1. Basic Policy

Khariis Co., Ltd. (“Khariis”, “we” or “us”), an international online platform operator, recognizes that protection of personal data of a registered user of our service (“you”, “User”, or “Users”) is one of our important corporate responsibility. Khariis has established a personal data protection policy (“Privacy Policy”) on collection and use of User’s Personal Data (which means “personal information” and “personal data” defined in the Japanese Act on the Protection of Personal Information, and “personal data” defined in the EU General Data Protection Regulation (“GDPR”)). We have also established a compliance framework and will ensure that our employees are fully aware of this Privacy Policy.

2-1. Collection of Personal Data

In the course of providing services to you, Khariis may obtain Personal Data from you. Khariis will obtain Personal Data to the extent necessary to provide our service, and the purpose and extent of the utilization of the information will be clearly explained.

2-2. How we collect Personal Data

In the course of providing our service, Khariis may collect Personal Data through the following means:

1. Directly from you
   Through our mobile application (“App”) (hereinafter collectively referred to as “Platform”)
2. From an authorized third-party application (e.g. Facebook)
   Such third-party application may include those authorized to provide certain account information on behalf of you.

2-3. Types of Personal Data collected by Khariis

1. User’s basic information, such as email address, name, country of origin, preferred language, profile picture;
2. Additional information, such as current city;
3. Information automatically obtained by App and/or Website, such as cookie, IP address, browser type, date/time of access, your whereabouts on the Internet, technical information about your devices and location;
4. Information required by administrative instructions, by law, regulations, ordinances

2-4. Refusal of Providing Personal Data

Khariis does not compel User to provide Personal Data. The User has the right to provide Personal Data to Khariis. However, in the event of refusing to provide User’s basic information mentioned above in 2-3, it may not be possible to recieve certain service from Khariis.

3. Consent

The consent of the User when signing up to the Platform will, as a rule, be the legal basis of processing Personal Data by Khariis. User may withdraw his/her consent at any time. The withdrawal of consent will not affect the lawfulness of using based on consent before its withdrawal. You have the right to withdraw your consent by contacting Khariis representative of Personal Data. It is noted that your name will be public after signing up to the Platform.

4-1. Purpose of used of Personal Data collected by Khariis

Khariis will use your Personal Data only within the scope and for the following purposes:

1. to manage our user relation with you, including managing your account and provide you with access to use our Platform;
2. fulfilment of our contractual obligations when delivering the Platform to you;
3. to deliver and improve the Platform;
4. to provide you with the opportunity to allow other users to follow your ratings;
5. to manage our business, improve our offerings, develop new features and updates, develop personalization services and other types of service, including but not limited to develop and implement algorithms and machine learning;
6. to display to you personalized marketing message on our Platform; and
7. to inform you about new features and updates on the Platform, and our policies and Terms and Conditions.

4-2. Marketing Message

You can give consent to receive marketing messages by e-mail and push notifications provided when signing up to the Platform, which you may withdraw at any time under your Profile Settings or by clicking the “Unsubscribe” button in any marketing e-mail.

If you withdraw your consent to receive personalized marketing message on our Platform, will we still display marketing message to you on the Platform, but they will be of a generic nature and therefore less relevant to you.

4-3. Location

Our App will ask for your permission to enable the collection of the location of your device/you. If you have given permission to collect your device location, we may/will use the location to show you certain offers available around your location as personalized marketing message. Location may also be used for analytics etc.

4-4. Cookies

Cookies are a widely used technology on the Internet for identifying a User’s computer. For purposes listed in 4-1, and also purposes of providing information appropriately and ensuring security at Platform and statistically analyzing maintenance management and usage status of Platform, Khariis may use information identifying the customer such as IP address, browser type, date/time of access combined with information on pages browsed by you, which is collected using cookies. You can disable cookies by changing the browser setting, but his may result in an inability to access some or all of the services provide on the Platform.

5. Provision to Third Parties and Joint Use of Personal Data

If Khariis is to provide a third party with your Personal Data, Khariis will obtain your consent beforehand, unless the provision falls under any of the exemption under GDPR or the laws of Japan. In such case, Khariis will select a third party with care, and request to take the same appropriate measures in management of Personal Data in accordance with GDPR, as if it were Khariis.

When using your Personal Data, Khariis may subcontract such information to a third-party subcontractor to the extent of legitimate use. Khariis will require such subcontractor to strictly manage Personal Data as if it were Khariis, and ensure necessary and appropriate monitoring of the subcontractor. In the event of using Personal Data by the subcontractor, Khariis will comply with the security of such Personal Data by entering into a contract which includes matters in accordance with GDPR.

