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This Privacy Notice is intended to inform you how we at KMEW Co., Ltd. use any information we collect about you (which we call "Personal Data” as defined below) in accordance with the Data Protection Directive of the European Union until 24 May 2018 and the General Data Protection Regulation (GDPR) thereafter, and to advise you of your rights and our obligations relating to the processing of your Personal Data.
This Privacy Notice applies to the use of our services, products and websites (collectively, our "Services”) and applies to your use of our Services you access via a computer, mobile phone, tablet, TV or other device.
For further information on our privacy practices, please click on the links below:
For the purpose of this Privacy Notice, "Personal Data” is defined as any and all information that relates to an identified or identifiable individual (such as you). Examples of Personal Data are your name, address, phone number, photographs, the products purchased by you, and online identifiers (e.g. cookies and IP address), among others. Personal Data also includes information which does not identify you by itself but which we are able to link to you.
We collect information about your use of our Services and your use of online applications. We are not permitted to process your Personal Data without valid legal grounds. Specifically, we process your Personal Data only where:
» To benefit from cost-efficient Services (e.g. we may opt to use a certain specific platform offered by suppliers);
» To protect the security of IT systems, architecture and networks; and
» To fulfil our corporate responsibility and responsibility vis-à-vis society, and to achieve related goals;
The purposes of our processing of your Personal Data, and legal basis we rely on therefore, are shown below:
|Create an account/login on websites, applications||To enable you to create a profile on our websites and applications and to login to such websites and applications||Legitimate interests
Performance of contractual obligations
|Provision of our Services||To provide specific functionality that you or our Services may require so that we can fulfil our contractual obligations to you (e.g. product warranties)||Performance of contractual obligations|
|Response to inquiries from website users||To improve the quality of our Services and products and to conduct marketing activities||Legitimate interests|
|Analytical purpose for service improvements||To evaluate and analyze markets, customers, products, and other Services for improvements of existing KMEW products and Services and development of new products and Services||Legitimate interests|
|Creation of statistical information||To create anonymous aggregated statistics about the use of our Services. Such anonymized data may be shared with third parties||Legitimate interests|
|Profiling||To predict your interests based on which direct marketing is provided to you||Legitimate interests|
|Customer support service||To provide customer support service for our Services or to respond to your inquiries and support-related requests (responding to dissatisfied customers, etc.)||Legitimate interests|
|Training||For staff training and quality assurance especially in relation to our customer support personnel||Legitimate interests|
Performance of contractual obligations
|Corporate transactions||To manage our corporate transactions such as reorganizations, mergers, transfers, sales, joint ventures, assignments and other dispositions of all or any portion of KMEW’s business, assets or shares including, without limitation, in connection with any bankruptcy or similar proceeding||Legitimate interests|
|Updates||To exchange information with you about your account, profile or transactions with us, to deliver important information about your products, applications and other Services, to send notices about important changes to our Privacy Notice and to communicate with you||Legitimate interests|
|Integration of Personal Data||To combine pieces of Personal Data KMEW collects for the provision of, for example, better support services and for the delivery of more personalized content, to name a few||Legitimate interests|
|Survey||To seek opinions and comments from you on our Services and to conduct other surveys||Consent|
|Dissemination and newsletters||To provide customized content, to issue recommendations based on your past activities related to our Services and ads (directly or through our partners such as social media networks) and to provide means of communication such as newsletters, postal mail, phone, e-mail and/or other electronic means of communication||Consent|
|Publication of customer comments and content uploading||KMEW may link to or publicly post (including in our advertisements) your product review, comment and content you upload to our websites, applications or community forums or you state in your voluntary survey response.||Consent|
Where required for contractual relationships with you and for your activities, we may lawfully collect Personal Data from our networks, other companies (insurance companies and financial institutions, etc. ) and other third parties and, where necessary, from publicly accessible sources (e.g. commercial registry and related documents, resident registry, media organizations, Internet and other media), and we may process the Personal Data we lawfully collect, receive or acquire in accordance with applicable laws. The following categories of Personal Data are of relevance to this:
We will process and store your Personal Data while a business relationship (including any pre-contractual relationship and contract execution) between you and us is in force. We are subject to a variety of storage and documentation obligations that arise out of applicable laws, but unless stipulated otherwise by applicable laws, we will keep your Personal Data as defined in this Privacy Notice for a maximum period of 10 years after the termination of a contractual or pre-contractual relationship.
