Privacy Policy

■Handling of Personal Information

1. Purpose of Use of Personal Information Handled by Our Company

(1) Purpose of Use of Personal Information Acquired Directly from the Individual in Writing (including via homepage or email)

Prior to acquisition, we will clearly state the purpose of use to the individual in writing.

(2) Purpose of Use of Personal Information Acquired by Methods Other Than Those in

the Preceding Paragraph

① Customer information for the business of buying and selling brand-name goods, precious metals, and other items, acquired from Rakuten Ichiba, Mercari Shops, Yahoo! Auctions, eBay, etc.

・For communication and contact operations with customers for the purpose of introducing products and services, responding to related inquiries, and providing after-sales service.

・For determining the feasibility of secondhand goods transactions, and for managing the transaction status after such secondhand goods transactions have commenced.

・For the appraisal of secondhand goods, and for customer identity verification.

・For the prevention of fraudulent transactions.

② Video footage acquired by surveillance cameras installed in our facilities.

・For the maintenance and security of our company's assets and equipment.

2. About Security

When personal information is submitted through this website, we use an industry-standard encryption method called TLS (Transport Layer Security) to encrypt the information to protect it from unauthorized access by third parties.

Personal information that our company deems necessary is protected by TLS encrypted communication, and we strive to ensure its security.

In addition, personal information acquired by our company is strictly managed based on our prescribed management standards, and we have implemented measures, such as installing firewalls and maintaining antivirus measures, to prevent loss, destruction, alteration, leakage, and virus infection.

3. Regarding the Acquisition of Personal Information by Methods Not Easily Recognizable by the Individual

(1) This website utilizes a technology called "Cookies."

A "Cookie" refers to a mechanism that temporarily stores specific information as data on the communication device used by customers., and identifies the customer, etc., based on that data at each connection.

As our company provides services that are premised on the use of Cookies, please be aware of the possibility that if customers., do not permit the use of Cookies, they may be unable to use a part of our services.

Whether to permit the use of Cookies can be configured in the browser of the customer, etc., so please check your settings as necessary.

(2) Furthermore, our company's advertisements are displayed on various sites on the internet by third-party ad distributors, including Google.

However, customers., can visit the Google advertising opt-out page to disable the use of Cookies by Google (or visit the Network Advertising Initiative opt-out page to disable the use of Cookies by third-party distributors).

(3) Our company uses Google Analytics to improve the performance and services of this website for customers. The information of customers, collected, recorded, and analyzed by Google Analytics does not contain any information that identifies a specific individual. The collected and analyzed information is managed by Google in accordance with its privacy policy.

① Tool Provider: Google Inc.

② Information to be Acquired: The usage status of our company's website by customers. (access status, traffic, routing, etc.)

It is also possible to stop the collection of information of customers, by our company's use of Google Analytics by disabling Google Analytics in your browser's add-on settings. This can be done by downloading and installing the "Google Analytics Opt-out Add-on" from Google's opt-out add-on download page and changing your browser's add-on settings. Please note that if a customer disables Google Analytics, Google Analytics will also be disabled on websites other than this site that the customer visits, but it is also possible for the customer to re-enable Google Analytics by reconfiguring the browser's add-on.

Google Analytics Terms of Service

http://www.google.com/analytics/terms/jp.html

Google Privacy Policy

http://www.google.com/intl/ja/policies/privacy/

Google Analytics Opt-out Add-on

https://tools.google.com/dlpage/gaoptout?hl=ja

■Public Notice of Matters Concerning Retained Personal Data

With respect to the retained personal data or records of third-party provision held by our company, requests from the individual or their representative for notification of the purpose of use, disclosure, correction, addition or deletion of content, suspension of use, erasure, and suspension of provision to a third party (hereinafter referred to as "Requests for Disclosure, etc.") will be handled in accordance with the following procedures.

a) Name, Address, and Name of the Representative of the Business Operator

Name of Business Operator: CircLuxe Inc.

Address: 2-5-8 Kita-Aoyama, Minato-ku, Tokyo

Representative Director: Yasuto Saito

b) Personal Information Protection Manager

Manager Name: Futoshi Uemura

Department: General Manager, Administration Division

Contact: 06-6251-6653

c) Purpose of Use of All Retained Personal Data

① Customer information acquired in the business of buying and selling brand-name goods, precious metals, etc.

・For communication and contact operations with customers for the purpose of introducing products and services, responding to related inquiries, and providing after-sales service.

・For determining the feasibility of secondhand goods transactions, and for managing the transaction status after such secondhand goods transactions have commenced.

・For customer identity verification.

・For the prevention of fraudulent transactions.

・For coordinating purchase schedules, etc.

・For providing guidance and communication regarding events, and for the provision of related services.

・For marketing, research, and analysis for the purpose of improving the quality and enhancement of our products and services.

② Customer information acquired at events hosted or exhibited by our company.

・For providing guidance and communication regarding events, and for the provision of related services.

③ Business partner information

・For business negotiations and various business-related communications, order placement and receipt operations, and billing and payment operations.

④ Our company's employee information

・For personnel and labor management, business management, health management, and security management of employees.

⑤ Personal information regarding job applicants

・For contacting job applicants and for our company's recruitment management.

⑥ Specific Personal Information

・For the purposes of use stipulated by the "My Number" Act.

