Koki Holdings Global Privacy Policy

Effective Date: April 1, 2022


As Koki Holdings Co., Ltd. ("Koki Holdings") states in the “Koki Holdings Group Code of Conduct,” one of our important basic policies is to recognize the importance of personal data and the need to observe applicable laws and regulations governing the protection of personal data, in order to respect human rights and to process personal data in a lawful and appropriate manner.

Based on this background, in addition to creating and maintaining local privacy policies at our respective group companies in accordance with applicable local laws and regulations, Koki Holdings has created this Global Privacy Policy (“Global Privacy Policy”) as set forth below, which explains how Koki Holdings and its group companies (“we,” “us,” or “our”) collect, store, use, disclose and transfer your personal data. To ensure the effectiveness of this Global Privacy Policy, Koki Holdings distributes it to the executives and employees of our group.

In the event of any conflict between this Global Privacy Policy and local laws and regulations and/or the local privacy policies of our group companies (collectively, “Local Laws”), relevant Local Laws shall prevail.

Collection of Personal Data

We collect personal data in a lawful and appropriate manner. We collect the minimum amount and type of personal data necessary to achieve the purpose(s) for which it was collected.

We collect personal data about you in the following ways:

  1. Collection directly from you
    This includes information that you give us through inquiry forms on this website, or in communications with us, whether by email, letter, phone, or otherwise. The information you give us is likely to include your contact information, such as your name, address, e-mail address, or phone number.
  2. Collection indirectly through third parties
    This includes information that third parties give us through inquiry forms on this website or through/from our business partners, through staffing agencies or through communications with us, whether by e-mail, letter, phone, or otherwise. The information third parties give us is likely to include your contact information such as your name, address, e-mail address, or phone number.
  3. Collection automatically through the website
    When you visit this website, the website automatically collects certain types of data related to you. These types of data include access logs, web beacons (also known as pixels), cookies, etc. These types of data may remain in your computer and continue to collect data.
  4. Collection through publicly available media
    We collect information through publicly available media, such as the Internet and social media including Twitter, Facebook, and other services.

Legal Bases for Processing Personal Data

We will process your personal data on the following legal bases unless such data processing would conflict with applicable laws and regulations:

  1. Consent: where you have consented to the processing of your personal data for one or more specific purposes. Subject to limitations under applicable laws and regulations, you may withdraw your consent at any time. Withdrawal of consent will not affect the legality of processing performed based on consent and prior to the withdrawal of the consent.
  2. Contract: where the processing is necessary for the performance of a contract or in order to take steps prior to entering a contract.
  3. Legal Obligations: where the processing is necessary for compliance with legal obligations.
  4. Vital Interest: where the processing is necessary to protect your vital interests or the vital interests of another natural person.
  5. Legitimate Interests: where the processing is necessary for the purposes of legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms. Legitimate interests include: (i) marketing to customers (direct marketing) without intrusive profiling, (ii) customer service, including product repairs, (iii) applications for recruitment by us, (iv) CCTV cameras for security purposes.

Purpose of Processing Personal Data

We process your personal data only for the following purposes, and only to the extent that necessary to fulfill the purposes described below.

For customers

  1. To communicate about our products and services, including for the purpose of providing and improving our products or services (Legitimate Interests)
  2. To provide information and communications, in connection with questionnaires relating to products, services, events, advertisements, campaigns, and similar matters (Consent, Legitimate Interests)
  3. To enter into a contract, to provide our products or services, or to operate our business. In the event that you do not provide your personal data, you may experience disadvantages or may be unable to use some of our services (Contract, Legitimate Interests)
  4. To perform analysis, investigations, studies, and research for purposes related to product development, sales, advertising, product marketing (including obtaining marketing approvals), web analytics, strategic planning, and other related business purposes (Consent, Legitimate Interests)
  5. To resolve disputes and/or litigations, enforce our contracts and agreements, and to establish, exercise, or defend against legal claims and/or litigation (Legal Obligation, Legitimate Interests)
  6. To respond to any inquiries, concerns or complaints raised by our users, business partners, or retirees (Contract, Legitimate Interests)
  7. For Public Benefit

  8. To ensure compliance with legal obligations, export controls and customs regulations, compliance screening obligations, industry standards, or our policies (Legal Obligation, Legitimate Interests)
  9. To notify or respond to requests or inquiries to comply with applicable laws and regulations from government authorities or other public institutions (Legal Obligation)

Sharing of Personal Data

We may share your personal data with the following categories of recipients to the extent necessary to fulfill the relevant purposes of use. The recipients of your personal data may be located outside of the country in which you reside.

  1. Our personnel
    We may share your personal data internally with our personnel.
  2. Affiliates
    We may share your personal data with our affiliates mainly for internal administrative purposes.
  3. Business partners
    We may share your personal data with business partners and their personnel. These business partners include distributors, retailers and electronic commerce service providers.
  4. Third-party vendors
    We may share your personal data with third-party vendors who provide products, services, and/or to take other actions necessary for the relevant purposes. The third-party vendors include internet service providers, web analytics service providers, and cloud service providers.
  5. Third parties, in connection with legal obligations
    We may share your personal data with courts, arbitration institutes, regulators, government authorities, attorneys, and consultants to comply with legal obligations.
  6. Other Third Parties, as legally permitted
    We may share your personal data with other third parties as permitted under applicable laws and regulations.

Cross-Border Transfers

We may transfer your personal data internationally including to the countries in which our affiliates, service providers or other recipients are located. If applicable laws and regulations, particularly those of the jurisdiction in which the personal data is located, impose restrictions on the cross-border transfer of personal data, we will take appropriate measures to comply therewith.

Retention Periods

We will retain your personal data only for the period necessary to achieve the purpose for which the personal data was collected, or otherwise to comply with applicable laws and regulations. The applicable retention period will be determined in consideration of the nature of personal data and the purpose of processing personal data, as well as legal and business needs, always in accordance with applicable laws and regulations.

Your Rights

You have certain legal rights with respect to your personal data. These rights may vary depending on where you are located and which data protection laws and regulations apply, but typically include:

  1. the right to be informed, in a transparent manner, as to how your personal data is processed
  2. the right to access your personal data, to know exactly what information is held and how it is processed
  3. the right to rectification if your personal data is inaccurate or incomplete
  4. the right to erasure your personal data (also known as the “right to be forgotten”)
  5. the right to restrict processing of your personal data
  6. the right to data portability to reuse the personal data for another service
  7. the right to object to our processing of your personal data
  8. the right in relation to automated decision-making and profiling, for you not to be subject to automated decision-making and automated profiling; instead, but can ask for human intervention
  9. the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal
  10. the right to lodge a complaint with a data protection supervisory authority.


We take appropriate technical and organizational security measures to protect your personal data against accidental or unlawful destruction, loss, use, alteration, or falsification, and against unauthorized disclosure or access. We will review and improve our technical and organizational measures on an ongoing basis, to ensure adequate protection of personal data.

Updates to this Privacy Policy

We may amend this Global Privacy Policy from time to time and will post the updated version(s) on the website. We recommend that you periodically check the website to ensure you have the latest information regarding this Global Privacy Policy.

Contact Information

If you have any questions or requests concerning this Global Privacy Policy, your rights, or any other issues regarding the protection of your personal data, you can reach out to us at the contact addresses below:

  • Email: data-protection@koki-holdings.co.jp
  • Address: Attn: Koki Holdings Co., Ltd.
    Personal Data Protection Inquiry, 2-15-1 Konan, Minato-ku, Tokyo 108-6018, Japan

Links to Local Privacy Policies

In addition to this Global Privacy Policy, our group companies maintain their own separate privacy policies. At the links below, you can see the local privacy policies in the primary geographic areas of where our group companies are located:

  1. Japan
    Koki Holdings Co., Ltd.
  2. Europe
    Metabowerke GmbH
  3. U.S.
    Koki Holdings America Ltd.