Privacy policy

WE FOLLOW OUR POLICIES
Introduction

CLS Central, LLC and its affiliates and subsidiaries (collectively, the “Tonino Lamborghini Tokyo,” “TLTokyo,” or “Company”) respect your data protection rights. This Global Privacy Policy provides a brief summary and detailed description of how we handle personal information .

Contents of this privacy policy:

  • Personal information we collect through our online stores, physical stores, websites, social media accounts, call centers and repair centers, and the purposes for which we use it.
  • Personal information that we transfer to a third party.
  • The rights you have and how you exercise those rights.

“Personal information” means information that can be used to identify you directly or indirectly. Examples of personal information include your name, email address, and products you have purchased.

  • Providing services

    We and our service providers process personal information about you in order to provide you with all the services and features we offer. This includes the data needed to open your account and the data required to receive goods and services.

  • Marketing

    We may use your data to provide personalized offers regarding our products and services for marketing purposes, unless you opt out.

  • Recipient

    We and our service providers access your data in order to provide services in accordance with the provisions of this Privacy Policy.

  • Customer rights

    You have the right to access your personal information, modify or delete it, or withdraw your consent.

  • Location of your data

    The data we use is primarily stored in Japan by us or our cloud service providers and has appropriate safeguards in place.

1. What personal data do we use, for which purposes and on which legal basis?

In order to provide you with our services and the full range of features, we and our service providers use your data (including your name, email address and IP address) for the following purposes:

  • When you create an online customer account, to manage your account, to provide access to your shopping cart, to display purchased, reserved and registered products, or to present other products presumably of interest to you, to verify your identity if you forgot your password and to process your product reviews.
  • When you choose to provide us further information, such as date of birth, address, personal settings, a wish list and your gender, to enable us to personalize both your profile and our recommendations for you.
  • When you order goods online, in this case we additionally need your address, telephone number and payment information, to process your purchase, send you confirmation or back-in-stock notification and scan transactions for fraudulent activity.
  • When you order goods to be picked-up in one of our stores, we need contact details such as name and email address of a pick up person other than you.
  • When you purchase a product in a Tonino Lamborghini store and request an e-receipt, to process your request.
  • When you participate in loyalty programs, recommend our products to others, redeem a gift card, or when we offer you discounts and bonuses etc. we use this information in addition to purchase-related information to determine whether you are eligible for additional discounts and special offers.
  • When you share a product or wish list via our homepage to a friend or when you provide us with the contact details of a friend we will use it only to process your request.
  • When you share any pictures/materials with us for publication on social media for such publication.
  • When you enter a sweepstake, contest/competition, or promotion sponsored by us to administer the sweepstakes, contest/competition or promotion.
  • When you return or exchange a product or when you send us your product for warranty or repair service, to process the request and any communication in connection with this.
  • When you contact us to answer your requests, provide customer support and handle your inquiry.

In principle (unless we have a legal or other legitimate reason to maintain it), we delete information related to you

  • upon your request,
  • after expiry of the relevant legal retention period,
  • once we do not have any business purpose for retaining the data anymore.

In addition to those just described, we want to explain certain of our processing activities to you in more detail:

1.1 Surveillance with security cameras

We process data obtained from surveillance cameras in our stores and on the premises for the purpose of ensuring security, shoplifting prevention, and fraud prevention. We will share this data in the circumstances stipulated in Section 3. The duration of the data storage depends on the governing national law unless storage is otherwise permitted

1.2 Interest-based advertising

We may contact you via email, mail, or other means of communication (eg social media, text messages, telephone) for direct marketing purposes. However, unless the customer refuses to receive a message for direct marketing purposes. We can determine which marketing information may be of interest to you and do the following to customize your advertising and offers:

  • Use publicly available information (eg, information available from your social media profile).
  • Analyze your account information and how you use our services such as our websites, social media accounts, advertisements on third party websites, and our newsletters.
  • Use information about your use of gift cards, rewards or perks, sweepstakes, contests, competitions, surveys or participation in loyalty programs.
  • Use the information collected by our service providers or partners (eg Google).
  • Use the information collected when you request an electronic receipt at our store or fill out a registration form.
1.3 Cross-device targeting

In order to save your preferences, analyze your usage of our websites, provide interest-based advertising to you and deliver tailored ads across multiple devices, we try to link the different devices you are using to you. Technically, we are storing cookies on all the devices you are using and match those cookies within our internal database.

1.4 Log files, cookies and similar technologies

Every time you visit our website, our system stores data related to your browser, its version, the operating system of your computer, your IP address, date, length and time of your visit, the website you accessed before and the one you visit following links on our website. We use this information for our legitimate security interest and we delete log files without undue delay.

1.5 Customer Reviews and Shared Content

When you post a product or seller review or upload an image or other material to our website, or when you share content with us on third party websites, such as social networks, we publish and use this information on our and third party websites. We do not control and do not assume responsibility for the use of information by such third party websites.

Please also note that you must own the intellectual property rights in the content you upload to our website and share with us and must not violate the rights of others (e.g. intellectual property or data protection rights). In uploading, you grant us, and our respective service providers, a royalty-free, unrestricted, non-exclusive, perpetual, irrevocable, sub-licensable, transferable and worldwide license to use, edit, copy, adapt, translate, publish, display, make available, communicate and distribute the content partially or in whole, and to incorporate it in other works for any purposes such as advertising, marketing and promotions and in any form, media or technology known today or later developed.

1.6 Legal basis (Japan)

We will comply with the Act on the Protection of Personal Information (hereinafter referred to as the “Personal Information Protection Act”), other applicable laws that stipulate the protection of personal information, and the laws that supplement them.

