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Privacy policy
THE KARUIZAWA PRIVACY NOTICE
Effective Date: June 24, 2021
1. INTRODUCTION
Karuizawa Distillers, Inc., and its subsidiaries ("Karuizawa") want you to be familiar with how we collect, use and disclose information from and about you because we respect your concerns about privacy, and we want to maintain your trust.
This Privacy Notice applies to information we collect from all sources, including in connection with our websites, mobile sites, applications ("apps"), widgets, conferences, events, and electronic newsletters or communications (collectively the "Karuizawa Services") that link to this Privacy Notice. If there is a conflict between this Notice and aspecific Karuizawa Services agreement, the Karuizawa Services agreement will take precedence.
This Notice describes the types of Personal Data we collect, how we use it, and with whom we share it. It also describes generally Karuizawa's practices for handling Other Information (e.g., interests, demographics and services usage) collected through our Karuizawa Services or from a third party to the extent such information is associated with a particular device, user or user account. We also describe the measures we take to protect the information, your options for choice and access, and how you can contact us about privacy practices. As described more fully below, we share information with our subsidiaries, and affiliated companies ("Karuizawa Affiliates"), for the purposes described in this Privacy Notice. By using the Karuizawa Services, you acknowledge you have read and accept this Privacy Notice.
Your decision to use the Karuizawa Services and provide your Personal Data is voluntary. We indicate on our online, mobile, and other registration forms what types of Personal Data are requested. You may choose not to submit requested information online, or may choose to restrict the use of cookies, but that may limit the services Karuizawa is able to provide to you.
The Karuizawa Services are not targeted to, and do not knowingly collect Personal Data from persons under legal age for consumption and purchase of alcoholic beverages, nor do we intentionally market alcoholic beverages to anyone under the legal purchase age, in each case as established under applicable law. We request that these individuals not to provide Personal Data through the Karuizawa Services.
2. WHAT WE COLLECT
Karuizawa and our service providers collect Personal Data to offer services you have requested or that we have a legitimate interest to believe are of interest to our customers, to manage the relationships we have with our customers and partners, and to perform activities based on your consent. Karuizawa and our service providers may collect the following information from and about you:
2.1 Personal Data
"Personal Data" for purposes of this Privacy Notice is the information that identifies you as an individual or relates to an identifiable person.
2.1.1 Personal Data You Submit
We collect Personal Data when you submit it to us, such as when you place an order; subscribe for newsletters or alerts; create a profile; participate in a sweepstakes, contest or game; take a survey; visit our Karuizawa Services; use an interactive feature (such as chat, chat bot or article sharing options); scan or use our QR codes; participate in a community forum; register for an event; or contact customer service. The Personal Data you submit may include your name, date of birth, postal address (including billing and shipping addresses), credit or debit card details, bank account details, telephone number, mobile number, email address, gender, username, or profile picture.
2.1.2 Personal Data We Receive From Third Parties
To the extent permitted by applicable law, we may receive Personal Data about you from third parties, such as social media services, commercially available sources, Karuizawa Affiliates, business partners, and, if applicable to you, the third party providers. The Personal Data we receive from third parties may include your name, contact information, information about your transactions, purchase history, or relationships with various product and service providers, and your use of certain applications. When you access the Karuizawa Services, you are authorizing Karuizawa to collect, store, and use such information and content in accordance with this Privacy Notice.
2.2 Other Information
"Other Information" is any information that is not intended to reveal your specific identity to us, such as browser information, usage data, information collected through cookies and other technologies, demographic information, geolocation data obtained with your consent where required by applicable law, and aggregated information.
2.2.1 Other Information You Submit
We collect Other Information when you submit it to us. This may include your password, birthday, education or graduation year, occupation, financial information (such as your income, investments, portfolio transactions and value, and other information) and interests. It will also include data about your orders and purchases, account preferences, payments to and from you.
2.2.2 Other Information We Receive From Third Parties
We may receive Other Information about you from third parties, including, for example, demographic data, social media account number, information about your interests, and information about your activities on other websites.
2.2.3 Other Information Collected Automatically
The Karuizawa Services may also be linked to sites or apps operated by third parties, and may carry advertisements or offer content, special offers, functionality or applications developed and maintained by third parties, using iframes, tools, or plug-ins (“Linked Services”). These third party Linked Services may use automated means to collect information about you and your use of these features. Some of these third party sites may be co-branded with a Karuizawa logo, even though they are not operated or maintained by us.
Karuizawa is not responsible for the privacy practices of such third parties, and once you leave the Karuizawa Services or click an advertisement, or sign up for a special offer, you should check the applicable third party privacy notice.
3. HOW WE USE YOUR PERSONAL DATA AND OTHER INFORMATION
We may use the Personal Data we collect from and about you for the purposes set forth below. We may use and disclose Other Information for any purpose, except if it is considered Personal Data under applicable law. If we combine Other Information with your Personal Data and the result is Personal Data under applicable law, we treat the combined information as Personal Data.
To improve the quality of our products and services and to personalize your experience by presenting content, products and offers tailored to you, we may also combine the Personal Data and Other Information we collect with information relating to your use of other Karuizawa products, services and websites. In addition, we may supplement the Personal Data and Other Information we collect with information from other sources, such as publicly available information from social media services, commercially available sources, and information from Karuizawa Affiliates or business partners.
Through third party analytics providers, ad networks, and advertisers, we can track your online activities over time and across third party websites, apps and devices, by obtaining information through automated means.
