Bushiroad Privacy Policy

BUSHIROAD GLOBAL PRIVACY POLICY

Bushiroad Inc., Bushiroad USA Inc., Bushiroad International Pte Ltd, and our group companies (collectively, hereinafter, the “Companies”, “we”, “our”, “us”) collect, use, and disclose personal information of our customers (hereinafter, the “Customer(s)”, “you”, or “your”). In order to protect your personal information (the “Personal Information”) in various countries, we have established this BUSHIROAD GLOBAL PRIVACY POLICY (this “Policy”). This Policy applies to any and all of our processing of Personal Information, unless you are a resident of Japan or the state of California, the United States. If you are a resident of Japan, the “Privacy Policy” and “Privacy Announcement Relating Personal Information” (both available at https://bushiroad.co.jp/privacy) shall apply to the processing of your Personal Information. In addition, if you are a resident of the state of California, the “Supplementary Provisions regarding the Handling of Personal Information of California Residents” set forth below shall also apply to the processing of your Personal Information.

In the processing of Personal Information, we will comply with this Policy, and the laws and regulations applicable to our processing of Personal Information (the “Applicable Laws”).

1. Processing of Personal Information

(1) Acquisition of Personal Information
We acquire Personal Information by legal and ethical methods, and at the same time, devote our utmost attention to ensuring Personal Information is used only for those purposes that are clearly specified in advance. When we ask you to provide your Personal Information, we will notify you of the purposes of acquisition and the details of use of such Personal Information in advance. Processing of Personal Information will be conducted only within the scope of our legitimate business purposes and processed only to the extent necessary to achieve the purposes set forth in “(2) Purposes of Processing” below.
Personal Information we collect from the Customers includes, but is not limited to, the following information:
Your name, gender, birth date, e-mail address, address, telephone number, passport number, Bushi Navi ID, Discord ID, username, cookie and any other information you provide us.

Some of the Personal Information is necessary for us to enter into a contract with you or the company to which you belong. In case you do not provide us certain information when requested, we may not be able to provide you or the company to which you belong our full support with respect to our services.

(2) Purposes of Processing
Personal Information provided to us will be used only within the scope of our legitimate business purposes and only to the extent necessary to achieve those purposes set out below.

To ensure the appropriate and smooth execution of our business operations.
To fulfill or meet the reason(s) you provided the Personal Information to us. For example, if you share your name and contact information to request a price quote or to ask a question about our products or services, we will use such Personal Information to respond to your inquiry. If you provide your Personal Information to purchase our products or services, we will use such Personal Information to process your payment and facilitate the delivery. We may also save your Personal Information to facilitate new product orders or process product returns.
To plan, operate, and manage our events (e.g., concerts, conventions, tournaments/competitions, live shows, sports entertainment, theatrical performances, and other entertainment events), including participant registration, ticketing, admission/check-in, seat management, attendee management, and post-event follow-up.
To conduct campaigns including, but not limited to, delivering prizes.
To enable the Customers to participate in online surveys.
To provide, support, personalize, and develop our website, products, and services.
To create, maintain, customize, and secure your account (including, but not limited to, for Bushi Navi and Bushiroad Global Online Store) with us.
To process the Customer’s requests, purchases, transactions, and payments and to prevent transactional fraud.
To send you marketing materials regarding our products and services.
To conduct marketing research, compile statistics, and perform analyses using marketing data.
To respond to law enforcement requests, and as required, by applicable law, court orders, or governmental regulations.

(3) Provision and Cross-border Transfer of Personal Information
We will disclose Personal Information listed in “(1) Acquisition of Personal Information” above to our service providers (including, but not limited to, local logistics service providers and our group companies (https://bushiroad.co.jp/company/group)) provided that such disclosure is conducted within the purposes and means set forth in “(2) Purposes of Processing” above. As a result of the disclosure, Personal Information may be transferred to locations outside of the country in which you are located. Personal Information protection laws in such locations to which Personal Information is transferred may not have the same standard of protection as that of your country of residence. In such cases, we will thoroughly examine the eligibility of the party to which the Personal Information is provided or entrusted and confirm that appropriate security measures are implemented in the processing of Personal Information from the perspective of security of Personal Information.

