Privacy Policy

Principle Co., Ltd. (“Principle” or the “Company”) processes the personal data of users located outside Japan (the “Users”) in accordance with the applicable data protection laws and regulations of the relevant countries, including the Regulation (EU) 2016/679 (the General Data Protection Regulation or the “GDPR”). This Privacy Policy (this “Policy”) describes how the Company, as the data controller, processes the personal data of the Users when they purchase products through the e-commerce website operated by the Company (the “Website”), contact the Company, subscribe to the Company’s email newsletter, or use any other services provided by the Company (collectively, the “Services”).
If users located in Japan use the Services, the Privacy Policy for Japan shall apply.

1. Personal Data the Company Collects

The Company collects and processes the following categories of personal data in connection with the provision of the Services.

(a) Data Provided by the Users

(1) Contact Information

The Company collects the contact information of the Users when they purchase products through the Website, subscribe to the Company’s email newsletter, or otherwise contact the Company.

This may include the names, email addresses, postal addresses, telephone numbers, and shipping information of the Users.

(2) Order and Transaction Data

The Company collects transaction data related to the purchase of products through the Website. This may include order history, the types of products purchased, payment dates, billing amounts, payment methods, and information regarding refunds.

(3) Inquiry and Feedback Information

The Company collects information relating to the Users’ inquiries, comments and feedback regarding the Company’s products and services, and participation in promotions, contests, and sweepstakes.

(b) Data Collected When the Users Use the Services

(4) Usage Data

The Company collects data relating to the Users’ activities on the Website.

This data may include access logs, browsing history, information about the use of the Services, browser types, and other system activity.

(5) Device Data

The Company collects data relating to the devices used to access the Website. This collected data may include device identifiers, online identifiers such as advertising IDs, device types, operating systems and versions, cookie information, language and time zone settings, browser types and versions, IP addresses, names of telecommunications carriers, and information about the municipalities in which the devices are located.

2. Purposes and Legal Reasons for Processing

(i) The Company uses personal data for the following purposes:

a. Performance of a Contract

The Company processes the Users’ personal data in the following categories for the following purposes, to the extent necessary to perform its contractual obligations in providing the Services to the Users.

Category Purpose of Use
Personal data in (1) and (2) above To Sell Products and Process Payments and Refunds

The Company processes the Users’ personal data to process the Users’ orders, confirm or modify order details, and process billing, payments, and refunds.

Personal data in (1) and (3) above To Communicate with the Users

The Company processes the Users’ personal data to respond to the User’s inquiries, send notifications regarding the Services, and keep records of inquiries.

b. Legitimate Interests

The Company processes the following categories of personal data for the following purposes, to the extent necessary to pursue its legitimate interests.

Category Purpose of Use
Personal data in (1), (2), and (3) above To Introduce the Company’s Products and Services and Conduct Promotional Activities

The Company processes the Users’ personal data to introduce the Company’s products and Services to the Users, send notifications regarding new information, conduct promotions, contests, and sweepstakes, verify eligibility for participation, and award or deliver prizes.

Personal data in (1), (2), (4), and (5) above To Provide Personalized Information and Deliver Advertisements

In order to provide information and Services tailored to the preferences of individual Users and to deliver advertisements suited to the Users, the Company provides the Users’ personal data to third parties (i.e., the companies described in Article 3 that provide advertising distribution services and other services pursuant to contracts with the Company) and processes such personal data.

Personal data in (4) and (5) above To Measure and Analyze the Performance of the Website

The Company processes the Users’ personal data to analyze the performance of the Website and use the results to improve its Services and support its marketing activities.

Personal data in (1), (2), (3), (4), and (5) above To Maintain and Improve the Services and Develop New Services

The Company processes the Users’ personal data to collect information for responding to system failures and troubleshooting, to improve the functionality of the Services, and to plan and develop new products and services. This may include the creation of statistical data categorized by the Users’ attributes.