This information, along with information we gather when you log in, can be used to understand use across sites and devices to help improve our products, remember your preferences, provide content recommendations, and show you advertisements on the Karuizawa Services or other third party websites and apps that may be tailored to your individual interests.
3.1 To Provide, Measure And Improve Our Products And Services
We use the information we collect from and about you to provide our products, services and features to you, including: to process and fulfill your orders, to create and manage your accounts, to send you information about your relationship or transactions with us, to measure and improve our products, services and features, to allow you to engage with us (e.g., to comment on our products and services and participate in promotions, special events, rewards programs, surveys or market research), to use collaboration tools to share content and collaborate with other users, to conduct research for potential articles if you choose to respond to a survey, to provide you with customer support, which may include online chat or chat bot, and to respond to inquiries. If you choose to use the collaboration tools, some of your Personal Data may be included in a directory that can be viewed and used by other users of these collaboration tools.
3.2 To Deliver Relevant Content And Recommendations
To make your experience more interesting and personalized, we may use any of the Personal Data and Other Information we collect to assist us in delivering content and recommendations on any Karuizawa Services, as they develop from time to time.
3.3 To Deliver Advertising And Interest-Based Advertising
We may work with third party online advertising companies, advertisers and ad networks who deliver ads about products and services tailored to your individual interests to you. Any Personal Data or Other Information you provide us when using Karuizawa Services or another service provided by Karuizawa, Karuizawa Affiliates, or unaffiliated third parties may be used to help deliver these ads to you. These third parties may collect and use information about your activities on our Karuizawa Services and on other websites, and Other Information about you which may include offline purchases, to limit the online ads you encounter to those consistent with your interests.
To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising.
If you provide your mobile phone number to us, we may ask for your consent to receive text message alerts from us containing product, event, or promotional information in a text or SMS message (“Text Messages”). Your consent to receive Text Messages is not required to purchase goods or services from us.
3.4 To Allow Social Sharing Functionality
If you log in with or connect a social media service account with a Karuizawa Service, we may use Personal Data and Other Information to facilitate your sharing of information between the Karuizawa Services and your social media service.
3.5 To Contact You
Karuizawa and Karuizawa Affiliates may periodically send promotional materials, with your permission where required, surveys, market research, contest or promotional awards, or notifications related to our products and services. To help make these materials more relevant to you, we may use and combine any of the Personal Data and Other Information we collect to assist us in sending you these materials. We may also use your Personal Data to contact you, including to respond to your comments, inquiries or requests.
3.6 To Protect The Rights Of Karuizawa And Others
Karuizawa may use your Personal Data as we believe to be necessary or appropriate in order to: protect, enforce, or defend the legal rights, privacy, safety, or property of Karuizawa, our Karuizawa Affiliates or their employees, agents and contractors (including enforcement of our agreements and our terms of use); protect the safety, privacy, and security of users of our products and services or members of the public; protect against fraud and other unlawful activity or for risk management purposes; comply with and enforce the law or legal process, including laws outside your country of residence, contractual obligations, and our policies; or respond to requests from public and government authorities, including public and government authorities outside your country of residence, to the extent permitted by applicable law.
4. HOW WE SHARE YOUR PERSONAL DATA AND OTHER INFORMATION
4.1 Our Disclosure of Personal Data and Other Information
Karuizawa Distillers, Inc. and its subsidiaries may share your Personal Data with one another, as well as with Karuizawa Affiliates for the purposes described in this Privacy Notice, including for each company's marketing purposes if you have consented to such use. Users who use Karuizawa Affiliates’ services should still refer to their separate privacy policies, which may differ in some respects from this Privacy Notice.
In addition, we may share your Personal Data with non-affiliated third parties when sharing is permitted by you or authorized by this Privacy Notice, including:
4.1.1 To Manage Membership Accounts
If your membership of any club operated by Karuizawa is part of an arrangement with a third party (such as a membership held by you for the benefit of such third party), we may share with them information about your access to and use of your membership, including your name and contact information. We may similarly share such information of such third party with you.
4.1.2 To Allow Third-Party Service Providers To Assist Us In Providing and Managing Our Products and Services
We may make your Personal Data available to third party service providers, such as contractors, agents or sponsors, or Karuizawa Affiliates, who help us manage or provide our products and services by, for example: developing or supporting products and features; sending email messages on our behalf; processing payments; fulfilling orders; delivering subscriptions; auditing; processing data or statistics; serving, customizing or delivering marketing, warehousing and delivery; marketing and advertising; credit card and data processing; age verification; software development; website hosting and management; information technology and office services; legal, accounting, audit and other professional service providers; and other services relevant to our business.
These third party service providers are required to protect Personal Data entrusted to them and not use it for any other purpose than the specific service they are providing on our behalf.
4.1.3 To Provide Co-Branded Services And Features
We may offer co-branded services or features, such as conferences, events, contests, sweepstakes or other promotions together with a third party ("Co-Branded Services"). By virtue of these relationships, we may share the information you submit in connection with the Co-Branded Service with the third party. The third party's use of your information will be governed by the third party's privacy notice.
4.1.4 To Permit Unaffiliated Third Parties To Send Promotional Materials
We may, if you have opted-in (and not subsequently exercised any applicable rights to opt-out), share your contact information with unaffiliated third party companies whose products and services may be of interest to you.
