Privacy and Cookies Policy

Effective date: May 24, 2018

ZenGroup INC ("us", "we", or "our") operates the http://zenpop.jp website (the "Services").

In this privacy & cookies policy ("Policy"), we describe the information that we collect about you, that you provide to us, is provided to us by third parties and will be processed by us, as you use this website (our "Website") and the Services available through this Website (collectively, our "Services").

We collect and use data to provide and improve our Services. By using the Services, you agree to the collection and use of information in accordance with this policy.

Definitions

• Services

Services is the http://zenpop.jp website and Services it provides, operated by ZenGroup INC

• Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

• Usage Data

Usage Data is data collected automatically either generated by the use of the Services or from the Services infrastructure itself (for example, the duration of a page visit).

• Cookies

Cookies are small pieces of data stored on your device (computer or mobile device).

• Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

• Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.

We may use the Services of various Service Providers in order to process your data more effectively.

• Data Subject (or User)

Data Subject is any living individual who is using our Service and is the subject of Personal Data.

Regarding compliance with laws and guidelines relating to the handling of personal information

Whenever handling personal information we do so strictly in line with relevant laws, legal guidelines, and any other responsibilities established within the jurisdiction of the relevant administrative agencies, as well as complying with internal policies and norms established by our Terms and Conditions. We strive to guard and safely use the Client's personal information in line with the laws and regulations set out by the below groups.

What data we collect:

We collect several different types of information for various purposes to provide and improve our Services to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally, identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Actual Address, State, Province, ZIP/Postal code, City
• Billing Address, State, Province, ZIP/Postal code, City
• Cookies and Usage Data
• Your IP addresses
• IP Address geolocation

Social Logins: ZenGroup also allows Users to login using social accounts like Facebook and Google. If you choose to login using your social media profile, some of your Personal Data from that profile will be shared with us. This includes but is not limited to your name, email address, social profile URL's and associated profile photos.

Usage Data

We may also collect information how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Services and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Services.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.

Examples of Cookies we use:

• Session Cookies. We use Session Cookies to operate our Services.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
• Security Cookies. We use Security Cookies for security purposes, including your login information protection and fraud prevention.

How we use your Data

ZenGroup INC uses the collected data for various purposes:

• To validate your identity.
• To provide and maintain our Services.
• To notify you about changes to our Services.
• To allow you to participate in interactive features of our Services when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our Services.
• To monitor the usage of our Services.
• To detect, prevent and address technical issues
• To detect, prevent and address fraudulent activities
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
• We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), ZenGroup INC legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

ZenGroup INC may process your Personal Data because:

• We need to perform a contract with you
• We need to deliver you the Services and goods you ordered
• You have given us permission to do so
• The processing is in our legitimate interests and it's not overridden by your rights
• For payment processing purposes
• To comply with the law of Japan and International Law

Retention of Data

ZenGroup INC will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, Tax Code of Japan), resolve disputes, and enforce our legal agreements and policies.

ZenGroup INC will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside Japan and choose to provide information to us, please note that we transfer the data, including Personal Data, to Japan and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

ZenGroup INC will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Consignment of Personal Data

In order to provide the smoothest possible service to the Client, personal data may in some cases be consigned to other companies which are cooperating in providing the Services. However in all cases were personal data is consigned to a cooperating company, the least possible amount of data will be provided.

Additionally; in all cases where personal data is consigned to a cooperating company, it is done only with the confirmation that said company upholds a Privacy Policy at a level equal to or in excess of our own.

Sharing of Personal Data

Personal information will never be shared with a 3rd party, except in the following cases:

• When there is prior expressed permission from the Client
• When outsourcing is necessary to fulfill the Client's purpose for using the site
• When required to do so by law
• To protect the life, wellbeing, and property of any individual, including cases where the Client's permission cannot be confirmed
• When necessary for public wellbeing, or to guard the well-being and development of children/minors, including cases where the Client's permission cannot be confirmed
• When necessary to carry out a duty which has been legally ordered by the government or other public organization, where acquiring the Client's permission may impede in carrying out that duty
• In such a case where the 3rd party is recognized as an authorized party and/or joint user of the data

Disclosure of Data

Disclosure for Law Enforcement

Under certain circumstances, ZenGroup INC may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

ZenGroup INC may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of ZenGroup INC
• To prevent or investigate possible wrongdoing of fraudulent activity in connection with the Services.
• To protect the personal safety of users or the public
• To protect against legal liability

Procedures Regarding the Disclosure of Saved Personal Data

We will promptly respond to our Client's requests pertaining to saved personal data we may be storing (reports on their usage of the site, disclosure of saved personal data, requests to make changes, additions, or deletion of data, termination of use, removal and/or suspension of data shared with 3rd parties, supplying records of data shared with 3rd parties ). If the Client makes such a request, upon confirming that the applicant is the person in question or their authorized representative, we will fulfill the request to a suitable extent within a reasonable time-frame.

Regarding requests for the disclosure of saved personal data, please contact the office below. Upon receiving the request the office will provide a "Saved Personal Data Disclosure Request Form" by mail, fax, or email. Fill in the form and return it along with any other required documents. (postage and any other associated costs will be borne by the applicant)

Upon confirming that the applicant is the person in question (or their legal representative), the requested saved personal data will be provided via the applicant's preferred medium.

We will take necessary and appropriate organizational, physical, personnel, and technical measures to prevent leakage, loss, or damage of customers' personal data and otherwise ensure its safe management.

※Please contact our Dept. for Personal Data Inquiries for more information about our security control measures.

• Inquiry to : Logistics Department Manager
• Address ：541-0048
  Osaka-fu, Osaka City, Chuo-ku, Kawaramachi, 1-7-7 Osaka Sakaisuji L Building 10F
• Telephone ：06-4560-4070
• Email ：[email protected]

Security of Data

We use appropriate technical and organizational security measures to protect any personal information we process about visitors to our Website against unauthorized access, disclosure, alteration, and destruction, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. We encourage you to take care when disclosing personal information online and to use Internet firewalls, secure e-mail and other technologies to protect yourself online.

Sensitive and private data exchange between the ZenGroup and its Users happens over a SSL secured communication channel and is encrypted and protected with digital signatures.

In case of an unauthorized security intrusion that materially affects you ZenGroup will notify you as soon as possible and will within reasonable time report the action we took in response.

"Do Not Track" Signals

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. ZenGroup INC aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

• The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where ZenGroup INC relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

We may employ third party companies and individuals to facilitate our Services ("Service Providers"), to provide the Services on our behalf or to assist us in analyzing how our Services are used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Services.

• Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Services. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/

Behavioral Remarketing

ZenGroup INC uses remarketing services to advertise on third party websites to you after you visited our Web site. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Web site.

• Google AdWords

Google AdWords remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/

• Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950

To opt-out from Facebook's interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation

Payments

We provide paid products and/or services and we use third-party payment collecting services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information. When you purchase our Services, we will also collect transaction information, which may include billing and mailing address, and other payment-related information.

The payment processors we work with are:

• Stripe

Their Privacy Policy can be viewed at https://stripe.com/us/privacy

• PayPal or Braintree

Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full

• Nihaopay

We use Nihaopay payment processing service for customers from China. You can contact them regarding Privacy Policy at https://nihaopay.com/contactUS

• Unionpay

Their Privacy Policy can be viewed at https://www.unionpayintl.com/en/privacyNotice/

• Crypto

Their Privacy Policy can be viewed at https://crypto.com/privacy/global

• Dlocal

Their Privacy Policy can be viewed at https://dlocal.com/legal/privacy-notice/

Storage

We use third-party web hosting and storage services to securely store our website and databases, including your Personal Data.

The service we use for data storage is Microsoft Azure. You can review Microsoft Azure privacy policy here: https://www.microsoft.com/en-us/TrustCenter/Privacy/default.aspx

Links to Other Sites

Our Services may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Children's Privacy

Our Services does not address anyone under the age of 18 ("Children").