2. Where to get personal information

Most of the personal data we process we received from you or your actions, be it because you entered the data during the registration process, placed an order, applied for a job vacancy or because we track your usage of our website or newsletter etc. However, we also may receive information about you from other sources, such as, CLS Central companies, and, if publicly available, from third party websites. In some cases we receive Personal Information about you from our service providers and partners, e.g. from Facebook, Google etc.

3. When do we share personal information

We will share your personal information if:

3.1 Legal obligations and internal purposes

We disclose your Personal Information

  • in order to comply with relevant laws, regulatory requirements and to respond to lawful requests, court orders, and legal processes, including requests to meet national security or law enforcement requirements,
  • in order to protect and defend the rights or property of us or third parties,
  • in an emergency, in order to protect the safety of our employees or any person.
3.2 Links to third party websites and services

On some pages we allow you to share Personal Information with third parties, such as social networks like Facebook. In these instances you are agreeing to the data being shared and the shared data being subject to the privacy policies of the third party. We do not control and do not assume any responsibility for the use of Personal Information by such third parties. For more information about the third party’s purpose and scope of their use of Personal Information in connection with sharing features, please visit the privacy policies of such third parties.

3.3 Advertising by a third party

We use third-party service providers to display advertisements across the internet. These advertising service providers may collect information about your visits to our website and your interaction with our products and services, as well as your visits to other websites. Such information does not include your name, address, email address but may contain browser-related information.

3.4 Public Disclosure

Any Personal Information that you include in the text of a product review may be made public in the product review section of our product pages. We may also share the information contained in your wish list with your friends and family as instructed by you or make it public on our Website in case you enable this function. Wish lists made public can be found by searching for your name or email address on our websites.

3.5 Sharing with third parties

We involve other companies for the provision of services, who are allowed to use Personal Information only on our behalf and must not use it for their own purposes, unless permitted by law.

As follows a list of categories of recipients together with the respective purposes:

  • Enable the functionality of our online application portal.
  • Providing customer care services.
  • To provide hosting and general IT services.
  • Use data cleansing technology to ensure the accuracy of data such as your address.
  • Take advantage of features, social, analytics-related technologies, and technologies that enable behavioral marketing
  • Use social media services.
  • To provide a payment service.
  • Use transportation and logistics services.
  • Conduct a direct marketing campaign.
  • Manage sweepstakes, contests and competitions.
3.6 Transfer of assets

We may transfer your Personal Information to a third party in the event of a transfer of all or some of our assets to a third party.

4. For how long do we use personal information

We will retain your Personal Information as long as necessary to provide you with functionality and services as described above under section 1, as long as reasonably necessary to further our legitimate interests or as long as we are required by law. Examples include the defense against, or the establishment of legal claims and legal obligations (e.g. tax law, or the principle of accountability, which requires us to demonstrate that our processing complies with applicable data protection laws). In order to verify whether you opted out or in to marketing activities, for example, we store your respective choice (e.g. via a cookie or a declaration).

4. Customer rights

With respect to the personal information you provide or the personal information collected under this Privacy Policy, you may opt out of use for direct marketing purposes, such as contacting us regarding products or promotions. Please consider that if you exercise your opt-out choices, it may take up to ninety (90) days for your opt-out choices to be fully effective. To exercise your opt-out rights, please contact us at privacy@clscentral.com.

6. Cross-border relocation

We also work with service providers outside of Japan. Unless we transfer personal information to any country or region under another exception that allows us to transfer it as permitted by applicable law, these service providers will enter into a contract between us and that service provider. We will take all possible measures to process your personal information based on this.

7. Personal information of minors

We do not knowingly collect, maintain or use Personal Information about children under 18. Persons under the age of 18 may not use our Website without supervision from a responsible adult. We will never request Personal Information from a child under 18 without verifiable parental consent. If we become aware that a child under 18 has sent Personal Information without prior parental consent, we will remove his or her Personal Information from our records.

8. Access to and your rights regarding personal information

This website gives you the ability to view and change the Personal Information you provided to us within the My Account section of the website. You may access information we hold about you, request a correction where data is incorrect or a deletion of your data, unless we have to keep your data for legal reasons. We encourage you to address any concerns you may have regarding our use of your Personal Information by using the contact details provided below.

9. Protection of personal information security

We are committed to making every effort to protect the security of your personal information from unauthorized access, use, duplication, modification, disclosure, destruction and alteration. Therefore, we have introduced risk-based physical, technical and organizational security measures. These measures include, but are limited to, regular testing of our technology and practices, including applying the latest security updates, system and network access control, encryption.

10. Complaints

If you are concerned that we do not respect your legal rights or comply with applicable privacy laws, you can send us an email using the contact page. You can file an internal complaint or formally file a complaint with the Personal Information Protection Commission ((https://www.ppc.go.jp/)).

11. What happens if we change this privacy notice?

This privacy policy will come into effect on January 28, 2021 and may be updated from time to time. We will notify you only if there are significant changes by posting a prominent notice on our website or by sending an email.

12. Links to and from other websites

Whenever we provide links to other websites on our website, this is in the interest of our users and should be understood as a courtesy. Pages to which we link and pages that link to our websites are not under our control. In such cases we are neither responsible for the content of these pages nor for compliance with the applicable data protection regulations of those providers. We recommend that you carefully read the privacy statements of these third parties to learn how your Personal Information is stored, used or shared.

13. Our basic information and contact

If you have any questions, concerns, inquiries, complaints or requests regarding our commitment to personal information, please contact Tonino Lamborghini Tokyo.

Phone number: +81 (0) 3-4530-0835

CLS Central LLC
Attn: Tonino Lamborghini Tokyo
106-0031
Minato-ku, Tokyo
3-2-13-1003 Nishiazabu

You can also contact our data protection team and our designated data protection officer by email ( privacy@clscentral.com).

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