Figaro Engineering Inc. (“we”, “us” or “our”) processes your personal data collected in connection with your use of our websites and the services we offer ("Services") in accordance with the General Data Protection Regulation (the "GDPR") and equivalent laws of the United Kingdom of Great Britain and Northern Ireland ("the UK GDPR") and Switzerland (“FADP”) and this Privacy Policy ("this Policy"). This Policy is applicable only to personal data concerning data subjects in the member states of the European Union and the four EEA/EFTA states- Iceland, Liechtenstein, and Norway, and Switzerland (collectively, the "EU"), the United Kingdom of Great Britain and Northern Ireland (the “UK”) and Switzerland.

1. (1) We may collect the following types of personal data directly from you:
   
   1. a. Identification data:
      Name, Date of Birth, Address (private and/or professional), Email Address, Demographics (e.g., age, sex, race), Title, Phone Number (residential, business or mobile), Occupation, Employer Information
   2. b. Order Information:
      Contents of previous transactions, purchase history, purchase/return/exchange information
   3. c. Payment Information:
      Bank account information, billing address, method of payment
   4. d. Other information you provide us:
      We collect any other information that you may choose to provide, including your responses to surveys that you choose to participate in (for example your preferences or customer satisfaction surveys) and information that you provide during your interactions with our Services and customer service representatives.
2. (2) Information we collect automatically:
   When you use and interact with our websites, we automatically receive certain information about your device, browser, and/or activity below:
   1. a. Usage Information
      When you interact with our websites, we automatically collect technical data regarding your usage on our website, including pages that you visit and links you click on, online identifiers (cookies, IP addresses, etc.) or device information (language, browser type, etc.)
   2. b. Location Data
      When your device is set to provide location information, we automatically collect information about your general location (e.g. IP address).
   3. c. Cookies, and other similar technologies
      When you visit or otherwise interact with our website, we (and our partners, advertisers, and third-party advertising networks) may automatically collect information about you using device identifiers, cookies and/or similar technologies. We use this information for various purposes, including to: make the Services function properly; understand how you use the Services; personalize your experience; and measure, manage, display, and customize the advertisements you see.
3. (3) Information from Third Parties:
   
   1. a. Information from Third-Party Data Providers
      We receive your personal data from tech vendors who support our websites and other business systems, operational companies such as delivery couriers, and payment service providers who help us process your payments. Such personal data includes your demographics, transaction and purchase history or information about your interaction with online content or advertisements.
   2. b. Information from Affiliated Companies
      Our group companies ("the Affiliated Companies"), which are listed in https://www.figaro.co.jp/en/company/group.html, may provide us with your personal data.
4. (4) Cookies Used on Our Websites
   
   1. a. We use cookies and similar technologies on our websites. Cookies are small data files that are stored on a user's computer when it is used to visit a website. When you visit our websites, we may collect information from you automatically through cookies or similar technology. We use cookies in a range of ways to improve your experience on our websites, including but without limitation, tracking user preferences or web pages visited while using our website.
   2. b. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set their browsers to remove and reject cookies. In some cases, removing or rejecting cookies may affect certain features or services on our websites. If you want to disable the use of cookies or remove them from your computer, you can disable or delete them at any time using your browser.
      For further information, visit https://allaboutcookies.org/
   3. c. We use the following analytics tools on our website to collect user preferences or web pages visited while using our website, analyze traffic to the Services and understand the usage of the Services:
      
      1. i. Google Analytics
         For more information about Google Analytics and its data handling, please visit https://policies.google.com/technologies/partner-sites
      2. ii SATORI
         For more information about SATORI and its data handling, please visit https://satori.marketing/privacy-policy/
5. (5) You are required to provide us with certain personal data when you use our Services. Personal data that is mandatory is indicated in the relevant forms. You may not be able to use whole or a part of our Services if such data is not provided.

1. (1) We may use your personal data for the following purposes:
   
   1. a. to respond to your customer support communications and inquiries and assist you in your use of the Services.
   2. b. to provide you with information about our products and services that we think you might like by e-mail, mail, call or in person.
   3. c. to send you an invitation to an exhibition. The lawful basis for these uses is your consent.
   4. d. to improve our products and services and to plan, research and/or develop new products and services.
   5. e. to process your transactions and to provide after-sales services.
   6. f. to conduct research and analytics of customer campaigns and inquiries.
   7. g. to conduct research and analytics of marketing data to improve and carry out our marketing activities.
   8. h. to analyze and measure our marketing and advertising activities' effectiveness.
   9. i. to understand which parts of our websites and the Services are of most interest to you based on how you browse, use, or otherwise interact with the Services, accordingly we display content, advertising, recommendations and otherwise personalize the Services to you.
2. (2) Under GDPR, UK GDPR and FADP, the lawful basis we rely on for processing your personal data are:
   
   1. a. Your consent. You are able to remove your consent at any time. You can do this by contacting us in writing at the postal address or the email address listed below in Paragraph 9. “Contact Information”.
   2. b. We have a contractual obligation.
   3. c. We have a legal obligation.
   4. d. We have a vital interest. or
   5. e. We need it to perform a public task.
3. (3) We do not use your personal data for automated decision making that produces legal effects concerning you or that could similarly significantly affect you.

