Privacy Policy

Our Company is part of Triumfield Holdings, which includes Our Company ""SBTJapan,"" ""Autocom Japan,"" ""Ru,"" ""Blauda,"" ""Axia,"" “Beelinks” and ""Triumfield Holdings."" This privacy policy will explain how our organization uses personal data we collect from you when you use our website.

We and our group companies (collectively, the "Group") believe it is vital to protect the personal data of our customers (including representatives of companies we do business with) and users of the Group’s website (collectively, "you") in order for the Group to fulfill the expectations of you and all other stakeholders. The Group sets out this privacy policy (this "Policy") with respect to the handling of personal information to ensure personal information will be appropriately managed and protected. Unless otherwise specified in this Policy, the terms used in this Policy shall have the meanings given to them in the "Japan Act on the Protection of Personal Information."

• Definitions

  For the purposes of this Privacy Policy:

  • "Personal Data" or “Personal information” refer to information relating to an identified or identifiable natural person.

  • "Statutes" refers to the General Data Protection Regulation (GDPR), Japan's Personal Information Protection Act and related national laws and regulations.

  • "Processing" means any activities relating to the use of personal data by the organization, whether by automated means or otherwise, including collection, recording, compilation, record keeping, or modification, retrieval, reference, use, disclosure by transmission, distribution or making available to any other party, alignment or combination, restriction, erasure or destruction.

• How do we Collect your Data?

  You directly provide The Group with most of the data we collect. We collect data and process data when you:

  • Register online or place an order for any of our products or services.

  • Voluntarily complete a customer survey, provide feedback on any of our message boards or via email or contact us.

  • Use or view our website via your browser’s cookies.

• Compliance with Laws and Regulations

  The Group handles personal information about you in accordance with the Personal Information Protection Act, the EU General Data Protection Regulation (the “GDPR”), Japan's Personal Information Protection Act and other applicable laws and regulations regarding protection of personal information and privacy.

• What Data do we Collect?

  The Group obtains your personal information described below. For the avoidance of doubt, the Group does not obtain your personal information without your consent.

  1. Identity verification information: Name, address, phone number, and email address.

  2. Information we obtain in relation to your use of services: Information that can identify a specific person using the browsing history, IP address of the person who accesses the Group’s website, cookie information, location information, individual device identification information, and other descriptions, or information containing an individual identification code, when you view the Group’s website.

• Purpose of Use

  The Group uses your personal information only within the scope of the following purposes except with your prior consent or where required by law.

  N°	Purpose of Use
  1	Performance of contract such as shipment of products, provision of services and issuance of invoice Response to your requests before execution of contract
  2	Group’s marketing activities such as communicating with and conducting a questionnaire with you
  3	Provision of customer services to you
  4	Product sales analysis, other surveys and studies, and development of new services and products
  5	Services incidental or related to any of the foregoing, and response to inquiries
  6	To respond to investigations by government agencies.

• Security Management Measures

  The Group takes necessary and appropriate security management measures to prevent personal information from being leaked, accessed by unauthorized users, lost, damaged or tampered with. Inquiries about security management measures The Group takes should be directed to the details set out in “16. Contact.”

• Supervision over a Trustee

  The Group may entrust a whole or part of the handling of personal information within the scope necessary to achieve the purpose of use. In such case, The Group will take appropriate security management measures in accordance with its Information Security Management Rules. In addition, The Group will ensure, through the execution of the service agreement, etc., that personal information will be handled by the Trustee under appropriate security management measures.

• Provision to Third Parties

  The Group will not disclose or provide your personal information to third parties without your prior consent or such provision, except where relevant law or regulation allows us to disclose or provide your personal information to third parties without your consent.
  However, in the cases indicated in “9. Sharing of Personal Information,” we may provide personal information to third parties.

• Sharing of Personal Information

  We may share your personal information in the manner described below.

  1. Items of personal information we share: Information described in “4. What data do we collect?”

  2. Those with whom we share personal information:

     Third-parties	Reason for sharing
     Our group’s companies	To carry out our daily business operations and so we can maintain, improve and provide SBT service and acquired companies’ services to you."
     Payment partners	So they can process your payments and for anti-fraud purposes.
     Google Analytics	To understand how users engage with our sites.
     Google Search Console	To understand how users access our sites.
     Microsoft Clarity	To understand how users engage with our sites.
     Zeta	To use our services related to the “recently viewed” and “recommend” functions.
     Yotpo	To use our services related to the “review” function.

