Privacy Policy
Introduction
Ryohin Keikaku Co., Ltd. ("we", "us" or "our") respects your privacy and is committed to protecting your personal data. This privacy notice (this "Privacy Policy") explains how we look after your personal data and tells you about your privacy rights.
Please also use the Glossary at the end of this Privacy Policy to understand the meaning of some of the terms used in this Privacy Policy.
<Table of Contents>
- 1. Important information and who we are
- 2. The data we collect about you
- 3. How is your personal data collected?
- 4. Purposes for which we use your personal data
- 5. Disclosures of your personal data
- 6. Cross-border data transfer
- 7. Data security
- 8. Data retention period
- 9. Your legal rights
- 10. Acquisition of camera images, etc.
- 11. Glossary
1. Important information and who we are
Purpose of this Privacy Policy
This Privacy Policy aims to give you information on how we collect and process your personal data when you use MUJI Passport (the "Application"), our website or our services.
We do not intend to knowingly collect data relating to children from children through the Application. However, if we have collected data relating to a child, we will process such data in accordance with applicable laws and regulations.
It is important that you read this Privacy Policy together with any and all notices we may provide on specific occasions so that you are fully aware of how and why we are using your personal data. This Privacy Policy supplements the other notices and is not intended to override them.
Management of your personal data
We are responsible for processing your data. Also, we inform you of the details of the Privacy Policy on behalf of the entire Ryohin Keikaku group (MUJI Group). Please see https://ryohin-keikaku.jp/eng/corporate/company.html for more information about the Ryohin Keikaku group companies.
If you have any questions about this Privacy Policy or to exercise your rights, please contact us at one of the following addresses.
Contact details
Full name of legal entity: Ryohin Keikaku Co., Ltd.
Contact Us: https://www.muji.net/contact/
Postal address: 4-26-3 Higashi-Ikebukuro, Toshima-ku, Tokyo
You have the right to make a complaint at any time to the supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority. You may contact us by sending us an email to the email address set out in the "Contact details" or by sending us a letter by mail to the postal address set out in the "Contact details". We will respond to your complaint appropriately, in accordance with applicable laws and regulations.
We have appointed a data protection officer within the EU in accordance with the General Data Protection Regulation (GDPR) of the EU. If you have any questions about processing of data for our businesses in Europe, please contact us at the following email address:
Changes to the Privacy Policy
This Privacy Policy was last updated on 2 April 2019
We reserve the right to change this Privacy Policy anytime to the extent permitted by applicable laws and regulations. We will notify you of any significant changes to this Privacy Policy by posting to our website (http://ryohin-keikaku.jp/) or by any other means we determine appropriate. The changed terms will come into force when we notify the users by such appropriate means as determined by us or when the terms are displayed on our website.
Also, it is important that the personal data we hold about you is accurate and current, so please keep us informed if your personal data changes.
Third‐party links
The Application, our website and our services may include links to third‐party websites, plug‐ins, and applications. Clicking on those links may allow third parties to collect data about you. We do not control these third‐party websites and are not responsible for their processing of personal data. We encourage you to read the privacy policy of such third-parties.
2. The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- CV Data includes details about your past employment, your contact details, your address and your phone number.
- Technical Data includes internet protocol (IP) address, your account login data, browser type and version, time zone setting and location, browser plug‐in types and versions, operating system, platform and the Application and other technology on the devices you use to access our website.
- Account Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your preferred method to receive such marketing communications.
For the purpose of this Privacy Policy, personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data anonymised pursuant to applicable laws ("Anonymised Data"). With respect to Anonymised Data, we collect and use statistical data such as statistical demographic data. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific app or website feature. The data underlying the Statistical Data may be derived from your personal data but is not considered personal data in law as this data generally does not directly or indirectly reveal your identity. However, if we combine or connect Statistical Data with your personal data so 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 Notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
In accordance with applicable laws and regulations, we will ask you to provide your personal data to us upon confirming that the personal data that you provide to us is accurate and current, and that when you provide us with personal data about any person other than you (if any), the consent of such person is obtained.
If you fail to provide personal data
Where we need personal data by law, or where we need personal data for our services and you fail to provide that personal data, we may not be able to provide you with goods or services. In this case, we may have to cancel your order but we will notify you if this is the case.
3. How is your personal data collected?
We use the following methods to collect data about you:
- Direct collections. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications including MUJI Mail;
- request marketing information be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
- Automated technologies. As you use the Application, our website or our services, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Technical Data from the following parties:
- (a) analytics providers such as Google;
- (b) search information providers such as Google.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services
- Identity and Contact Data from publicly availably sources.
- Applying for a career with us and our group companies by way of email. You would normally provide your CV to us when applying for a career with us and our group companies.
4. Purposes for which we use your personal data
Most commonly, we will use your personal data in the following circumstances, to the extent permitted by laws and regulations:
- Where we must use your personal data to in order to fulfill our performance of contract with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those legitimate interests.
