PRIVACY POLICY

Published: December 7, 2023
Last updated: Month Date, Year

We, EPOCH CO., LTD., respect your privacy. As we operate this website and provide you with our services, we process personal data about you, we undertake to comply with applicable data protection laws, including the Personal Information Protection Act of Japan (the “PDPA”), the General Data Protection Regulation of the European Union (the “GDPR”), the amendments to the California Consumer Protection Act (the “CCPA”) adopted pursuant to the California Privacy Rights Act (CPRA) , and Children’s Online Privacy Protection Act of the United State of America (the “COPPA”). This is our privacy policy on how we process and protect your personal data.
We may revise this privacy policy from time to time. You can obtain the latest version of this policy at the following link:
https://epoch.jp/global/en/privacy.php

If you have any questions or concerns about this privacy policy or your personal data, including any requests to exercise your legal rights, please contact us using the following contact information:

Privacy Manager
EPOCH COMPANY, LTD.
2-2-2, Komagata Taito-ku, Tokyo 111-8618, Japan
privacy@epoch.jp

This section of our privacy policy is addressed to our guests who live in the countries of the European Union, Iceland, Norway, Lichtenstein and the United Kingdom.

1. PERSON IN CHARGE

This privacy policy is issued by us, EPOCH CO., LTD., a company registered in Tokyo, Japan. When we process your personal data, we are the data controller in the meaning of GDPR and are responsible for protecting your rights with personal data.

2. HOW WE PROCESS YOUR PERSONAL DATA

As we provide you with our services on this website, we collect, use, store, generate or disclose to third-parties (hereinafter collectively referred to as “process”) your personal data for the following purposes:

1. To analyze your use of our website in order to generate insight that is useful for improving our services, products and marketing:
   1. Categories of your personal data we process: your interaction with our website collected by use of cookie(s), including your browsing record on our website together with IP address and other information about your terminal device.
   2. Lawful basis: processing is necessary for the purpose of our legitimate interest, i.e. improving our services, products and marketing. Data collected about your interaction with our website are analyzed in anonymized, statistical and aggregated manner, so that such processing does not affect your privacy by any means.
   3. Period for which we store your personal data: log data is deleted after 33 days.
   4. Recipients we disclose your personal data to: our contractors that assist us in analyzing web traffic data, e.g. Google and transcosmos.
2. To protect your privacy and security, integrity and availability of this website:
   1. Categories of your personal data we process: your browsing record on our website collected by web access logging, including your IP address, type and version of your web browser, web browser plugins, operating system and other information about your terminal device and technologies you use when accessing our website.
   2. Lawful basis: processing is necessary for the purpose of our legitimate interest, i.e. protecting your privacy and this website from fraudulent or unlawful access by monitoring web access traffic.
   3. Period for which we store your personal data: 33 days.
   4. Recipients we disclose your personal data to: our contractors that assist us in monitoring web access traffic.

3. SENSITIVE PERSONAL DATA

We usually don’t collect and/or use sensitive categories of your personal data as defined in Articles 9 or 10 of GDPR on our website.

4. COOKIES

Cookie is a small text file that our website sends to your terminal device for the purpose of keeping certain records.

By using cookies:

• Your terminal devices (e.g. browsers) remember your preferences (e.g. language used) and activities (e.g. login status, items in cart, etc.) on our website, so that we can deliver a personalized and better user experience on our website (essential cookies);
• We keep track of your interaction with our website, giving us useful and important insight for improving our website (performance cookies); and
• Based on your consent, our Adtech partners keep track of your browsing records across internet, so that we can deliver personalized advertisement that is more likely to be of your interest (advertising cookies).

The cookie identifies your terminal device, typically your web browser, but it cannot identify your individual identity. You can choose whether to allow us or third-parties (our Adtech partners) to set performance cookies and advertising cookies. When we use cookies for the purpose of personalizing our advertisement or analyzing web access, we request your prior consent thereto.

For more information and to change your cookie settings, including withdrawal of your consent, visit our Cookie Preference Center.

We do not set and use cookies for the purpose of advertisement or web access analytics for our users under 16 years of age. To ensure this policy, we request you to declare you are 16 years of age or older when we obtain your consent to our setting cookies for these purposes.

