“Personal data” is any data that can be used to identify you directly or indirectly (e.g., your identity data, your credit card details, device identifier, location, browsing activity, IP address, etc.).
- Who we are;
- What personal data we collect from you and how we collect it;
- What purpose we are processing it for;
- Whether providing us with your personal data is mandatory;
- How long we store it for;
- Whether there are other recipients of your personal information;
- Whether we intend to transfer it to another country; and
- Whether we do automated decision-making or profiling.
- We only process the data that is strictly necessary with regard to its purpose;
- You remain in control of your personal data; and
- Your data is processed in a transparent, confidential and secure manner.
When you connect to our Sites or purchase our products and services from us or from our brands, we are the “data controller” of your personal data, (i.e., the organisation that is responsible for ensuring that your personal data is processed in compliance with applicable regulations). Our contact details are as follows:
Japan Centre Group Ltd
Unit B, Park Royal,
Park Royal Road, NW10 7NZ
London, United Kingdom
If you have any concerns, questions or if you would like to exercise any of your rights with respect to your personal data, you may contact our Data Protection Officer at firstname.lastname@example.org
3. What Personal Data We Use
We collect your personal data through a variety of methods: either you provide it to us directly, or we collect it by using automated means.
3.1 The data you provide us directly:
In short: During our interactions with you, you may be asked to provide us with information that relates to you. For example, we collect this personal information when you subscribe to a newsletter, fill out a form, place an order for products, make a table reservation or apply for a position with us. You will also be told whether the collection of the personal data is mandatory or not.
In detail: The personal data that you provide to us directly includes:
- Your name and email when you sign up to our newsletter or participate in one of our competitions;
- When you place an order on our website: name, shipping address, billing address, phone number, credit card details or other payment information, and proof of age (in case you purchase restricted products and services such as alcohol);
- Name, contact details, LinkedIn profiles, references when you apply for a job on our website;
- Your business contact details if you are a client of our wholesale site;
- Name, e-mail and your opinions when you participate in one of our online surveys, direct research programmes or in our product or service review;
- Your social media user identifier and the comments you may leave on our social media pages;
- Username and encrypted password used to identify you on our site;
- The products and services that you purchase, or the promotional offers that you participate in;
- Information relating to your purchase history.
3.2 The data we collect automatically when you use our services:
In short: During each of your visits to our site, we collect information about your connection and your browsing activity.
4. Why We Collect Your Personal Data
In short: We must have a pre-defined objective to collect your personal data. These pre-defined objectives are not only necessary for delivering you products and services, but also for marketing purposes.
In detail: We process your personal data for the following purposes:
4.1 To provide you with our products and services:
- Taking into account of your order for products or services and execution of this order;
- Management of subscriptions to our newsletters and / or e-mail alerts;
- Billing; collection of payments;
- Management of deliveries and follow-up of orders;
- Customer relations: provision of Customer Service accessible by mail, telephone, e-mail or instant messaging such as chat, for any question or complaint;
- Carrying out satisfaction surveys, product or service review, direct research programmes;
- Processing your job applications;
- Sending information on the modification or evolution of our services;
- Management of unpaid bills and disputes; fraud prevention;
- Management of the exercise of your rights over your personal data;
4.2 To send you marketing and commercial communications:
We use your personal data for the following purposes:
- Sending of information relating to our latest activities (e.g., new store opening or anniversary);
- Sending of marketing, advertising and promotional offers relating to our products via email;
- Collection of customer opinions;
- Development of trade statistics.
4.3 To comply with our legal obligation:
- To comply with obligations of age verification for the selling of restricted products, such as alcohol.
5. On What Basis Do We Collect Your Data
In short: We must have a valid reason to use your data. One of the reasons we need to collect your personal data is that it is necessary for us to perform our contract with you. Another reason is the fact that we have a legitimate interest that justifies the processing, or that we have a legal obligation to process the data. In all other cases, we will process your personal data because we have your consent.
5.1 For processing activities, we require your prior consent:
You will always be prompted to take clear, affirmative action so that we can ensure that you agree with the processing of your personal data. This action may, for example, take the form of a checkbox or a link that you can click on. For example, we will ask for your consent when you subscribe to our newsletter.
Before obtaining your consent, we will systematically inform you of the purposes of the processing, and you can choose to consent to certain uses that we will make of your data and to refuse others.
If you have given us your consent, you may always change your mind, and withdraw your consent at any time and easily; all you need to do is to send us an email at the following address email@example.com or click on the "unsubscribe link" at the bottom of our marketing e-mail communications.
If you refuse to give us your consent, or decide to withdraw it, you will not suffer any negative consequences and will be able to continue to use the rest of our service, however some functionality or features may be limited.
If you have given us your consent, and the processing we carry out on your personal data changes significantly, we will collect your consent again.
5.2 Processing operations on the basis of a contract that we have with you:
Certain processing of your personal data is necessary so that we can perform the service you have asked us to perform.
We also use this justification if you ask us to take certain actions even before we enter into a contract with you (for example, you want to know if we deliver our products to your country of residence).
We justify our processing on our contract with you to process all the personal data that is necessary to ship your products, to respond to any queries you may have, and to prepare your customs documents for product exportations where applicable.
