隱私政策

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.

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]

 

Special Provisions for Hong Kong Residents　    

Established November 12, 2024 

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. 

This Privacy Policy applies to the SOÉJU online store and the App and when you share your Personal Data with us through our in-store subscriptions, by e-mail by phone, or via other voluntary means in Hong Kong (hereinafter referred to as the “Site”).

It explains how we may collect, use, and disclose your Personal Data, including our obligations and your rights in respect of our dealings with your Personal Data under the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (hereinafter referred to as the “PDPO”) and our privacy policy. We understand the importance of protecting your personal information and pledge to comply with the PDPO.

If you are a Hong Kong resident consumer, the Company will apply to you " Special Provisions for Hong Kong 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 terms used in the Special Provisions shall have the same meanings as those expressly defined in the PDPO and the RMC.

1.     Collection, use or disclosure of personal information

1.1　The Company may collect, use, or disclose the following categories of personal information in order to provide services to you.

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)

1.2　 We may collect, use, and share aggregated data such as statistical or demographic data for any other purpose. However, if we combine or connect aggregated data with your personal data such that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

1.3　 Please note that it is mandatory for you to provide certain categories of Personal Data (as specified at the time of collection). In the event that you do not provide any Personal Data marked as mandatory, we may not be able to process your request or provide you with our products or services.

2 . Data Storage and Security

2.1 To fulfil your order and to provide services to you, we may transfer your collected data to storage outside of Hong Kong. We are currently storing all collected data at our service provider’s server located outside of Hong Kong. If we do store or transfer data outside of Hong Kong or the region where you live, we will take all reasonable steps to ensure that your data is treated safely and securely in compliance with applicable data privacy laws. Your acceptance of the Policy shall be your consent permitting us to store or transfer data to and from outside of Hong Kong or the region where you live if it is for our legitimate business purposes.

2.2 Data security is important to us. To protect your data, we have put in place suitable physical, electronic, and managerial measures to prevent unlawful or accidental destruction, accidental loss, unauthorized disclosure or access or other unlawful forms of processing. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

2.3 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

2.4 Notwithstanding the security measures that we take, the transmission of data via the Internet may not be completely secure and we advise you to take suitable precautions when transmitting data to us via the Internet. You understand that no data transmission over the Internet can be guaranteed as totally secure. Although we strive to protect such information and your personal data, we do not warrant and cannot ensure the security of any information which you transmit to us. Any information which you transmit to us is transmitted at your own risk. We disclaim any liability for any theft, loss of, damage or unauthorized access of any data or communications. By using the Site, you acknowledge that you understand and agree to assume these risks.

2.5 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 the PDPO.

We may however be required to retain personal data for a longer period to ensure we comply with legislative and regulatory requirements. We will review our data retention obligations to ensure we are not retaining data for longer than we are legally obliged to.

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 Laws.

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

4. Rights of Hong Kong residents

Hong Kong 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 Hong Kong resident, to determine whether we have personal information about you, and to verify your identity.

(1) You have the right to do the following:

(a)request access to, deletion of or correct, your personal data held by us;

(b)request that your personal data be transferred to another person;

(c)be informed of what data processing is taking place;

(d)restrict processing;

(e)to object to the processing of your personal data;

(f)complain to a supervisory authority; and

(2) You shall note that under section 19(1) of the PDPO, the data access request would be complied with within 40 days after receiving such request. If the request is unable or has valid grounds to refuse to comply, in accordance with the section 19(2) or 21(2) of the PDPO, we will give you a notification of such matter within the same 40 days period.

(3) We reserve the right to charge you a reasonable fee for complying with a data access request as

permitted by the applicable laws.

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

Hong Kong residents have the right not to be discriminated against or retaliated against for exercising their rights under the laws that apply to their place of residence.

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

Hong Kong 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 the PDPO without their consent and be limited to only what is necessary to provide our products or services. 

5. Procedure for claiming Hong Kong resident's rights

(1) How to request

If you, as a Hong Kong resident, wish to exercise any of the above rights of disclosure, deletion, correction, and nondiscrimination, please contact us by e-mail 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 LAWS 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 the PDPO.

6. Contact Us

Inquiries regarding the Special Provisions or exercising your rights under the LAWS 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 150-0002, Japan

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 does 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 laws, he or she should contact the “Contact Us". 

9. Disclosure to Third Parties

(1) We may disclose, use or transfer (including cross-border data transfers) your Personal Data to third parties, including our parent company, subsidiaries, and affiliates, in order to accomplish the purposes described in Purpose of use of personal information.

