GDPR PRIVACY POLICY

Luceo Co., Ltd. (hereinafter referred to as “Luceo”) strives to protect your privacy. This GDPR Privacy Policy (this “Privacy Policy”) shall be only applicable to the processing of personal data subject to the General Data Protection Regulation (“GDPR”) of the EU and relevant national implementation acts (GDPR and such acts, collectively, the “Applicable Privacy Legislation”). Please read through this Privacy Policy carefully before using our website (https://luceo.co.jp/en/) (our “Website”).

ARTICLE 1. PERSONAL DATA COLLECTED

1.1　　Luceo may collect the following personal data from you, or our partner companies including sales agents, distributors, and service agencies:
a. Name
b. E-mail address
c. Telephone number
d. Purchase information, content of inquiries, orders and contract information
e. IP address, cookies, etc.

1.2　　Luceo does not collect sensitive personal data via our Website.

ARTICLE 2. PURPOSES AND LEGITIMATE BASIS OF DATA PROCESSING

2.1　　Luceo collects and processes your personal data only for the purposes mentioned as below:

Luceo may use your personal data to answer questions you have asked us. The processing of such personal data is based on consent and/or our legitimate interests, i.e., it is necessary for carrying out our ordinary business.
Luceo may use your personal data for various communications to provide you with services tailored to your request. The processing of such personal data is based on our legitimate interests, i.e., it is necessary for providing our products and services to you, or providing, improving and developing our products, services and advertisements.

2.2 If Luceo intends to further process your personal data for purposes other than that for the processing when your personal data have been collected, Luceo will provide you with information for such other purposes and all relevant additional information prior to the further processing.

ARTICLE 3. TRANSFER OF PERSONAL DATA TO THIRD PARTIES

3.1 Luceo may, subject to compliance with relevant laws and regulations, share your personal data with our business partners including sales agents, distributors, and service agencies.

3.2 Luceo may transfer your personal data to businesses located in countries outside the European Economic Area (EEA) which do not provide adequate protection of personal data. In cases where Luceo transfers your personal data to a country outside the EEA, it shall ensure that your personal data will be protected and transferred thereto in a manner in accordance with statutory requirements applicable to such personal data. In cases where your personal data is transferred to a country outside the EEA, you may obtain further information concerning the protection of such personal data by contacting Luceo.

ARTICLE 4. SECURITY

4.1　　In order to protect your personal data, Luceo takes appropriate organizational and technical security measures to prevent unauthorized use, loss or alteration. In addition, Luceo grants access rights only to our employees, agents, contractors and other third parties who need to access to your personal data. They bear the obligation of confidentiality under the contract.

4.2 In the event of a personal data breach, if it is required under the Applicable Privacy Legislation, Luceo will notify it to the relevant supervisory authorities and the data subjects.

ARTICLE 5. RETENTION PERIODS

5.1 Luceo does not store your personal data beyond the limit necessary for the specific purposes of data collection.

5.2 If your personal data is no longer necessary in comparison with the purposes of collecting or processing it, Luceo will delete the personal data.

ARTICLE 6. COOKIES

6.1 Luceo uses cookies in order that our Website functions properly.

6.2 Cookies are information that are stored on your computer by its browser. Luceo uses different types of cookies for different purposes.

Functional cookies: cookies that are necessary for our Website to function properly.
Analytical cookies: cookies that get information how you use (part of) our Website. These enable to improve our Website and fit our Website to your concerns or important matters as much as possible. Luceo uses the data obtained with these cookies only to analyze the usage of our Website.

6.3 Luceo uses third party cookies only to improve the quality and effectiveness of our Website. For example, Luceo uses Google Analytics, which is set up in a privacy-friendly manner. Data collected by Google Analytics does not include any information that identifies you. Also, such collected data will be administered by Google LLC. Google Analytics Terms of Service and explanations on Google’s privacy policy are shown at the following links:

Google Analytics Terms of Service: https://www.google.com/analytics/terms/

6.4 Most browsers are set to enable cookies by default. By setting the browser, you can disable cookies or display it when sending cookies. However, the functions and services on our Website and other websites may not function properly if cookies are disabled.

6.5 On our Website, a notification banner is shown to request your consent to the collection of cookies. If you do not consent to the collection of cookies by Luceo, your information terminal will not be targeted for the purpose of marketing-related activities.

ARTICLE 7. YOUR RIGHTS

7.1 If the processing of your personal data is based on your consent, you have the right to withdraw your consent regarding your personal data at any time.

7.2 You have the right to request access to your personal data. This enables you to receive copies of your personal data that Luceo holds.

7.3 You have the right to request correction of your personal data that Luceo holds. This enables you to have Luceo correct any incomplete or inaccurate data Luceo holds about you.

7.4 You have the right to request deletion of your personal data. This enables you to have Luceo delete your personal data, if there are no legitimate grounds for Luceo to keep it processing.

7.5 You have the right to object to the processing of your personal data, if Luceo is relying on legitimate interests. Luceo will discontinue processing your personal data, unless there are unavoidable legitimate grounds to take precedence over your interests, rights and freedoms or to be related to the start or pursuit of, or substantiation of legal actions.

7.6 You have the right to request restrictions to the processing of your personal data.

7.7 You have the right to request the transfer of your personal data to you or to third parties. Luceo will provide your personal data to you or third parties designated by you in a structured, commonly used, machine-readable format. Please note that this right applies only to the information which Luceo has used with your consent or under the contract with you, and of which the processing has been automated.

7.8 There is no cost for the exercise of the above-mentioned rights. Luceo will provide you with information regarding the status of addressing your request within one month after receiving your request. Depending on the complexity and the number of requests, this period may be extended by additional two months. If the period is extended, Luceo will notify you within one month after receiving your request.

7.9 If your requests are manifestly unfounded or excessive, especially if the requests are repeated, Luceo will charge you reasonable fees or refuse to respond to your request.

7.10 In addition to the above-mentioned rights, you have the right to file complaints with supervisory authorities at any time (particularly those competent in the place where your residence or workplace is located, or the supervisory authorities of the EU member country in which it is alleged that GDPR violation has occurred). However, it is appreciated if you could inform us in advance to allow us to respond to your complaints before you contact the supervisory authorities.

ARTICLE 8. ENQUIRIES

The controller of your personal data is Lucio. If you ask any questions, complaints or you wish to exercise the rights mentioned Article 7 of this Privacy Policy, the contact details are as below:

Contact:	Luceo Co., Ltd.
Address:	30-9 Ohyamakanai-cho, Itabashi-ku, Tokyo, 173-0024 Japan
Telephone Number:	+81-3-3956-4111

ARTICLE 9. GENERAL PROVISIONS

9.1 Luceo reserves the right to revise this Privacy Policy on a regular basis. Please confirm the applicable provisions regularly at your responsibility. This Privacy Policy was revised last on Dec 12, 2023.

9.2 If a provision of this Privacy Policy contravenes laws and regulations, such provision shall be replaced by a provision to the same meaning that reflects that intention, to the extent permitted under laws and regulations. Even in that case, the other provisions shall continue to apply without changes.