4.1.5 To Allow Social Sharing Functionality
If you log in with or connect a social media service account with a Karuizawa Service, you are authorizing us to share information we collect from and about you with the social media service provider and other Karuizawa Services, and you understand that the social media service's use of the shared information will be governed by the social media service's privacy notice.
4.1.6 To Protect The Rights Of Karuizawa And Others
There may be instances when Karuizawa may disclose your Personal Data, including situations where we have a good faith belief that such disclosure is necessary in order to: protect, enforce, or defend the legal rights, privacy, safety, or property of Karuizawa, our Karuizawa Affiliates or their employees, agents and contractors (including enforcement of our agreements and our terms of use); protect the safety, privacy, and security of users of our products and services or members of the public; protect against fraud and other unlawful activity or for risk management purposes; comply with and enforce the law or legal process, including laws outside your country of residence, contractual obligations, and our policies; or respond to requests from public and government authorities, including public and government authorities outside your country of residence, to the extent permitted by applicable law.
4.1.7 To Complete A Merger, Sale Of Assets, Or Bankruptcy
If Karuizawa sells all or part of its business or assets, or is otherwise involved in a merger, reorganization, dissolution, liquidation, or transfer of all or part of its business, as part of that transaction Karuizawa may transfer your information to the party or parties and their advisors involved in the transaction.
4.2 Information Made Public Through Use of Our Services and User Privacy Settings
Certain features on the Karuizawa Services may give you an opportunity to interact with us and others. These may include the collaboration tools, community forums, chats, submitting a letter to the editor, creating community profiles, and rating, tagging, and commenting on articles. When you use these features, you should be aware that any information you choose to submit, including your name, user name, location, email address, profile information, picture or image, likes, status, and comments, including any political or religious or other beliefs you express, may be publicly available to anyone, including other users, search engines, advertisers, third party application developers, and anyone else with access to the Karuizawa Services. We are not responsible for any information you choose to submit and make public through these interactive features.
5. HOW WE PROTECT AND RETAIN PERSONAL DATA
Karuizawa uses a combination of administrative, technical, personnel and physical measures to safeguard Personal Data in its possession against accidental, unlawful or unauthorized loss, use, access, disclosure or modification. We make reasonable efforts to ensure a level of security appropriate to the risk of the processing, taking into account the costs of implementation and nature of the processing of Personal Data. However, no one can guarantee the complete safety of your information. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting Customer Service.
We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or allowed by law.
6. YOUR RIGHTS AND CHOICES
6.1 Your Choices Regarding Our Use and Disclosure of Your Personal Data
We give you many choices regarding our use and disclosure of your Personal Data for marketing purposes.
6.1.1 Direct Marketing From Karuizawa And Karuizawa Affiliates
We will ask you to opt in to receive electronic communications from us (including surveys, notifications, or promotions from us on behalf of third parties), or our sharing of your Personal Data with Karuizawa Affiliates for their direct marketing purposes, by notifying us. You can choose not to opt in, or subsequently choose to opt out of direct marketing from Karuizawa Affiliates subject to their applicable policies.
Please note that there are certain service notifications that you may not opt out of, such as renewal notices and notifications of changes to Karuizawa products and services or policies. For apps, you should be able to disable push notifications in settings on your device or through the app.
6.1.2 Direct Marketing From Unaffiliated Third Parties
We will ask you to opt in to our sharing of your contact information with unaffiliated third parties for their marketing.
6.1.3 To Opt Out Of Online Interest-Based Or Text Advertising
We will ask you to opt in to online interest-based advertising.
If you consented to receiving promotions or advertising via Text Message, you can unsubscribe from receiving Text Messages at any time by notifying us.
6.1.4 To Change Mobile App Privacy Settings
You may change the privacy settings for Karuizawa apps by accessing and updating privacy settings and permissions within the mobile app or on your mobile device.
6.2 How To Access, Correct or Update Your Personal Data
You can access, review, correct, update, delete or modify your profile information and modify your marketing preferences by contacting Customer Service. Please note that you may need to update your information for each Karuizawa Service separately.
If you are in the European Economic Area or Switzerland (collectively, “EEA”), you can also object to or restrict the processing of your Personal Data, or exercise your right to data portability. If you are in Nevada, you can also exercise your “Do Not Sell” right to opt out of interest-based advertising. For California residents, please see additional detail below in the California Privacy Rights section.
Where you have provided your consent for our use of your Personal Data, you have the right to withdraw your consent and we will apply your preferences going forward.
For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions you began prior to requesting such change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Data provided until after the completion of such purchase or promotion).
6.3 California Privacy Rights
6.3.1 California Shine the Light
Subject to certain limitations, California Law permits California residents to request certain information regarding our disclosure of Personal Data during the past 12 months to third parties for their own direct marketing purposes. To make such a request, California residents can write to us at privacypolicy@karuizawadistillers.com, Re: CA Shine the Light, and include your name and the address to which you would like us to respond.
6.3.2 California Consumer Privacy Act
The California Consumer Privacy Act of 2018 (“CCPA”) requires notice about certain issues, and provides specific rights to California residents, which are detailed below. Certain terms in this section have the meaning given to them in the CCPA.
6.3.2.1 CCPA Privacy Notice
The following chart lists the categories of Personal Data and Other Information (together, Personal Information as defined in the CCPA) we, in the past 12 months, may have collected from and about individuals who use our Services, sources of that information, purposes for which we may have used the information, and third parties with whom it may have been shared.
