FISH LETTER

PRIVACY NOTICE FOR SERVICE USERS AND OTHER RELATED PERSONAL DATA

• 1Who is responsible for processing your data?

  K. Mikimoto & Co., Ltd. is a luxury pearl and jewelry brand. We are committed to respecting your privacy, and this privacy notice explains how we collect, use, disclose, retain and protect your personal data in connection with the services we provide on this website (the “Services”).
  For the purpose of the General Data Protection Regulation 2016/679 and any implementing legislation (the “GDPR”), K. Mikimoto & Co., Ltd. (“Mikimoto” or “we” or “us” or “our”) will be the data controller responsible for any personal data we process. For the purpose of laws other than the GDPR, "data controller" shall mean a similar person who is subjectively responsible for the processing of personal data, such as a business operator handling personal information under the Act on the Protection of Personal Information (the “APPI”) in Japan.
  Please take the time to read this privacy notice, since it contains important information about the way that we process personal data.
  Questions, comments, and requests for information regarding this privacy notice, or our privacy practices in general, are welcomed and should be addressed to The Data Protection Manager. Any queries and requests regarding this privacy notice may be emailed to or sent by post to The Data Protection Manager provided in section 7.

• 2What personal data we collect and why?

  We may source, use and otherwise process your personal data. In such cases we are committed to protecting your personal data.
  
  The following subsections describe how we obtain your personal data and how we treat it.

  • A - Sources of personal data

    We may obtain your personal data from the following sources:

    • a) from you directly (for example, at the time of subscribing to the Services, or when you contact the contact point on this website);
    • b) from other users of the Services who send you messages; and/or
    • c) from your device or browser.

    If you contact us, we may keep a record of that correspondence.

  • B - Personal data that we collect and process

    • a) name;
    • b) email address;
    • c) communication preferences;
    • d) cookie data (for more information please see our Cookie Notice); and/or
    • e) IP address.

  • C - Why do we collect your personal data and what are our lawful bases for it?

    • We may use your personal data to:

    • Our lawful basis for doing so is:

    • Our legitimate interests in doing so are:

    • Provide the Services to you, whereby users are able to use them

    • Contract

    • Provide you with the Services

    • Allow you to participate in interactive features of our website when you choose to do so (including the Contact Us)

    • Legitimate interests

    • Account Management

    • Learn about our websites(s) users’ browsing patterns and the performance of our website(s)

    • Legitimate Interest

    • Account Management
      Management Reporting

    • Perform user due diligence checks

    • Legitimate Interest

    • Website Management

    • Safeguard the security of our infrastructure and systems

    • Legitimate Interest

    • Managing security, risk and crime prevention
      Management Reporting

  Where we use cookies or similar technologies, we will seek your prior consent where required to do so by law.

• 3To whom we disclose your personal data?

  We do not sell your personal data to third parties.

  • Our Partner Organisations and Service Providers

    We may disclose information about you to organisations that provide a service to us, ensuring that they are contractually obligated to keep your personal data confidential and will comply with the APPI, the GDPR and other relevant data protection laws.
    We may share your information with the following types of service providers:

    • a) technical support providers who assist with our website and IT infrastructure;
    • b) third party software providers, including ‘software as a service’ solution providers, where the provider hosts the relevant personal data on our behalf;
    • c) professional advisers such as attorneys, accountants, tax advisors, auditors and insurance brokers;
    • d) providers that help us generate and collate reviews in relation to the Services; and/or
    • e) our advertising and promotional agencies and consultants and those organisations selected by us to carry out the Services on our behalf.

  • Law enforcement or government bodies

    We may disclose your personal data as permitted by law in order to investigate, prevent or take action regarding illegal activities, suspected fraud, violation of our intellectual property rights, situations involving potential threats to the physical safety of any person, violation of our Terms and Conditions or other agreements, or as required by law.

• 4PROCESSING OF PERSONAL DATA OUTSIDE YOUE COUNTRY OR REGION.

  • a) Processing in Japan

    We obtain and process your personal data directly in Japan through the Service.

  • b) Third Party Suppliers

    We disclose personal data to external vendors or service providers or suppliers that we engage to perform services or functions on our behalf and under our instructions. Where these vendors are located within Japan, we ensure that they are contractually obligated to comply with the APPI. We also ensure in our contracts with these organisations that they only process personal data in accordance with our instructions and in order to provide the agreed services and protect the integrity and confidentiality of your personal data entrusted to them.
    We may also disclose personal data to our advisers, consultants, law enforcement and other public authorities, the police, prosecutors, courts and tribunals. All these recipients are themselves responsible to comply with the APPI.

• 5Your Rights

  We provide you with certain rights in relation to the processing of your personal data, including to:

  • • Request access to personal data about you (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you, and to check that we are lawfully processing it.
  • • Request rectification, correction, or updating to any of the personal data that we hold about you. This enables you to have any inaccurate our outdated information we hold about you corrected.
  • • Request personal data provided by you to be transferred in machine-readable format ("data portability").
  • • Request erasure of personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove personal data where you have exercised your right to object to processing (see below).
  • • Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you (e.g. if you want us to establish its accuracy or the reason for processing it).
  • • Object to the processing of your personal data in certain circumstances. This right may apply where the processing of your personal data is based on the legitimate interests of Mikimoto, as explained above.
  • • Withdrawal of consent. If we rely on your consent (for example, when setting cookies on your device), you may withdraw your consent at any time.

  These rights listed may be subject to various conditions under applicable data protection and privacy legislation.
  If you would like to exercise any of your rights set out above, you can contact us by emailing using the email address in section 7.
  If you are unhappy with how we dealt with your request or complaint, we encourage you to file a complaint with the Personal Information Protection Commission, a Japanese supervisory authority, but you also have the right to file a complaint with your national or regional data protection supervisory authority.

• 6Retention period

  We will keep your personal data only for as long as is necessary for the purposes for which it was collected in connection with your requests via our website or your use of the Services.

• 7Contact us

  Data Protection Manager: Person in charge at Secretariat of Personal Information Protection Committee of Mikimoto
  Email: soumu01@mikimoto.com (Secretariat of Personal Information Protection Committee of Mikimoto)
  Address: K. Mikimoto & Co., Ltd. General Affairs Section, General Affairs Department 5-5-13 Toyosu, Koto-ku Tokyo 135-8145 Japan