(4) Procedures for Disclosure, Correction, Deletion, etc. of Personal Information
If you wish to request disclosure, correction, addition, deletion, suspension of use, suspension of provision to a third party, or data portability, etc., of Personal Information, or to make a related objection, as permitted under the Applicable Laws, please contact us by using the contact channels set forth in “4. To Contact Us” below. The Companies will usually respond to such request regarding Personal Information within a reasonable period of time, upon our confirmation that the request is made by the data subject of the Personal Information and that the data subject is eligible to exercise the rights under the Applicable Laws.
You may also request to withdraw your consent for the Companies to collect, use or disclose your Personal Information for any purposes, without affecting the lawfulness of its processing based on your consent before withdrawal thereof, by using the contact channels set forth in “4. To Contact Us” below. In some cases, withdrawing such consent may hinder the Companies’ ability to facilitate, process, administer, provide, or maintain our services to you.
You may exercise your rights before and after the Companies disclose Personal Information to third parties in accordance with “(3) Provision and Cross-border Transfer of Personal Information” above if this is allowed under the Applicable Laws.

(5) Filing a Complaint
You may have the right to complain to your local data protection authority, or to a court of law under the Applicable Laws, if your data protection rights are violated. You may be entitled to claim compensation for damage or distress incurred or suffered in consequence of the unlawful processing of your Personal Information.

2. Security Measures and Retention Period

(1) Security Measures
We have established a management system and implemented appropriate security measures to protect Personal Information from unauthorized access, loss, destruction, falsification, leakage, etc., and to help ensure the security and accuracy of your Personal Information. In addition to restricting the entry of unauthorized persons into the office areas in which we process Personal Information, and conducting educational activities for all directors, employees, and other staff involved in the protection of Personal Information, we will appoint a person responsible for the management of Personal Information and strive to manage Personal Information appropriately. For details of the security measures implemented by the Companies, please contact us by using the contact channels set forth in “4. To Contact Us” below.

(2) Retention Period
We will retain Personal Information only for the period necessary to achieve the purposes of processing described in Section (2) “Purposes of Processing”.

3. Changes to this Policy

As part of the Companies’ efforts to ensure that we properly manage, protect, and process Personal Information, we will be reviewing this Policy, procedures, and processes in using Personal Information from time to time.

The Companies reserve the right to amend and update the terms of this Policy at our absolute discretion. You are encouraged to visit this Policy from time to time to ensure that you are well informed of the Companies’ latest policies in relation to the protection of the Personal Information.

4. To Contact Us

Inquiries regarding our processing of Personal Information are welcomed via the following contact channels:

Bushiroad Inc.
Sumitomo Nakanosakaue Building 5th floor, 1-38-1, Chuo-ku, Tokyo, Japan
Email: privacy-contact@bushiroad.com

Bushiroad USA Inc.
2988 Columbia Street, Torrance, CA, 90503, the United States
Email: privacy_usa@bushiroad.com

Bushiroad International Pte Ltd
331 North Bridge Road
#03-03 Odeon Towers, Singapore 188720
Email: privacy_sg@bushiroad.com

The contact information for the Company’s representative in the EU is as follows:
Name: TMI Avocats & Associés
Address: 40 avenue Niel, 75017, Paris, France
E-Mail：Bushiroad-EUrep@tmi.gr.jp

Supplementary Provisions regarding the Handling of Personal Information of California Residents

Information that identifies you as residing in the state of California, the United States, as well as information that relates to you, describes you, can reasonably be associated with you, or can reasonably be linked directly or indirectly to you (hereinafter, the “Personal Information”) shall be processed according to the California Consumer Privacy Act as amended by the California Privacy Rights Act (collectively, hereinafter, the “CCPA”) and is subject to this Policy (as defined above) and these Supplementary Provisions. If any provisions differ between those of these Supplementary Provisions and this Policy, these Supplementary Provisions shall prevail.
These Supplementary Provisions provide information about how the Personal Information held by us is processed.