6.3.2.2 Notice of Financial Incentive
We may offer financial incentives to participate in certain surveys or focus groups. Details of the incentive, if applicable, including how to opt in or out and the basis for the value of the incentive, will be provided prior to your participation.
6.3.2.3 CCPA Privacy Rights
California residents may have certain rights under the CCPA, many of which are subject to limitations or exceptions under applicable law:
Right to Know
You may have the right to request the following information about the Personal Data or Other Information we may have collected about you during the past 12 months:
• the categories and specific pieces of Personal Data and Other Information we may have collected about you;
• the categories of sources from which we collected the Personal Data and Other Information;
• the business or commercial purpose for which we collected or sold the Personal Data and Other Information;
• the categories of third parties with whom we shared the Personal Data and Other Information; and
• the categories of Personal Data and Other Information we sold (per CCPA), or disclosed for a CCPA business or commercial purpose, and
• the categories of third parties to whom we sold (per CCPA), or disclosed for a CCPA business or commercial purpose, that information.
Right to Delete
You may have the right to request that we delete the Personal Data and Other Information we have collected from you. Certain information may be exempt from such requests under applicable law. In addition, we may need to retain certain information for recordkeeping purposes and/or to provide our Services to you. If you submit a request to delete, you may no longer be able to access or use our Services.
Right to Nondiscrimination
We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise CCPA Privacy Rights.
Do Not Sell/Right to Opt Out of Sale of Personal Data or Other Information
You have the right to opt out of the sale of your Personal Data and Other Information. Sale under California law may include sharing of Personal Data and Other Information with a third party for monetary or other consideration, such as allowing third parties to receive certain information including IP address and/or browsing behavior to deliver interest-based (also called targeted) advertising, or the sharing of a print mailing address with unaffiliated third party companies whose products and services may be of interest to you.
6.3.2.4 How to Exercise CCPA Privacy Rights
If you would like to exercise the Right to Know, Right to Delete, or Do Not Sell, please contact Customer Service.
For your protection, we may only implement requests with respect to the Personal Data or Other Information associated with the particular email(s) you provide in your Privacy Request, and we will take steps to verify your identity before granting access to your Personal Data or Other Information or complying with your Privacy Request. For example, we may verify your Privacy Request by matching information you provide with our records, or you may be asked to log in to your online account (if applicable). We may request additional information to verify your identity depending on the nature of the Privacy Request and the sensitivity of the information sought, if you do not have an account with us, or if we have reason to suspect the security of your account is compromised.
You can use an authorized agent to submit your Privacy Request. If you use an authorized agent, in addition to verifying the Privacy Request itself (see above), we will also verify the authorized agent’s ability to act on your behalf (they should submit written permission to act on your behalf or a power of attorney).
Once we have verified your identity (and your authorized agent, as applicable), we will respond to your Privacy Request as appropriate. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your Privacy Request. If we are unable to complete your Privacy Request in whole or in part, we will let you know why.
How We Have Responded to CCPA Privacy Requests
To learn how we responded to CCPA Privacy requests received during the prior calendar year, please contact Customer Service.
7. OTHER IMPORTANT INFORMATION
7.1 Updates to Privacy Notice
Karuizawa may periodically update this Privacy Notice without prior notice to reflect changes in our practices. Please look at the Effective Date at the top of this Privacy Notice to see when this Privacy Notice was last revised. Any changes to this Privacy Notice will become effective when we post the revised Privacy Notice on the Karuizawa Services. Your use of the Karuizawa Services or your provision of Personal Data to us following these changes means you acknowledge you have read and accept the revised Privacy Notice.
7.2 Do Not Track Disclosure
Since no technology standard for Do Not Track (“DNT”) signals has been developed or adopted to date, Karuizawa does not currently respond to DNT signals.
7.3 Transfers
Your Personal Data may be stored, transferred to, and processed in any country where we have facilities or in which we engage service providers. These countries may be outside your country of residence, including the Japan, and may have different data protection laws than in your country.
If you are located in the EEA, we will implement appropriate safeguards to protect your Personal Data as required if we transfer it outside the EEA.
7.4 Collection of Personal Financial Information by a Payment Service
In some cases, we may use an unaffiliated payment service to allow you to purchase a product or make payments (“Payment Service”). If you wish to purchase a product or make a payment in such a case, you will be directed to a Payment Service webpage. Any information that you provide to a Payment Service will be subject to the applicable Payment Service’s privacy notice, rather than this Privacy Notice. We have no control over, and are not responsible for, any Payment Service’s use of information collected through any Payment Service.
8. CONTACT US
If you have questions about this Privacy Notice or how we or our service providers handle your Personal Data, please contact our Data Protection Officer at kdiwsj@karuizawadistillers.com.
Or you may write to:
Attention: Privacy
Karuizawa Distillery, Inc.
Sanno Park Tower 3F
2-11-1 Nagata-cho, Chiyoda-ku , Tokyo
100-6103 Japan
If you are located in the EEA, the entity responsible for the collection and processing of Personal Data in connection with the Karuizawa Services is Karuizawa Distillery, Inc.
We will respond to your questions and complaints about our processing of your Personal Data. If you are not satisfied with our response, depending on where you are located you can contact a relevant supervisory authority. Please do not disclose any sensitive Personal Data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, or trade union membership), social security numbers, or criminal background information when contacting us.
Effective Date: June 24, 2021
1. INTRODUCTION
Karuizawa Distillers, Inc., and its subsidiaries ("Karuizawa") want you to be familiar with how we collect, use and disclose information from and about you because we respect your concerns about privacy, and we want to maintain your trust.
