tenso, inc.,Tenso UK Ltd. and tenso Hong Kong Limited (together referred to as the "Company") aims at creating an environment in which customers around the world can readily obtain Japanese products. The Company handles a range of personal information, including information about customers and clients, as part of its business activities.

As a business entity that handles the personal information of customers and clients who uses its services, the Company recognizes the importance of protecting personal information. The Company also understands that it has an obligation to appropriately use and protect such information. For this reason, the Company is committed to the proper protection of personal information and to continuing to take all steps required to ensure appropriate handling and security. The Company regards the protection of personal information as critical to its business and has consequently established "tenso.com's Policies for Personal Information Protection," below.

1. The Company shall comply with the applicable laws, regulations, and guidelines and other rules pertaining to the protection of personal information and anonymized information (hereinafter collectively referred to as “Personal Information”).
2. In the provision of the online services, the Company shall notify the customer of the available point of contact at the Company and receive consent before obtaining personal information within the appropriate extent.
3. The Company shall prevent and correct unauthorized access to Personal Information, as well as the loss, destruction, falsification, and leakage of any personal information.
4. The personal information obtained shall be handled within the scope of the purpose of use set forth in the Company’s Privacy Policy and the company shall establish and implement confirmation procedures to prevent use outside the scope of the purpose of use.
5. The Company shall respond in good faith to inquiries and requests for disclosure from customers in relation to personal information.
6. The Company shall conduct ongoing improvement of the management structure and framework related to the protection of Personal Information.

tenso, inc., Tenso UK Ltd. and tenso Hong Kong Limited (hereinafter referred to as the “Company”) hereby sets forth the Company’s Privacy Policy. This Privacy Policy sets forth the policy on the use and management of personal information in relation to the operation of the website and other businesses by the Company.

The Company believes that it is most important to comply with laws and regulations pertaining to the protection of personal information and to thoroughly implement the appropriate collection, use, and management of such information within the Company for customers to feel secure in using the services provided by the Company.

1. 1. Definition of Personal Information

   The term "Personal Information" as used in this Privacy Policy shall have the meaning defined in Subarticle 2.1 of the Act on the Protection of Personal Information; information about a living individual and falls under one of the following items:

   1. Information (membership ID, name, gender, e-mail address, telephone number, address, nickname, pen name, date of birth, occupation, job title, credit card information, purchase history, and any other relevant information that can be used to identify a specific individual through a combination of information) that can be used to identify the specific individual due to its inclusion of a name, date of birth, or other description contained in such information (any and all matters written, recorded or otherwise expressed using voice, movement or other methods in documents, drawings or electromagnetic records).
   2. Information that contains individual identification codes.

2. 2. Handling of anonymized information

   The Company currently does not create anonymized personal information. If the Company creates anonymized information or provides it to a third party, the Company shall take precautions for safety management in compliance with the separately stipulated Rules for Handling Anonymized Information.

3. 3. Purposes of use, legal basis

   The Company shall use personal information for the following purposes:

   1. Member management
   2. Sales (including the conclusion, etc. of an agreement to provide services; this meaning applies below) of products, rights, digital content and services (hereinafter referred to as the "products, etc." This shall include financial products, etc.) of the Company and third parties
   3. Running of campaigns, prize planning and questionnaires
   4. Simplification of work operations such as member registration for the use of services that require member registration
   5. Notification (including notification via electronic mail) of matters necessary for the operation of this website
   6. Advertisement and sales solicitation (including those via electronic mail) of the products, etc. of the Company and third parties
   7. Transmission of e-mail magazines
   8. Packing and shipping operations of the products, etc.
   9. Billing calculation and billing
   10. Provision of services such as points, coupons and mileage (hereinafter referred to as "points, etc.")
   11. Posting of submitted information
   12. Inquiries and after-sales services
   13. Research and analysis of marketing data and development of new services
   14. Preparation of statistical data
   15. Execution of operations when the Company handles personal information under contract for another business entity, etc.
   16. Enforcement of rights and the performance of obligations based on contracts and laws, etc.
   17. Recruitment
   18. Consideration of business alliance

   The Company process personal data in the performance of the contract to which an individual is party. The provision of personal data is requirement necessary to enter into a service contract with the Company. If the individual chooses to withhold any personal data requested by the Company, it may not be possible for him or her to use the Company’s services.

   Where the Company processes personal data based on consent, individuals have a right to withdraw consent at any time.

4. 4. Data controller and management of personal information

   The data controller is tenso, Inc. (the company registered in Japan under registration no. 0107-01-020921). The Company represent the data controller and appoints a Personal Information Administration Manager to the division responsible for managing personal information, and that division shall facilitate and supervise activities to protect personal information through the appropriate management of such information.

   Customer Support Center of tenso, inc.

   E-mail: privacy@tenso.com

   Personal data will be retained by the Company for as long as it is necessary for the purpose set out in Article 3 above.

5. 5. Provision of personal information

   The Company takes appropriate steps to protect personal information and shall not disclose nor provide it to a third party in a form that allows an individual to be identified without the consent of that individual, except where allowed by the Personal Information Protection Law, and other applicable laws and regulations.

   Personal data held by the Company may be transferred to third party payment service providers.

