Date of Enactment: Nov. 11, 2024

TOKAI RIKA CO., LTD. (hereinafter referred to as the “Company” or “we”) has established this privacy policy (hereinafter referred to as this “Policy”) regarding the handling of customer information provided to the Company when a customer (hereinafter referred to as the “Customer” or “you”) uses certain services provided by ZENAIM (hereinafter referred to as the “Service”).

You must agree to this Policy before you use the Service. This Policy is an agreement between each Customer and the Company and applies to all the Customers using the Service.

Please read all of the following terms of this Policy carefully before accepting this Policy. In addition, to use the Service, you must agree to the Terms and Conditions, which are separately specified by the Company, and this Policy constitutes a part of such Terms and Conditions.

If you are under the age of 13, you cannot agree to this Policy by yourself and your legal representative, such as a person with parental authority, must agree to this Policy on your behalf.

The scope of this Policy applies only to the Service. Please check the privacy policy of the linked website for the handling of Customer information on the websites of other businesses, excluding outsourcing contractors, that are linked to our website.

1. Source of Customer information

We obtain your information in a variety of ways: (i) The customer himself / herself; (ii) trusted suppliers (e.g., payment providers, marketing agencies); (iii) IT systems, including via the Company’s platform; (iv) cookies on the Company’s website; (v) IT service providers.

2 . Customer information we obtain

2 .1 Customer information we obtain when you create an account

We obtain the information you provide when you create a ZENAIM account. This includes an email address, and password.

2 .2 Customer information about purchase

We may obtain your name, address, product delivery address, telephone number, credit card information and other payment information, and information related to purchased products and services.

2 .3 Customer information we obtain when you use the Service

We may obtain information such as email addresses, passwords, product names, serial numbers, USB device information, firmware versions, and on-board memory information.

2 .4 Customer information about your activities on the Services

We may obtain information such as your service usage history, software usage history, email opening history and linked site browsing information that we distribute to you, and responses to questionnaires that we distribute to you.

2 .5 Customer information about your inquiry

We may obtain information such as your name, email address, mailing address, telephone number, inquiry details, product name, serial number, order number, shipping number, date of purchase, and shipping address information.

2 .6 Cookies

We may use cookies (including similar technologies) when you access the Service. Cookies are small data files that are downloaded to your information terminal and are used to enable

the Service to function securely and smoothly and to allow us to obtain information about your preferences.

3 . Providing Customer information to third parties

We do not sell your personal data.

We may share your personal data with your consent or to complete a transaction or to provide you with a product or service that you have requested or authorized. We also share personal data among our affiliates and subsidiaries under our control for the purposes described in this Policy and where required by law.

We may share personal data with vendors or agents who work on our behalf for the purposes described in this Policy. These companies must comply with our data protection and security requirements and may not use the personal data they receive from us for any other purpose.

The Company will appropriately manage the collected customer information and will not share or disclose it to third parties without the prior consent of the customer, except in the following cases:

• When outsourcing within the scope necessary to achieve the purpose of use;
• To comply with the law or respond to legal process, such as national security requirements, law enforcement, or other government agencies;
• When it is necessary to protect the life, body or property of a person, or when it is necessary to prevent spamming attempts to defraud our users, and it is difficult to obtain the consent of the person in question.;
• When it is particularly necessary to improve public health or promote the sound growth of children and it is difficult to obtain the consent of the Customer; and
• When it is necessary to cooperate with a national or local government or its subcontractors in the performance of their legally prescribed duties and obtaining the consent of the Customer may impede the performance of those duties.
• Information you provide to third parties; 

We are not responsible for any information you provide to third parties, and that information is not covered by this Policy. You are solely responsible for any privacy, security, and other risks associated with providing any information, including personal information, to third parties. In order to understand the privacy practices of third parties, you should refer to the privacy policies of third parties, if any.