This Privacy Notice applies to information we collect from all sources, including in connection with our websites, mobile sites, applications ("apps"), widgets, conferences, events, and electronic newsletters or communications (collectively the "Karuizawa Services") that link to this Privacy Notice. If there is a conflict between this Notice and aspecific Karuizawa Services agreement, the Karuizawa Services agreement will take precedence.
This Notice describes the types of Personal Data we collect, how we use it, and with whom we share it. It also describes generally Karuizawa's practices for handling Other Information (e.g., interests, demographics and services usage) collected through our Karuizawa Services or from a third party to the extent such information is associated with a particular device, user or user account. We also describe the measures we take to protect the information, your options for choice and access, and how you can contact us about privacy practices. As described more fully below, we share information with our subsidiaries, and affiliated companies ("Karuizawa Affiliates"), for the purposes described in this Privacy Notice. By using the Karuizawa Services, you acknowledge you have read and accept this Privacy Notice.
Your decision to use the Karuizawa Services and provide your Personal Data is voluntary. We indicate on our online, mobile, and other registration forms what types of Personal Data are requested. You may choose not to submit requested information online, or may choose to restrict the use of cookies, but that may limit the services Karuizawa is able to provide to you.
The Karuizawa Services are not targeted to, and do not knowingly collect Personal Data from persons under legal age for consumption and purchase of alcoholic beverages, nor do we intentionally market alcoholic beverages to anyone under the legal purchase age, in each case as established under applicable law. We request that these individuals not to provide Personal Data through the Karuizawa Services.
2. WHAT WE COLLECT
Karuizawa and our service providers collect Personal Data to offer services you have requested or that we have a legitimate interest to believe are of interest to our customers, to manage the relationships we have with our customers and partners, and to perform activities based on your consent. Karuizawa and our service providers may collect the following information from and about you:
2.1 Personal Data
"Personal Data" for purposes of this Privacy Notice is the information that identifies you as an individual or relates to an identifiable person.
2.1.1 Personal Data You Submit
We collect Personal Data when you submit it to us, such as when you place an order; subscribe for newsletters or alerts; create a profile; participate in a sweepstakes, contest or game; take a survey; visit our Karuizawa Services; use an interactive feature (such as chat, chat bot or article sharing options); scan or use our QR codes; participate in a community forum; register for an event; or contact customer service. The Personal Data you submit may include your name, date of birth, postal address (including billing and shipping addresses), credit or debit card details, bank account details, telephone number, mobile number, email address, gender, username, or profile picture.
2.1.2 Personal Data We Receive From Third Parties
To the extent permitted by applicable law, we may receive Personal Data about you from third parties, such as social media services, commercially available sources, Karuizawa Affiliates, business partners, and, if applicable to you, the third party providers. The Personal Data we receive from third parties may include your name, contact information, information about your transactions, purchase history, or relationships with various product and service providers, and your use of certain applications. When you access the Karuizawa Services, you are authorizing Karuizawa to collect, store, and use such information and content in accordance with this Privacy Notice.
2.2 Other Information
"Other Information" is any information that is not intended to reveal your specific identity to us, such as browser information, usage data, information collected through cookies and other technologies, demographic information, geolocation data obtained with your consent where required by applicable law, and aggregated information.
2.2.1 Other Information You Submit
We collect Other Information when you submit it to us. This may include your password, birthday, education or graduation year, occupation, financial information (such as your income, investments, portfolio transactions and value, and other information) and interests. It will also include data about your orders and purchases, account preferences, payments to and from you.
2.2.2 Other Information We Receive From Third Parties
We may receive Other Information about you from third parties, including, for example, demographic data, social media account number, information about your interests, and information about your activities on other websites.
2.2.3 Other Information Collected Automatically
The Karuizawa Services may also be linked to sites or apps operated by third parties, and may carry advertisements or offer content, special offers, functionality or applications developed and maintained by third parties, using iframes, tools, or plug-ins (“Linked Services”). These third party Linked Services may use automated means to collect information about you and your use of these features. Some of these third party sites may be co-branded with a Karuizawa logo, even though they are not operated or maintained by us.
Karuizawa is not responsible for the privacy practices of such third parties, and once you leave the Karuizawa Services or click an advertisement, or sign up for a special offer, you should check the applicable third party privacy notice.
3. HOW WE USE YOUR PERSONAL DATA AND OTHER INFORMATION
We may use the Personal Data we collect from and about you for the purposes set forth below. We may use and disclose Other Information for any purpose, except if it is considered Personal Data under applicable law. If we combine Other Information with your Personal Data and the result is Personal Data under applicable law, we treat the combined information as Personal Data.
To improve the quality of our products and services and to personalize your experience by presenting content, products and offers tailored to you, we may also combine the Personal Data and Other Information we collect with information relating to your use of other Karuizawa products, services and websites. In addition, we may supplement the Personal Data and Other Information we collect with information from other sources, such as publicly available information from social media services, commercially available sources, and information from Karuizawa Affiliates or business partners.
Through third party analytics providers, ad networks, and advertisers, we can track your online activities over time and across third party websites, apps and devices, by obtaining information through automated means.
This information, along with information we gather when you log in, can be used to understand use across sites and devices to help improve our products, remember your preferences, provide content recommendations, and show you advertisements on the Karuizawa Services or other third party websites and apps that may be tailored to your individual interests.