Personal data in (1), (2), (3), (4), and (5) above To Protect the Company, the Users, and the Public

The Company may process the Users’ personal data to respond to violations of the Company’s rules, to investigate, detect, and prevent unauthorized use, and to investigate and resolve complaints, disputes, and other matters.

(ii) Principle does not collect or process the Users’ personal data of a sensitive nature, such as information relating to religious beliefs or health conditions.

(iii) Principle does not make automated decisions based solely on personal data that may affect the Users.

(iv) Principle separately informs the Users when providing personal data is required by law or under a contract, or is necessary for entering into a contract, as well as of the possible consequences of failing to provide such personal data.

3. Personal Data Retention Period

Principle retains the Users’ personal data for as long as necessary to achieve the purposes of collecting and processing the Users’ personal data set out in Article 2 of this Policy. The specific retention period is determined based on: (i) the purpose for which the personal data is collected and processed; (ii) the nature of the personal data; and (iii) the need to retain the personal data for legal or business reasons.

4. Disclosure of Personal Data

For the purposes set out in this Policy, Principle may, in accordance with the GDPR, disclose the Users’ personal data to the following recipients and to such other third parties to whom the relevant User has consented to the disclosure of such personal data.

5. Cross-Border Transfers of Personal Data

When the Company transfers the Users’ personal data outside Japan, the Company takes appropriate protective measures in accordance with applicable laws and regulations.

6. Users’ Rights

(i) The Users have the following rights in relation to the personal data collected and processed by Principle.

  • a. Obtaining Information Regarding Data Processing

    The Users have the right to obtain from Principle all information necessary regarding Principle’s data processing activities relating to them.

  • b. Access to Personal Data

    The Users have the right to obtain confirmation from Principle as to whether their personal data is being processed, and if so, the right to access such personal data and certain related information.

  • c. Correction or Deletion of Personal Data

    The Users have the right to request that Principle correct any inaccurate personal data about them without undue delay, and to have any incomplete personal data completed. In addition, if certain conditions are met, the Users have the right to request that Principle delete their personal data without undue delay.

  • d. Restrictions on the Processing of Personal Data

    If certain conditions are met, the Users have the right to request that Principle restrict the processing of their personal data.

  • e. Objection to Processing of Personal Data

    If certain conditions are met, the Users have the right to object to the processing of their personal data.

  • f. Portability of Personal Data

    If certain conditions are met, the Users have the right to receive their personal data in a structured, commonly used, and machine-readable format, as well as the right to transmit that data to another controller without hindrance from Principle.

  • g. Exclusion from Automated Decision-Making

    If certain conditions are met, the Users have the right not to be subject to automated decision-making, including profiling, based on personal data that could have legal or similarly significant effects on them.

(ii) If the Users wish to exercise the rights described above, please contact Principle using the contact information provided in Section 8 (Identity and Contact Details of the Controller) of this Policy. Within one month of receiving a request (which may be extended by an additional two months if necessary), Principle will either provide information regarding the actions taken in response to the request or notify the requester of the reasons for not taking action within one month of receiving the request.

(iii) The Users may file a complaint regarding Principle’s processing of their personal data with the data protection supervisory authority of the jurisdiction where they reside, work, or where the alleged infringement occurred.

7. Changes in this Policy

Principle may amend this Policy from time to time. In the event of any substantial or significant changes, Principle notifies the Users via the Website.

8. Identity and Contact Details of the Controller

If the Users have any questions, complaints, or other inquiries regarding the handling of their personal data, please contact the data protection officer or the designated representative listed below:

  • ・Contact: info@lemma-kobe.com
  • ・Operating company: Principle Co., Ltd.
  • ・Store name: Lemma
  • ・Address: 4th Floor, Towa Building, 2-2-3 Kaigan-dori, Chuo-ku, Kobe City, Hyogo Prefecture 650-0024
  • ・Representative: Mitsutoshi Murata
  • ・Data protection officer: Atsushi Sawada

If you have any questions or inquiries about Lemma products, please contact us through our email form.

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