For purposes of this Privacy Policy, “personal data” means information that identifies, relates to, describes or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular individual. Please note, subject to applicable laws, as used in this Privacy Policy, “personal data” does not include information that has been anonymized or aggregated in a way that cannot be used to identify a specific individual.

How we use your information

We may collect personal data that you provide to us when you access our website, transact business with us through a website or otherwise, contact customer service, participate in a promotion, participate in another feature of our website that requires your personal data, provide us with comments, suggestions or content for, and/or provide your information to third party marketing affiliates. We only collect personal data that is necessary for the purposes identified herein. Please note that we do not control the collection or use of your personal data by third parties who may provide it to us, and such is subject to their privacy policies.

Some of our personal data collection is completely transparent. This means that you will know when and how it is happening. We can only gather the personal data you voluntarily provide. If you object to or limit processing of certain personal data of this nature, you may not be able to easily or efficiently use all of the features of the website or interact or transact business with us. By providing us with this personal data, you understand and acknowledge that we will collect, use, store, and disclose it for the purposes you provided it. The categories of personal data we may collect from you may include:

Contact Information: Such as name, address, phone number; email address; social pages.
Payment Info: Such as credit card type. Please note that we do not store credit card numbers and all credit card processing is done by third parties.
Preferences: Such as product types; quantities of products; delivery preferences.
Purchase History: Such as historical purchase records; order numbers; identification of products and quantities purchased.
Chat, Email, Other Electronic Communications: Any personal data you voluntarily share in your written, electronic, telephone, and in-person communications with us, including, without limitation, questions; product inquiries; requests to be contacted; comments and/or feedback about products.
Other Personal Data: Any other personal data you choose to provide to us, including, without limitation, through marketing email sign-ups; participation in contests, surveys and other promotions.
We may, subject to our compliance with applicable laws, including, without limitation, with your consent where required by law, collect personal data about you without your express knowledge, including, without limitation, as more fully described in this Privacy Policy and our Cookie Policy through the use of cookies, pixels, web beacons, clear gifs, pixel tags or other similar technologies (collectively, such analytics tools are referred to in this Privacy Policy as “cookies”); through our websites and electronic marketing materials (such as emails); and from third parties. In addition to other information provided in this Privacy Policy, this type of information may include:

Information from Third Party Platforms: If you access our websites or communicate with us using your account credentials from a third-party owned or operated platform/service (e.g., Amazon, Apple, AWS, Facebook, Google, Shopify, Twitter, etc.), post content from one of our websites to a social network, or use various social media features (e.g., “Life” button), we may process certain information from the third parties, such as your username, “likes”, location, birthday, comments and reviews, preferences, network reach and influence, and any other information you provided to third parties in connection with your account. Depending on your account and privacy settings on such third-party platforms, we may also be able to see information that you post when using these third parties whether or not you are an active customer.
Information from Third Party Service Providers: We may also collect personal data about you from our third-party service providers who provide us with e-commerce and/or technical related support or services associated with the functionality and purposes of a website and our transaction of business and interaction with you.
Advertising Data: From time to time, we may obtain data from third parties who collect data from other third-party sources outside of our control. These third parties may use their own cookies and other tracking technologies. We do not control these third parties and their actions are governed by their privacy policies.

Sharing information with third parties

Save as noted elsewhere in this Privacy Policy or in our Cookie Policy (e.g. in relation to DEKEY merging with or being acquired by another organisation, or upon a sale of its assets), DEKEY will never sell any information about you to anyone outside of its group. We do not share, sell or rent to other third parties any information that you provide to us, except with your consent or as described in this Privacy Policy or our Cookie Policy. We do not link personally identifiable information with aggregate information.

