We and our group companies (collectively, the “Group”) believe it is vital to protect privacy/personal information of our customers (including representatives of companies which we do business with) and users of the Group’s website (collectively, “you”) in order for the Group to fulfill expectations of you and all other stakeholders. The Group sets out this privacy policy (this “Policy”) with respect to the handling of personal information to ensure personal information will be appropriately managed and protected. Unless otherwise specified in this Policy, the terms used in this Policy shall have the meanings given to them in the Act on the Protection of Personal Information (the “Personal Information Protection Act”).

1. Compliance with Laws and Regulations
The Group handles personal information about you in accordance with the Personal Information Protection Act, the EU General Data Protection Regulation (the “GDPR”) and other applicable laws and regulations regarding protection of personal information and privacy.

2. Items of Personal Information We Obtain The Group obtains your personal information described below. For the avoidance of doubt, the Group does not obtain your personal information without your consent.
(1). Identity verification information
Name, address, telephone number and email address
(2). Information we obtain in relation to your use of services
Information which can identify a specific person using the browsing history, IP address of the person who accesses the Group’s website, cookie information, location information, individual device identification information and other descriptions, or information containing an individual identification code, when you view the Group’s website.

3. Purpose of Use
The Group uses your personal information only within the scope of the following purposes except with your prior consent or where required by law.

No	Purpose of Use
1	(i) Performance of contract such as shipment of products, provision of services and issuance of invoice (ii) Response to your requests before execution of contract
2	Group’s marketing activities such as communicating to and conducting a questionnaire with you
3	Provision of customer services to you
4	Product sales analysis, other surveys and studies, and development of new services and products
5	Services incidental or related to any of the foregoing, and response to inquires

4. Security Management Measures
The Group takes necessary and appropriate security management measures to prevent personal information from being leaked, accessed by unauthorized users, lost, damaged or tampered. Inquiries about security management measures the Group takes should be directed to the details set out in “11. Contact.”

5. Supervision over a Trustee
The Group may entrust a whole or part of the handling of personal information within the scope necessary to achieve the purpose of use. In such case, the Group will take appropriate security management measures in accordance with its Information Security Management Rules. In addition, the Group will ensure, through the execution of the service agreement, etc., that personal information will be handled by the Trustee under appropriate security management measures.

6. Provision to Third Parties
The Group will not disclose or provide your personal information to third parties without your prior consent except where relevant law or regulation allows us to disclose or provide your personal information to third parties without your consent.

7. Sharing of Personal Information
We may share your personal information in the manner described below.
(1) Items of personal information we share: Information described in “2. Items of Personal Information We Obtain”
(2) Those with whon we share personal information: our group companies
(3) Purpose of use of personal information we share: Purposes described in “3. Purpose of Use”
(4) Person responsible for management of sharing personal information Name: Triumfield Holdings Co., Ltd.Address: Oak Yokohama Building 2F, 2-15-10 Kitasaiwai, Nishi-ku, Yokohama-shi, Kanagawa Representative: Masaki Itoh, President and Representative Director

8. Request for Disclosure, etc. of Personal Information
(1) Request for Disclosure, etc.
The Group will, in accordance with the Personal Information Protection Act, appropriately respond to your (1) request for disclosure of personal information or records of provision to third parties, (2) request for notification of the purpose of use, (3) request for correction, (4) request for addition, (5) request for deletion, or (6) request for suspension of use or cessation of provision to third parties (collectively, the “Request for Disclosure, etc.”) with respect to your personal information the Group holds to the extent permitted by the Personal Information Protection Act.
(2) Procedures
Inquiries about a Request for Disclosure, etc. including our prescribed procedures and fee amounts should be directed to the details set out below in “11. Contact for Inquiries” and we will reply to them without delay.

9. GDPR Special Provisions
If you are in the European Economic Area (the “EEA”), the GDPR applies to you. Therefore, the special provisions specified below (these “Special Provisions”) apply in accordance with the GDPR. If you are in the United Kingdom of Great Britain and Northern Ireland, the data protection regulation equivalent to the GDPR applies to you. Therefore, these Special Provisions apply.
(1) Purpose of Use of Personal Data and Legal Basis therefor
The Group obtains and processes your personal data under the following specific legal bases.

No	Purpose of Processing	Purpose of Processing
1	(i) Performance of contract such as shipment of products, provision of services and issuance of invoice by the Group (ii) Response to requests from users of the Group’s website before execution of contract	Your consent, performance of contract
2	Communicating to and conducting a questionnaire with users of the Group’s website for the Group’s marketing purposes	Performance of contract, legitimate interests (for the Group’s normal business purposes)
3	Provision of customer services by the Group to you	Performance of contract, legitimate interests (for the Group’s normal business purposes)
4	Product sales analysis, other surveys and studies, and development of new services and products	Legitimate interests (for the Group’s normal business purposes)
5	Services incidental or related to any of the foregoing, and response to inquires	Performance of contract, legitimate interests (for the Group’s normal business purposes)

Personal data specified above is essential for the Group to provide its services to you and if you do not provide such data, we may not be able to provide necessary services to you. If the Group processes personal information for purposes other than those listed above, the Group will provide you with the purpose of processing and other necessary information and obtain your prior consent.

(2) Retention Period of Your Personal Data
The Group will store your personal data only for the period necessary to achieve the purposes specified in this Policy.

(3) Your rights
A Right to request access, rectification, erasure or restriction
You are entitled to the following rights regarding your personal data the Group holds:
a) Right to request access to your own personal data
b) Right to request rectification to your own personal data
c) Right to request erasure of your own personal data
d) Right to request restriction of processing of your own personal data
e) Right to request transfer of your own personal data to you or a third party
B Right to object to processing
You have the right to object us to processing your own personal data for our legitimate interests.
C Right to withdraw consent
If the Group processes your personal data based on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
D Procedures for the exercise of your rights
Inquiries about the procedures for the exercise of your rights (including how to withdraw consent) should be directed to the details set out in “11. Contact for Inquiries” of our Policy and we will reply to them without delay.

10. Handling of Cookies
(1) Use of Cookies
The Group’s website uses cookies and other similar tracking or analytical technologies (collectively, “Cookies”) to improve services for you.
(2) Overview of Cookies
Cookies are exchanged between a web server and your internet viewing software (browser) and are placed on your device by the website that you visit. You may disable the function of cookies by setting your browser. However, if you do this, you may not be able to use a part or the whole of the website’s services.
(3) Google Analytics
The Group uses Google Analytics provided by Google as an access analytics tool. Google collects information about your browsing activities based on Cookies set by us or Google. The Group receives Google Analytics results to understand your service usage and may use such information for the Group’s services. For details on how Google handles data with Google Analytics, please see the following Google website.
policies.google.com/privacy?

11. Contact
Please direct any inquiries, requests, complaints or suggestions about personal
information to:
Name: Kiyoshi Anzai
Address: Oak Yokohama Bldg 2F, 2-15-10 Kitasaiwai, Nishi-ku, Yokohama, Kanagawa, 220-0004, Japan
Email: csd@blauda.com
Telephone number: +81-45-670-2574
Office hours: 9:00AM – 6:00PM (JST)