We may share your personal data with the following recipients:

1. a. Any of our Affiliated Companies
2. b. Members of our authorized distributors
   Our authorized distributors are listed in https://www.figaro.co.jp/en/distributors/
3. c. Our service providers that provide services on our behalf, such as tech vendors who support our websites and other business systems, operational companies such as delivery couriers, and payment service providers who help us process your payments.
4. d. Financial institutions, government entities and shipping companies or postal services involved in fulfilment of the transaction.

We securely store your data.
We strive to keep our processing activities with respect to your personal data as limited as possible. In the absence of specific retention periods set out in this policy, your personal data will be retained only for as long as we need it to fulfil the purpose outlined in this Privacy Policy for which we have collected and process it and, if applicable, as long as required by statutory retention requirements.

We are a company with operations around the world. Accordingly, our business requires the transfer of personal data to and from other Affiliated Companies or third parties, which may be located outside EU, UK and Switzerland, including Japan. Japan is recognized by the European Commission as providing an adequate level of data protection. We will only transfer personal data to countries that provide for ou an adequate data protection standard meeting the requirements as set out by the European Commission. Data transfers to countries not meeting that threshold will only occur in accordance with international data transfer agreements based on EU Standard Contractual Clauses.

1. (1) Under the GDPR, UK GDPR and FADP you have the right to ask us:
   
   1. a. to access to your personal data, which includes the right to obtain confirmation from us as to whether or not personal data concerning you is being processed, and where that is the case, access to the personal data and information related to how it is processed. You may always contact us to find out what personal data we have concerning you and its origin.
   2. b. for a copy of your personal data. We may charge you a small fee for this service.
   3. c. to correct your personal data you believe is inaccurate, including requesting to complete personal data you believe is incomplete.
   4. d. to erase your personal data, under certain conditions.
   5. e. to restrict or object to processing of your personal data under certain circumstances (e.g., where you contest the accuracy of your personal data, processing is unlawful, or your personal data is no longer needed for the purposes of processing).
   6. f. To transfer your personal data which we have collected to another organization, or directly to you, under certain conditions.

   Please note that these rights are subject to the exceptions under the GDPR and applicable local laws.

   To exercise any of these rights, please contact us in writing at the postal address or the email address listed below in Paragraph 9. “Contact Information” .

2. (2) your right to object to the processing of your personal data
   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 we process your personal data for direct marketing purposes, you have an absolute right to opt out of such processing. To exercise any of these rights, please contact us in writing at the postal address or the email address listed in Contact Information below
3. (3) Withdrawing consent
   Wherever we rely on your consent in order 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 any of this right, please contact us in writing at the postal address or the email address listed in Contact Information below.
4. (4) Your right to lodge a complaint with a data protection supervisory authority
   You have the right to lodge a complaint with a data protection supervisory authority, in particular, in the member state of the EU where you have a habitual residence or place of work or where the alleged infringement of the GDPR took place.

We reserve the right to change this Policy from time to time by updating our website respectively. Please visit the website regularly and check our respective current privacy policy. This policy was last updated on 31st August 2023.

1. (1) Data Controller
   Figaro Engineering Inc. is responsible for your personal data as a data controller. If you have any questions about our privacy policy, your data we are storing, or you would like to exercise one of your data protection rights, please do not hesitate to contact us at:
   
   Email :
   Phone : +81-72-728-2044
   Mail : 1-11-46 Senbahigashi, Mino, Osaka 562-0035, JAPAN
2. (2) EU Representative
   Our representative in the EU is Eduard Schaefer. You can contact our representative at:
   Email :
   Mail : Alte Strasse 55 D-46519, Alpen, Germany
3. (3) UK and Switzerland Representative Our representative in the UK is DataRep. You can contact our representative at:
   Email:
   Mail : DataRep, 107-111 Fleet Street, London, EC4A 2AB, United Kingdom (if you are in the UK)
   DataRep, Leutschenbachstrasse 95, ZURICH, 8050, Switzerland (if you are in Switzerland)
   For more information about our Data Protection Representative, DataRep and how to contact them, please see the attachments hereto.