6. 6. Shared use of personal information

   The Company may use the personal information described in Article 1 jointly with its parent company, subsidiaries and equity-method affiliates, those affiliates as defined in the Securities and Exchange Law (hereinafter referred to as the "affiliates"), as well as subsidiaries and affiliates of the parent company (hereinafter collectively referred to as "the Group") for the purposes of use stipulated in Article 2. Companies specified as the Group shall be renewed from time to time.

   The administration manager of the shared use of personal information shall be as set out in Article 4.

   The associated company with whom we share your personal information and its purpose.

   (1) Associated medium enterprise

   Our associated medium enterprise may provide our service via paper medium, the television, the radio, or the Internet etc. And based on the Article 3, we may share your personal information with them.

   (2) Associated point service enterprise

   Individual information is shared with our company and associated point service enterprise to provide the service of the point.

7. 7. Transfer to third countries

   Where the Company transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfer will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU.

8. 8. Security

   When personal information is provided through this website, it is encrypted using the industry standard encryption method called SSL (Secure Sockets Layer) to protect it from unauthorized access of a third party.

   The Company shall provide security by using SSL encrypted communication to protect personal information when the Company deems it necessary to do so.The Company also places strict controls on personal information based on the management standard it has predetermined and takes steps to prevent access to and the loss, destruction, alteration, leakage and infection of personal information by establishing a firewall, developing antivirus measures, and taking other action.

9. 9. Cookie

   (1) This website uses the technology known as cookies.

   Cookies are a system for allowing a communications device used by a customer to temporarily retain certain information as data and identify the customer based on the data whenever the customer revisits the website.

   (2) The Company also places advertisements via 3rd party distribution services such as Google.

   Users of this website can choose to opt out of Google advertisements by visiting the applicable Google page and turning off cookies, or choose to opt out of advertisements via 3rd party distribution services by visiting Network Advertising Initiative and turning off cookies.

   (3) We use Google Analytics to improve the performance and service of our website to our users. We obtain the following information via Google Analytics: which pages are visited on our website, how long a specific page is viewed, type of browser/version, referrers, access source, etc. However, we do not obtain any personal information that would identify a specific person. Furthermore, we do not distribute any of the acquired information to a third party.

   Google Privacy Policy

   https://www.google.com/intl/en/policies/privacy/

   Use of user’s data by Google to a Google partner website or app

   https://www.google.com/intl/en/policies/privacy/partners/

   If you would not like to provide any information to Google, follow the link below to opt out. Be advised that by opting out you may not be able to use some of the services on our website.

   https://tools.google.com/dlpage/gaoptout/

10. 10. Information provision or linked websites and services

    The Company is not responsible for the use of personal information that is collected independently at websites linked from this website, such as websites and services of third parties that can be accessed through this website.

    The Company accepts no liability or responsibility for the independent provisions and activities of these websites or companies.

    The Company advises users to check the privacy policy of each website.

11. 11. Disclosure, revision and deletion of personal information

    The Company shall respond to requests for the disclosure, revision, addition, deletion, discontinuation of use, elimination, cessation of provision to third parties and notification of purposes of use of personal information, withdrawal of consent (where applicable) in accordance with the Personal Information Protection Law and other applicable laws and regulations.

    If the request does not meet the requirements stipulated by the Personal Information Protection Law, the Company may be unable to respond to the request.

12. 12. Method of accepting a request for the disclosure of personal information

    When making a request for the disclosure, revision, addition, deletion, discontinuation of use, elimination, or cessation of provision to third parties of personal information,

    please complete the specified request form in accordance with procedures separately set out by the Company and send it by mail to the Personal Information Customer Consultation Service of the Company together with identity documents. In the event of a request for disclosure, please enclose the predetermined fee and postage.

    Contact

    Personal Information Customer Consultation Service, tenso, inc.

    Gotenyama Trust Tower 6F, 4-7-35 Kitashinagawa, Shinagawa-ku, Tokyo 140-0001

13. 13. Method of accepting request for notification of purposes of use of personal information

    To request notification of the purposes of use of personal information, please make a request to the Personal Information Customer Consultation Service of tenso, inc.

14. 14. Update of Privacy Policy

    The Company may revise this Privacy Policy when laws or regulations are changed or as necessary to improve the protection of personal information.

    On these occasions, the Company shall post the updated Privacy Policy.

15. 15. Opinions, complaints and objections as to the Privacy Policy

    For inquiries about this Privacy Policy and the handling of personal information, please contact the following consultation service:

    Contact

    Personal Information Customer Consultation Service, tenso, inc.

    Gotenyama Trust Tower 6F, 4-7-35 Kitashinagawa, Shinagawa-ku, Tokyo 140-0001

    E-mail: privacy@tenso.com

    Contact of Representative in the European Union

    Shop Airlines Europe B.V.

    Evert van de Beekstraat 104, The Base B, 1118CN Schiphol, the Netherlands

    E-mail: privacy@tenso.com

    Representative office in the United Kingdom

    Tenso UK Ltd.

    130 Shaftesbury Avenue, 2nd Floor, London, W1D 5EU, United Kingdom

    E-mail: privacy@tenso.com