1. Personal Information We Collect

In particular, we have collected the following categories of Personal Information from the consumers in the preceding twelve (12) months:

Category	Examples
A. Identifiers.	Your name, telephone number, address, e-mail address, passport number, username, Bushi Navi ID, Discord ID, cookie, etc.
B. Personal Information categories as listed in the California Customer Records statute (CCPA Section 1798.80(e)).	Your name, address, telephone number, passport number, etc.
C. Protected classification characteristics under California or federal law.	Gender
D. Commercial information.	None
E. Biometric information.	None
F. Internet or other similar network activity.	None
G. Geolocation data.	None
H. Sensory data.	None
I. Professional or employment-related information.	None
J. Non-public education information (as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	None
K. Inferences drawn from other Personal Information.	None
L. Sensitive Personal Information (as defined in the CCPA Section 1798.140(ae)).	Passport number

Personal Information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, such as:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.
- Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) the California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994 (DPPA).

We obtain the categories of Personal Information listed above from the following categories of sources:

Directly from you. For example, from forms you complete, via SNS, or our products and services that you purchase.
Indirectly from you. For example, from observing your actions on our website.

Our website does not respond to “do not track” or similar signals. No other parties are authorized by us to collect personally identifiable information about an individual consumer’s online activities over time or across different websites when a consumer uses our website.

Uses of Personal Information

We may use or disclose Personal Information we collect for one or more of the following purposes:

To ensure the appropriate and smooth execution of our business operations.
To fulfill or meet the reason(s) you provided the Personal Information to us. For example, if you share your name and contact information to request a price quote or to ask a question about our products or services, we will use such Personal Information to respond to your inquiry. If you provide your Personal Information to purchase our products or services, we will use such Personal Information to process your payment and facilitate the delivery. We may also save your Personal Information to facilitate new product orders or process product returns.
To plan, operate, and manage our events (e.g., concerts, conventions, tournaments/competitions, live shows, sports entertainment, theatrical performances, and other entertainment events), including participant registration, ticketing, admission/check-in, seat management, attendee management, and post-event follow-up.
To conduct campaigns including, but not limited to, delivering prizes.
To enable Customers to participate in online surveys.
To provide, support, personalize, and develop our website, products, and services.
To create, maintain, customize, and secure your account (including, but not limited to, for Bushi Navi and Bushiroad Global Online Store) with us.
To process Customer’s requests, purchases, transactions, and payments, and to prevent transactional fraud.
To send you marketing materials regarding our products and services.
To conduct marketing research, compile statistics, and perform analyses using marketing data.
To respond to law enforcement requests and as required by applicable law, court orders, or governmental regulations.
As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

We will retain Personal Information only for the period necessary to achieve the purposes of processing described in Section “Uses of Personal Information” above. Your disclosure of Personal Information to us is voluntary and is not required by any applicable law or contract, except to the extent that your Personal Information is required for us to provide our services to you, as stated elsewhere in this Policy.

2. Selling and Sharing Personal Information

We have not sold or shared any Personal Information in the preceding twelve (12) months and we will not sell or share any Personal Information in the future.

In these Supplementary Provisions, the term “selling” means disclosing, etc. your Personal Information to a third party for monetary or other valuable consideration, and the term “sharing” means disclosing your Personal Information to a third party for cross-text behavioral advertisements, whether for monetary or other valuable consideration or free of charge.