  3. Purpose of use of personal information we share: Purposes described in “5. Purpose of Use”

  4. Person responsible for the management of sharing personal information
     Name: Triumfield Holdings Co., Ltd.
     Address: Oak Yokohama Building 2F, 2-15-10 Kitasaiwai, Nishi-ku, Yokohama-shi, Kanagawa
     Representative: Masaki Ito, President and Representative Director

• Request for Disclosure, etc. of Personal Information

  1. Request for Disclosure, etc.
     The Group will, in accordance with Japan’s Personal Information Protection Act, appropriately respond to your (a) request for disclosure of personal information or records of provision to third parties, (b) request for notification of the purpose of use, (c) request for correction, (d) request for addition, (e) request for deletion, or (f) request for suspension of use or cessation of provision to third parties (collectively, the “Request for Disclosure, etc.”) with respect to your personal information the Group holds to the extent permitted by Japan’s Personal Information Protection Act.

  2. Procedures
     Inquiries about a Request for Disclosure, etc. including our prescribed procedures and fee amounts should be directed to the details set out below in “16. Contact” and we will reply to them without delay."

• GDPR Special Provisions

  If you are in the European Economic Area (the “EEA”), the GDPR applies to you. Therefore, the special provisions specified below (these “Special Provisions”) apply in accordance with the GDPR. If you are in the United Kingdom of Great Britain and Northern Ireland, the data protection regulation equivalent to the GDPR applies to you. Therefore, these Special Provisions apply.

  1. Purpose of Use of Personal Data and Legal Basis therefor
     The Group obtains and processes your personal data under the following specific legal bases."

     N°	Purpose of Processing	Legal Basis
     1	Performance of contract such as shipment of products, provision of services and issuance of invoice by the Group Response to requests from users of the Group’s website before execution of contract	Your consent, performance of contract
     2	Communicating to and conducting a questionnaire with users of the Group’s website for the Group’s marketing purposes	Performance of contract, legitimate interests (for the Group’s normal business purposes)"
     3	Right to request access, rectification, erasure or restriction	Performance of contract, legitimate interests (for the Group’s normal business purposes)"
     4	Product sales analysis, other surveys and studies, and development of new services and products	Legitimate interests (for the Group’s normal business purposes)"
     5	Services incidental or related to any of the foregoing, and response to inquiries	Performance of contract, legitimate interests (for the Group’s normal business purposes)"

     Personal data specified above is essential for the Group to provide its services to you and if you do not provide such data, we may not be able to provide necessary services to you.
     If the Group processes personal information for purposes other than those listed above, the Group will provide you with the purpose of processing and other necessary information and obtain your prior consent.

  2. Retention Period of Your Personal Data
     The Group will store your personal data only for the period necessary to achieve the purposes specified in this Policy.

  3. Your rights

     • Right to request access, rectification, erasure or restriction
       You are entitled to the following rights regarding your personal data the Group holds:

       • Right to request access to your own personal data

       • Right to request rectification to your own personal data

       • Right to request erasure of your own personal data

       • Right to request restriction of processing of your own personal data

       • Right to request transfer of your own personal data to you or a third party

     • Right to object to processing
       You have the right to object us to processing your own personal data for our legitimate interests.

     • Right to withdraw consent
       If the Group processes your personal data based on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

     • Procedures for the exercise of your rights
       Inquiries about the procedures for the exercise of your rights (including how to withdraw consent) should be directed to the details set out in “13. Contact for Inquiries” of our Policy and we will reply to them without delay.

• Handling of Cookies

  This cookie policy explains what cookies are and how we use them on our website. You should read this policy so you can understand what type of cookies we use, the information we collect using the cookies and how that information is used. Every time you visit this website, you will be prompted to accept or refuse cookies.

  1. What are cookies?

     Cookies are text files which contain a small amount of information. Cookies are stored on the browser or hard drive of your computer or device.

  2. Use of Cookies

     SBT’s website uses cookies and other similar tracking or analytical technologies (collectively, “Cookies”) to improve services for you.
     We use cookies to distinguish you from other users of our website and to provide a browsing experience that is unique to you. Cookies are used by us so that our website can remember what you have done whilst browsing, for instance, your log-in details, how far you have progressed with an order.

  3. Overview of cookies

     Cookies are exchanged between a web server and your internet viewing software (browser) and are placed on your device by the website that you visit. You can disable the function of cookies by setting your browser. However, if you do this, you may not be able to use a part or the whole of the website’s services.

