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Privacy Policy

Privacy Policy

[Established September 13rd, 2024]

Moderato Inc. (hereinafter referred to as "the Company", throughout the site, the terms “we”, “us” and “our” refer to the Company.) recognizes that the protection of personal and specific personal information is a serious responsibility for the Company. Therefore, we hereby declare that we have established a personal information protection management system to realize the following policy based on our personal information protection philosophy and the code of conduct we have established, and that we will make company-wide efforts to continuously improve the system while always recognizing the latest trends in IT technology, changes in social demands, and changes in the business environment, etc. 

  1. We will acquire, use, and provide personal information appropriately in consideration of the nature and scale of our business, which includes clothing retail, personal styling services, and cosmetics sales, and will not handle personal information beyond the scope necessary to achieve the specified purpose of use. The Company will also take measures to ensure that such personal information is not used for purposes other than those specified.

  2. We will comply with laws and regulations, national guidelines, and other norms regarding the handling of personal information.

  3. We have established regulations and systems to prevent leakage, loss, or damage of personal information by taking reasonable security measures and will continue to improve them. In the event that such a risk should occur, we will promptly take corrective measures.

  4. We will respond promptly and sincerely to complaints and consultations regarding the handling of personal information.

  5. The personal information protection management system will be reviewed and continuously improved in a timely and appropriate manner in light of changes in the environment and actual conditions surrounding our company.

Asuka Ichihara,

Representative Director,

Moderato Inc.

[Inquiries about personal information]

VORT AOYAMAⅡ 3F, 2-1-12 Shibuya, Shibuya-ku, Tokyo 150-0002, Japan

Moderato Inc. Contact for Inquiries Regarding Personal Information

E-mail address: admin@moderato-inc.jp

[Purpose of use of personal information]

We use personal information for the following purposes In cases where there are reasons permitted under the Personal Information Protection Law or other laws and regulations, we will use the personal information of the person in question (meaning the "person in question" as defined in Article 2, Paragraph 8 of the Personal Information Protection Law. The same shall apply hereinafter).), or when we have separately notified or announced the purpose of use, we will not use personal information for any purposes other than those listed below. In cases where the purpose of use of personal information is separately stipulated in the terms of use of services provided by the Company, such purpose of use shall also be included.

1. Personal information of customers, inquiries, and requests for information materials

  1. To provide personal styling services, cosmetics services, and other services of the Company (hereinafter referred to as the "Company's Services").

  2. To provide information to our stylist partners in order to provide our services

  3. To hear about the use of our services, results of use, requests, etc.

  4. To confirm the identity of the customer for our services

  5. To provide information regarding our services

  6. To create statistical data and other data that cannot identify individuals

  7. To analyze and classify acquired customer and user information to create trend data and marketing data to improve our service measures

  8. Distribution of behavioral targeting ads using ad-serving providers such as Google, Yahoo!

  9. To advertise or promote (including sending direct mailings and e-mails) our services or the services of third parties To advertise or promote our services or the services of third parties (including sending direct mailings and e-mails)

  10. To conduct sweepstakes, campaigns, etc.

  11. To research and develop new services for the Company

  12. To investigate and respond to conduct prohibited by contracts, terms of use, etc.

  13. To respond to inquiries

  14. For purposes incidental to the above purposes

2. Personal information of our shareholders

  1. To manage shareholders in accordance with the Companies Act and other laws and regulations

  2. To notify and contact shareholders

  3. To submit notifications, reports, etc. to government and municipal offices

  4. For purposes incidental to the above purposes

3. Personal information of employment applicants

  1. To contact you for employment selection, scheduling, etc., and to notify you of employment results

  2. To carry out the hiring procedure

  3. For purposes incidental to the above purposes

4. Information on our employees

  1. For labor management and internal procedures

  2. To pay salaries, bonuses, etc.

  3. For business communication

  4. To submit notifications, reports, etc. to government and municipal offices

  5. To investigate and respond to conduct prohibited by employment regulations, employment contracts, etc.

  6. For purposes incidental to the above purposes

5. Information on subcontractors

  1. For business communication

  2. To pay business consignment fees, etc.

  3. To investigate and respond to conduct prohibited by contract, etc.

  4. For purposes incidental to the above purposes

6. Personal number information provided by you

It is used for "social insurance procedures" and "tax processing" as specified by law.

7. Appropriate acquisition of personal information

When acquiring personal information, we will do so in an appropriate and fair manner.

In addition, we will not acquire any personal information requiring special consideration unless we have obtained your prior consent or are permitted to do so by law. When a customer links or connects his/her account for the online store or other Company services to an account of a third-party service (Google, Facebook, LINE, etc.), the Company will obtain the ID, name, and e-mail address of the linked third-party service.