- Where we are obligated to use your personal data in order to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data and the legal basis therefor (in detail)
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where necessary under applicable laws and regulations.
If express consent for collection, use, disclosure and processing of personal data for certain purposes is required by applicable laws and regulations, we will collect, use, disclose and process personal data upon obtaining express consent. However, to the extent permitted by applicable laws and regulations, you will be deemed to have consented to our collection, use, disclosure and processing of your personal data for certain purposes when you provide your personal data to us in accordance with this Privacy Policy.
Note that we may process your personal data pursuant to more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
<Legend>
Purpose / Activity
- Type of data
- Lawful basis for processing including basis of legitimate interest
To register you as a new customer
- (a) Identity (b) Contact
- Performance of contract with you
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (c) Transaction information
- (a) Identity (b) Contact (c) Transaction
- (a) Performance of contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey
- (a) Identity (b) Contact (c) Profile (d) Marketing and Communications
- (a) Performance of contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
- (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications
- Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
- (a) Identity (b) Contact (c) Technical
- (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with legal obligations
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
- (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical
- Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
- (a) Technical (b) Usage
- Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
- (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile
- Necessary for our legitimate interests (to develop our products/services and grow our business)
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will carry out marketing and advertising for clothing products, fashion accessories, household goods, food products and any other products we sell and/or services we provide, in accordance with applicable laws and regulations.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
However, when we send you voice mails, text messages or fax messages for the purpose of advertisements, promotions or offers in relation to products or services, if opting in is required by applicable laws and regulations, we will comply with such laws and regulations by providing a checkbox.
Third‐party marketing
We will get your express opt‐in consent before we share your personal data with any company outside the MUJI Group of companies for marketing purposes. If express prior consent is required by applicable laws and regulations when sharing your personal data with a MUJI Group company, we will comply with such laws and regulations by obtaining your express prior consent.
We will not sell, distribute or lease your personal data to third parties unless we have your permission or are required by law to do so.
Opting out
You can ask us to stop sending you marketing messages at any time by:
- following the opt‐out links on any marketing message sent to you; or
- by contacting us at any time.
You can also request to opt‐in or to opt‐out of receiving MUJI Mail on your online account.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please refer to the following.
| Types of Cookies | Explanation | Purpose of Use |
|---|---|---|
| 9834CF25B413A61DF9E00C08B7177BA6skey | Secure session key | Marketing |
| IKKNM | Cookie for load balancer | |
| JSESSIONID | FrontAP session ID | |
| Atkey | Auto log-in | |
| Encsid | Encryption session ID (Used for API-GW request) | |
| Lkey | Logged-in member identifier | |
| Mchat | accessToken delivered to review API call parameter | |
| Nlkey | Non-logged in member identifier | |
| Prvsid | Pre-Encryption session ID (Used for API-GW request) |
Change of purpose
Generally we will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason to the extent permitted by applicable laws and regulations and that reason is compatible with or directly relevant to the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. Please note that we may process your personal data without your knowledge, where this is required or permitted by law.
5. Disclosures of your personal data
We will not provide personal data to any third party without obtaining prior consent of the data subject, except if it is:
- (1)
- in accordance with laws and regulations;
- (2)
- necessary to protect lives, bodies or properties and is difficult to obtain consent of the data subject;
- (3)
- particularly necessary for improvement of public health or promotion of sound upbringing of children and is difficult to obtain consent of the data subject; or
- (4)
- necessary for cooperating with a national agency or local government or any person who is engaged by them in their performance of the services set forth under laws and regulations and obtaining consent of the data subject may interrupt performance of such services.
Supervisor of contractor
We engage third parties for the processing of personal data, in whole or in part, within the scope of purpose of use, in relation to system development, maintenance and other services. In such cases, we appoint a person accredited to process personal information properly in accordance with the security measures of such third party, properly stipulate regarding security, confidentiality, subcontracting and other matters regarding processing of personal data in a services agreement, understand the circumstances of processing of personal data by such third party, and provide necessary and appropriately supervision.
Shared use
For the purposes as set out in "4. Purposes for which we use your personal data", we may share your personal data with a third party.
For more information about the items to be shared and the scope of such sharing, please refer to the following.
- Shared personal data item(s)
IP Address - Scope of persons with whom we share information
Internal third parties listed in the glossary:
Office Kuroko & Co.
IREP Co., Ltd.
UNCOVER TRUTH Co., Ltd. - Purpose of [use by] joint user
- Delivering relevant website content and advertisements to you, and measuring or understanding the effectiveness of advertisements delivered to you.
- Using data analytics to improve our websites, products/services, marketing, customer relationships and customer experience
- Persons responsible for the management of shared personal data
Ryohin Keikaku Co., Ltd.
