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ERENEH

PRIVACY POLICY

Last Updated: October 8, 2024

1. About this Policy

The data controller of the personal data collected and processed through the website www.braqmon.com (the “Site”) is by Sleeve Studios Co. Ltd. (hereinafter “Sleeve Studios”). This Privacy Policy shall also apply to the sales conducted and the services rendered through our e-commerce platforms and shops.

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1.1 At BRAQMON ("BRAQMON", "us", "we", or "our"), we respect your privacy and we want to be transparent about the types of Personal Data (as defined below) we collect about you and how we use it. This Website Privacy Policy (hereafter the "Policy") explains how we  collect, share and use any information that, alone or in combination with other information, relates to you ("Personal Data") when you ("you" and "your") use our website braqmon.com (the "Website"), or when you call us or answer our surveys.

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1.2 This Policy sets out the rights that you have in relation to the Personal Data that we process about you and how you can exercise them. This Policy also describes the measures we implement to protect your Personal Data.

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1.3 The Website is managed by Sleeve Studios Co. Ltd incorporated in Japan, who is the data controller for the Personal Data that is collected via the Website. As a data controller, BRAQMON is responsible for ensuring that the processing of Personal Data complies with applicable data protection laws, which includes the General Data Protection Regulation ((EU) 2016/679) ("GDPR"), if you live in the EU and the UK GDPR (“UK GDPR”), if you live in the UK.

 

1.4 Please take the time to read this Policy carefully. If you have any questions or comments, please contact us as described in the "How to contact us" section below.

2. What Personal Data BRAQMON collects, how and why

2.1 BRAQMON collects your Personal Data:

  • directly from you when you create a user account on our website, or subscribe to our newsletter;

  • directly from you when you make a purchase with BRAQMON, answer customer feedback surveys, click on our ads, respond to marketing campaigns, or directly reach out to BRAQMON for inquiries; and 

  • automatically via our use of cookies and other tracking technology on our Website. 

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2.2 Please note that the information you provide on our Website may be necessary for contractual purposes and for us to comply with our legal obligations. Without such information, we may not be able to process your order or to answer your queries. 

 

2.3 In particular, we may be required to disclose your Personal Data in response to legal or regulatory requests from public authorities, including to meet national security, anti-fraud or other legal requirements.

3. Who BRAQMON shares your Personal Data with

We may disclose your Personal Data to the following categories of recipients:

  • to our group companies for purposes consistent with this Policy, and in particular, so that they may contact you regarding products and services that may be of interest to you where you have given your consent. We take precautions to allow access to Personal Data only to those staff members who have a legitimate business need for access and with a contractual prohibition of using the Personal Data for any other purpose. 

  • to our third party vendors, services providers and partners who provide data processing services to us, or who otherwise process Personal Data for purposes that are described in this Policy or notified to you when we collect your Personal Data. This may include disclosures to third party vendors and other service providers we use in connection with the services they provide to us, including to support us in areas such as IT platform management or support services, infrastructure and application services, marketing, data analytics. Our third party vendors, service providers and partners include, without being limited to: 

 

Controllers: Worldpay, Paypal, First Data (Payeezy/IPG), Klarna, Google Premium Analytics, Riskified, PerimeterX, Signifyd, Partnerize, Rakuten. For more information about the manner in which these controllers are processing your data, please check the privacy policies on their respective websites. 

 

Processors: HostedPCI, Stripe,  Avalara, Zendesk, SAP, KIBO, StellaConnect, Loqate, Chatdesk, Google Cloud Platform,Google GSuite/Insight,  Braze, AWS, Regalix, Chatdesk, Clearsale, Bing, SurveyMonkey, Talon.One, MailChimp, MailChimp, SendGrid, Meta (Facebook).

 

  • to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;

  • to our auditors, advisors, legal representatives and similar agents in connection with the advisory services they provide to us for legitimate business purposes and under contractual prohibition of using the Personal Data for any other purpose;

  • to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your Personal Data only for the purposes disclosed in this Policy;

  • to any other person if you have provided your prior consent to the disclosure.

4. How BRAQMON protects your Personal Data

We will process your Personal Data in accordance with the following principles:

  1. Fairness: We are transparent about how we process Personal Data and we will process it in accordance with applicable laws.

  2. Lawfulness: We will process Personal Data only on lawful grounds.

  3. Purpose limitation: We will process Personal Data for specified explicit and legitimate purposes, and will not process it in a manner that is incompatible with those purposes, unless permitted by applicable laws.

  4. Data minimization: We will process Personal Data that is adequate, relevant and limited to what is necessary to achieve the purposes for which the Personal Data are processed.