We do not intentionally collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes to This Privacy Policy

We reserve the right to reassess our Privacy Policy, and make changes as necessary. Any changes made take effect on the day that the revised version is published.

Enacted: 24th May, 2018
Revised: 1st,December 2022

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Web site prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

• By visiting this page on our website: https://zenmarket.jp/help.aspx#feedback
• By mail: 541-0048 Japan, Osaka prefecture, Osaka Chuo Ward, Kawaramachi, 1-chōme-7-7,Osaka Sakaisuji L Tower 10F

General Policies Regarding Information Security

ZenGroup Inc. meets the requirements for the ISO27001 security standard.

First and foremost; our company aims to provide satisfaction to all of our Clients and business partners not only through cross-border eCommerce itself, but in all tasks we carry out in relation to cross-border eCommerce, export, providing a shopping platform, carrying out marketing, and providing consulting service, and to be a believable and trustworthy company.

Action Plan

• To plan and take appropriate measures both organizationally and technologically to safeguard the confidentiality, safety, and accessibility of information resources, so as to meet with the demands of evolving technologies and emerging threats.
• To raise and maintain the awareness of all staff regarding the implementation and policy pertaining information security, through education and training.
• To put in place management systems and goals relating to information security, and to regularly review progress with the aim of maintaining and continuously improving upon outcomes.
• To assign roles and delegate responsibilities to staff to oversee the implementation, maintenance, and improvement of the aforementioned management systems.

21st February, 2022
ZenGroup Inc.
CEO
Naumov Andriy

Handling of Personal Information in Membership Registration

1. Name or Title of Business

ZenGroup INC

2. Personal Information Protection Manager

Personal Information Protection Manager: Shin Sugahara
Email: [email protected]
Telephone: 06-4560-4070

3. Purpose of Use of Personal Information

• Provision of ordered products and services
• Purchase processing and delivery, customer support
• When using our Service as a registered member of our Service, authentication of the Client during and after login, and automatic display of member information on various screens
• Providing various types of information such as email newsletters in the businesses handled by us

4. Sharing of Personal Information to Third Parties

Personal Information obtained will not be provided to third parties except as required by law.

5. Consignment of Handling of Personal Information

We will consign all or part of the handling of acquired Personal Information.
In such cases, we will select a consignee with a well-developed Personal Information protection system for use.

6. Consequences for not Giving Personal Information

Providing Personal Information is voluntary. In the case Clients do not provide us with some Personal Information, we may not be able to provide them with the full extent of our services.

7. Disclosure, etc. of Personal Information Subject to Disclosure and Contact for Inquiries

At the Client's request, we will comply with their request for disclosure, notification of purpose of use, correction, addition, or deletion of content, suspension of use, elimination, suspension of provision to third parties, and disclosure of records of provision to third parties (hereinafter referred to as "Disclosure, etc.") concerning the Personal Data we hold.
Please refer to "Contact for Complaints, Consultations, etc. Concerning our Handling of Personal Information" below for the contact information for Disclosure, etc.

8. Acquisition of Personal Information in a Manner not Easily Recognizable by the Client

We use cookies, web beacons, and other means to collect Personal Information in ways that are not easily recognizable by the Client. For more information, please refer to our Privacy & Cookies Policy.

9. Security Control Measures for Personal Information

We will take necessary and appropriate measures to prevent leakage, loss, or damage of Personal Information and to correct such leakage, loss, or damage, and to otherwise safely manage Personal Information.
After responding to the Client's inquiry, we will delete the Personal Information obtained within our company.

10. Personal Information Protection Policy

Please refer to our Personal Information Protection Policy from within the "Privacy & Cookies Policy" page of our website.

