Thirty Five Summers Co., Ltd. (hereinafter referred to as "our shop" or "the Company") recognizes its social responsibility to appropriately protect the personal information of all customers. Therefore, we have established this Privacy Policy (hereinafter referred to as "this Policy") as follows, and will take all reasonably possible measures to appropriately handle and protect all personal information, including that of individuals located in the European Economic Area (hereinafter referred to as the "EEA") who are protected under the General Data Protection Regulation 2016/679 (hereinafter referred to as "GDPR"). In cases where domestic laws in the individual’s location mandate compliance, such laws shall be positioned to supplement this Privacy Policy.

1. Definitions

In this Policy, the following terms shall have the meanings defined below:
(1) Customer
Refers to a customer who is an identifiable natural person to whom the personal information pertains.
(2) Personal Information
Refers to any information that can identify an individual (including information that can be easily cross-referenced with other information to identify a specific individual).
(3) Applicable Laws
Refers to the GDPR and the Act on the Protection of Personal Information of Japan.
(4) Processing
Refers to any operation performed on personal information, whether by manual or automated means, including collection, recording, storage, editing, processing, modification or alteration, retrieval, reference, use, disclosure by transmission, distribution, allowing access by other means, erasure or deletion, and restoration.
(5) Customer Consent
Refers to a clear, affirmative indication of the customer's wishes, given freely and with full information, by which the customer signifies agreement to the processing of personal information relating to them.

2. Collection of Personal Information

Our shop collects personal information when customers engage in the following:
(a) Registering online
(b) Purchasing products or making inquiries
(c) Browsing or using our shop's website
(d) Subscribing to our shop's email newsletter
Personal information is collected through lawful and fair means, with the purpose of use clearly specified.

The personal information collected by our shop is as follows:
(a) Name, phonetic name
(b) Address
(c) Telephone number
(d) Email address
(e) Username and password
(f) Shipping information
(g) Transaction history with our shop and its details
(h) Customer credit card, debit card, and other payment information
(i) Location data, behavioral data
(j) IP address, cookie information, and other online identifiers
(k) Information that can identify a specific individual by combining the above

3. Use of Personal Information

The purposes for which our shop uses the personal information provided by customers are as follows:
(a) Confirmation and inquiry of orders
(b) Confirmation and inquiry of product shipments
(c) Replying to inquiries
(d) Providing after-care and other support
(e) Sending marketing communications, displaying advertisements, and sending advertising emails
(f) Maintaining and improving services
(g) Analyzing usage trends
(h) Tailoring advertisements and content displayed on our shop's website to the customer
(i) Assisting in searching for the customer’s nearest store
(j) Verifying the customer's identity

Our shop will not disclose or provide personal information to third parties without the customer's consent, except in the following cases:
(a) When required by law, or when it is necessary to cooperate with national institutions, local public bodies, or those entrusted by them in performing duties prescribed by law.
(b) When it is necessary for the protection of human life, body, or property, and it is difficult to obtain the consent of the person concerned.
(c) When sharing personal data with affiliates of the company operating our shop, while ensuring compliance with the GDPR. In such cases, our shop will establish an appropriate legal framework applicable to the transfer and handling of data (GDPR Articles 26, 28, and 29). In addition, when our shop shares personal information with third parties outside the EEA, we will establish an appropriate legal framework applicable to the transfer of such personal information (which may include Standard Contractual Clauses approved by the European Commission).

4. Legal Basis for Processing Personal Information

The legal bases for processing are as follows:
(a) When the customer has given consent to the processing of their personal information for one or more specific purposes.
(b) When processing is necessary for the performance of a contract to which the customer is a party, or to take steps at the request of the customer prior to entering into a contract.
(c) When processing is necessary for compliance with a legal obligation to which the Company is subject.
(d) When processing is necessary to protect the vital interests of the customer or another natural person.
(e) When processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
(f) When processing is necessary for the legitimate interests pursued by the Company or a third party.

5. Security Management and Retention Period

(1) The security management of personal information provided by customers is handled by the service provider through reasonable organizational, physical, personnel, and technical measures, and our shop strives to prevent unauthorized access, loss, falsification, leakage, etc., of personal data by ensuring appropriate handling in accordance with relevant laws and regulations.
(2) The Company will store personal information for the period prescribed by applicable law if a minimum retention period is stipulated. After the minimum retention period has elapsed, or if there is no minimum retention period, personal information will be promptly deleted if it is no longer necessary in relation to the purposes of use defined in Article 3.

6. Outsourcing

The Company may entrust all or part of the handling of personal information to third parties in order to fulfill the purposes set forth in this Policy, including the provision of our shop's services.
When concluding outsourcing contracts, the Company carefully examines whether the third party is suitable as a contractor. The outsourcing contracts will stipulate security management measures, confidentiality, conditions for re-outsourcing, and other matters concerning the appropriate handling of personal information, and we will appropriately supervise the contractors through monitoring the status of the outsourced operations.