  5. Data accuracy: We take appropriate measures to ensure that the Personal Data that we hold about you is accurate, complete and, where necessary, kept up to date. However, it is also your responsibility to ensure that your Personal Data is kept as accurate, complete and current by informing us promptly of any changes or errors to the Personal Data that we hold about you (e.g. a change of address).

  6. Data security: We use appropriate technical and organisational measures to protect the Personal Data that we collect and process about you. These measures are designed to provide a level of security that is appropriate to the risk of processing your Personal Data.  In particular, all data is protected according to the varying levels of risks through physical measures, such as secure areas, technical measures, such as encryption, and organisational measures such as employee security through vetting and supervision.

  7. Limited Retention: We keep your Personal Data in a form that allows us to identify you for as long as necessary to achieve the purposes for which we are processing your Personal Data (as described above) and we do not store your Personal Data for longer, unless we must comply with applicable laws.

5. Your rights

In accordance with applicable data protection laws and regulations, you have a right to request access to, rectification or erasure of your personal data, or restriction of processing, and to object to said processing, as well as the right to data portability to the extent applicable.

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You can also object to the use of your Data to build up your client profile; in this case you will no longer benefit from customised advertisement, offers and services. Moreover, you entitled to withdraw your consent in respect to the delivery of marketing materials and advertisement through electronic means and the creation profile based on your preferences including the use and/or combination of external sources.

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These rights may be exercised directly with BRAQMON by contacting us directly. You may be asked for proof of identity.

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You also have the right to lodge a complaint before the relevant supervisory authority if you consider that the processing of your personal data infringes the applicable data protection laws.

6. Data storage, retention and deletion

6.1 The Personal Data we collect from you is stored in our servers located in the Japan.

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6.2 We retain Personal Data we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements) only  as long as it is needed.

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6.3 When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymise it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.

7. Transfers of Personal Data outside the EU/EEA or the UK

7.1 Your Personal Data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.

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7.2 Specifically, our Website servers are located in the Japan, and our group companies and third party service providers and partners operate around the world. This means that when we collect your Personal Data we may process it in any of these countries.

  • For transfers of personal data outside of the EU/EEA: 

    • When transferring your Personal Data to Canada, we rely on the EU Commission's adequacy decision 2002/2/EC available here. 

    • When transferring your Personal Data to other entities of the BRAQMON group located in the Japna or other third countries outside of the European Union/European Economic Area (EU/EEA), we rely on the EU Commission's standard contractual clauses. When transferring your Personal Data to our third party services providers who are also located in third countries outside the EU/EEA, which do not benefit from an EU Commission’s adequacy decision, we have implemented the European Commission's standard contractual clauses with those third parties. 

    • The EU Commission standard contractual clauses may be amended or replaced from time to time and at such time as they are amended or replaced in relation to data protected under the GDPR by the European Commission, we will amend our data transfer documents accordingly.

 

  • For transfers of personal data outside of the UK: 

    • When transferring your Personal Data to Canada, we rely on the UK's adequacy decision.

    • When transferring your Personal Data to other entities of the BRAQMON group located in the United States or other third countries outside the U.K. without a U.K. adequacy regulation, we rely on the U.K. Addendum to the EU Commission's standard contractual clauses.

    • When transferring your Personal Data to our third party services providers who are also located in third countries outside the U.K. without a U.K. adequacy regulation, we rely on the U.K. Addendum to the EU Commission's standard contractual clauses.

    • The U.K. Addendum to the EU Commission's standard contractual clauses may be amended or replaced from time to time and at such time as they are amended or replaced in relation to data protected under the UK GDPR by the UK Secretary of State, we will amend our data transfer documents accordingly.

11. Changes to this Privacy Policy

11.1 We may update this Policy from time to time in response to changing legal, technical or business developments. When we update our Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Policy changes if and where this is required by applicable data protection laws.

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11.2 You can see when this Policy was last updated by checking the “last updated” date displayed at the top of this Policy.

8. Profiling

In some instances, we may use your Personal Data in order to better understand your preferences and to provide customized products or services to you. However, we do not make any decisions based solely on automated processing of such data, which either produce legal effects that concern you or similarly significantly affect you.

9. Minors

The services we provide on this Website are not intended for individuals below the age of 16. If you are under 16, please do not use or register on this Website.

10. External Links

10.1 The Website may contain hyperlinks to websites owned and operated by third parties. These websites have their own privacy policies and we urge you to review them. They will govern the use of Personal Data you submit whilst visiting these websites.

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10.2 We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.

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