1. Processing Personal data, etc.
- “Personal data” means any data relating to an identified or identifiable natural person, including, without limitation, names, addresses, dates of birth, telephone numbers, e-mail addresses, and any other information collected in connection with operation of the Website.
- “Processing” means any operation or set of operations which is performed on personal data, etc. or on sets of personal data, etc., whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- （2）Purposes of use of personal data, etc.
- The Company may collect the following personal data about Customers:
- - Personal data acquired from e-commerce transactions
- - Personal data acquired from promotional activities or surveys of purchasing behaviors
- - Personal data received from users of our golf course（s）
- - Personal data required from inquiry forms or other Q&A processes
- - Personal data acquired through transactions or business contracts
- - Personal data received via recruiting procedures
- - Other data concerning the Customers’ use of the Website（e.g. cookies）
The Company will process the Customers’ personal data only for the following purposes of use:
- - Delivering merchandise or documents from our e-commerce businesses, or notifications of new items, publications or services
- - Delivering giveaways or presents from consumer promotional activities
- - Invitation of surveys for product development, marketing strategy or other consumer-related research
- - Sending information about promotional activities or new merchandise via e-mail
- - Recognizing members on websites where membership is a requirement
- - Sending discount information or membership newsletters from our golf course（s）
- - Responding to inquiries, questions or other forms which requires personal information input
- - Analyzing the effectiveness of advertising, conducting a market analysis and marketing
- - Sending invitations, notifications or other documents to transaction partner representatives
- - Sending notifications or results of recruiting activities
- - All other purposes, with previous consent from the owner of personal information
In the case of processing the Customers’ personal data for purposes other than the above, The Company will notify Customers in advance of such new purposes of use and other matters as required by applicable laws.
We will process personal data concerning the Customers to the minimum extent necessary for us to achieve the purposes of use above. Therefore, we have a legitimate interest in processing such personal data for such purposes. In addition, in some cases, the Company will process the Customers’ personal data based on such Customers’ consent; provided, however, that Customers may withdraw such consent at any time. Even in that case, this will not affect the lawfulness of processing performed pursuant to consent before the Customers’ withdrawal thereof.
- （4）Retention Period
- The Company will retain the Customers’ personal data as long as the Company requires such data for achieving the purposes of use specified above. Therefore, the personal data concerning Customers will not be stored in the Company’s server and be deleted immediately after the providing Customers with the location information of the shops.
- Except for the previously mentioned purposes, the Company will never reveal or provide the Customers’ personal date to other third parties without the Customers’ consent. However, based on the reasons below, the Company owns the right to reveal or provide the Customers’ personal date without the Customers’ prior agreement:
（a）When requested by law,
（b）On occasions where prior agreement is hard to reach and lives, health or properties of others are in imminent danger,
（c）Under legal request of local or central authorities, when getting consent from the Customers may significantly impact the execution of critical issues,
（d）When the Customers’ inquiry is considered proper to be dealt with by other related parties or shops that represent the Company.
- （6）Rights of Customers
- The Customers may have the rights allowed in accordance with the applicable laws. For example, the Customers may request from the Company access to, rectification or erasure of, and restriction of processing of their personal data, may object to the processing of the Customers’ personal data, and may request data portability. The Company accepts such Customers’ requests at the contact point set forth in “3. Contact” below.
The Company may refuse the Customers’ requests if the Company deems that there is no basis for such Customers’ requests or if they are deemed excessive.
The Customers may raise objections with the data protection authorities having jurisdiction over the location of the Customers’ domicile with regard to the processing of their personal data.
2. Safety Management Measures
In order to protect from unauthorized access to personal data, loss, etc. of personal data, taking into account the type of personal data, the degree of sensitivity and the degree of economic influence and mental harm caused to Customers in the case of a personal data breach, the Company comprehensively evaluates and judges the risks of personal data breaches, implements appropriate personal, organizational and technical safety management measures based on the risk of a personal data breach, if necessary, checks such safety management measures, sets up a process for correction, and constantly strives to improve security.
The Company shall strive to appropriately manage personal data by restricting the entry of outsiders into the offices which are processing personal data, conducting educational awareness activities for all officers and employees involved in the protection of personal data, and placing a manager in charge for each division processing personal data.
The contact information for the Company is as follows:
<MORINAGA & CO., LTD.>
33-1, SHIBA 5-CHOME, MINATO-KU, TOKYO 108-8403 JAPAN