7. Customer Rights

Under applicable laws, including the GDPR, customers have the following rights. Please notify us via email or postal mail at the contact address provided below if you wish to exercise these rights. Furthermore, if you have registered as a user, you can correct your personal information from the "My Account" menu on this site.
The Company will respond to the aforementioned requests regarding your personal information in a reasonable and appropriate manner after verifying your identity. However, under certain applicable laws, you may not be able to exercise certain rights (e.g., under the Japanese Act on the Protection of Personal Information, the right to data portability in (1) ⑥ of this Article is not recognized at the time of revision of this Policy). Additionally, there may be cases where the Company cannot provide satisfactory services if all or part of the personal information is deleted or its use is terminated. Also, due to specific legal obligations, the Company may be unable to delete or terminate the use of information in its possession.

(1) Types and Contents of Rights
① Right to withdraw consent
If the processing of personal information is based on the customer's consent, the customer has the right to withdraw their consent related to their personal information at any time.
② Right of access
The customer has the right to request access to their own personal information. The Company will provide a copy upon request for access.
③ Right to rectification
The customer can request that the Company correct incomplete or inaccurate personal information.
④ Right to erasure
The customer has the right to request the deletion of personal information concerning themselves if the Company continues to process it without justifiable reason.
⑤ Right to restriction of processing
The customer has the right to request that the Company restrict the processing of their personal information.
⑥ Right to data portability
The customer has the right to receive personal information concerning themselves in a structured, commonly used, and machine-readable format.
⑦ Right to object
The customer has the right to object to the processing of personal information by the Company. The Company will stop processing the personal information for which the objection was raised, unless (a) the processing is necessary for the performance of a task carried out in the public interest or (b) there are compelling legitimate grounds that override the interests, rights, and freedoms of the customer, or are related to the initiation, exercise, or defense of legal claims.
⑧ Right to lodge a complaint with a supervisory authority
Customers have the right to lodge a complaint with a supervisory authority at any time. However, we would appreciate the opportunity to address your concerns before you contact the supervisory authority, so please contact us first using the contact information at the end of this document.

(2) Expenses Required for Exercising Rights
When a customer exercises the above rights, the administrator may charge a fee based on applicable laws.

(3) Cases Where We May Refuse to Respond, etc.
If a customer's request is manifestly unfounded or excessive, or if the same or similar requests are repeated, the Company may charge a reasonable fee or refuse to respond to the request.

8. Use of Cookies

To provide better services to customers, the Company may use cookies and other similar technologies (hereinafter referred to as "cookies, etc.") for the following purposes: for the provision of our services, to confirm the appropriate operation of such services, to analyze our business and marketing activities, and to track and optimize the use of our shop's website or services for each customer. With these technologies, for example, customers do not need to re-enter necessary data into forms each time they use our shop's website. Information stored in cookies, etc., is used to identify customer preferences and tailor content according to their areas of interest.
When you access our shop, a pop-up will appear on your browser allowing you to choose whether or not to consent to the use of cookies. You can block or allow cookies by selecting on the pop-up. You can also block these cookies, etc., or display warnings through your browser settings. However, please note that if you restrict certain cookies, etc., some parts of our shop's site may become unavailable.
Furthermore, our shop may allow third parties to provide advertisements and acquire certain anonymous information when you visit our shop's site. Such third parties may use information collected while you are browsing our shop's site or other websites, as well as information similar to personal information, to provide advertisements for products and services that match your interests. These third parties mainly use cookies, etc., to acquire the aforementioned information, recognize users, or associate information across different devices or browsers, and use cookies, etc., to provide more effective targeted advertising.

* A cookie is information sent from a server computer to your browser and stored on the hard disk of the computer you are using.

9. Use of SSL

When entering personal information, we use SSL (Secure Sockets Layer) technology to ensure security and prevent this information from being intercepted, interfered with, or falsified.
* SSL is a function that prevents eavesdropping and data falsification by encrypting information. By using SSL, it becomes possible to transmit information more securely.

10. Contact Information (Administrator)

For questions or complaints, or if you wish to exercise the rights described in Article 7 of this Policy, please contact us at the following address:

Data Controller: Thirty Five Summers Co., Ltd.
Address: Please see the notation based on the Act on Specified Commercial Transactions.
Email: aoyama@anatomica.jp

11. Changes to the Privacy Policy

Our shop may change the personal information we collect, the purposes of use, or this Policy due to compliance with legal amendments or for other reasons. For the personal information our shop collects, the latest version of this Policy will always apply. When you access our shop's website or use our shop's services after this Policy has been revised, you are deemed to have agreed to such revisions. When this Policy is revised, we will post it on this page, and it will become effective as of the date of posting.