4. Purpose of use of your information

We use the information specified in “3 . Customer information we obtain” for the following purposes:

1. To sell products and provide the Service;

2. To provide information on events, seminars, campaigns, special offers, questionnaires, and other various plans, and to implement such plans;

3. To analyze your registration information (including your area of residence), history of comments and inquiries, product device identifiers, product usage history (including website viewing history and app usage history), and service usage history (website viewing history, purchase history, and app usage history), and to conduct advertising and promotion about products and services (including digital marketing such as the distribution of advertisements);

4. To advise on the purchase of products and services and to suggest for related products and services;

5. To provide after-sales support related to products and services, including product warranties, replacements and repairs;

6. To respond to customer comments, requests, inquiries, etc.;

7. To issue member IDs and to provide services using member IDs for personal authentication;

8. To settle related to products, services and after-sales support provided in accordance with the Purpose 5 mentioned above;

9. To develop future products and services and to improve and enhance products and services and their sales activities;

10. To analyze and implement information security measures as we deem necessary to identify potential information security threats and protect you and us from such threats;

11. To analyze and implement countermeasures as we deem necessary to identify threats of unauthorized use of credit cards or other payment instruments by third parties, and protect you and us from such threats; and

12. To prepare statistical data. 

5. Transfer of Customer information out of the country

When we transfer your information outside of a country, we will take steps to ensure that your personal data is adequately protected.

6 . Management of contractors handling Customer information

To facilitate the smooth operation of our business, we may outsource a part of our business and provide the outsourced company with Customer information to the extent necessary to achieve the purpose of use, which has been specified in advance. In such cases, we will require such outsourced company to handle the Customer information provided by us in an appropriate manner and manage it appropriately.

7. Retention of Customer information

We will retain your information only for as long as necessary to accomplish the relevant purposes set forth in this Policy.

8. Automated decision making

Automated decision-making refers to situations in which decisions are made using personal data that is processed solely by automatic means (i.e., using algorithms or other computer software) rather than decisions made with some form of human involvement. We use your information to divide large groups of Customers into subgroups of Customers (known as segments) based on some shared characteristic, such as geography or behavior. We use segmentation and/or Customer-specific personal data to make automated decisions and provide specific information and benefits based on Customer characteristics.

9 . Customer’s rights to information

9 .1 Disclosure of Customer’s personal information

When a Customer requests disclosure of his/her personal information held by us, we will disclose it to the Customer without delay after confirming that the request was made by the Customer himself/herself (if such personal information does not exist, we will notify the Customer to that effect). However, this does not apply to the extent that we are not required to disclose the information under federal and state privacy laws.

9 .2 Correction and Suspension of Use of Customer’s Personal Information

When we receive a request from a customer for correction, we will conduct the necessary investigation without delay after confirming that the request is made by the Customer himself/herself. Based on the results we will conduct Correction, etc. or suspension of use of such Customer’s personal information, and notify the Customer to that effect (if we decide not to conduct such Correction etc. or suspension of use, we will notify the Customer of such decision). However, this does not apply in cases where the Company is not obligated to correct or suspend use under federal law or state laws regarding the protection of personal information.

9 .3 Deletion of your personal information

If the Company is requested by a customer to delete the information, the Company will conduct the necessary investigation without delay after confirming that the request is made by the customer himself/herself, and based on the results, will appropriately delete the personal information in a form that cannot be restored.

10. Cookies and online identifier information

10 .1 Disabling cookies

You may set your browser to disable cookies or to warn you when cookies are sent, but if you disable cookies, you may not be able to use some or all the features of the Service.

10.2 Disabling analysis tools

We may use cookies and mobile device identifiers (including similar technologies) to obtain information from you in accordance with this Policy. For such purposes, we may ask the provider of the analytical tool to provide us with information that cannot be personally identifiable by itself, and such information will be handled in accordance with the privacy policy or other provisions established by the provider of the analysis tool. You may, except in cases of natural or technical difficulties, stop the provision of your information to the provider of the analysis tool by any means provided by us or the provider of the analysis tool (including the following methods).Google Analytics

Provided by: Google
How cookies are collected and used: stipulated on Google’s page
How to disable cookie collection: see Google Analytics Opt-Out Add-on, Google’s ad display settings or in-app settings.

