PRIVACY POLICY

Aoki Co Ltd endeavors to protect the privacy of its clients. Aoki operates Business to Business B2B). The main activity of the Rotterdam branch of Aoki Co Ltd is to forward fee quotes and requests from its clients to Japan and vice versa.

ARTICLE 1. DEFINITIONS

In this Privacy Policy, the following definitions apply:

Aoki	Aoki Co Ltd. Westblaak 140 3012 KM Rotterdam The Netherlands
Applicable Privacy Legislation:	Privacy legislation, including the General Data Protection Regulation (hereinafter: GDPR) and any other applicable law relating to the processing of personal data.
Personal Data:	any information concerning an identified or identifiable natural person that is processed by Aoki as described in article 3 of this Privacy Policy.
Privacy Policy:	The present Privacy Policy.
Processing:	An operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
Controller:	The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data;
Processor:	The person who processes Personal Data on behalf of the controller, without being subject to his direct authority.

ARTICLE 2. SCOPE PRIVACY POLICY

2.1

This Privacy Policy applies to the website of Aoki and to all personal data processed by Aoki in the performance of its business. The Website of Aoki contains references to websites of third parties (for example hyperlinks, banners or buttons). Aoki is not responsible for compliance with the Applicable Privacy Legislation by these third parties.

ARTICLE 3. PERSONAL DATA COLLECTED

3.1	Aoki processes the following Personal Data from clients and/or other companies of the Aoki Group:
	a.	Business name and communication details of clients
	b.	Details of the orders of clients
	c.	IP address of clients
3.2	These Personal Data are collected at the moment the client or a company of the Aoki Group shares these data with Aoki.
3.3	Aoki will only process the Personal Data in accordance with the Applicable Privacy Legislation.
3.4	Aoki will only use the Personal Data as described in this Privacy Policy.

ARTICLE 4. PURPOSES AND LEGAL GROUND FOR PROCESSING

4.1	Aoki collects and processes the Personal Data it receives from the clients of the Aoki group solely for the purposes specified below:
	a.	Performance of a Contract: If the client and/or a company of the Aoki Group shares Personal Data, these Personal Data will be processed by Aoki for the performance of the Contract. This includes the processing of details of the order, forwarding fee quotes and requests from clients of the Aoki Group. No more Personal Data are processed than strictly necessary for the performance of a Contract.
	b.	Communication: Personal Data are used to communicate with the client or a company of the Aoki Group about fee quotes and requests from clients and/or companies of the Aoki Group. This Processing of Personal Data is necessary for the performance of a Contract and/or for purposes of a legitimate interest pursued by the Aoki Group, namely to conduct its normal business.
	c.	Marketing purposes: Your Personal Data will be used to send newsletters/mailings with regard to the products of the Aoki Group. These newsletters/mailings will always be related to products that are similar to the products your company has ordered. You always have the option to unsubscribe from newsletters/mailings by contacting us at aokirtim@euronet.nl. This Processing of Personal Data is necessary for purposes of a legitimate aokiinterest pursued by the Aoki Group, namely to perform marketing activities.
4.2	If Aoki intends to further process the Personal Data for a purpose other than for which the Personal Data have been collected, Aoki will provide its clients with information about that other purpose and all relevant further information before that further processing.

ARTICLE 5. TRANSFER OF PERSONAL DATA BY THIRD PARTIES

5.1	Aoki may provide Personal Data to its partners for the performance of a Contract with a client.
5.2	Aoki shares Personal Data with the following entities:
	a.	Other companies of the Aoki Group
5.3	Aoki only shares Personal Data with third parties after having entered into contracts with these third parties regarding the processing of Personal Data. In this way, Aoki ensures that the Processors and/or other Controllers take appropriate technical measures, treat the Personal Data confidentially and guarantee the rights of clients regarding Personal Data.

ARTICLE 6. SECURITY

6.1

Aoki takes appropriate organisational and technical security measures to protect the Personal Data and to prevent misuse, loss or alteration thereof.