3.1 To Provide, Measure And Improve Our Products And Services
We use the information we collect from and about you to provide our products, services and features to you, including: to process and fulfill your orders, to create and manage your accounts, to send you information about your relationship or transactions with us, to measure and improve our products, services and features, to allow you to engage with us (e.g., to comment on our products and services and participate in promotions, special events, rewards programs, surveys or market research), to use collaboration tools to share content and collaborate with other users, to conduct research for potential articles if you choose to respond to a survey, to provide you with customer support, which may include online chat or chat bot, and to respond to inquiries. If you choose to use the collaboration tools, some of your Personal Data may be included in a directory that can be viewed and used by other users of these collaboration tools.
3.2 To Deliver Relevant Content And Recommendations
To make your experience more interesting and personalized, we may use any of the Personal Data and Other Information we collect to assist us in delivering content and recommendations on any Karuizawa Services, as they develop from time to time.
3.3 To Deliver Advertising And Interest-Based Advertising
We may work with third party online advertising companies, advertisers and ad networks who deliver ads about products and services tailored to your individual interests to you. Any Personal Data or Other Information you provide us when using Karuizawa Services or another service provided by Karuizawa, Karuizawa Affiliates, or unaffiliated third parties may be used to help deliver these ads to you. These third parties may collect and use information about your activities on our Karuizawa Services and on other websites, and Other Information about you which may include offline purchases, to limit the online ads you encounter to those consistent with your interests.
To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising.
If you provide your mobile phone number to us, we may ask for your consent to receive text message alerts from us containing product, event, or promotional information in a text or SMS message (“Text Messages”). Your consent to receive Text Messages is not required to purchase goods or services from us.
3.4 To Allow Social Sharing Functionality
If you log in with or connect a social media service account with a Karuizawa Service, we may use Personal Data and Other Information to facilitate your sharing of information between the Karuizawa Services and your social media service.
3.5 To Contact You
Karuizawa and Karuizawa Affiliates may periodically send promotional materials, with your permission where required, surveys, market research, contest or promotional awards, or notifications related to our products and services. To help make these materials more relevant to you, we may use and combine any of the Personal Data and Other Information we collect to assist us in sending you these materials. We may also use your Personal Data to contact you, including to respond to your comments, inquiries or requests.
3.6 To Protect The Rights Of Karuizawa And Others
Karuizawa may use your Personal Data as we believe to be necessary or appropriate in order to: protect, enforce, or defend the legal rights, privacy, safety, or property of Karuizawa, our Karuizawa Affiliates or their employees, agents and contractors (including enforcement of our agreements and our terms of use); protect the safety, privacy, and security of users of our products and services or members of the public; protect against fraud and other unlawful activity or for risk management purposes; comply with and enforce the law or legal process, including laws outside your country of residence, contractual obligations, and our policies; or respond to requests from public and government authorities, including public and government authorities outside your country of residence, to the extent permitted by applicable law.
4. HOW WE SHARE YOUR PERSONAL DATA AND OTHER INFORMATION
4.1 Our Disclosure of Personal Data and Other Information
Karuizawa Distillers, Inc. and its subsidiaries may share your Personal Data with one another, as well as with Karuizawa Affiliates for the purposes described in this Privacy Notice, including for each company's marketing purposes if you have consented to such use. Users who use Karuizawa Affiliates’ services should still refer to their separate privacy policies, which may differ in some respects from this Privacy Notice.
In addition, we may share your Personal Data with non-affiliated third parties when sharing is permitted by you or authorized by this Privacy Notice, including:
4.1.1 To Manage Membership Accounts
If your membership of any club operated by Karuizawa is part of an arrangement with a third party (such as a membership held by you for the benefit of such third party), we may share with them information about your access to and use of your membership, including your name and contact information. We may similarly share such information of such third party with you.
4.1.2 To Allow Third-Party Service Providers To Assist Us In Providing and Managing Our Products and Services
We may make your Personal Data available to third party service providers, such as contractors, agents or sponsors, or Karuizawa Affiliates, who help us manage or provide our products and services by, for example: developing or supporting products and features; sending email messages on our behalf; processing payments; fulfilling orders; delivering subscriptions; auditing; processing data or statistics; serving, customizing or delivering marketing, warehousing and delivery; marketing and advertising; credit card and data processing; age verification; software development; website hosting and management; information technology and office services; legal, accounting, audit and other professional service providers; and other services relevant to our business.
These third party service providers are required to protect Personal Data entrusted to them and not use it for any other purpose than the specific service they are providing on our behalf.
4.1.3 To Provide Co-Branded Services And Features
We may offer co-branded services or features, such as conferences, events, contests, sweepstakes or other promotions together with a third party ("Co-Branded Services"). By virtue of these relationships, we may share the information you submit in connection with the Co-Branded Service with the third party. The third party's use of your information will be governed by the third party's privacy notice.
4.1.4 To Permit Unaffiliated Third Parties To Send Promotional Materials
We may, if you have opted-in (and not subsequently exercised any applicable rights to opt-out), share your contact information with unaffiliated third party companies whose products and services may be of interest to you.
4.1.5 To Allow Social Sharing Functionality
If you log in with or connect a social media service account with a Karuizawa Service, you are authorizing us to share information we collect from and about you with the social media service provider and other Karuizawa Services, and you understand that the social media service's use of the shared information will be governed by the social media service's privacy notice.
