Effective date: June 1, 2020

ZenGroup Inc. ("us", "we", or "our") operates the https://zenplus.jp/en/ website and its subdomains, such as but not limited to https://shop.zenplus.jp (the "Services").

In this Privacy & Cookies Policy (“Privacy Policy”), we describe the information that we collect about you, that you provide to us, is provided to us by third parties, and will be processed by us, as you use this website (our “Website”) and the services available through this Website (collectively, our “Services”).

We collect and use data to provide and improve our Services. By using the Services, you agree to the collection and use of information in accordance with this Privacy Policy.

Services
Services collectively refers to the https://zenplus.jp/en/ website and the services it provides, including the subdomains, such as but not limited to shop.zenplus.jp, operated by ZenGroup Inc.

Personal Data
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data
Usage Data is data collected automatically and either generated by the use of the Services or from the Services infrastructure itself (for example, the duration of a page visit).

Cookies
Cookies are small pieces of data stored on your device (computer or mobile device).

Data Controller
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information is, or is to be, processed.
For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processor (or Service Provider)
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
We may use the Services of various Service Providers in order to process your data more effectively.

Data Subject (or User)
Data Subject is any living individual who is using our Service and is the subject of Personal Data.

We collect several different types of information for various purposes to provide and improve our Services to you.

Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Actual address, state, province, postal code, city
• Billing address, state, province, postal code, city
• Cookies and usage data
• Your IP addresses
• IP address geolocation

Social Logins: We allow Users to log in to our Services using social accounts like Facebook and Google. If you choose to log in using your social media profile, some of your Personal Data from that profile will be shared with us. This includes but is not limited to your name, email address, social profile URLs, and associated profile photos.

Usage Data
We may also collect information about how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (IP address), browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

Tracking & Cookies Data
We use cookies and similar tracking technologies to track the activity on our Services and hold certain information.
Cookies are files with small amounts of data that may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Services.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.
Examples of cookies we use:

• Session Cookies. We use Session Cookies to operate our Services.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
• Security Cookies. We use Security Cookies for security purposes, including login information protection and fraud prevention.

ZenGroup Inc. uses the collected data for various purposes:

• To validate your identity
• To provide and maintain our Services
• To notify you about changes to our Services
• To allow you to participate in interactive features of our Services when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our Services
• To monitor the usage of our Services
• To detect, prevent, and address technical issues
• To detect, prevent, and address fraudulent activities
• To provide you with news, special offers, and general information about other goods, services, and events we offer that are similar to those that you have already purchased or inquired about (unless you have opted not to receive such information)
• We may use your Personal Data to contact you with newsletters, marketing or promotional materials, and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send, or by contacting us.

If you are from the European Economic Area (EEA), ZenGroup Inc.'s legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.
ZenGroup Inc. may process your Personal Data because:

• We need to enter into a contract with you
• We need to deliver the Services and goods you ordered to you
• You have given us permission to do so
• The processing is in our legitimate interests and is not overridden by your rights
• For payment processing purposes
• To comply with the law in Japan and any other country around the world

ZenGroup Inc. will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, Tax Code of Japan), resolve disputes, and enforce our legal agreements and policies.

ZenGroup Inc. will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or when we are legally obligated to retain this data for longer time periods.

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in and from your jurisdiction.

If you are located outside Japan and choose to provide information to us, please note that we transfer the data, including Personal Data, to Japan and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

ZenGroup Inc. will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, and that no transfer of your Personal Data to an organization or a country will occur unless there are adequate controls in place including the security of your data and other personal information.

Disclosure for Law Enforcement
Under certain circumstances, ZenGroup Inc. may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements
ZenGroup Inc. may disclose your Personal Data in the good faith belief that such action is necessary:

• To comply with a legal obligation
• To protect and defend the rights or property of ZenGroup Inc.
• To prevent or investigate possible wrongdoing or fraudulent activity in connection with the Services
• To protect the personal safety of Users or the public
• To protect against legal liability

We use appropriate technical and organizational security measures to protect any personal information we process about visitors to our Website against unauthorized access, disclosure, alteration, and destruction, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. We encourage you to take care when disclosing personal information online and to use Internet firewalls, secure e-mail, and other technologies to protect yourself online.

Sensitive and private data exchange between the Services and its Users happens over a SSL secured communication channel and is encrypted and protected with digital signatures.

In case of an unauthorized security intrusion that materially affects you, ZenGroup Inc. will notify you as soon as possible and will, within reasonable time, report the action we took in response.

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. ZenGroup Inc. aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

• The right to access, update, or delete the information we have about you. Whenever made possible, you can access, update, or request deletion of your Personal Data directly within your account settings. If you are unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where ZenGroup Inc. relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

We may employ third-party companies and individuals to facilitate our Services ("Service Providers"), to provide the Services on our behalf or to assist us in analyzing how our Services are used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

We may use third-party Service Providers to monitor and analyze the use of our Services.

Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Services. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visitors' activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://www.google.com/intl/en/policies/privacy/

ZenGroup Inc. uses remarketing services to advertise on third-party websites to you after you visit our Website. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Website.

Google AdWords
Google AdWords remarketing services are provided by Google Inc. You can opt out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: https://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://www.google.com/intl/en/policies/privacy/

Facebook
Facebook remarketing services are provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt out from Facebook and other participating companies through the Digital Advertising Alliance in the USA https://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada https://youradchoices.ca/, or the European Interactive Digital Advertising Alliance in Europe https://www.youronlinechoices.eu/, or opt out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation

We provide paid products and/or services and we use third-party payment collecting services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of payment information. When you purchase from our Services, we will also collect transaction information including but not limited to billing and mailing address, and other payment-related information. The payment processors we work with are:

• Stripe. Their Privacy Policy can be viewed at https://stripe.com/us/privacy.
• PayPal or Braintree. Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full.
• Nihaopay. We use the Nihaopay payment processing service for customers from China. You can contact them regarding their Privacy Policy at https://nihaopay.com/contactUS.

We use third-party web hosting and storage services to securely store our Website and databases, including your Personal Data. The service we use for data storage is Microsoft Azure. You can review the Microsoft Azure privacy policy here: https://www.microsoft.com/en-us/TrustCenter/Privacy/default.aspx

Our Services may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Our Services do not address anyone under the age of 18 ("Children"). We do not intentionally collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that one or more of your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

ZenGroup Inc.

ZenGroup Inc.