6.2

Aoki stores your Personal Data on servers in and outside of Europe, including Japan. If and insofar as Aoki Rotterdam stores and/or shares Personal Data with parties in countries that do not have an adequate level of protection, it will agree with these parties standard data protection provisions set by the European Commission or take other measures to ensure that data can be exchanged in compliance with the GDPR. A copy of the agreed standard provisions can be requested from aokirtim@euronet or telephone number: + 31 (0)10-4124138

ARTICLE 7. STORAGE PERIODS

7.1	Aoki does not store the Personal Data longer than strictly necessary in relation to the purposes for which they are processed. Except where there is a legal retention term;
	a.	IP addresses of website visitors are kept 3 months;
	b.	E-mail address, user names and passwords are stored for 5 years after the services/fee quotes are provided;
	c.	E-mails are kept as long as they may be commercially relevant.

ARTICLE 8. COOKIES

8.1	Aoki uses cookies to ensure that the Website functions properly.
8.2	Cookies are small pieces of information that are stored by the browser on the Website Visitor’s computer. Aoki uses different types of cookies for different purposes.
	a.	Functional cookies: cookies that are necessary for the Website to function properly, including cookies that are necessary to create an account;
	b.	Analytical cookies: cookies that ensure that insight can be gained into how Website Visitors use (parts of) the Website, so that Aoki can improve the Website and that it fits as well as possible with what Website Visitors find interesting and important. Aoki does not use the data obtained with these cookies to study the use of the Website at an individual level, but only at an aggregated level.
8.3	Aoki only uses third party cookies to improve the quality and effectiveness of the Website. For example, it uses Google Analytics, which are set up in a privacy-friendly manner. Google Analytics processes the IP addresses for Aoki.
8.4	To the extent required by law, the Website Visitor gives prior unambiguous consent to the use of cookies.
8.5	Most browsers are set to accept cookies by default. The website visitor can set the browser to disable cookies or indicate when a cookie is being sent. However, it is possible that some functions and services of both Aoki and other websites do not function properly if cookies are disabled.

ARTICLE 9. SCOPE OF YOUR OBLIGATIONS TO PROVIDE DATA

Generally, you are not obliged to provide Aoki with personal data. However, if you do not provide this information, we may not be able to make our website available to you, answer your questions and enter into a contract with you.

ARTICLE 10. YOUR RIGHTS

10.1	You can request Aoki at all times to view, correct, rectify, supplement, delete or restrict your Personal Data if these are factually incorrect, incomplete or if they are processed in violation of a legal obligation. In so far as the data processing is based on consent (see above), you have the right to withdraw this consent at any time.
10.2	You can request Aoki to obtain the Personal Data that you have provided to Aoki in a structured and commonly used form, so that you can transfer the data to another controller. You are only entitled to this insofar as the processing is based on consent or if it concerns a processing that is based on the performance of a Contract and the processing is carried out by automated means.
10.3	If you wish to make use of one of the rights mentioned in this article, you can request this from Aoki:

Address:	Westblaak 140 3012 KM Rotterdam The Netherlands
Email address:	aokirtim@euronet.nl
Telephone number:	+31 (0) 10 412 41 38

10.4	Aoki will provide you with information about the follow-up given to the request immediately and in any case within one month of receipt of the request. Depending on the complexity of the request and on the number of requests, this period can be extended by another two months. Aoki will notify you of such an extension within one month of receipt of the request.
10.5	If your requests are manifestly unfounded or excessive, in particular because of the repetitive character, Aoki will either charge you a reasonable fee or refuse to comply with the request.

ARTICLE 11. DATA PROTECTION AUTHORITY

You have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work or of an alleged infringement of the GDPR at all times.

ARTICLE 12. AUTOMATED DECISION MAKING / PROFILING

Aoki will not use automated decision making or profiling (an automated analysis of your personal circumstances).

ARTICLE 13. MISCELLANEOUS

13.1	Aoki reserves the right to change this Privacy Policy on a regular basis. It is your responsibility to regularly review the applicable conditions. This Privacy Policy is last amended and revised in May 2018.
13.2	If a provision from this Privacy Policy is in conflict with the law, it will be replaced by a provision of the same purport that reflects the original intention of the provision, all this to the extent legally permissible. In that case, the remaining provisions remain applicable unchanged.