4.1.6 To Protect The Rights Of Karuizawa And Others
There may be instances when Karuizawa may disclose your Personal Data, including situations where we have a good faith belief that such disclosure is necessary in order to: protect, enforce, or defend the legal rights, privacy, safety, or property of Karuizawa, our Karuizawa Affiliates or their employees, agents and contractors (including enforcement of our agreements and our terms of use); protect the safety, privacy, and security of users of our products and services or members of the public; protect against fraud and other unlawful activity or for risk management purposes; comply with and enforce the law or legal process, including laws outside your country of residence, contractual obligations, and our policies; or respond to requests from public and government authorities, including public and government authorities outside your country of residence, to the extent permitted by applicable law.
4.1.7 To Complete A Merger, Sale Of Assets, Or Bankruptcy
If Karuizawa sells all or part of its business or assets, or is otherwise involved in a merger, reorganization, dissolution, liquidation, or transfer of all or part of its business, as part of that transaction Karuizawa may transfer your information to the party or parties and their advisors involved in the transaction.
4.2 Information Made Public Through Use of Our Services and User Privacy Settings
Certain features on the Karuizawa Services may give you an opportunity to interact with us and others. These may include the collaboration tools, community forums, chats, submitting a letter to the editor, creating community profiles, and rating, tagging, and commenting on articles. When you use these features, you should be aware that any information you choose to submit, including your name, user name, location, email address, profile information, picture or image, likes, status, and comments, including any political or religious or other beliefs you express, may be publicly available to anyone, including other users, search engines, advertisers, third party application developers, and anyone else with access to the Karuizawa Services. We are not responsible for any information you choose to submit and make public through these interactive features.
5. HOW WE PROTECT AND RETAIN PERSONAL DATA
Karuizawa uses a combination of administrative, technical, personnel and physical measures to safeguard Personal Data in its possession against accidental, unlawful or unauthorized loss, use, access, disclosure or modification. We make reasonable efforts to ensure a level of security appropriate to the risk of the processing, taking into account the costs of implementation and nature of the processing of Personal Data. However, no one can guarantee the complete safety of your information. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting Customer Service.
We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or allowed by law.
6. YOUR RIGHTS AND CHOICES
6.1 Your Choices Regarding Our Use and Disclosure of Your Personal Data
We give you many choices regarding our use and disclosure of your Personal Data for marketing purposes.
6.1.1 Direct Marketing From Karuizawa And Karuizawa Affiliates
We will ask you to opt in to receive electronic communications from us (including surveys, notifications, or promotions from us on behalf of third parties), or our sharing of your Personal Data with Karuizawa Affiliates for their direct marketing purposes, by notifying us. You can choose not to opt in, or subsequently choose to opt out of direct marketing from Karuizawa Affiliates subject to their applicable policies.
Please note that there are certain service notifications that you may not opt out of, such as renewal notices and notifications of changes to Karuizawa products and services or policies. For apps, you should be able to disable push notifications in settings on your device or through the app.
6.1.2 Direct Marketing From Unaffiliated Third Parties
We will ask you to opt in to our sharing of your contact information with unaffiliated third parties for their marketing.
6.1.3 To Opt Out Of Online Interest-Based Or Text Advertising
We will ask you to opt in to online interest-based advertising.
If you consented to receiving promotions or advertising via Text Message, you can unsubscribe from receiving Text Messages at any time by notifying us.
6.1.4 To Change Mobile App Privacy Settings
You may change the privacy settings for Karuizawa apps by accessing and updating privacy settings and permissions within the mobile app or on your mobile device.
6.2 How To Access, Correct or Update Your Personal Data
You can access, review, correct, update, delete or modify your profile information and modify your marketing preferences by contacting Customer Service. Please note that you may need to update your information for each Karuizawa Service separately.
If you are in the European Economic Area or Switzerland (collectively, “EEA”), you can also object to or restrict the processing of your Personal Data, or exercise your right to data portability. If you are in Nevada, you can also exercise your “Do Not Sell” right to opt out of interest-based advertising. For California residents, please see additional detail below in the California Privacy Rights section.
Where you have provided your consent for our use of your Personal Data, you have the right to withdraw your consent and we will apply your preferences going forward.
For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions you began prior to requesting such change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Data provided until after the completion of such purchase or promotion).
6.3 California Privacy Rights
6.3.1 California Shine the Light
Subject to certain limitations, California Law permits California residents to request certain information regarding our disclosure of Personal Data during the past 12 months to third parties for their own direct marketing purposes. To make such a request, California residents can write to us at privacypolicy@karuizawadistillers.com, Re: CA Shine the Light, and include your name and the address to which you would like us to respond.
6.3.2 California Consumer Privacy Act
The California Consumer Privacy Act of 2018 (“CCPA”) requires notice about certain issues, and provides specific rights to California residents, which are detailed below. Certain terms in this section have the meaning given to them in the CCPA.
6.3.2.1 CCPA Privacy Notice
The following chart lists the categories of Personal Data and Other Information (together, Personal Information as defined in the CCPA) we, in the past 12 months, may have collected from and about individuals who use our Services, sources of that information, purposes for which we may have used the information, and third parties with whom it may have been shared.
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* Select third parties use Advertising Cookies to choose and deliver ads that aim to be relevant to you and your interests, understand their effectiveness, and conduct market research. This involves accessing information from your browser or device, such as advertising and device identifiers, and processing this and other Personal Data such as IP address. Advertising Cookies remember what you have looked at or purchased on our Services and other sites over time, and may be combined with other information received from third parties such as demographics. ** We may share your contact information with unaffiliated third party companies whose products and services may be of interest to you. |
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6.3.2.2 Notice of Financial Incentive
We may offer financial incentives to participate in certain surveys or focus groups. Details of the incentive, if applicable, including how to opt in or out and the basis for the value of the incentive, will be provided prior to your participation.
