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PRIVACY POLICY SENSAI Website

Last revised May, 25, 2018

SENSAI Cosmetics Inc., 14-10, Nihonbashi Kayabacho 1-chome, Chuo-ku, Tokyo, Japan ("SENSAI" or "we" or "our") and each of its affiliates and subsidiaries in Japan takes data privacy seriously. This Privacy Policy informs the users of the webpages on which this Privacy Policy is displayed (“the Webpages”) how we collect and process the personal data and other information of such users in connection with their usage of the Webpages.

1. Categories of Personal Data and Processing Purposes

- What personal data do we process about you and why?

1.1 Metadata

You may use the Webpages without providing any personal data about you. In this case, we will collect only the following metadata that result from your usage of the Webpages: browser type and version, operating system and interface, website from which you are visiting us (referrer URL), webpage(s) you are visiting on the Webpages, date and time of accessing the Webpages, and internet protocol (IP) address.

Your IP address will be used to enable your access to the Webpages. Once the IP address is no longer necessary for this purpose, we will shorten your IP address by removing the last octet of your IP address. The metadata, including the shortened IP address, will be used to improve the quality and services of the Webpages and services by analyzing the usage behavior of our users.

1.2 Enquiries

If you make an enquiry on the Webpages, you will be asked to provide the following personal data about you: name, email address, enquiry detail and address (country and city only). We process such personal data for purposes of answering your queries, providing information requested, improving the Webpages according to usage patterns, and for technical administration or other purposes to which you have agreed.

2. Processing Basis and Consequences

- What is the legal justification for processing your personal data and what happens if you choose not to provide it?

We rely on the following legal grounds for the collection, processing, and use of your personal data:

your consent to the processing of your data for one or more specific purposes;
the processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract;
the processing is necessary for compliance with a legal obligation to which we are subject;
the processing is necessary to protect the vital interests of you or another natural person;
the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us; or
the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of you which require protection of personal data, in particular if you are a child; such legitimate interests are the fulfilment of the processing purposes set out above in Section 1.

The provision of your personal data is not required by a statutory or contractual obligation. The provision of your personal data is voluntary for you.

Not providing your personal data may result in disadvantages for you. However, unless otherwise specified, not providing your personal data will not result in legal consequences for you.

3. Categories of Recipients and International Transfers

- Who do we transfer your personal data to and where are they located?

We may transfer your personal data to third parties for the processing purposes described above as follows:

Within our parent entity and its affiliates and subsidiaries: Our parent entity, Kao Corporation, in Japan and each of its affiliates and subsidiaries (the parent entity or each affiliate or subsidiary including us referred to as "the group company") <http://www.kao.com/global/en/about/outline/group-companies/> may receive your personal data as necessary for the processing purposes described above. Depending on the categories of personal data and the purposes for which the personal data has been collected, different internal departments within the group company may receive your personal data. Moreover, other departments within the group company may have access to certain personal data about you on a need to know basis.
With data processors: Certain third parties, whether affiliated or unaffiliated, may receive your personal data to process such data under appropriate instructions ("Processors") as necessary for the processing purposes described above, such as website service providers, IT support service providers and other service providers who support us in maintaining the Webpages. The Processors will be subject to contractual obligations to implement appropriate technical and organizational security measures to safeguard the personal data, and to process the personal data only as instructed.
Other recipients: We may transfer - in compliance with applicable data protection law - personal data to law enforcement agencies, governmental authorities, judicial authorities, legal counsel, external consultants, or business partners. In case of a corporate merger or acquisition, personal data may be transferred to the third parties involved in the merger or acquisition. We will not disclose your personal data to third parties for advertising or marketing purposes or for any other purposes without permission.

Any access to your personal data is restricted to those individuals that have a need-to-know in order to fulfill their job responsibilities.

International transfers. The personal data that we collect or receive about you may be transferred to and processed by recipients that are located inside or outside the European Economic Area ("EEA") or Switzerland.