When we are no longer required to fulfil contractual or legal obligations, we will erase relevant Personal Data periodically, except where further processing is necessary to achieve the purposes of compelling and legitimate interests and the purposes of use outlined in this Privacy Notice. Legitimate interests are deemed to exist in cases where data cannot be erased as a result of the selection of a specific method of data storage and where the cost of erasing is unreasonably high and appropriate technical and organizational measures in place exclude processing for other purposes.
KMEW may disclose your Personal Data to the following companies:
The Personal Data we collect from you may be stored and processed in your region, or transferred to, stored or processed outside the European Economic Area ("EEA”), including but not limited to Japan and Russia or in any other countries which do not have an adequate level of data protection as prescribed by the European Commission, and where KMEW, its affiliates, subsidiaries or service providers maintain facilities.
Should we transfer Personal Data to a non-EEA region, we will ensure that appropriate protection measures, including transfer agreements (EU standard contractual clauses) are in place to ensure an appropriate level of protection will be accorded to your Personal Data. You may request additional information on this and obtain a copy of relevant protection measures from the contact indicated in Section 8 below.
Appropriate technical and organizational measures are in place for the protection of Personal Data we collect in connection with our Services. The protection measures take the following factors into account:
The objective of these measures is to protect against accidental or unlawful destruction or alteration, accidental loss, unauthorized disclosure or access, and other unlawful forms of processing.
Please note that although we take appropriate measures to safeguard your Personal Data, no website, product, online application, data transmission, computer system or wireless connection is completely secure and hence we cannot guarantee the security of your Personal Data.
KMEW will collect, store and process your Personal Data in accordance with your rights under applicable data protection laws.
Your rights under the GDPR include the right to access a copy of your Personal Data, the right to request corrections of inaccurate information about yourself or request updates of your Personal Data, and the right to object to the processing of your Personal Data under the conditions set forth by the GDPR.
You also have the right to request the erasure of your Personal Data. Even if you have agreed to the processing of your Personal Data, you have the right to withdraw your consent at any time (note that such withdrawal will not affect the lawfulness of the processing prior to your withdrawal). Furthermore, you have the right to transfer data in certain cases. This is the right to request the return of your Personal Data you have provided to us in a structured, commonly-used, machine-readable format and to request the transfer of such Personal Data to a third party without hindrance from us and subject to your own confidentiality obligations.
If you wish to exercise your rights stated above, please contact us by using any of the methods shown below. You need to submit to us a document that serves as proof of your identify when exercising your right.
We will respond to your complaint within a month of our receipt, except where a longer period is permitted under applicable privacy protection laws.
If you are not satisfied with the way we process your Personal Data, you may file a complaint with the competent data protection authority in addition to exercising your rights explained above.
Our websites, applications and products may contain links to other third-party websites that are not operated by us, and our websites may contain applications that you can download from third parties. Since such linked sites and applications are not under our control, we are not responsible for the privacy practices or content of such sites and applications. If you opt to use a third-party website or application, any Personal Data collected by the third-party website or application will be subject to the privacy protection policy of that third party. We strongly recommend that you carefully review and understand the privacy protection policy of any third party to which you provide your Personal Data.
Please note that you may change your browser setting so that you will be notified when cookies are sent out to it. If you do not wish to receive cookies, you may refuse all cookies by activating the relevant setting on your browser. However, please be warned that if you choose to refuse all cookies, some features of our Services may become inaccessible by your browser or may not work properly. Finally, you may also delete the cookies that have already been sent.
We reserve the right to change this Privacy Notice from time to time. The "Date last updated” at the bottom of this page indicates the date of the most recent update, and changes will become effective upon our posting of the revised Privacy Notice.
Where required by applicable laws, we will seek your consent in respect of changes. We will give this notice by e-mail or by posting notice of changes on our websites or through relevant Services.
Last updated on: [October] 2018