5.3 Processing operations that are necessary to meet our legitimate interests:
Legitimate interest is a set of commercial or business reasons that justify that we process personal data about you.
Our legitimate interests are to comply with our obligations of detection of fraudulent payments and ensuring network and information security.
We will use legitimate interest only when we have carried out an assessment on the impact that this processing may have on you, and concluded that the processing does not unduly infringe your rights and freedoms. For example, we do not use this justification if we process sensitive data, or when the processing would be unexpected for you, or if we consider it to be too intrusive.
5.4 Processing operations that are necessary to meet our legal obligations:
Like many companies that sell restricted products such as alcohol, we are subject to a number of regulations which require us to collect data about you. These regulations are for example the UK Licensing Act of 2003.
6. How Long We Store Your Personal Data
In short: We will not retain your personal data indefinitely. Our retention periods vary depending on whether we have an ongoing contractual relationship (you are an active customer), or whether we have had a contractual relationship with you in the past (you are an inactive customer) or whether we never have had such a relationship with you (you are a prospective customer).
In detail: When their retention is no longer justified by legal, commercial or customer account management requirements, or if you have made use of a right of modification or erasure, we will delete your personal data securely.
We will retain your personal data as long as it is necessary to meet our legal obligations according to the main retention periods for EU Member State law or Union law, we are subject to. Your personal data will be deleted as soon as the purpose for which they were collected is achieved.
As such, we will retain the personal data we collect from you:
- for 3 years after our last contact with you if you are a prospect;
- for 3 years after our contract has ended if you are no longer our client.
7. Access To The Data We Collect
7.1 Disclosure to employees within our organisation:
In short: We only disclose your personal data to a limited number of individuals within our organisation.
In detail: The following individuals within our organisation may have access to some of your data: customer service, administrative, accounting and management control, IT and marketing & sales.
Access to your data is based on individual and limited access permissions. Staff who can access personal data are subject to an obligation of confidentiality and are trained in the protection of privacy.
7.2 Disclosure of personal data to external organisations:
In detail: The following may have access to some of your data:
- Organisations that process your personal data on our behalf
These processors have access to your personal data in particular for securing your online payments, fraud prevention, shipping your orders, collecting customer reviews, and facilitating our marketing and e-commerce operations.
For instance, when proceeding through the checkout with alcohol products, our processor, AgeChecked will automatically take your name, address and email address to verify your age against national data sets. If successful, you will receive a one-time only email by AgeChecked to let you know you have been successfully age verified. If unsuccessful, you will then be prompted to provide a scan of a valid ID through AgeChecked.
AgeChecked does not retain your personal data and does not store personal details on their system.
The disclosure of your personal data to our processor is made on the basis of signed contracts that are binding and that mention their obligations in terms of data protection, data security and confidentiality.
- Police authorities, judicial or administrative authorities
We may disclose your personal data when we are required or authorised by law to cooperate with local, national or international law enforcement or other authorities for the reporting and/or investigation of improper or unlawful activities, or if we need to comply with court orders.
8. International Transfer of Personal Data
In short: The personal data we collect when you use our website as part of our services may be transferred to processors located in other countries, some of which may have legislation on the protection of personal data that is less protective than the GDPR.
9. Your Rights
9.1 Your rights under the GDPR:
In short: You have the right to ask us what data we process about you, and ask us to correct it, erase it, restrict it, and ask us to transfer your personal data to another controller in certain circumstances by contacting our Data Protection Officer at the following address firstname.lastname@example.org
In detail: You have the right to access your personal data and request that it be rectified, supplemented or updated. You can also request the erasure of your data, to restrict our processing, or object to their processing, provided you can justify a legitimate reason.
You can ask to exercise your right to the portability of your data, that is to say the right to receive the personal data that you have provided to us in a structured, commonly used format, and the right to transmit this data to another data controller.
You can exercise your rights by contacting our Data Protection Officer at the following address: email@example.com
Before responding to your request, we will verify your identity and / or ask you to provide us with more information to respond to your request, if we have any doubts about your identity. We will do our best to respond to your request within one month, unless your request is particularly complex (for example if your request concerns a large amount of sensitive data). In such a case, we will inform you of the need to extend this response time by two additional months.
9.2 Your rights to object to commercial communications:
In short: When we use your personal information to contact you for marketing purposes, you can object to these communications at any time.
In detail: In any case, you always have the option to object to the sending of these commercial emails by clicking on the unsubscribe link provided in each e-mail, by going to your online account or by writing to us at the following address firstname.lastname@example.org
9.3 How to exercise your right to lodge a complaint:
If you think that we are doing something wrong, you can complain to us about it, by contacting our Data Protection Officer. In the event of an unsatisfactory response, you can lodge a complaint with our EU representative:
IDEAMOTIVE Sp. z o.o.
Zlota 61/101, 00-819 Warsaw
Poland, European Union
10. Children's Privacy
In short: We do not provide services directly to children and proactively collect their personal data.
In detail: We do not knowingly collect personally identifiable information from anyone under the age of 16.
If you are a parent or guardian and you are aware that your child 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.
11. Changes To This Policy
12. Last Updated
Last updated: 11/4/21