1.　This policy describes the processing of personal data by YAMADA HOLDINGS CO., LTD. 1-1 Sakae-cho, Takasaki, Gunma 370-0841, Japan (hereinafter referred to as "we", "us", or "our") as a data controller concerning the personal data of EU data subjects in regard to cookies and other tracking technologies used at https://www.yamada-holdings.jp(hereinafter collectively referred to as "Websites").

2.　We process your personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the General Data Protection Regulation; "GDPR").

3.　This policy applies in addition to the YAMADA HOLDINGS CO., LTD.’s Privacy Policy, and in particular in relation to the GDPR.

1.　We process personal data which we collect from you through cookies and other tracking technologies used on the Websites.

2.　Depending on the particular cookie or tracking technology that we use, the types of personal data may include online identifiers, including cookie identifiers, IP addresses, device identifiers, as well as client identifiers and session ID (hereinafter referred to as the “Website visit data”). For more information about cookies and other tracking technologies, please see our Cookie Policy.

1.　We process your personal data on the legal grounds set forth in the GDPR.

2.　We process your personal data for specified, explicit and legitimate purposes and will not process it further in a way that is incompatible with these purposes.

3.　The legal grounds that we rely on, are as follows:

　a.Consent
We process the Website visit data collected through analytical and advertising cookies based on your prior consent. We use such data for development, improvement and promotion of products and services provided by us on the Websites.
We use analytical cookies to analyse how the data subjects use our Websites. By analysing how you use the Websites, we are able to consider how we can provide a more customer-focused service.
We use advertising cookies to provide the data subjects with advertising that is highly relevant to their interests. We may record information about the Websites you visit in conjunction with cookies and share this information with third party service providers who are our partners.
You always have the right to withdraw the consent by changing your preferences on our Websites. Withdrawal of the consent does not affect the legality of the processing of your personal data prior to withdrawal.

　b.Legitimate interests
Your Website visit data is processed based on our legitimate interests for the purposes of provision of core services on the Websites. For that, we process your Website visit data via authentication and other technical cookies. Our interest is to run our business online, however without using this type of cookies, our Websites will simply not function properly.
You have the right to ask clarifications regarding the processing based on the legitimate interests. You also have the right to send us the objection, if you find that processing of your data for the purposes provided above prejudice your rights. Please see Your rights section of this policy for our contact details.

1.　In some cases, we may transfer your personal data to third persons. These are categorised as follows:

　a.Our group companies who act either as our data processors or as separate controllers;

　b. Partners who provide the services to us (note that persons mentioned below process the personal data on behalf of us and can use your personal data only for the provision of services agreed with us and in limited cases), e.g.:

　　　i. providers of ICT and information society services (including providers of website hosting services and other providers of cloud services);

　　　ii. providers of accounting services;

　c.Auditors and attorneys;

　d.Public authorities and supervisory bodies, e.g. court, law enforcement authorities, data protection authorities.

2.　We may transfer your personal data to third countries (i.e., the countries outside the European Economic Area or Japan). If we do so, such transfers of personal data will be made on an appropriate legal basis and we will take appropriate safeguards.

3.　You have the right to obtain additional information regarding the transfer of your personal data.

1.　We process your personal data in a manner that ensures adequate security (including protection against unauthorized or unlawful processing, accidental loss, destruction or damage). We will take appropriate technical and organizational measures to achieve such a level of protection.

2.　We will retain your personal data only for as long as is necessary to fulfil the purposes set out in this policy unless a longer retention period is required or permitted by law.

3.　You can find out how long we retain cookies in our Cookie Policy. More specific terms of retention can be exercised by accessing your personal data. Please see the explanation of Your rights below.

1.　Right of access to your data. You have the right to know, whether personal data concerning you are being processed or not, what is the purpose of processing and what are the categories of personal data. Besides, to whom the data is disclosed (especially the recipients in third countries), for how long the data is retained and what are your rights concerning rectification, erasure and restriction of the processing.

2.　Right of rectification. You have the right to demand rectification of the personal data concerning you if the data are inaccurate or incomplete.

3.　Right of erasure. In some cases, you have the right to demand erasure of the personal data concerning you, for example in case when you withdraw your consent and there are no other legal grounds for the processing of the data.

4.　Right to restrict the processing. In some cases, you have the right to restrict processing of the personal data concerning you for a certain time (e.g., if you have objected the processing of personal data).

5. 　Right to object. You have the right to object the processing of personal data, which is processed based on the legitimate interest, including profiling. Upon objection, we will no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms.

6.　Right to data portability. If processing of your personal data is based on your consent or the contract with us and the data processing is carried out by automated means, then you have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format. Also, you have the right to claim us to transmit those data to another service provider if it is technically possible.

7.　Right to turn to us, supervisory authority, or a court. You have the right to complain to or seek advice from a supervisory authority and/or bring a claim against us in any court of competent jurisdiction. If you wish to exercise the above rights, please contact: