tenso, inc., Tenso UK Ltd. and tenso Hong Kong Limited (hereinafter 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 "Policies for Personal Information Protection" below.

1. The Company shall, with respect to personal information and information obtained by processing it (hereinafter collectively referred to as “Personal Information”), comply with applicable laws, regulations, and guidelines and other rules pertaining to the protection of Personal Information.
2. In the provision of the online services, the Company shall notify its customers and clients 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 leakage, loss, or destruction of, and other damage to Personal Information.
4. Personal Information obtained by the Company 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 together referred to as the “Company”) establish the Company’s Privacy Policy as set forth below. 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 (meaning applicable laws, regulations, and guidelines and other rules pertaining to the protection of Personal Information; the same shall apply hereinafter) and to thoroughly implement the appropriate collection, use, and management of such information within the Company for customers and clients (hereinafter referred to as “Customers”) to feel secure in using the services provided by the Company.

1. 1. Personal information the Company may collect

   In order to achieve the purpose of use described in Article 3 below, the Company may collect and retain the personal information specified below. The personal information collected from Customers includes information provided directly by Customers, information obtained automatically through Cookies and other means, and information obtained from third parties. Specifically, it refers to information about a living individual that falls under any of the items below. For more information about Cookies, please refer to Article 10 below.

   1. Information (member 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 and pseudonymized information

   The Company currently does not create anonymized information (meaning anonymously processed information as defined in the Act on the Protection of Personal Information; the same shall apply hereinafter). 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. If the Company creates or collects pseudonymized information (meaning pseudonymously processed information as defined in the Act on the Protection of Personal Information; the same shall apply hereinafter), the Company shall use it for statistical data analysis and take precautions for safety management in accordance with laws and regulations pertaining to the protection of personal information. The Company will not provide pseudonymized information to third parties, except in accordance with laws and regulations pertaining to the protection of personal information.

3. 3. Purpose of use, legal basis

   The Company shall use personal information collected for the purposes described below.
   The Company shall, except as permitted by laws and regulations pertaining to the protection of personal information, obtain the consent of Customers each time when using their personal information beyond the extent necessary to achieve the purposes described below. In addition, the Company shall not use personal information in a manner that may encourage or induce illegal or unjust acts.

   1. Member/user 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 Customers to use services requiring member registration provided by the Company and its group companies (meaning the parent company, subsidiaries, and equity method affiliates of the Company, and subsidiaries and equity method affiliates of the Company’s parent company; the same shall apply hereinafter)
   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. Exercise of rights and performance of obligations under contracts and laws and regulations
   17. Recruitment
   18. Consideration of business alliance

   The Company processes personal data provided by Customers in the performance of contracts with Customers for the services of the Company. For this reason, entering into a contract between Customers and the Company for the Company’s services is subject to the consent of Customers and provision of personal data by Customers as requested by the Company.

   Please note that if Customers fail to, or opt not to, provide any personal data requested by the Company, Customers may not use the Company’s services. Where the Company processes personal data based on the consent of Customers, Customers have the right to withdraw consent at any time.

4. 4. Controller and management of personal information

   The controller of personal information held by the Company is tenso, Inc. (the company registered in Japan under registration no. 0107-01-020921). The Company represents the 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

5. 5. Retention of personal information

   The Company will retain personal information held by the Company only for as long as necessary to fulfill the purposes described in Article 3 above; provided, however, that if the Company is required by laws and regulations pertaining to the protection of personal information and any other applicable laws and regulations to retain personal information, the Company shall comply with the relevant laws and regulations.

6. 6. Provision of personal information

   The Company takes appropriate steps to protect personal information in accordance with laws and regulations pertaining to the protection of personal information and shall not disclose nor provide personal information in a personally identifiable form to a third party without the consent of the subject, except as permitted by laws and regulations pertaining to the protection of personal information. Please note that personal data held by the Company may be transferred to a third party payment service provider or to a third party business partner if it is necessary to deal with such illegal activities as money laundering.

7. 7. Sharing of personal information

   The Company may share personal information as follows:

   Sharing with the group companies of the Company

   (1) Items of personal data to be shared
   Same as the personal information described in Article 1 above

   (2) Scope of those who share personal data
   Group companies of the Company (including new group companies of the Company participated after establishment of this Privacy Policy)

   (3) Purposes of use by those who share personal data
   Same as those purposes of use described in Article 3 above

   (4) Name and address of the person responsible for the management of the personal data and, in the case of a corporation, the name of its representative
   tenso, inc., President and CEO Shota Naoi
   Gotenyama Trust Tower 6F, 4-7-35, Kita-Shinagawa, Shinagawa-ku, Tokyo, Japan

8. 8. Transfer of personal information to third countries

   If the Company transfers personal data to a country that the European Commission does not certify as providing an adequate level of protection for personal data (a country that does not have a so-called “adequacy decision”), the Company will carry out the transfer on the basis of an agreement that meets the requirements set by the EU for the transfer of personal data outside the EU.

   Because of the global nature of the Company’s business, the Company will take appropriate measures in accordance with the provisions of laws and regulations pertaining to the protection of personal information when making overseas transfers of the personal data of Customers.

9. 9. Security

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

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

10. 10. Cookies

    1. This website uses the technology known as cookies.

       Cookies are a system for allowing a communications device used by Customers to temporarily retain certain information as data and identify the Customers based on the data whenever Customers revisit the website. The Company provides services on the premise that cookies are used. Please note that If Customers do not allow the use of cookies, some of the Company's services may not be available. Customers can set whether or not to allow cookies on the Customers’ browser. Please check the settings as necessary.

    2. The Company’s advertisements are placed on various websites on the Internet by third party distribution services such as Google.

       However, Customers can disable the use of cookies by Google by visiting the Google advertising opt-out page (or disable the use of cookies by third party distribution services by visiting the Network Advertising Initiative opt-out page.

    3. The Company uses Google Analytics to improve the performance and service of our website to Customers. Customers’ information collected, recorded, and analyzed by Google Analytics does not include any information that can identify a specific individual. Collected and analyzed information is managed by Google Inc. based on its privacy policy.

       1. Tool provider: Google Inc.
       2. Information obtained: Website usage (access status, traffic, routing, etc.)

       By disabling Google Analytics in your browser’s add-on settings, it is also possible to stop the Company from collecting Customers’ information by use of Google Analytics. In order to disable Google Analytics, please download and install the "Google Analytics Opt-out Browser Add-on" on Google’s download page and change the add-on settings in your browser.
       When Google Analytics is disabled, Google Analytics will also be disabled on websites other than this site that a user may visit, however, Google Analytics may be enabled again by reconfiguring the add-on settings in your browser yourself.

       
       

       Google Analytics Terms of Service

       https://marketingplatform.google.com/about/analytics/terms/gb/

       Google Privacy Policy

       https://policies.google.com/privacy?hl=en

       Google Analytics Opt-out Browser Add-on

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

11. 11. Information provision to business partners

    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.

    Therefore, the Company accepts no liability or responsibility for the independent provisions and activities of these websites or companies. The Company advises Customers to check the privacy policy of each website.

12. 12. Disclosure/revision/deletion of personal information

    The Company shall respond to requests for 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), and disclosure of third-party records, in accordance with laws and regulations pertaining to the protection of personal information.

    However, if such request does not meet the requirements provided by laws and regulations pertaining to the protection of personal information, the Company may not respond to the request.

13. 13. Method of accepting a request for disclosure of personal information

    When making a request for disclosure, revision, addition, deletion, discontinuation of use, elimination, or cessation of provision to third parties of personal information, or other requests, please complete the specified request form in accordance with procedures separately set out by the Company and send it by mail to the contact address below.

    In the event of a request for disclosure, please enclose the predetermined fee, and document delivery postage if (but only when) you request disclosure in writing.

    Contact

    Personal Information Customer Consultation Service, tenso, inc.

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

14. 14. 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 contact the Company at privacy@tenso.com

15. 15. Compliance with laws and regulations pertaining to the protection of personal information

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

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

16. 16. 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 Kita-Shinagawa, 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

    Representative office in the People’s Republic of China

    必诺希电子商务（上海）有限公司

    上海市黄浦区河南南路1号10楼01室 (实际楼层8层01室) A04单元

    E-mail ： privacy@tenso.com