6-1. Retention and Deletion of Personal Data

Khariis will take appropriate measures to ensure that your Personal Data is kept accurate and up-to-date. Khariis will retain Personal Data for the period necessary to achieve the purpose of use, and within a reasonable period after expiration of the storage period, Khariis will safely erase or anonymize the Personal Data. Khariis will not make decisions based solely on automated processing, including profiling of Personal Data.

Khariis may also store some of your Personal Data to comply with our legal obligations. You may add or update certain information to your account. When you update information, however, Khariis often maintain a copy of the unrevised information in systems back-ups for a period of time until our backup is updated with the latest version.

You may request deactivation of your account by following the instructions at the Platform. If you deactivate your account, Khariis will not delete your information but holds it for you until such time as you either activates your account again or delete it.

When you delete your account, Khariis will delete the data attached to your account including your name. The name will be deleted from all reviews, and the reviews will be anonymized for future viewing. Please note that some information may remain in our records after your account has been deleted, and that Khariis may only be able to delete this information later when updating our backups.

6-2. Your Rights to the Personal Data

You have the following right under GDPR, and are able to exercise the following rights by contacting Khariis’s representative of Personal Data. When you notify us that you wish to exercise your rights and we verify your identification, Khariis will, as a general rule, contact you within one month from the date of receipt of your notice.

1. You have the right to access your Personal Data. You can always access your account to review the personal data we have collected about you, and you may delete and amend the data collected. You also have the right to obtain a copy of the personal data free of charge. However, Khariis may charge a fee corresponding to administrative costs if further copies of the information are requested, or if the request is unfounded or excessive.
2. You have the right of rectification of incorrect or inaccurate data concerning you, or to have incomplete personal data completed. You can use your access to your account to update your personal data.
3. You have the right of erasure of personal data regarding you (under certain circumstances). You can at any time withdraw your consent by deleting your profile or delete your account in the in-app settings.
4. You have the right of restriction of the processing of your data (under certain circumstances).
5. You have the right to object to the processing of your data for marketing purposes by withdrawing your personal consent.
6. You have the right to receive Personal Data provided to Khariis, in a structured, commonly used and machine-readable format and the right to transmit such data to another controller without our hindrance.

6-3. Your Right to Lodge a Complaint with a Supervisory Authority

You have the right to lodge a complaint with a supervisory authority of a country, territory, international organization in accordance with GDPR regarding Khariis’s processing of the Personal Data.

7. Transfer of Personal Data to Third Countries

Khariis expects to transfer Personal Data collected from EEA member countries to Japan or other countries, territories or international organizations within/outside EEA. Countries to which we intend to transfer Personal Data include countries recognized in GDPR as providing adequate level of data protection (including Japan). Khariis will not transfer your Personal Data to a country without an adequacy decision unless we receive your explicit consent to transfer, or Khariis will take measures of the standard data protection to lawfully transfer your Personal Data under GDPR.

8. Security Management of Personal Data

Khariis complies with the GDPR as well as other relevant laws, regulations and industry guidelines. Khariis makes every effort to protect your Personal Data, including taking with preventive and security measures to protect against unauthorized access, destruction, tampering or divulgence.

User accounts including personal data are protected by a password for your privacy and security. You should ensure no unauthorized access to your account and personal data by choosing and protecting your password appropriately, and by signing off when finishing accessing your account. When signing in via third-party application provider your password is solely managed by such third-party.

The Platform is intended for use by adults of legal drinking age in the jurisdiction in which you reside. When receiving notice or reasonably believe that someone under the legal drinking age has provided us with personal information, Khariis will promptly delete the account and all personal information that has been provided to us.

9. Contact Inquiries

This Privacy Policy may be amended from time to time. You will be notified before we make changes to this policy and you will be given the opportunity to review this revised policy before you choose to continue using the Platform.

Khariis has established a customer service desk to respond to your inquiries, comments, and complaints regarding your Personal Data collected and kept by Khriis. After conducting the required verification of your identification, we will respond in good faith to be reasonably necessary. Please note that depending on the inquiry, comment, or complaint, it may take some time for us to provide a response.

Khariis’s representative of Personal Data

• Khariis Co., Ltd.
• 5F Daiwa Azabu Terrace, 3-20-1 Minami Azabu, Minato-ku, Tokyo
• General Manager　Anna Akizuki
• Email privacy@khariis.com