1. Definition of Personal Data
Makuake, Inc. (“Makuake”) recognizes that personal data is any information about a living individual relating to an identified or identifiable natural person prescribed under the Data Protection Act 2018 and UK General Data Protection Regulation; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
2. Category of Personal Data and Purposes and Legal Basis for Processing
Makuake collects and processes the following personal data in the context of our services based on your consent to this Policy; your name, address, date of birth, gender, e-mail address, telephone number, credit card information, user ID, user name, return ID, return title, return details, purchase history, cookies, IP address information and browsing history. Other than justified by the consent, Makuake may process your personal data time to time in order to conduct our business, pursue our legitimate interests, and fulfil obligations under a contract or take steps linked to a contract executed between you and us.
3. Proper Acquisition of Personal data
Makuake acquires personal data in a proper manner and does not acquire personal data through deception or any other wrongful means. In addition, Makuake is also mindful to avoid collecting information of a personal nature from any child under  years old unless Makuake has good reason to do so and the consent of a person who has parental authority.
4. Specification of Purpose of Utilization of Personal Data
Makuake utilizes personal data for the following purposes:
Makuake does not handle your personal data beyond the scope necessary for achieving the purpose of utilization.
5. Changes to Purpose of Utilization of Personal Data
Makuake will not change the purpose of utilization of your personal data without your consent beyond a scope in which it is reasonably considered that the purpose of utilization after the change remains compatible with that before the change and will notify you of or publicly announce any change to the purpose of utilization.
6. Secure Management of Personal Data and Supervision of Employees
Makuake provides personal data protection regulations to prevent leakage of, loss of, or damage to personal data and to otherwise securely manage personal data and carries out necessary and appropriate supervision of its employees.
7. Supervision of Delegated Parties
If Makuake completely or partially delegates handling of personal data, then Makuake will enter into an agreement with the delegated party that includes provisions concerning confidentiality or will request that delegated party’s agreement with stipulations made by Makuake and will carry out necessary and appropriate supervision to ensure that the delegated party carries out secure management of the personal data.
8. Recipients of Personal Data
Makuake may disclose your personal data to the following recipients:
9. Source of Personal Data
Makuake obtains your personal data from you in our relationship with you, including, but not limited to, when you (i) make your personal account of our service, (ii) access or use our service, and (iii) communicate with us for inquiry about our service.
10. Transfer to Recipients in Third Countries
In order to provide our services, Makuake needs to transfer your personal data to countries outside of the UK, including Japan and Singapore. In case such countries are not recognized by the data protection authority in the UK (Information Commissioner’s Office) as providing an adequate level of data protection, Makuake only transfers personal data to these countries when Makuake has been able to implement suitable safeguards that assure the protection of your personal data. For further information about such safeguards, including the way to obtain a copy of the documents used to protect your personal data, please contact us in the manner set forth in Article 15 of this Policy.
11. Storage Period
Makuake stores your personal data for as long as needed in light of the purposes described when Makuake obtains your personal data. The criteria used to determine our storage periods include: (i) the length of time Makuake has an ongoing relationship with you; (ii) whether there is any legal obligation to which Makuake is subject; and (iii) whether there is a need in order to perform a contract to which you are party.
12. Your Rights
You have the right to ask Makuake: for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provided to us for a contract or with your consent in a structured, machine readable format (i.e. the right of data portability). In addition, you can object to the processing of your personal data under certain conditions (for further information, see the section below entitled “Your right to object to processing”).
These rights may be limited, such as if the fulfilment of your request would reveal personal data about another person, where it would infringe upon the rights of a third party (including our rights) or if you ask us to delete information which Makuake is required by law to keep or have compelling legitimate interests in keeping.
To exercise any of these rights, please contact us in the manner set forth in Article 15 of this Policy.
13. Your Right to Object to Processing
You have the right to object at any time to the processing of your personal data which is based on our legitimate interests, including “profiling” (i.e. analyzing or predicting your behavior based on your information). When Makuake processes your personal data for direct marketing purposes, you have an absolute right to opt out of direct marketing or the profiling Makuake carries out for direct marketing. To exercise any of these rights, please contact us in the manner set forth in Article 15 of this Policy.
14. Withdrawing Consent
Wherever Makuake relies on your consent to process your personal data, you have the right to withdraw that consent at any time. Such withdrawal does not affect the lawfulness of any processing performed pursuant to the consent given prior to the withdrawal. To exercise this right, please contact us in the manner set forth in Article 15 of this Policy.
Daiwa Shibuya Miyamasuzaka Bldg. 10F, 2-16-1 Shibuya, Shibuya-ku, Tokyo 150-0002