(2) If we disclose, use, or transfer your Personal Data to third parties, we will implement appropriate agreements and other appropriate measures with such third parties to ensure compliance with this Privacy Policy and applicable privacy laws.

(3) We may provide aggregated, non-personally identifiable data to third parties for the purpose of understanding your needs and improving our products and services (including for marketing and advertising purposes).

(4) If we deem it necessary to provide your personal data to third parties for reasons other than those set forth in this section, we will notify you and proceed only if you have indicated your consent/no objection.

(5) we will take prompt and all appropriate steps to address the risk of suspected fraud, threats to personal safety, or any other violation or potential violation of our Terms of Use or relevant laws.

(6) by providing us with your personal information through the Site or otherwise, you expressly authorize us to use your personal information. If you do not consent to the provision of your information to third parties, please do not proceed.

10. Updates and amendments to the Special Provisions

10.1 The Company reserves the right to update or modify the Special Provisions without prior notice. In the event that we use personal data for the purpose of automated decision-making and those decisions have a legal (or similarly significant) effect on you, you have the right to challenge such decisions under applicable laws, requesting human intervention, expressing your own point of view, and obtaining an explanation of the decision from us.

10.2 The right described in this section does not apply in the following circumstances:

  (a) the decision is necessary for the entry into, or performance of, a contract between you and us;

(b) the decision is authorized by law; or

(c) you have given your explicit consent.

10.3 Changes to the Privacy Policy

We may change our Privacy Policy from time to time. Any changes we may make to our Privacy Policy in the future will be posted on the Site and, where appropriate and feasible, may be notified to you by e-mail.

隱私權政策

1. 歡迎您光臨SOÉJU(以下簡稱「本網站」)，本網站由日商摩德拉拾股份有限公司（即Moderato Inc.）（以下簡稱「本公司」）所經營之網站。為了幫助您瞭解本網站如何蒐集、處理、利用及保護您所提供的個人資料，在訪問本網站之前，請您詳細閱讀本隱私權政策及相關條款。

當您開始使用本網站服務或在本網站輸入個人資料時，將視為您已清楚瞭解並同意本隱私權政策及相關條款。

1. 本公司會根據服飾零售、個人造型服務、化妝品銷售等業務內容及規模，適當地取得、使用及提供個人資料，並且不會超出已特定的使用目的範圍來處理個人資料。

2. 本公司以合法公正的方法取得個人資料。

3. 本公司依照法律告知蒐集目的，除法律另有規定外，本公司僅在下述蒐集目的範圍内使用個人資料。

4. 針對個人資料可能面臨的洩漏、遺失、損毀等風險，本公司將採取合理的安全管理對策，建立預防機制與體制，並持續改進。此外，若發生意外，本公司將迅速採取糾正措施。

5. 除下述告知範圍或法律另有規定外，本公司不會將個人資料提供給第三人。

6. 本公司在接獲顧客本人提出個人資料的確認、修正、停止使用、刪除等相關要求時，將會依相關法律及本隱私權政策（以下簡稱「本政策」）妥適處理。

7. 本公司將及時、誠實地應對有關個人資訊處理的投訴和諮詢。

8. 本公司將根據公司周圍環境和實際情況的變化，及時、適當地審查並持續改進個人資訊保護管理系統。

1. 本政策的適用範圍

本政策說明了本網站如何處理在您使用網站服務時所收集的個人資料。本政策不適用於本網站以外的相關連結網站，也不適用於未經本公司授權或管理的第三方人員。

1. 個人資料權益告知

本公司依據個人資料保護法（以下簡稱「個資法」）第八條第一項規定，向您告知下列事項，敬請詳閱：

1. 資料蒐集之目的（本公司將依下列特定目的，蒐集您的個人資料）：

1. 顧客相關個人資料

• 契約、類似契約或其他法律關係事務。

• 消費者、客戶管理與服務。

• 為分析和分類獲得的顧客資訊及用戶資訊，製作趨勢數據和行銷數據（包含為商品促銷、新商品開發所進行之市場調查、資料統計、研究開發新服務等），以改善本公司服務的策略。

