Legal Area

Privacy Policy

This Privacy Policy (hereinafter referred to as “this Policy”) is intended to inform customers of ADAL Co., Ltd. (3-13-2 Kanenokuma, Hakata-ku, Fukuoka-shi, Fukuoka Prefecture) and its group company ADAL EUROPE SRL (Largo Francesco Richini, 6, 20122 Milano, Italy) (hereinafter collectively referred to as “our company”), customers, visitors to our website, and our employees (hereinafter collectively referred to as “you”), who are located in the European Economic Area (EEA) about the collection, use, disclosure, transfer, and other processing of personal data.

We process your personal data in accordance with EU data protection regulations, including the EU General Data Protection Regulation 2016/679 (hereinafter referred to as “GDPR”)

About the Personal Data We Process

We process the following categories of personal data:

Contact Information: Name, business name, business address, region, country, department name, telephone number, fax number, email address
Transaction-related Information: Contract details, transaction details, bank account information, past transaction history, etc.
Online Identifiers: IP address, cookies, etc.
Employment-related Information: Employee ID, resume (e.g., work experience, education), address, whether or not you have dependents, date of birth
Bank Account and Insurance Information: Bank account information, national social security or tax identification numbers (EEA)

How We Collect Personal Data

We receive or acquire personal data in the following cases.

1. Contact information (name, business name, business address, region, country, department name, telephone number, fax number, email address) and transaction-related information (contract details, etc.) will be acquired directly from you via methods 1.1 through 1.6 below.

1.1 When you fill out a “Contact Us” form
1.2 When you contact us through our website
1.3 When you contact us by email, phone, or in person
1.4 When you fill out an application form to use our services
1.5 When you send, transmit, or deliver other necessary documents to us
1.6 When we collect personal information in the course of a specific transaction with you (including information collected 　through the exchange of business cards and at exhibitions, etc.)

2. Online identifiers (IP addresses, cookies, etc.) are automatically collected when you visit our website.

3. Employment-related information is collected when job applicants send it to us by email or international mail, etc.

4. Bank account and insurance information is collected when employees send it to us by email or international mail, etc. when joining the company.

In addition to the above, we may collect contact information and transaction information of existing customers, as well as contact information of potential customers, from our group company ADAL EUROPE SRL, located in Italy, for the purpose of initiating new transactions and providing after-sales service.

Purposes and legal basis for processing personal data

We process personal data for the following purposes and legal bases. We strive to ensure that the personal data processed is adequate, relevant, and minimized to the extent necessary to achieve those purposes. If we process personal data for a purpose different from the original purpose, we will notify you.

Purpose	Categories of personal data	Legal basis
To identify customer	Contact information: name, business name, business address, region, country, department name, telephone number, fax number, email address	Performance of a contract (Article 6(1)(b) of the GDPR)
To provide and sell products and services to customer	Contact information: Name, business name, business address, region, country, department name, telephone number, fax number, email address Transaction-related matters: Contract details, transaction details, past transaction history, etc.	Performance of a contract (Article 6(1)(b) of the GDPR)
To carry out export procedures (including customs procedures) and import procedures (including customs procedures) in the local country that customers entrust to us	Contact information: name, business name, business address, region, country, department name, telephone number, fax number, email address Transaction-related information: contract details, transaction details, past transaction history, etc.	Performance of a contract (Article 6(1)(b) of the GDPR)
To send or e-mail materials required for our transportation services and other related services	Contact information: Name, business name, business address, region, country, department name, telephone number, fax number, email address Transaction-related matters: Contract details, transaction details, past transaction history, etc.	Performance of a contract (Article 6(1)(b) of the GDPR)
To provide information and guidance on our products and services to existing and potential customers	Contact information: name, address, telephone number, email address, business name, industry, job type	Legitimate interests (Article 6(1)(f) of the GDPR): Providing our services and relevant, useful information to existing and potential customers who may be interested is essential to building relationships with customers and growing our business. We believe this purpose is within the scope of your reasonable expectations, and we take care not to unduly affect your rights and interests by guaranteeing you the right to easily unsubscribe from receiving such information at any time.
To respond to inquiries made through our website	Contact information: name, business name, email address Transaction-related information: contract details, transaction details, past transaction history, etc.	Legitimate interests (Article 6(1)(f) of the GDPR): To acquire customers by accurately providing the details of our services to potential customers who are considering using our services, or to respond to questions from customers during transactions.
For recruitment selection and contact regarding the selection process	Employment-related information: resume (e.g., work experience, education), address, whether you have dependents, date of birth	Legitimate interest (Article 6(1)(f) of the GDPR): To carry out the proper recruitment procedures and effective selection process.
For personnel and labor management	Employment-related information: employee ID, resume (e.g., work experience, education), address, whether you have dependents, date of birth Bank account and insurance information: bank account information, social security number	Performance of a contract (Article 6(1)(b) of the GDPR)