8. Use of Cookies and Google Analytics

We use cookies. However, please note that restricting the use of cookies may limit the features available on our services and website. In addition, we use Google Analytics to understand how our website is used. For more information on Google Analytics, including data collection and processing methods, please refer to the following URL.

https://marketingplatform.google.com/about/analytics/terms/jp/

https://policies.google.com/privacy?hl=ja

https://policies.google.com/technologies/partner-sites?hl=ja

[Regarding Dissemination of Matters Concerning Retained Personal Data and Records of Provision to Third Parties]

Moderato Inc. (hereinafter referred to as "the Company") will inform you of the following matters concerning requests for disclosure, etc. (notification of purpose of use, disclosure, correction, addition or deletion of content, suspension of use, elimination, and suspension of provision to third parties) of retained personal data and requests for disclosure of records of provision of personal data to third parties.

  1. Name and address of the Company and name of its representative

Name: Moderato Inc.

Address: VORT AOYAMAⅡ 3F, 2-1-12 Shibuya, Shibuya-ku, Tokyo 150-0002, Japan

Representative: Asuka Ichihara

  1. Personal information protection manager

Katsumi Tomita, General Manager, Administration Dept.

Contact:+81-03-6416-3089

  1. Purpose of use of retained personal data

As described “Purpose of use of personal information" in the Privacy Policy above.

  1. Contact for complaints regarding handling of retained personal data

Inquiries regarding retained personal data are accepted at the "Personal Information Inquiry Desk" above.

The Company has been working on the following projects.

  1. Our membership in authorized personal information protection organizations

There is no authorized personal information protection organization that we are a member of.

  1. Procedures for disclosure, etc.

If you have any requests for disclosure, etc., please contact the Personal Information Inquiry Desk above.

Please contact us. We will send you an explanation of the necessary procedures and the required application documents.

  1. Measures taken for the secure management of retained personal data, etc.

We have established rules and regulations regarding the handling of personal information and specified personal information, as well as rules and regulations regarding safety measures. We have implemented organizational, human, physical, and technical security control measures.

Special Provisions for California Residents

Moderato Inc. (hereinafter referred to as the "Company") has established the following policy regarding the handling of personal information of customers who use the Company's services.

The California Consumer Privacy Act of 2018 (hereinafter referred to as the "CCPA") and its amendment, the California Privacy Rights Act of 2020 (hereinafter referred to as the "CPRA"), establish the rights of California residents with respect to the personal information of such residents in their possession. 

If you are a California resident consumer, the Company will apply to you " Special Provisions for California Residents" (hereinafter referred to as the "Special Provisions"). Special Provisions are complementary to the Company’s “Privacy Policy" (hereinafter referred to as the "Policy"). 

In the event of any inconsistency between the Policy and the Special Provisions, the Special Provisions shall prevail. The Special Provisions shall also apply to consumers residing in other states to the extent consistent with or in conflict with the privacy Acts of such other states. 

The terms used in the Special Provisions shall have the same meanings as those expressly defined in the CCPA.

  1. Collection, use or disclosure of personal information

The Company may collect, use, or disclose the following categories of personal information in order to provide services to you. In addition, the personal information that may have been collected and may have been disclosed by the Company in the past 12 months is described below.

Personal Information/

Categories of Sensitive Personal Information and Examples

Categories of Sources

Business or commercial purposes

Categories of third parties to whom personal information is disclosed

Personal identification information

(Name, contact information (address, telephone number, fax number, e-mail address, and other unique identifying information), account name, and other similar identifying information)

・Directly from the individual

・Execution of a contract, or response to a request prior to the conclusion of a contract

・Responding to inquiries or requests to the Company

・Provision or improvement of our products and services

・Registration on our membership site, provision of membership services, analysis of usage, and quality improvement

・Payment for our products and services

・Handling of product warranty and quality issues

・Marketing

・Security Incident Detection

・Protection against fraudulent or illegal activities

・Third party business partners (including credit card companies, credit card processing agents, Internet service providers and service providers in the IT sector)

Commercial Information

(Details of inquiries, order details, information related to product purchases (purchase history, etc.), and details related to contracts)

・Directly from the individual

・Execution of a contract, or response to a request prior to the conclusion of a contract

・Responding to inquiries or requests to the Company

・Provision or improvement of our products and services

・Payment for our products and services

・Handling of product warranty and quality issues

・Marketing

・Security Incident Detection

・Protection against fraudulent or illegal activities

・Third party business partners (including credit card companies, credit card processing agents, Internet service providers and service providers in the IT sector)

Network Activity Information

(Information collected by cookies, web beacons, etc.)