⑦ Inquiry information

・For responding to inquiries and sending notifications.

d) Point of Contact for Complaints Regarding the Handling of Retained Personal Data

【Gallery Rare Business Division】

Yotsubashi Star Bldg. 5F,

1-12-19 Minamihorie, Nishi-ku, Osaka-shi, Osaka 550-0015

CircLuxe Inc. Gallery Rare Business Division, Personal Information Inquiry Desk

E-mail: privacy@g-rare.co.jp

TEL: 06-6251-6653 (Reception hours: 11:00-19:00)

【Brandear Business Division】

Sankyu Heiwajima Logistics Center 5F,

3-3-8 Heiwajima, Ota-ku, Tokyo 143-0006

CircLuxe Inc. Brandear Business Division, Personal Information Customer Consultation Desk

E-mail: kanribu@defactostandard.co.jp

Responses for inquiries made on Saturdays, Sundays, national holidays, the year-end and New Year holidays, and during the Golden Week period will be handled on the next business day or thereafter.

e) Accredited Personal Information Protection Organization

Name of the accredited personal information protection organization to which our company belongs

:Japan Institute for Promotion of Digital Economy and Community (JIPDEC)

Point of contact for the resolution of complaints

:Personal Information Protection Complaint Consultation Service

Phone number: 03-5860-7565 / Toll-free: 0120-700-779

*This is not the contact for inquiries regarding our company's products, services, etc.

f) Procedures for Responding to Requests for Disclosure, etc. of Retained Personal Data

or Records of Third-Party Provision

1) Point of Contact for Requests for Disclosure, etc.

Please submit your Requests for Disclosure, etc. to the Personal Information Inquiry Desk mentioned above.

*Those who wish to request disclosure, etc. through electronic means, please state so. In principle, we will process your request as desired.

2) Procedures for Requests for Disclosure, etc.

① After receiving your request, our company will mail you the prescribed request form, "Request Form for Disclosure, etc. of Retained Personal Data."

② Please mail the completed request form, documents verifying the identity of the representative in the case of a request by a representative, and a postal money order for the fee (only for requests for notification of the purpose of use and for disclosure) to the Personal Information Inquiry Desk mentioned above.

③ After receiving the above request form, for the purpose of identity verification, we will inquire about approximately two items of personal information registered with our company that can be used for identity verification (e.g. telephone number and date of birth).

④ In principle, the response will be sent to the individual in writing (by sealed mail).

3) Documents to Verify the Identity of a Representative in the Case of a Request by a Representative

If the person making the Request for Disclosure, etc. is a representative, please enclose documents that prove the representative's authority and documents that prove the representative's own identity. For all documents, please limit the registered domicile information to the prefecture, and black out or otherwise process any subsequent information. Furthermore, please send documents that do not contain an Individual Number ("My Number"), or black out all digits.

① Documents to prove the representative's authority

The individual's power of attorney (original)

<In the case where the representative is a legal representative of a minor> A copy of one of the following:

Family register

Certificate of residence (with the relationship stated)

Other official documents that can confirm legal representation

<In the case where the representative is a legal representative of an adult ward> A copy of one of the following:

Certificate of registered matters concerning guardianship registration

Other official documents that can confirm legal representation

② Documents to prove the representative's own identity

Driver's license

Passport

Health insurance card (Please black out all digits of the insured person's symbol, number, etc., before submission)

Certificate of residence

4) Fee for Requests for Notification of the Purpose of Use or Disclosure

1,000 yen per request.

(For requests made on paper, please enclose a postal money order with the request form that you send. For requests made by other methods, we will consult with you at the time of the request.)

g) Details of the Personal Information Handling System and Measures Taken

1) Formulation of a Basic Policy

To ensure the proper handling of personal data, we have formulated a "Personal Information Protection Policy" concerning matters such as "Compliance with Related Laws, Regulations, Guidelines, etc." and a "Contact Point for Questions and Complaints."

2) Establishment of Regulations Pertaining to the Handling of Personal Data

We have established personal information protection regulations that stipulate the handling methods, responsible persons and their duties, etc., for each stage of acquisition, use, storage, provision, and deletion/disposal.

3) Organizational Security Control Measures

① We have appointed a person responsible for the handling of personal data, clarified the scope of employees who handle personal data and the personal data they handle, and established a system for reporting to the person responsible in the event that a fact or sign of a violation of laws or handling regulations is identified.

② We conduct regular self-inspections of the handling status of personal data and undergo audits by other departments and external parties.

4) Personnel Security Control Measures

① We provide regular training to our employees on matters to be aware of regarding the handling of personal data.

② We have included matters concerning the confidentiality of personal data in our work regulations.

5) Physical Security Control Measures

① In areas where personal data is handled, we manage employee entry and exit and restrict the equipment they bring in, and have implemented measures to prevent unauthorized persons from viewing personal data.

② We have implemented measures to prevent the theft or loss of equipment, electronic media, and documents that handle personal data, and have taken measures to ensure that personal data cannot be easily identified when such equipment and electronic media are carried, including when moving within the business premises.

6) Technical Security Control Measures

① We have implemented access control to limit the scope of persons in charge and the personal information databases, etc., that they handle.

② We have introduced a mechanism to protect the information systems that handle personal data from unauthorized access from external sources or from malicious software.