Privacy Policy for End Users in the European Economic Area (EEA) and United Kingdom

Pacoloa Co., Ltd. (hereinafter “Paccloa”) has established the below Privacy Policy to indicate its handling of personal data (refers to personal data as defined in the “General Data Protection Regulation” below) for end users in the European Economic Area (hereinafter “EEA”) and United Kingdom (hereinafter collectively “end users”).

When collecting personal data from end users, we comply with the following:
REGULATION （EU） 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC （General Data Protection Regulation）

Personal data obtained from end users

End user’s name, company name, job title, address, telephone number, e-mail address, location data, IP address, website access history, etc.

Purposes of the handling of personal data

Paccloa will only handle personal data for the following purposes:

1. To respond to inquiries
2. To propose or offer internationalization support checks, internationalization support professionals, and other services
3. To provide information through Paccloa’s owned media, corporate site content and publications, as well as information on sales and subscriptions
4. To provide information on seminars and workshops, and their respective operation
5. Business communication, payment, and investigation relating to outsourcing and procurement
6. Website access analysis and security measures
7. Other operations associated with the above

Source of personal data

Paccloa acquires personal data from the following sources for the purposes of handling as prescribed in the preceding Article.

1. Directly from end users (e.g. personal data on the application form)
2. Indirectly from end users (e.g. IP address obtained when browsing Paccloa’s website)
3. Social media (e.g. Twitter, LinkedIn, Facebook）

Provision and sharing of personal data

We may share personal data and information that does not identify individuals with the following third parties for the purposes of Article 2. If this is necessary, we will comply with applicable privacy laws and regulations.

1. Paccloa’s group companies
2. Occupational professionals such as lawyers, tax accountants, and certified public accountants
3. Financial institutions
4. Current, past, and future employees
5. Service providers and suppliers, including marketing companies, etc.

Reasons for handling personal data

Our reasons for handling personal data are as follows:

1. When the end user grants consent to the processing of his or her personal data for one or more specific purposes. However, in the case of consent-based handling, the end user may withdraw the consent at any time. In the case of such withdrawal, the legality of the processing of personal data based on consent before withdrawal will not be affected by the withdrawal of consent.
2. When processing is required for the fulfillment of a contract to which the end user is a party, or when processing is required to carry out procedures at the request of the end user prior to the conclusion of a contract.
3. When processing is required in order to comply with required legal obligations.
4. When processing is required to protect the important interests of end users or other natural persons.
5. When processing is necessary in the fulfillment of business performed for public interest or for the exercise of public authority granted to Paccloa.
6. When processing is required for legitimate interests pursued by Paccloa or a third party (e.g. marketing to end users or customer service). However, this excludes cases where the fundamental rights and freedoms of the end user which seek protection of personal data, especially when the end user is a child, take precedence over such interests.

Retention of personal data

Paccloa will retain personal data for the period necessary to carry out the purposes set out in Article 2 or for the period stipulated by laws and regulations. After the said period has elapsed, we will promptly and safely erase personal data unless necessary in connection with the purpose of the contract or other processing.

Transborder data transfer

Paccloa may transfer the end user’s personal data from its offices (branches, representative offices, local subsidiaries, etc.) in the EEA and UK to its sales offices in Japan or to the Group’s overseas bases. The personal data of the end user that may be transferred includes the end user’s personal data and the personal data of the employees of the offices in the EU.

The transfer of personal data to Japan is based on adequacy certification regarding transborder data transfer obtained by Japan or the standard contract clauses already entered into by Paccloa.

The transfer of personal data to third countries other than Japan, EEA and the UK (excluding countries/regions with adequacy certification) will be carried out via the method of conclusion prescribed in the Standard Contractual Clauses.

Please refer to the European Commission’s website (https://ec.europa.eu/info/law/law-topic/data-protection_en) for details on Japan’s adequacy certification.

Please contact Paccloa via our inquiry form for information on how to obtain the Standard Contractual Clauses that we have entered into.

End users’ rights

The end user reserves the right of access, the right to be informed, the right to rectification, the right of erasure (the right to be forgotten), the right to restrict processing, the right to notify regarding the correction/erasure/processing restriction of personal data, the right not to be subjected to automated processing such as profiling, the right to object, and the right to data portability. To exercise data rights, please contact us via our inquiry form. Paccloa will not perform automated processing of end user personal data, including profiling.

Voluntary provision of personal data

The provision of personal data is not a legal or contractual requirement, nor is it a requirement to enter into a contract, unless there is a separate contract between the end user and Paccloa. Additionally, end users are not obligated to provide personal data. However, if an end user does not provide personal data, we may be unable to respond to inquiries or consultations.