5. TRANSFER TO NON-EU COUNTRIES

When we disclose your personal data including your browsing record on our website to Google, your personal data may be transferred to the United States of America. In that case, your personal data are protected by Google in accordance with the EU-U.S. Data Privacy Framework or model contract clauses that are approved by the European Commission and are incorporated in the contract between Google and us. More detail of the protection of transferred personal data is provided by Google (https://policies.google.com/privacy/frameworks?hl=en)

Otherwise, we do not transfer your personal data to any entities located in any third countries outside of the European Economic Area (EEA) or Japan. In the event that we transfer your data to an entity located outside the EEA or Japan, we either ask for your prior consent thereto or protect your rights with personal data by virtue of a data transfer contract with the relevant recipient in accordance with GDPR and PDPA, which impose on such recipients contractual obligations to ensure adequate level of data protection equivalent to those laid down by GDPR and PDPA.

6. YOUR LEGAL RIGHTS

Provided that certain conditions are met, you have legal rights to request from us the following:

• Revocation of previously given consent to our processing of your personal data
• Access to your personal data and to certain supplementary information covered by this policy;
• Rectification of your personal data if inaccurate or incomplete;
• Erasure of your personal data in certain circumstances;
• Suspension of using your personal data in certain circumstances;
• Stopping processing your personal data in certain circumstances; and
• Obtaining your personal data in a structured, commonly used, and machine-readable format.

If you wish to exercise your right, please contact us.

7. COMPLAINT

You can lodge complaints about our way of processing your personal data with data protection supervisory authorities of your country of residence.

This section of our privacy policy explains how we collect, use, share, and protect personally identifiable information of California residents and any information related to it ("personal information") and non-personal information.

1. RIGHT TO KNOW ABOUT PERSONAL INFORMATION COLLECTED, DISCLOSED, OR SOLD

• The CCPA states you have the right to request us to disclose what personal information we collect, use, disclose, and sell, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about the consumer.
• You can exercise your above-mentioned rights unless you have exercised the rights within the preceding 12 months. We endeavor to respond to you within 45 days of receiving a verifiable request from you. If you intend to exercise such rights, please refer to section 8.
• We use your information (mail address) to verify your request. You may be asked to provide additional information so that we can verify your request.
• The categories of personal information we collected, business or commercial purpose, sources, the length of time to retain and the category of third parties we shared, sold, or disclosed within the preceding 12 months are as follows:

• Use or disclosure of Sensitive personal information stipulated in CCPA 1798.140(ae)
  (1) We do not use or disclose your Sensitive personal information.
• Sale or Sharing of Personal Information
  (1) We do not have actual knowledge that we Sell or Share personal information about residents who we know are younger than 16 years old.
  Under the CCPA, "Sell" means disclosing by electronic or other means, a consumer's personal information to a third party for monetary or other valuable consideration, and "Share" means sharing a consumer's personal Information to a third party for cross-context behavioral advertising.
  (2) Under the CCPA, the activities in which we share information collected from cookies or email addresses with advertising agencies to manage our personalized advertising to those of you 16 years of age or older based on your preferences may be considered a "sale" or "share" of personal information.
  Opt-out rights can be exercised by visiting our Cookie Policy or by going directly to our Cookie Settings page and deleting or preventing cookies from being used. You can also click on the "Do Not Sell or Share My Personal Information" link at the bottom of every webpage.
• Disclosure of Personal Information
  (1) We only allow our service providers to handle your personal information when we have confirmed that they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure that they can only use your personal information to provide services necessary to receive, handle and respond to your inquiries. We may also share personal information with external auditors.
  We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
  We may also need to share some personal information with other parties, such as potential buyers of some or all of our businesses or during a re-structuring. Usually, information will be anonymized but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
  We will not share your personal information with any other third party.

2. RIGHT TO REQUEST DELETION OF PERSONAL INFORMATION

• The CCPA states you have the right to request us to delete your personal information collected by us, subject to certain exceptions.
• We endeavor to respond to you within 45 days of receiving a verifiable request. If you intend to exercise such rights, please refer to section 8.
• We use your information (mail address) to verify your request. You may be asked to provide additional information so that we can verify your request.

3. RIGHT TO CORRECT INACCURATE PERSONAL INFORMATION

• The CCPA states that you have the right to correct inaccurate personal information collected by us.
• We endeavor to respond to you within 45 days of receiving a verifiable request. If you intend to exercise such rights, please refer to section 8.
• We use your information (email address etc.) to verify your request. You may be asked to provide additional information so that we can verify your request.