11. Contact for Complaints, Consultations, etc. Concerning our Handling of Personal Information

Handling of Personal Information in Inquiries

1. Name or Title of Business

ZenGroup INC

2. Name or Title of the Personal Information Protection Manager (or his/her representative), Affiliation and Contact Information

Personal Information Protection Manager: Shin Sugahara
Email: [email protected]
Telephone: 06-4560-4070

3. Purpose of Use of Personal Information

To respond to Clients’ inquiries

4. Sharing of Personal Information to Third Parties

Personal information obtained will not be provided to third parties except as required by law.

5. Consignment of Handling of Personal Information

We will consign all or part of the handling of acquired Personal Information.
In such cases, we will select a consignee with a well-developed Personal Information protection system for use.

6. Consequences for not Giving Personal Information

Providing Personal Information is voluntary. In the case Clients do not provide us with some Personal Information, we may not be able to respond to their inquiry.

7. Disclosure, etc. of Retained Personal Data and Contact for Inquiries

At the Client's request, we will comply with their request for disclosure, notification of purpose of use, correction, addition, or deletion of content, suspension of use, elimination, suspension of provision to third parties, and disclosure of records of provision to third parties (hereinafter referred to as "Disclosure, etc.") concerning the Personal Data we hold.
Please refer to "Contact for Complaints, Consultations, etc. Concerning our Handling of Personal Information" below for the contact information for Disclosure, etc.

8. Acquisition of Personal Information in a Manner not Easily Recognizable by the Client

We use cookies, web beacons, and other means to collect Personal Information in ways that are not easily recognizable by the Client. For more information, please refer to our Privacy & Cookies Policy.

9. Security Control Measures for Personal Information

We will take necessary and appropriate measures to prevent leakage, loss, or damage of Personal Information and to correct such leakage, loss, or damage, and to otherwise safely manage Personal Information.
After responding to the Client's inquiry, we will delete the Personal Information obtained within our company.

10. Personal Information Protection Policy

Please refer to our Personal Information Protection Policy from within the "Privacy & Cookies Policy" page of our website.

11. Contact for Complaints, Consultations, etc. Concerning our Handling of Personal Information

Personal Information Protection Policy

ZenGroup INC recognizes that Clients' Personal Information is important information that constitutes privacy in the course of conducting its purchasing agency, cross-border EC, shopping platform provision service, marketing business, and consulting business. When handling Personal Information in the course of business, ZenGroup INC will respect our Clients and live up to their expectations and trust in us by establishing laws and regulations concerning Personal Information and internal rules stipulated for the protection of Personal Information, as well as by developing an organizational structure and striving to protect Personal Information appropriately.

Acquisition, Use, and Provision of Personal Information

We will specify the purposes of use of Personal Information within the scope of our business activities, and will acquire, use, and provide Personal Information fairly and appropriately to the extent necessary to achieve those purposes. We will also take steps to ensure that Personal Information acquired will not be used for purposes other than those specified.

Compliance with Laws and Regulations

We will comply with laws, national guidelines, other norms, and social order concerning Personal Information, and strive to protect Personal Information appropriately.

Proper Management of Personal Information

We are fully aware of the dangers of unauthorized access, loss, destruction, falsification, and leakage of the Personal Information we handle, and we will implement reasonable security measures and take appropriate corrective action if problems arise.

Responding to Inquiries

We will respond appropriately to inquiries from the Client regarding disclosure, correction, suspension of use, or complaints about Personal Information handled by us.

Continuous Improvement

We have established management regulations and a management system for the protection of Personal Information, which are thoroughly implemented by all employees, and are regularly reviewed in an effort to continuously improve our Personal Information protection management system.

Enacted: 21st February, 2022
Revised: 1st December, 2022

ZenGroup INC
CEO Naumov Andriy

Contact Information for Personal Information Protection Policy
Personal Information Inquiry Dept.
Address: Osaka-fu, Osaka City, Chuo-ku, Kawaramachi, 1-7-7
Osaka Sakaisuji L Building 10F
Personal Information Protection Manager: Shin Sugahara
TEL 06-4560-4070