Regarding the length of time we retain data, we will retain personal data to the extent necessary for the purposes stated above, and will not retain personal data for longer than necessary unless we are legally obligated to retain the data. Specifically, we will retain personal data for the following periods:

Categories of personal data	Data Retention Period
Contact information: name, business name, business address, region, country, department name, telephone number, fax number, email address	In accordance with Japanese law, we will retain your personal information for seven years from the end of the transaction.
Transaction-related matters: contract details, transaction details, past transaction history, etc.	In accordance with Japanese law, we will retain the information for seven years from the end of the transaction.
Online identifiers: IP addresses, cookies, etc.	Duration necessary for data processing
Employment-related information: employee ID, resume (e.g., work experience, educational background), address, whether you have dependents, date of birth	In accordance with Japanese law, the information will be retained for five years from the end of the employment contract.
Banking and Insurance Information: Banking information, Social Security number	In accordance with Japanese law, the information will be retained for five years from the end of the employment contract.

How We Share Personal Data

In accordance with the GDPR, we share your personal data with third parties operating the following types of businesses for the purposes set out in this Privacy Policy. This sharing also includes transferring your personal data to Japan, which is outside the EU/EEA.

1. Cloud Services Managing Your Information

To manage your information, we use a customer relationship management system operated by an external service provider (ZohoCRM) that uses servers located in the USA. Your contact information, transaction information, etc., on our website are shared with this customer relationship management system provider.
For information on ZohoCRM’s handling of personal information, please see the following privacy policy: https://www.zoho.com/privacy.html

2. Companies Providing Data Analysis Tools (Locations: Japan and the US)

Your personal data may be transferred to Japan, or the US, which are outside the EU/EEA (this may change depending on changes in the business environment).

3. Sharing among our group companies

We(ADAL Co., Ltd. and ADAL EUROPE SRL) share your contact information, transaction information, etc. between our companies in order to provide potential customers in Europe with information about our products and to respond to inquiries from current or potential customers.

Regarding transfer of personal data to countries outside the EEA:

When transferring personal data outside the EEA, we enter into appropriate contracts for data transfers, such as the Standard Contractual Clauses defined by the European Commission Decision of June 2021 (Commission Implementing Decision (EU) 2021/914). Furthermore, for transfers to the US, we comply with the EU-US Data Privacy Framework (EU-US DPF). If you would like a copy of the non-confidential portion of the transfer safeguards, please contact us using the details below. If the country to which we are transferring is recognized by the European Commission as having a level of personal data protection equivalent to that of the EU, we will transfer the data without using safeguards such as the Standard Contractual Clauses.

Regarding disclosure of personal data to authorities and courts:

In the context of investigations or legal proceedings, we may be required to disclose personal data upon order from public authorities or courts. We may also disclose personal data when we believe in good faith that disclosure is reasonably necessary to protect our rights and pursue available remedies.

Regarding Your Rights

You have the following rights regarding the personal data we process.

1. Right of Access

You have the right to access your personal data, etc. In addition, you may receive a copy of your personal data held by our company (however, this does not necessarily have to be in writing).

2. Right of Rectification

You have the right to request the correction of inaccurate personal data concerning them.