［Purpose of use]

To improve our Services

To investigate the number of users and traffic of our Services

To develop and deploy new products and services.

11 . Safety management

We shall, in accordance with the provisions of the laws, take necessary and appropriate measures to control access to the Customer information, limit the means of transfer of the Customer information, prevent unauthorized access from outside, prevent leakage, loss, or damage of the Customer information, and otherwise safely manage the Customer information.

12 . Name, address, and name of representative of the person responsible for the management of personal information and the Personal Information protection officer

Name: TOKAI RIKA CO., LTD.

Address: 3-260, Toyota, Oguchi-cho, Niwa-gun, Aichi, 480-0195, Japan

Representative: Hiroyoshi Ninoyu, President and Representative Director

Personal Information Protection Officer: Sumikazu Sasaki, [General Manager], Corporate Group

Business Manager of the Service: Masahiko Sato, Executive Vice President and Director

13 . Contact for inquiries

For inquiries about this policy and how we handle your information, please refer to this page of Customer Inquiries (https://zenaim.com/en/pages/contact).

14 . Revisions to this Policy

The Company reserves the right to change this Policy at any time. The revised Policy will be posted on the Company’s website and will become effective from the time it is posted. Please check the latest Policy from time to time when using the Service.

If the Company makes any revisions that require the consent of the customer, the Company will obtain the customer's consent in a manner specified by the Company.

ZENAIM Privacy Policy (USA)

Privacy Policy for California Residents

Information Collected by the Company

The following table shows the personal information of Customers that has been collected within the past 12 months. 

Childrens’ Information

Our services are not directed to children under 13 years old, and we do not knowingly collect personal information from children. If you are a parent or guardian and believe we have collected personal information from children, please contact us as set out in the Contact Information. We will delete the personal information. The Company does not sell or share any personal information of any Customers we know to be under the age of 16.

Security

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

Consumer’s Rights under the CCPA

The California Consumer Privacy Act (hereinafter referred to as this “CCPA”) grants specific rights regarding personal information to the Customers.

1.1 Right to access

With certain exceptions, Customers may request the Company to disclose the following information related to the collection and use of their personal information:

(i) Categories of personal information the Company has collected concerning such Consumer

(ii) Categories of sources from which the personal information was collected

(iii) Business or commercial purposes of collecting, selling or sharing personal information

(iv) Categories of third parties with whom the Company discloses the personal information

(v) Specific pieces of personal information

(vi) Categories of personal information sold or shared by the Company, and categories of third parties to whom the Company sold or shared the personal information

(vii) Categories of the personal information disclosed by the Company for business purposes

(viii)Categories of service providers or contractors to whom the personal information disclosed by the Company for business purposes.

1.2 Right to request deletion

With certain exceptions, Customers may request the Company to delete their personal information that the Company has collected from the Consumer.

1.3 Right to request correction

With certain exceptions, Customers may request the Company to correct the personal information the Company maintains.

1.4 Right to Opt out of the Sale or Sharing

We do not sell or share your personal information with third parties. 

1.5 Exercising of Your Rights

To exercise your rights to access, correct, or delete your personal information, please send a data subject request (specifying which right you wish to exercise) to this email address(support_us@zenaim.com). We will acknowledge receipt of your request within 10 business days and respond to your request within 45 days. Rights must be exercised in the manner specified above.Only you or your authorized agent may make requests related to your personal information. If you use an authorized agent, we will require written and signed proof of the agent’s permission to do so and may verify your identity directly with you.

The Company will verify your identity upon receipt of requests related to your personal information. Your request is unacceptable if we are unable to verify your identity.