We require third parties to respect the security of your personal data and treat the same in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes, but only for specified purposes and in accordance with our instructions.
6. Cross-border data transfer
We may transfer your personal data outside of the country.
Whenever we transfer your personal data outside of the country, we will protect your personal data by implementing safeguards as set forth by laws and regulations.
Also, when required by the laws and regulations of the country from which the data is transferred, we ensure that the foreign corporation, etc. receiving the personal data provides at least the equivalent level of protection as the laws and regulations of the country from which the data was transferred.
We store and process your personal data in Japan. In the countries to which your personal data is transferred, the laws of such foreign countries, which differ from the laws and regulations of your country, are applicable to such transferred personal data. Furthermore, there is a possibility that your personal data may be accessed, without notice to you, by courts, governments, executive agencies, regulatory agencies, and public security agencies in the country to which your personal data is transferred.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit the granting of access to your personal data to persons 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.
8. Data retention period
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, or for the purposes of satisfying any legal requirements. We usually keep your personal data for two years after you cease being a customer.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
We hold and store the personal data collected in electromagnetic form on servers either owned by us or owned by third parties which have contracted with us.
In some circumstances, pursuant to applicable laws and regulations, you can ask us to delete your personal data: see Right to erasure of personal data below for further information.
If required by applicable laws and regulations, when personal information is no longer necessary due to expiration of personal information retention period, achievement of purposes of processing or otherwise, we will discard such personal information without delay. When we need to continue keeping personal information pursuant to other laws and regulations, despite expiration of personal information retention period consented to by you or purposes of processing are achieved, we will transfer such personal information to separate database (DB) or keep such personal information at a separate storage place. We will select personal information that has a reason to be discarded and discard the personal information upon obtaining approval of our personal information protection officer. We will discard personal information recorded or stored in a form of electronic file by means that such record cannot be reproduced and discard personal information recorded or stored in a form of printed material by shredding or incinerating.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. To find out more about these rights, please refer to the items of the Glossary below:
- Request access to your personal data.
- Request correction of your personal data.
- Request deletion of your personal data.
No fee required (as a general rule)
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a fee of JPY 1,000 (including consumption tax) for each request if your request is clearly unfounded, repetitive, or excessive. Alternatively, in such circumstances, and when permitted under applicable laws and regulations, we may refuse to comply with your request.
What we may need from you
We may need to request specific information from you to help us confirm your identity before we respond to any requests. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also ask you for further information to speed up our response.
Time required for response
We try to respond to all requests and questions within one month. If your request or question is complex or you have made a number of requests or asked a number of questions, please note that it may take us longer than a month to respond. We will notify you if this is the case.
In cases where a different time required for response is set out under applicable laws and regulations, we will comply with such laws and regulations.
10. Acquisition of camera images, etc.
We sometimes analyze camera images to improve product displays and product assortments.
In this case, we will analyze the customer's in-store activity history.
In this initiative, we will use video information from in-store cameras to investigate appropriate layouts, enhance product assortments, and prevent missing product shelves.
Images of cameras in stores are not saved, but data indicating customer characteristics are extracted immediately, and the position and behavior in front of the shelves in the customer's store are used as coordinate values.
This coordinate value is used to analyze the movement and retention conditions in the customer's store and the products taken from the shelves.
Characteristic data is discarded at the same time as the coordinate value is obtained, and the data estimating the customer's action history does not include personally identifying information.
Data will be used only by our group and will not be provided to other companies.
- Shooting time: during our store business hours
- Data to be acquired, processed, estimated, and analyzed from images
[Acquisition]
Full-body images, including customer's faces
[Processing]
Data showing the customer's characteristics generated from the whole-body image, including the face
[Estimation]
Gender, age
[Analysis]
In-store transportation and retention conditions, and the products that customers have picked up
11. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we have assessed our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your personal data where it is necessary for the performance of obligations under a contract to which you are a party, or for the performance of obligations under a contract intended to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Internal Third Parties means other companies in the MUJI Group (for more information, please see https://ryohin-keikaku.jp/eng/corporate/company.html) acting as controllers or processors and providers of IT and system administration services.
Cookies are small text files which are sent by a webserver to the browser of your computer or mobile device when you access a website, and then stored on the hard drive of your computer or mobile device.
YOUR LEGAL RIGHTS
With regard to your personal data, you have the following rights:
Access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are processing it lawfully.
Correction of personal data. This enables you to request that we correct or delete any incomplete or inaccurate personal data that we hold about you or add the complete or accurate personal data to the data that we hold about you, though we may need to verify the accuracy of the new data you provide to us.
Right to delete of your personal data. This enables you to request that we discontinue the utilization of or delete your personal data if (a) we use your personal data in violation of the restrictions imposed by the purpose of use, or (b) we do not acquire your personal data properly. In addition, if we illegally provide your personal data to a third party, you may request that we discontinue the provision to a third party.