We may share your personal data with selected recipients:

If necessary to fulfill your orders or to provide you with tailored products, product promotions and advertisements, product support services, or other communications, we may disclose your personal data within the DEKEY family of entities.
We engage third parties to perform services in connection with the operation of our business. Examples of these services include payment processing and authorization, fraud protection and credit risk reduction, product customisation, order fulfilment and shipping, marketing and promotional material distribution, website evaluation, data analysis and, where applicable, data cleansing. We need to share personal information with these third parties so that they can perform these services, however, we limit the personal information that we give to them and authorise them to use this information only for the purpose of performing those services.
We use a third party payment processor to process payments made to us. In connection with the processing of such payments, we do not retain any personal data or any financial information, such as credit card numbers. Rather, all such information is provided directly to our third party payment processor, Cybersource Corporation (a Visa company), whose use of the information they collect from and about you is governed by their Privacy Policy.
In proceeding with your online credit card order, both your name and address and those of the delivery name and address (if different) will be checked using third parties.
We share aggregated demographic information about our user base with our agents, including agencies or third-party vendors so that they can provide marketing analysis and consult on advertising strategies. This information does not identify individual users. We also share non-personal information, such as the number of users who visited the website during a specific time period or who purchased a specific product through the website, with our marketing partners, advertisers and others from time to time. This information generally is shared in an aggregated form.
We release your information to law enforcement agencies, public authorities or other organisations if we believe in good faith that: (1) the law or legal process requires it; (2) such disclosure is necessary for the detection, prevention or to otherwise address security, fraud or technical issues; (3) if we have received a valid administrative request from a law enforcement agency, or (4) we need to protect our rights, property or safety, that of our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
As with any business, it is possible that as our business develops, we might go through a business transition, such as a merger, acquisition by another company, sale of all or a portion of our assets or buying online stores or other assets. In such transactions, information about customers will likely be transferred.
The data that we collect from you will be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. Where a transfer of information involves a transfer of information collected or stored within the EEA to a country or territory located outside the EEA, such information will be transferred to, and stored at/processed in the United States of America or other countries where our affiliates or service providers maintain facilities. These transfers outside the EEA in accordance with appropriate or suitable safeguards recognized under applicable laws, including applicable adequacy decisions and standard contractual clauses. Please note, all personal data collected through our websites is initially collected via websites hosted within the United States of America.

You have the right to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by choosing to opt-out (see “How to opt-out, remove or modify information provided to us”) or by completing a Data Deletion Request.

You have additional rights in relation to the personal data we hold about you. Some of these only apply in certain circumstances. We have described these situations below, as well as how you can exercise your rights. To exercise any of your rights, please complete the applicable form.

• Access: You have the right to ask us to access the personal data we hold about you and be provided with certain information about how we use your personal data and who we share it with. (Data Request Form)
• Correction: You also have the right to ask us to correct your personal data where it is inaccurate or incomplete. (Data Request Form)
• Objection: In certain circumstances, the right to restrict or object to our processing of your personal information (e.g. where you request correction or erasure, you also have a right to restrict processing of your applicable data while your request is considered). You can object to our processing of your personal data based on our legitimate interests by contacting us at info@dekey.co.jp, and we will no longer process your personal data unless we can demonstrate an overriding legitimate ground.

In addition, you have the right to complain to the applicable data protection supervisory authority.

• If you are located in the European Economic Area, further information about how to contact your local data protection authority is available.
• If you are located in Switzerland, you can make a complaint at any time to the Federal Data Protection and Information Commissioner, the Swiss data protection authority for data protection issues.
• If you are located in the United Kingdom, you can make a complaint at any time to the Information Commissioner’s Office (ICO), the UK data protection authority for data protection issues.

However, we would appreciate the opportunity to address your concerns before you contact your local data protection authority; so, if you do have any concerns, please contact our Data Protection Officer as follows:

• By email at info@dekey.co.jp
• By mail to:
  DEKEY INTERNATIONAL
  4-4-18 Nishitenma, Kita-ku, Osaka 530-0047
  ATTN: Privacy

Please note that these rights are limited, for example, where fulfilling your request would adversely affect other individuals or company trade secrets or intellectual property, where there are overriding public interest reasons or where we are required by law to retain your personal data.