• 廣告或推廣（包含發送郵件和電子郵件）本公司的服務或第三方的服務。

• 使用 Google、Yahoo等廣告服務供應商散佈行為定位廣告。

• 資（通）訊與資料庫管理（為進行本公司服務中的身份確認、製作無法識別個人身份的統計數據等）。

• 網路購物及其他電子商務服務。

• 其他經營合於營業登記項目或組織章程所定之業務。

• 為提供本公司商品或服務（包含個人造型服務、化妝品服務及本公司其他服務）。

• 向本公司的造型師合作夥伴提供信息，以便提供本公司服務。

• 進行抽獎、活動、生日優惠卷等。

• 為回覆您的詢問。

• 為提升本公司服務品質（包含瞭解本公司服務的使用狀況、結果及收集您的需求）。

• 為提供本公司商品或服務資訊。

• 為本公司服務中的本人身分驗證

• 調查並應對合約、使用條款等禁止的行為。

1. 應徵者相關個人資料

• 錄用、徵才活動之應徵者的聯絡及有關本公司運營及錄取訊息提供。

• 將徵才過程的記錄作為對求職者的資料管理。

• 為辦理入職手續。

1. 職員相關個人資料

• 為進行人事管理(包含徵才、錄用活動、離職及所屬員工基本資訊、現職、學經歷、薪資待遇、差勤、福利措施或其他人事措施)。

• 為支付薪資、獎金等。

• 為業務聯絡。

• 為向政府機關進行申報及報告（包含全民健康保險、勞工保險或其他社會保險、團體保險）。

• 健康管理。

• 為調查和應對違反就業相關規定、聘雇合約等行為。

1. 業務委託方資訊

• 用於商務溝通（業務聯絡）。

• 為支付業務委託費用等。

• 為調查和應對違反合約等行為。

1. 個人資料之類別：

根據您使用本網站的目的和需求，本公司將會蒐集和使用以下類別的個人資料。本公司亦可能根據您的需求調整所收集的資料類別，以便提供更適合的服務：

1. 基本資料：姓名、性別、出生日期、地址、電話、職稱、電子郵件、網路平台帳號及其他可識別您的個人資料。

2. 財務資料：金融機構帳戶之號碼與姓名、信用卡之號碼、個人之其他號碼或帳戶等辨識財務之資料。

3. 法定資料：依法律要求必須收集的資料類別，例如根據稅捐稽徵法規定，您於辦理退貨時，需要提交的銷貨退回單及相關個人資料。

4. 其他相關資料：個人相關描述及身體描述、消費習慣及其他以便本公司提供服務的個人資料。

1. 個人資料利用之期間、地區、對象及方式：

1. 期間：本公司將於完成本服務所述目的之必要期間內保留您的資料，除非必要得允許或法律規定可保留更長之期間。

2. 對象：本公司、本公司國內外代理品牌企業、國內外集團關係企業、宅配貨運業者、信用卡公司、金融聯合徵信中心、業務委外單位、未受中央目的事業主管機關限制之國際傳輸個人資料之接收者、依法有調查權機關或金融監理機關。

3. 地區：中華民國境內及前揭利用對象之所在地。

4. 方式：以自動化機器或其他非自動化之利用方式，包含國際傳輸。

1. 非經您同意或未依法令規定者，本公司不會擅自修改任何您的個人資料。此外，依據個資法第三條規定，就本公司所登錄或保存您的個人資料，您得行使下列權利：

1. 請求查詢、閲覧或製作複本。但本公司得酌收必要之成本費用。

2. 請求補充或更正個人資料。

3. 通知本公司停止蒐集、處理或利用個人資料。個人資料正確性有爭議時，原則上依您的請求停止處理或利用。但因執行業務所須並註明其爭議或經您書面同意者，不在此限。

4. 請求刪除個人資料。個人資料之蒐集目的消失或期限屆滿時，依您的請求刪除個人資料、停止處理或利用個人資料。但因執行業務所須或經您書面同意者不在此限。

1. 不提供個人資料所致權益之影響：

若您不願意提供各服務或交易所要求的相關個人資料予本公司，且不同意本公司就該等個人資料依法令規定、以及本政策內容為相關之個人資料蒐集、處理、利用及國際傳輸，本公司將尊重您的決定，但依照各該服務之性質或條件，您可能因此無法使用該等服務或完成相關交易，本公司並保留是否同意提供該等相關服務或完成相關交易之權利。