4. Retention Period

- How long do we keep your personal data?

Your personal data will be retained as long as necessary to fulfill the processing purposes described above. Once the processing purposes are completed or otherwise ended your relationship with us, we will remove your personal data from our systems and records or take steps to properly anonymize it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which the group company is subject).

We may also retain your personal data if your personal data are necessary to comply with any applicable laws or if we need your personal data to establish, exercise or defend a legal claim, on a need to know basis only. To the extent possible, we will restrict the processing of your personal data for such limited purposes.

5. Your Rights

- What rights do you have and how can you assert your rights?

Right to withdraw your consent: If you have declared your consent regarding certain collecting, processing and use of your personal data, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal. Please contact us as stated in Section 7 below to withdraw your consent.

Additional data privacy rights: Pursuant to applicable data protection law, you may have the right to: (i) request access to your personal data; (ii) request rectification of your personal data; (iii) request erasure of your personal data; (iv) request restriction of processing of your personal data; (v) request data portability; and/or (vi) object to the processing of your personal data.

Please note that these aforementioned rights might be limited under the applicable local data protection law. If you are a EU Resident, the following rights apply:

Right to request access to your personal data: You may have the right to obtain from us confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, to request access to the personal data. This access information includes – inter alia – the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipient to whom the personal data have been or will be disclosed. However, this is not an absolute right and the interests of other individuals may restrict your right of access. You may have the right to obtain a copy of the personal data undergoing processing free of charge. For further copies requested by you, we may charge a reasonable fee based on administrative costs.
Right to request rectification: You may have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Right to request erasure (right to be forgotten): Under certain circumstances, you may have the right to obtain from us the erasure of personal data concerning you and we may be obliged to erase such personal data.
Right to request restriction of processing: Under certain circumstances, you may have the right to obtain from us restriction of processing your personal data. In such case, the respective data will be marked and may only be processed by us for certain purposes.
Right to request data portability: Under certain circumstances, you may have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit those data to another entity without hindrance from us.
Right to object: Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data by us and we can be required to no longer process your personal data. Such right to object may especially apply if we collect and process your personal data for profiling purposes in order to better understand your interests in our products and services or for direct marketing. If you have a right to object and you exercise this right, your personal data will no longer be processed for such purposes by us. You may exercise this right by contacting us as stated in Section 7 below. Such a right to object may, in particular, not exist if the processing of your personal data is necessary to take steps prior to entering into a contract or to perform a contract already concluded.

To exercise your rights, please contact us as stated under Section 7 below. You also have the right to lodge a complaint with the competent data protection supervisory authority.

6. Cookies and other tracking technologies

We use cookies to improve the Webpages, including enhancing information and services provided and making the Webpages easier to use, and, on some webpages, to authenticate membership for login, customize the service contents or distribute advertising based on browsing history. A cookie is an electronic file that is transmitted from a particular webpage to a browser viewing that page, which can be retrieved later to distinguish a user's computer.

The Webpages use a system operated by a provider other than us for use of cookies. For more details, see here.

You can disable or delete cookies in your browser settings. However, this makes certain services, including services requiring login, unavailable to you.

7. Questions and Contact Information

If you have any questions about this Privacy Policy or if you want to exercise your rights as stated above in Section 5, please contact us at:

SENSAI Cosmetics Inc.,

14-10, Nihonbashi Kayabacho 1-chome, Chuo-ku, Tokyo 103-8210 Japan

E-mail: Privacy@sensai-cosmetics.co.jp

The contact details of our representative within the EU are as follows:

Kanebo Cosmetics Deutschland GmbH

Poeseldorfer Weg 20-22, 20148 Hamburg, Germany

8. Changes to this Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, regulatory or operational requirements. We will notify you of any such changes, including when they will take effect, by updating the "Last revised" date above or as otherwise required by applicable law. Your continued use of the Webpages after any such updates take effect will constitute acceptance of those changes. If you do not accept updates to this Privacy Policy, you should stop using the Webpages.