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PRIVACY POLICY

SANTILLO CICLI respects and appropriately protects your personal information, and strives to comply with laws and regulations related to personal information protection and other standards, as well as to protect privacy.
This privacy policy explains how we protect your personal information.

1. Definition of Personal Information

For our company and this website, personal information refers to information that can identify you, such as your name, gender, date of birth, contact information (address, residence, telephone number), email address, etc., that you provide to us, as well as your usage history on this website that can be combined with this information to identify you.

2. Purpose of use of personal information

Our company and this website use personal information provided by customers, such as name, gender, date of birth, etc. for the following purposes:

3. Handling of Personal Information

When handling users' personal information, we will take and implement necessary and appropriate measures to prevent unauthorized access, leakage to outside parties, loss or damage, and other safe management of personal data. In addition, in order to improve the services we provide to our customers, we may outsource the operation of individual services to affiliated companies.

4. Provision and Entrustment of Personal Information to Third Parties

Except as required by law, within the scope of the above-mentioned purposes of use, we may provide or entrust personal information to the following parties in writing, by email, postal mail, telephone, etc. In addition, we require affiliated companies and contractors to whom we outsource work to implement appropriate safety management measures when handling personal information.

5. Confidentiality of Personal Information

We will not disclose or provide personal information to third parties other than our company or our subcontractors without your consent. However, if the following conditions apply, we may disclose personal information regardless of whether or not you have given your consent.
・When responding to legal requests from public institutions made to our company or contractors ・When protecting the rights or property of our customers or our company ・When taking emergency action to ensure the physical safety of our customers, the general public, our employees, contractors, etc.

6. Correction of personal information

We will respond to inquiries about your personal information (personal information subject) and
If you wish to make any corrections, additions or deletions,
After confirming that the person making the request is the person in question,
We will respond to inquiries and correct, add, or delete information within a reasonable period and scope.

7. Contact point for inquiries regarding personal information

Neptune Design Co., Ltd. [Personal Information Disclosure, Complaints, and Consultation Desk]
TEL: 0467-67-1515 (main)
TEL: 050-5235-9127 (Japanese only)

Address: 301, 42-1 Tokiwa, Kamakura City, 248-0022
Reception hours: 10:00-17:00 (excluding Saturdays, Sundays, national holidays, and the New Year holidays)

8.Revision of Privacy Policy

The principles of this Privacy Policy may be revised as appropriate in response to changes in social conditions, changes in public awareness, technological advances, the status of the Personal Information Protection Act, etc., and any such revisions will be notified on this website.

Information Security Basic Policy

We recognize that protecting the security of information assets, including personal information, and living up to the trust of our customers and the society around them is a social responsibility and is essential for the continuation of our business.
For this reason, we have established an "Information Security Basic Policy" and will strive to properly handle and maintain information assets in order to maintain their confidentiality, integrity, and availability.

1. Management and protection of information assets

We will establish an information security management system and strive to properly manage information assets.

2. Compliance with laws and regulations

We will comply with all laws and regulations related to information security, national guidelines, other social norms, and contractual security obligations.

3. Protection of personal information

Personal information will be managed in accordance with our "Privacy Policy."

4. Education and training

We will continue to provide the necessary training to ensure information security and promote thorough awareness of this basic policy.

5. Continuous improvement

We will continually review and improve the above activities through daily monitoring, regular internal audits, and reviews by our representatives.

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March 15, 2012
SANTILLO CICLI
Representative Director Francesco Santillo

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