  4. What type of cookies do we use?

     Cookies can be in the form of session cookies or persistent cookies. Session cookies are deleted from your computer or device when you close your web browser. Persistent cookies will remain stored on your computer or device until deleted or until they reach their expiry date. We use the following cookies:
     
     Strictly necessary cookies.  (Always active) These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
     
     Functionality cookies.  (Always active) These cookies are used to recognise you when you return to our website. This enables us to personalize our content for you, such as greeting you by name and remembering your preferences. It also allows for live chat support during your browsing experience.
     
     Analytical/performance cookies.  These cookies allow us to recognise and count the number of visitors to our website and to see how visitors move around when they are using it. This helps us to improve the way our website works, for example, by ensuring that users find what they are looking for easily.
     
     Targeting cookies.  These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. These cookies allow you to share and send information to other websites.

  5. Strictly necessary and functionality cookies (Always active)

     These necessary cookies include "strictly necessary cookies" and "functional cookies," which cannot be deactivated. Strictly necessary cookies are essential for the website or application to function properly, while functional cookies are necessary to save your preferences and settings, such as keeping track of your privacy choices and enabling you to use our chat service.

  6. How do you block cookies?

     Most browsers allow you to refuse cookies. You may block our cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.
     
     If you block our use of cookies, you may be unable to access certain areas of our website and certain functions and pages will limit the service that we are able to provide to you and may affect your user experience.

  7. Google Analytics

     SBT uses Google Analytics provided by Google as an access analytics tool. Google collects information about your browsing activities based on Cookies set by us or Google. The Group receives Google Analytics results to understand your service usage and may use such information for SBT’s services. Google Analytics does not collect any personally identifiable information.The data collected through the use of Google Analytics is governed by Google's Privacy Policy. For the Google Analytics Terms of Service and Privacy Policy, please visit the Google Analytics homepage for the Google Analytics Terms of Service and Google Policies and Terms. In addition, we shall not be responsible for damages caused by the use of Google Analytics services. https://policies.google.com/privacy?hl=en-US
     
     In addition, we may also use Google Search Console to monitor and fine-tune how Google Search indexes and ranks our content. The search console does not use cookies, log-in or other information. Further information concerning the terms and conditions of use and data privacy can be found at https://privacy.google.com/. 
     

  8. Microsoft Clarity

     We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heat maps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement. https://privacy.microsoft.com/en-GB/privacystatement
     

• Zeta

  SBT uses Zeta for the “search”, "recently viewed”, and “recommend” functions of our sites. Zeta collects information about your browsing activities based on cookies set by us or Zeta. Further information concerning the terms and conditions of use and data privacy can be found at https://zeta.inc/privacy (only in Japanese).

• Yotpo

  1. SBT uses Yotpo Ltd as a data processor. Yotpo Ltd helps us with our handling and administration of your review. When we share your data, it will be used for the same purposes for which we originally collected it.

  2. SBT and the moderator of the reviews will see all the information you provide. The information you provide when submitting your review may be used to improve our products and services.

  3. SBT and third-party suppliers may use your email address to contact you as part of your review. Your email address will not be used for marketing purposes.

  4. Yotpo typically processes your first and last names, email, country, and IP addresses as well as other information related to your order as provided via our integration with Yotpo Ltd.

  5. Our external data processor, Yotpo Ltd, is established outside Japan, and in the USA. For more information about how Yotpo collects and uses your data, visit the Yotpo Privacy Policy. https://www.yotpo.com/privacy-policy/

• Changes to our Privacy Policy

  Our Company keeps its privacy policy under regular review and places any updates on this web page.

• Contact

  Please direct any inquiries, requests, complaints or suggestions about personal information to:
  SBT CO., LTD.
  Email: personalinfo@sbtjapan.com
  TEL: number: +81-45-290-9480
  Office hours: 9:00 a.m. to 5:00 p.m. Japan time(JST)

• Data Protection Officer (DPO)

  We have appointed a Data Protection Officer (DPO) in accordance with data protection laws, such as the GDPR, to monitor compliance with our data protection policy and the secure management of personal data, and to handle data protection inquiries and complaints from data subjects.
  
  Contact Information:
  Data Protection Officer：Masahiro Saito
  Email: personalinfo@sbtjapan.com
  Phone: +81-45-290-9480
  Please contact us between 9:00 am and 5:00 pm on weekdays. We are committed to ensuring the security of your data in accordance with applicable data protection laws.