, the following categories of Personal Information as listed in the CCPA:

1. “Identifiers.” Identifiers, such as name, contact information, IP address, and other online identifiers;
2. “Customer Records Information.” Personal information, as defined in the California customer records law, such as name, contact information;
3. “Protected Class Information.” Characteristics of protected classifications under California or federal law, such as age, gender, national origin, primary language;
4. “Transaction Information.” Commercial information, such as transaction information and purchase history;
5. “Online Use Information.” Internet or network activity information, such as browsing history and interactions with our website;
6. “Geolocation Data.” Geolocation data, such as device location and approximate location derived from IP address;
7. “Audio/Video Data.” Audio, electronic, visual and similar information, such as photographs and audio and video recordings;
8. “Inferences.” Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences, behavior, or characteristics.

19-3. Use of Personal Information

We use these categories of Personal Information for the purposes of operating, managing, and maintaining our business, providing our products and services, and accomplishing our business purposes and objectives, including using Personal Information to:

• Fulfill your requests, and respond to your inquiries;
• Develop, improve, repair, and maintain our products and services;
• Personalize, advertise, and market our products and services;
• Conduct research, analytics, and data analysis;
• Establish and maintain user accounts and authenticate user identity;
• Administer contests, sweepstakes, promotions, surveys, and questionnaires;
• Maintain our property and our records, and undertake quality and safety assurance measures;
• Conduct risk and security control and monitoring, and detect and prevent fraud;
• Perform identity verification, accounting, audit, and other internal functions, such as internal investigations and record-keeping;
• Carry out corporate transactions, such as mergers, joint ventures, or acquisitions; and
• Comply with law, legal process, and internal policies, and exercise and defend legal claims.

19-4. Disclosure and Sale of Personal Information

We do not “sell” and have not “sold” Personal Information for purposes of the CCPA in the last 12 months. We do not sell the Personal Information of minors under 16 years of age.

19-5 Individual Rights and Requests

If you are a California resident, you may make the following requests:

1. “Request to Know”

   You may request that we disclose to you the following information covering the 12 months preceding your request:

   1. The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
   2. The specific pieces of Personal Information we collected about you;
   3. The business or commercial purpose for collecting (if applicable) Personal Information about you; and
   4. The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).

2. “Request to Delete”

   You may request that we delete Personal Information we collected from you.

    

   To make a Request to Know or a Request to Delete, please contact us at： 2-28-1, Asakusa, Taito-ku, Tokyo, Japan 111-0032
   We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as name, email address, mailing address and information regarding your previous interactions with us, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. You may make a request on behalf of a child who is under 13 years old if you are the child’s parent or legal guardian. If you make a Request to Delete, we may ask you to confirm your request before we delete your Personal Information.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

19-6. Authorized Agents

If you want to make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above. As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent, which also may include:

• Proof of your registration with the California Secretary of State to conduct business in California; and/or
• A power of attorney from the California resident pursuant to Probate Code sections 4121-4130; and/or

If you are making a Request to Know or a Request to Delete on behalf of a California resident and have not provided us with a power of attorney from the resident pursuant to Probate Code sections 4121-4130, we may also require the resident to:

• Verify the resident’s own identity directly with us; or
• Directly confirm with us that the resident provided you permission to submit the Request to Know or Request to Delete.

 

Links to Other Websites

We are not responsible for your Personal Information on third-party websites linked to websites operated by HANAYASHIKI CO., LTD.

 

Provision of Personal Information from Minors

If we need to provide Personal Information from Minor, we may need to obtain the consent of guardian as necessary.

 

Requests for disclosure of Personal Information, etc

For requests for disclosure of Personal Information and notification of the purpose of use, we will charge a fee. If you would like to correct, suspend, delete your Personal Information, it’s free.

A fee : 800 yen (including tax) will be charged per request.

Payment option: You can send a fixed-amount money order (issued at Post office counter) with application form for disclosure of Personal Information and other required documents.

Send to;

2-28-1, Asakusa Taito-ku, Tokyo, Japan 111-0032

HANAYASHIKI CO., LTD. Personal Information inquiry section

*Please note that we may not be able to respond appropriately if you provide insufficient or incorrect information in the application form for disclosure of Personal Information.

*Personal Information provided by your application form for disclosure of Personal Information will be used for the appropriate response to requests for disclosure from you, and we will keep the Personal Information strictly for a certain period of time.

We will not return the application form for disclosure of Personal Information and other required documents that could not be verified.