3. Your Rights and Choices in California

The CCPA provides consumers who are California residents with specific rights regarding their Personal Information. This section describes your rights under the CCPA and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information in the preceding twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of Personal Information we collected about you.
The categories of sources for the Personal Information we collected about you.
Our business or commercial purposes for collecting or selling such Personal Information.
The categories of third parties with whom we share such Personal Information.
The specific pieces of Personal Information we collected about you (also called the “data portability request”).
If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing the:
- Sales, identifying the Personal Information categories that each category of recipient purchased; and
- Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Right
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Upon our receiving and confirming your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining such Personal Information is necessary for us or our service providers to:
1. Complete the transaction for which we collected the Personal Information, provide our goods or services that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Help ensure the security and accuracy of your Personal Information to the extent the use of your Personal Information is reasonably necessary and proportionate for those purposes.
3. Debug products to identify and repair system errors, etc. that impair existing intended functionality.
4. Exercise free speech, ensure the right of other consumers to exercise their free speech rights, or to exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the Personal Information’s deletion would likely render impossible or seriously impair the research’s achievement goals, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of the Personal Information that are compatible with the context in which you provided such Personal Information.

Exercising Access to Specific Information, Data Portability, and Deletion Request Rights

To exercise the access to specific information, data portability, and deletion request rights described above, please submit a verifiable consumer request to us by either:

Calling us at: 800-979-5505
Visiting us at: https://en.bushiroad.com/
Emailing us at: privacy_usa@bushiroad.com

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may make a verifiable consumer request for access or data portability only twice within a twelve (12)-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected the Personal Information, or your authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond thereto.

We cannot respond to your request or provide you with the Personal Information if we cannot verify your identity or authority to make the request and confirm that the Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through a password protected account with us to be sufficiently verified when the request relates to Personal Information associated with such specific account.

We will use Personal Information provided to us in a verifiable consumer request only to verify the requestor’s identity or authority to make the request.

For instructions on exercising sale opt-out rights, please see Personal Information Sales Opt-Out Rights below.

Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to such account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will cover only the twelve (12)-month period preceding our receipt of the verifiable consumer request. The response we provide will also explain the reason(s) we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you why we made that decision and provide you with a cost-estimate before completing your request.

Personal Information Sales Opt-Out Rights
We have not sold or shared any Personal Information collected from you in the preceding twelve (12) months and we will not sell or share any of your Personal Information in the future.

Right to Limit the Use or Disclosure of Sensitive Personal Information
We have not used or disclosed and will not use or disclose any of your sensitive Personal Information for any purpose other than those listed below:

To perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services.
To help ensure the security and accuracy of your Personal Information to the extent the use of your Personal Information is reasonably necessary and proportionate for those purposes.
For short-term, transient use (except uses involving profiling or changes to future consumer experiences).
Performing services on our own behalf.
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, controlled by or manufactured for us, and
Other purposes as authorized by the regulations.

4. Non-Discrimination

We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by the CCPA, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Retaliate against our employees for exercising their rights under the CCPA.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer you will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

5. Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy_usa@bushiroad.com or write to us at: Bushiroad USA Personal Information Protection Manager, 2988 Columbia Street, Torrance, CA 90503, the United States.

6. Changes to these Supplementary Provisions

The Companies reserve the right to amend and update these Supplementary Provisions at our absolute discretion and at any time. When we make changes to these Supplementary Provisions, we will post these updated Supplementary Provisions on our website and update these Supplementary Provisions’ effective date. Your continued use of our services following the posting of such changes constitutes your acceptance of such changes.

7. Contact Information

If you have any questions or comments about these Supplementary Provisions, the ways in which we collect and use your Personal Information, your choices and rights regarding such use, or if you wish to exercise your rights under California law, please contact us by using the contact channels set forth below:

Phone: 800-979-5505
Website: https://en.bushiroad.com/
Email: privacy_usa@bushiroad.com
Postal Address:
Bushiroad USA Inc.
Attn: Bushiroad USA Personal Information Protection Manager
2988 Columbia Street
Torrance, California 90503
The United States

Bushiroad Inc.
Sumitomo Nakanosakaue Building 5th floor, 1-38-1, Chuo-ku, Tokyo, Japan
Email: privacy-contact@bushiroad.com

Bushiroad International Pte Ltd
331 North Bridge Road, #03-03
Odeon 331, Singapore 188720
Email: privacy_sg@bushiroad.com