・By using our site

・Passively obtained through activities on the customer's website

・Marketing

・Improvement of our website

・Advertising technology partners (advertising companies that collect by cookies, web beacons, etc.)

Sensitive personal information

・The contents of e-mails and other text messages sent and received through the Company's e-mail system

・Social Security Number

・Driver's License Information

・State ID card information

・Passport Information

・Credit Card Number

・Directly from the individual

・Execution of a contract, or response to a request prior to the conclusion of a contract

・Provision or improvement of our products and services

Payment for our products and services

・Provide service for product warranty and quality issues

・Marketing Activities

・Security Incident Detection

・Protection against fraudulent or illegal activities

・Third party business partners (including credit card companies, credit card processing agents, Internet service providers and service providers in the IT sector)

 

2. Retention period of personal information

The Company does not retain personal information for longer than is necessary for the purposes for which it was collected unless longer retention is required or permitted pursuant to law.

3. Sale and sharing of personal information

"Sale" means the sale, sell, lease, announcement, disclosure, distribution, making available, transfer or other conveyance by a business to a third party of a consumer's personal information, whether orally, in writing, by electronic means or otherwise, for the purpose of obtaining money or other valuable consideration.

"Sharing" means the share, leasing, publication, disclosure, distribution, making available, transferring, or otherwise communicating, whether in exchange for money or other valuable consideration, personal information of consumers by a business to a third party, orally, in writing, electronically or otherwise, for the purpose of cross contextual behavioral advertising. This includes any transaction between a business and a third party that does not involve the exchange of money for cross-context behavioral advertising.

The Company may place cookies, web beacons, etc. from our advertising technology partners on our site to collect network activity information, and our advertising technology partners may serve ads based on such information on our site or on the sites of other companies. The use of third-party cookies for marketing purposes may be defined as a "sale" of personal information under the CCPA. 

We do not "sale" or "share" personal information except as described above.

4. Rights of California residents

California residents have the rights described below. To exercise any of the rights described below, please contact “Contact Us". Please note that in order to respond to your request, we must obtain information from you to verify that you are a California resident, to determine whether we have personal information about you, and to verify your identity.

(1) Right to know about the collection, disclosure, sale or sharing of personal information

California residents have the right to request that we disclose the following personal information that we have collected, used, disclosed, sold, or shared within the past 12 months

(i) Categories of personal information and Sensitive Personal Information collected by the Company.

(ii) Categories of the sources from which such personal information is collected.

(iii) Business purposes for which personal information is collected, disclosed, sold, or shared.

(iv) Categories of third parties to whom we sell or share personal information in the event that we sell or 

share personal information.

(v) Categories of personal information that we have sold or shared with third parties.

(2) Right to request deletion or correction of personal information

California residents have the right to have their personal information that we have collected from them deleted or corrected. However, such personal information will not be deleted if we are required to retain it by law. For example, we may retain such personal information if it is necessary to provide you with the services you have requested, if it is necessary to provide you with assurances and security related to the services, or if it is necessary to comply with our legal obligations.

(3) The right to opt out of the sale or sharing of personal information

California residents have the right to instruct us not to sell or share their personal information.

(4) The right not to be discriminated against in the exercise of rights

California residents have the right not to be discriminated against or retaliated against for exercising their rights under the CCPA.

(5) Right to restrict use or disclosure of Sensitive Personal Information

California residents have the right to request that Sensitive Personal Information not be used or disclosed for any purpose other than the specific purpose required by law without their consent and be limited to only what is necessary to provide our products or services.

5. Procedure for claiming California resident's rights

(1) How to request

If you, as a California resident, wish to exercise any of the above rights of disclosure, deletion, correction, and nondiscrimination, please contact us by email or mail at the address listed under "Contact Us".

The Company may need to verify your identity before processing your request. In such cases, the Company may send a link to your e-mail address on file with us and request additional information to the extent necessary to verify your identity. Please be aware that as a result of exercising your right to delete your personal information, you may no longer be able to receive services provided by us using that information.

To exercise your right to opt-out of the sale or sharing of your personal information and to limit the use or disclosure of your Sensitive Personal Information, please see “Do Not Sell/Share My Personal Information “or “Limit the Use of My Sensitive Personal Information" if you wish to exercise your rights and restrict the use or disclosure of your Sensitive Personal Information. In addition, modern browsers support Global Privacy Controls (hereinafter referred to as the "GPC") settings that are recognized by U.S. websites. GPC settings, which are recognized by websites on the U.S. side of the world. When enabled in your preferences or browser extension, the GPC will send opt-out settings to these websites, informing them that you do not wish to have your personal information "sold" to them. For more information about GPC, including how to enable it in your specific browser, please click here.