6.3.2.3 CCPA Privacy Rights
California residents may have certain rights under the CCPA, many of which are subject to limitations or exceptions under applicable law:
Right to Know
You may have the right to request the following information about the Personal Data or Other Information we may have collected about you during the past 12 months:
• the categories and specific pieces of Personal Data and Other Information we may have collected about you;
• the categories of sources from which we collected the Personal Data and Other Information;
• the business or commercial purpose for which we collected or sold the Personal Data and Other Information;
• the categories of third parties with whom we shared the Personal Data and Other Information; and
• the categories of Personal Data and Other Information we sold (per CCPA), or disclosed for a CCPA business or commercial purpose, and
• the categories of third parties to whom we sold (per CCPA), or disclosed for a CCPA business or commercial purpose, that information.
Right to Delete
You may have the right to request that we delete the Personal Data and Other Information we have collected from you. Certain information may be exempt from such requests under applicable law. In addition, we may need to retain certain information for recordkeeping purposes and/or to provide our Services to you. If you submit a request to delete, you may no longer be able to access or use our Services.
Right to Nondiscrimination
We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise CCPA Privacy Rights.
Do Not Sell/Right to Opt Out of Sale of Personal Data or Other Information
You have the right to opt out of the sale of your Personal Data and Other Information. Sale under California law may include sharing of Personal Data and Other Information with a third party for monetary or other consideration, such as allowing third parties to receive certain information including IP address and/or browsing behavior to deliver interest-based (also called targeted) advertising, or the sharing of a print mailing address with unaffiliated third party companies whose products and services may be of interest to you.
6.3.2.4 How to Exercise CCPA Privacy Rights
If you would like to exercise the Right to Know, Right to Delete, or Do Not Sell, please contact Customer Service.
For your protection, we may only implement requests with respect to the Personal Data or Other Information associated with the particular email(s) you provide in your Privacy Request, and we will take steps to verify your identity before granting access to your Personal Data or Other Information or complying with your Privacy Request. For example, we may verify your Privacy Request by matching information you provide with our records, or you may be asked to log in to your online account (if applicable). We may request additional information to verify your identity depending on the nature of the Privacy Request and the sensitivity of the information sought, if you do not have an account with us, or if we have reason to suspect the security of your account is compromised.
You can use an authorized agent to submit your Privacy Request. If you use an authorized agent, in addition to verifying the Privacy Request itself (see above), we will also verify the authorized agent’s ability to act on your behalf (they should submit written permission to act on your behalf or a power of attorney).
Once we have verified your identity (and your authorized agent, as applicable), we will respond to your Privacy Request as appropriate. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your Privacy Request. If we are unable to complete your Privacy Request in whole or in part, we will let you know why.
How We Have Responded to CCPA Privacy Requests
To learn how we responded to CCPA Privacy requests received during the prior calendar year, please contact Customer Service.
7. OTHER IMPORTANT INFORMATION
7.1 Updates to Privacy Notice
Karuizawa may periodically update this Privacy Notice without prior notice to reflect changes in our practices. Please look at the Effective Date at the top of this Privacy Notice to see when this Privacy Notice was last revised. Any changes to this Privacy Notice will become effective when we post the revised Privacy Notice on the Karuizawa Services. Your use of the Karuizawa Services or your provision of Personal Data to us following these changes means you acknowledge you have read and accept the revised Privacy Notice.
7.2 Do Not Track Disclosure
Since no technology standard for Do Not Track (“DNT”) signals has been developed or adopted to date, Karuizawa does not currently respond to DNT signals.
7.3 Transfers
Your Personal Data may be stored, transferred to, and processed in any country where we have facilities or in which we engage service providers. These countries may be outside your country of residence, including the Japan, and may have different data protection laws than in your country.
If you are located in the EEA, we will implement appropriate safeguards to protect your Personal Data as required if we transfer it outside the EEA.
7.4 Collection of Personal Financial Information by a Payment Service
In some cases, we may use an unaffiliated payment service to allow you to purchase a product or make payments (“Payment Service”). If you wish to purchase a product or make a payment in such a case, you will be directed to a Payment Service webpage. Any information that you provide to a Payment Service will be subject to the applicable Payment Service’s privacy notice, rather than this Privacy Notice. We have no control over, and are not responsible for, any Payment Service’s use of information collected through any Payment Service.
8. CONTACT US
If you have questions about this Privacy Notice or how we or our service providers handle your Personal Data, please contact our Data Protection Officer at kdiwsj@karuizawadistillers.com.
Or you may write to:
Attention: Privacy
Karuizawa Distillery, Inc.
Sanno Park Tower 3F
2-11-1 Nagata-cho, Chiyoda-ku , Tokyo
100-6103 Japan
If you are located in the EEA, the entity responsible for the collection and processing of Personal Data in connection with the Karuizawa Services is Karuizawa Distillery, Inc.
We will respond to your questions and complaints about our processing of your Personal Data. If you are not satisfied with our response, depending on where you are located you can contact a relevant supervisory authority. Please do not disclose any sensitive Personal Data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, or trade union membership), social security numbers, or criminal background information when contacting us.
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