1. 與第三方共用個人資料之政策

本公司絕不會提供、交換、出租或出售任何您的個人資料給其他個人、團體、私人企業或公務機關，但有法律依據或合約義務者，不在此限。

前項但書之情形包含不限於：

1. 經由您書面同意。

2. 法律明文規定。

3. 為免除您生命、身體、自由或財產上之危險。

4. 與公務機關或學術研究機構合作，基於公共利益為統計或學術研究而有必要，且資料經過提供者處理或蒐集者依其揭露方式無從識別特定之當事人。

5. 當您在網站的行為，違反服務條款或可能損害或妨礙網站與其他使用者權益或導致任何人遭受損害時，經網站管理單位研析揭露您的個人資料是為了辨識、聯絡或採取法律行動所必要者。

6. 有利於您的權益。

7. 本公司委託廠商協助蒐集、處理或利用您的個人資料時，將對委外廠商或個人善盡監督管理之責。

1. 適當取得個人資訊

在獲取個人資訊時，本公司將以適當且公平的方式進行。此外，除非本公司事先獲得您的同意或相關法律允許，否則本公司不會取得任何您的特定個人資訊。當您將線上商店或其他公司服務的帳戶與第三方服務（Google、Facebook、LINE 等）的帳戶連結時，本公司將獲得您的特定個人資訊（ID、姓名和電子資訊等）。

1. 關於cookies和Google Analytics之使用

1. 將訪問網站的訪客訊息在電腦（硬碟驅動器）及APP上進行紀錄管理的技術被稱作「Cookie」。在本網站中，為使顧客能便利地使用本網站，將有使用Cookie技術的頁面。透過變更瀏覽器對Cookie的使用設定而拒絕使用Cookie時，可能導致商品購買等服務之全部或一部無法利用。

2. 本公司使用Google Analytics 來瞭解網站的使用情況。有關Google Analytics的更多信息，包含資料收集和處理方法，請參閱以下網址。

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

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

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

1. 跨境傳送

本公司向您蒐集到的個人資料可能會在您所在國家以外之國家進行儲存或處理，其資料保護法規可能與您所在國家不同。您同意本公司得移轉、儲存、運用您的個人資料至其他國家。將您的個人資料跨境傳輸時，本公司會遵循本政策來保護您的個人資料。

1. 資訊安全

本公司會採取適當的安全措施，來防止未經授權的資料存取、竄改、披露或損毀，其中包含就資料的蒐集、儲存、處理慣例和安全措施進行內部審查，以及實體的安全措施，以防止本公司儲存個人資料的系統遭到未經授權的存取。但網際網路資料的傳輸不能保證百分之百的安全，儘管本公司努力保護您的個人資料安全，然因資料傳輸過程牽涉您上網環境保全之良窳，本公司無法確信或保證您傳送或接收本公司服務平臺資料的安全，您仍須注意並承擔資料傳輸之風險。

1. 自我保護措施

請妥善保管您的帳號、密碼及任何個人資料，不要將任何個人資料，尤其是密碼提供給任何人。若您完成登入本網站並使用後，務必記得登出帳戶，若您與他人共用電腦或使用公共電腦，務必要關閉瀏覽器視窗，以防止他人讀取您的個人資料或信件。

1. 未成年人保護：

未滿十八歲之未成年人於註冊或使用本網站服務，同意本公司蒐集、利用其個人資訊時，應按其年齡由其法定代理人代為或在法定代理人之同意下為之。

1. 免責聲明

1. 本公司就本網站服務不負任何明示或默示之擔保責任，且不保證本網站服務之穩定、安全、無誤及不中斷，亦不保證本網站資訊內容之正確、完整及適當得宜。

2. 本網站如有無法使用、失誤刪除、備份儲存失敗等情形，致生有直接、間接、衍生、或特別損害等，本公司均不負任何賠償責任。

1. 隱私權政策之修訂

為因應本公司服務內容及/或相關法律規範之變更，本公司將可能不定時修訂本政策之內容，並於本網站上通知及公告修訂之內容。除法律另有規定外，如您於本政策修訂後繼續使用本服務，將視為您已閱讀、瞭解並同意本公司對於本隱私權保護政策之修訂。

1. 問題與建議

若您對本公司隱私權政策或資料處理方式有任何問題或疑慮，或是想要針對可能違反隱私權法律的情況提出申訴或建議，敬請透過客服信箱與本公司聯絡。

【個人資料相關諮詢窗口】

〒150-0002　東京都渋谷区渋谷2-1-12VORT AOYAMAⅡ 3F

Moderato Inc. 日商摩德拉拓股份有限公司     　

個人資料相關諮詢窗口

mail： admin@moderato-inc.jp

電話號碼：03-6416-3089

制定日：2024年10月31日（民国113年10月31日）