Please be aware that as a result of exercising your right to opt-out of the sale or sharing of your personal information and your right to restrict the use or disclosure of your Sensitive Personal Information, you may not be able to receive the services we provide using that information.

(2) In the case of a request by an authorized agent

You may have a properly authorized agent exercise your rights on your behalf. The Company may ask the agent to provide us with a written document evidencing his/her authority of representation signed by the principal.

(3) For billing purposes

・If we are unable to verify your identity or authority to make a request with the degree of certainty required by the CCPA and related laws and regulations, we will not be able to respond to your request.

・The Company does not charge a fee for this service, but the Company asks that you bear the costs of preparing a document evidencing your authority of representation and contacting us.

・The Company will use and retain the personal information provided in response to your request only for the purpose of responding to your request and to the extent permitted by law.

6. Contact Us 

Inquiries regarding the Special Provisions or exercising your rights under the CCPA should be directed to one of the following:

(1) By e-mail

E-mail address: admin@moderato-inc.jp

(2) By mail

Address: VORT AOYAMAⅡ 3F, 2-1-12 Shibuya, Shibuya-ku, Tokyo

To: Moderato Inc.

7. Do Not Track "DNT" signal

Due to a lack of common agreement on the interpretation of DNT signals and how to respond to them, the Company does not currently support "Do Not Track" ("DNT") signals in web browsers.

8. Customers under 16 years old

The Company do not intend to collect, sell, or share personal information from customers under the age of sixteen. In the unlikely event that a customer under the age of sixteen provides us with personal information and such customer under the age of sixteen or his or her parent or guardian desires appropriate treatment under applicable law, he or she should contact the “Contact Us".

9. Updates and amendments to the Special Provisions

The Company reserves the right to update or modify the Special Provisions without prior notice. The updated or amended the Special Provisions shall supersede the rules in effect prior to the update or amendment.

[Amended September 13st, 2024]

Special Provisions for Nevada, Virginia, Colorado, Connecticut, and Utah Residents

Moderato Inc. (hereinafter referred to as the "Company") has established the following policy regarding the handling of personal information of customers who use the Company's services. 

The Nevada Privacy Act (SB 260) (effective October 1, 2021), the Virginia Consumer Data Protection Act (effective January 1, 2023), the Colorado Privacy Act (effective July 1, 2023), the Connecticut Personal Data Privacy and Online Monitoring Act (effective July 1, 2023), and the Utah Consumer Privacy Act (effective December 31, 2023), each Act establishes the rights of residents of each state with respect to such residents' personal information in their possession.

If you are a consumer residing in Nevada, Virginia, Colorado, Connecticut, and Utah, the Company will apply to you the "Special Provisions for Nevada, Virginia, Colorado, Connecticut, and Utah Residents".

The Special provisions for Nevada, Virginia, Colorado, Connecticut, and Utah Residents (hereinafter referred to as the "Special Provisions") are complementary to the Company’s "Privacy Policy" (hereinafter referred to as the "Policy"). In the event of any inconsistency between the Policy and the Special provisions, the Special Provisions shall prevail. 

The terms used in these Special provisions shall have the same meanings as those expressly defined in the privacy Acts of the respective states (collectively, the "State Privacy Laws").

1. The categories of Personal Data that we process, the purposes for which we process them, and the categories of Personal Data that we share with third parties and third parties

The statements under "1. Collection, use or disclosure of personal information" in the "Special Provisions for California Residents" apply to you as well. Please refer to those descriptions.

2. How to exercise your rights under applicable State Privacy Laws

You have the following rights, in whole or in part, or similar rights under applicable State Privacy Laws and subject to the definitions and limitations of such Laws.

(1)  The right to confirm whether we are processing your personal data and the right to access your personal data.

(2)  The right to correct inaccuracies in your personal data.

(3)  The right to delete personal data provided by you or collected from you.

(4)  The right to obtain a copy of any personal data you have previously provided to us in a portable and readily accessible format.

(5)  The right to opt out of the sale of your personal data or the processing of your personal data for targeted advertising purposes.

(6)  The right to opt out of profiling that facilitates decisions that have legal or similar material effects with respect to you.

You may exercise the above rights in substantially the same manner as set forth in "5. Procedure for claiming California resident's rights " of the "Special Provisions for California Residents".

In the event that the Company is unable to comply with your claim based on these rights in spite of your exercising the rights, the Company shall notify you of the reason and inform you of the method for filing an objection to the Company's decision. You may file an objection with us in accordance with the provisions of the State Privacy Laws.

[Established September 13rd, 2024]