4. RIGHT TO OPT-OUT OF THE SALES OR SHARE OF PERSONAL INFORMATION

• The CCPA states you have the right to opt-out of the Sale or the Share of your personal information if we sell or share your personal information.
• Under the CCPA, the activities, in which we share information collected from cookies or email addresses with advertising agencies to manage our personalized advertising to those of you 16 years of age or older based on your preferences, may be considered a “sale” or "share" of personal information.
  Opt-out rights can be exercised by visiting our Cookie Policy or by going directly to our Cookie Settings page and deleting or preventing cookies from being used. You can also click on the “Do Not Sell or Share My Personal Information” link at the bottom of every webpage.

5. RIGHT TO LIMIT THE USE OR DISCLOSURE OF SENSITIVE PERSONAL INFORMATION

• The CCPA states that you have the right to limit the use or disclosure of sensitive personal information if we use or disclose your Sensitive personal information for reasons other than those set forth in section 7027, subsection (m) of CALIFORNIA CONSUMER PRIVACY ACT REGULATIONS.
• We do not use or disclose your Sensitive personal information.

6. RIGHT TO NON-DISCRIMINATION FOR THE EXERCISE OF A CONSUMER’S PRIVACY RIGHT

• The CCPA states you have a right not to receive discriminatory treatment by us for the exercise of the privacy rights conferred by the CCPA, including an employee's, applicant's, or independent contractor's right not to be retaliated against for the exercise of their CCPA rights.
• We do not discriminate against you for the exercise of your privacy right.

7. AUTHORIZED AGENT

• When you use an authorized agent to submit a request to know or a request to delete, or a request to correct, we may require that you:
  (1) Verify your own identity directly with us; and.
  (2) Directly confirm with us that you provided the authorized agent with permission to submit the request

8. HOW THIS SITE RESPOND TO “DO NOT TRACK” SIGNALS OR OPT-OUT PREFERENCE SIGNALS

Some web browsers incorporate a “Do Not Track” (DNT) feature or opt-out preference signals, which when turned on signals to websites you visit that you do not want to be tracked.
Our site responds to the DNT signals or opt-out preference signals. You can confirm your settings by going directly to our Cookie Settings page. You can also click on the "Do Not Sell or Share My Personal Information " link at the bottom of every webpage.

9. YOUR CALIFORNIA PRIVACY RIGHTS

Pursuant to California Civil Code Section 1798.83, we only share Personal Informationn of California residents with third parties for those third parties’ direct marketing purposes if you specifically opt-in or are offered the opportunity to opt-out and elect not to opt-out from such sharing at the time you provide Personal Information or at the time you choose to participate in a feature. If you do not opt-in or if you opt-out at the applicable time, we do not share your information with those identified third parties for those third parties’ own direct marketing purposes. If you are a California resident, and we do not have a policy of providing choices regarding certain kinds of sharing, as described above, you have the right to receive from us: (a) information identifying any third party(ies) to whom we may have disclosed, within the preceding calendar year, your Personal Information for that third party’s own direct marketing purposes; and (b) a description of the categories of Personal Information disclosed. If you are a California resident, please write to the contact point referred to in contact information on the top of this page to obtain information free of charge regarding our compliance with this law. (Requests received by other means may result in a delayed response.) Please use "Your California Privacy Rights" in the subject line of your e-mail or letter. Please include your name, street address, city, state, and zip code. We are not responsible for requests that are not labeled or sent properly, or do not have complete information.
Please note that we are only required to respond to one request per customer each calendar year. We will respond to these requests within thirty (30) days.

Some of our websites contain content appropriate for a wide range of audiences, including Children(in this provision, we call the children who are under 13 years old).
We do not collect and store personal information about Child if this information is submitted by a Child without prior parental consent or by the parent or guardian of the Child. If a Service is directed to children under COPPA, we may ask users to verify their dates of birth before collecting any personal information from them. Those users that indicate they are Children are either blocked from the activity or taken through a parental consent process.
We are prohibited by COPPA from conditioning a Child's participation in an activity - like contests - on the Child's disclosure of more personal information than is reasonably necessary to participate in the activity.

If we discover that we’ve unintentionally collected information from a child in a way that doesn’t meet COPPA requirements, we will delete the information immediately.
A parent who has already given our permission to collect and use his or her Child's personal information can, at any time, do the following: (1) review, correct, or delete the Child's personal information; and/or (2) discontinue further collection or use of the Child's personal information. To do so, please refer to the contact information on the top of this page.