3. Right of Erasure

You may request the erasure of your personal data if any of the following requirements are met.

3.1 The personal data is no longer necessary for the purposes for which it was collected or processed.
3.2 The processing of your personal data is based on your consent, and they withdraw that consent, and we are no longer able 　　to rely on another legal basis for processing.
3.3 You object to the processing of your personal data, and there are no overriding legal grounds for processing.
3.4 The personal data has been unlawfully processed.
3.5 The erasure of personal data is necessary to comply with a legal obligation to which we are subject.
3.6 The personal data was collected in connection with the provision of information society services pursuant to Article 8(1) of the 　　GDPR.

However, we are not required to comply with requests from you if the processing is necessary (i) to exercise the right to freedom of expression and the right to information, (ii) to comply with a legal obligation involving processing, (iii) for reasons of public interest in the field of public health, (iv) for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, or (v) for the establishment, exercise, or defence of legal claims.

4. Right to Restriction of Processing

You may request the restriction of processing of your personal data if any of the following conditions are met:

4.1 You dispute the accuracy of the personal data, during the period required for us to verify the accuracy of that personal data
4.2 The processing of personal data is unlawful, and you oppose the erasure of the personal data and instead request the 　　restriction of its use
4.3 We no longer need the personal data for the purposes of the processing, but you require it for the establishment, exercise, or 　　defense of legal claims
4.4 You have objected to the processing of your data, and we are not yet certain whether our legitimate grounds override those 　　of ours.

However, this does not apply if: (i) you have consented; (ii) it is for the establishment, exercise, or defense of legal claims; (iii) it is necessary to protect the rights of another natural or legal person; or (iv) it is necessary for important public interests of the EU or a Member State.

5. Right to Data Portability

If the processing of personal data is based on your consent or the performance of a contract and is carried out by automated means, you have the right to receive the personal data they have provided in a structured, commonly used, machine-readable format and to request the transmission of such personal data to another controller.

6. Right to Object

You have the right, on grounds related to your particular situation, to object at any time to the processing of your personal data carried out in accordance with Article 6(1)(e) or (f) of the GDPR, including in the case of profiling based on these provisions. We will not process the personal data of you unless we can demonstrate compelling legitimate grounds for the processing, which relate to the interests, rights, and freedoms of you, or the establishment, exercise, or defence of legal claims. Furthermore, if personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing.

7. Right to Object to Profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or significantly affects you. However, this does not apply in any of the following cases:

7.1 Where it is necessary for the conclusion or performance of a contract between you and our company
7.2 Where it is required by EU law or Member State law to which our company is subject and which also sets out appropriate 　　measures to safeguard the rights and freedoms and legitimate interests of you
7.3 Where it is based on your explicit consent

8. Right to Withdraw Consent

If the processing of personal data is based on consent, you have the right to withdraw your consent related to your personal data at any time.

9. Right to File a Complaint with a Supervisory Authority

If you believe that the processing of your personal data violates applicable data protection laws, you may file a complaint with your local supervisory authority regarding data protection issues.

Automated Decision-Making

We do not make automated decisions (including profiling) that have legal effects on you or similarly significantly affect you.

Privacy Policy Updates

We may revise or update this Policy from time to time. Any changes to this Policy will become effective when the revised Privacy Policy is posted on our website.

Contact Us

If you have any questions or requests regarding this Policy, please contact us at the address below.

ADAL Co., Ltd.
3-13-2 Kanenokuma, Hakata-ku, Fukuoka-shi, Fukuoka 812-0863
Email: [email protected]

ADAL EUROPE SRL (EU Subsidiary)
Address: Largo Francesco Richini, 6, 20122 Milano, Italy
Email: [email protected]

Cookie name	Purpose of use	Retention period	Recipient and Privacy Policy	Legal basis
cf_clearance	To demonstrate that a website has bypassed Cloudflare’s security protections and passed Cloudflare’s security checks	About 1 year	Cloudflare, Inc. https://www.cloudflare.com/privacypolicy/	Legitimate interest (Art. 6(1) (f) of the GDPR): To provide you with a secure use of our website through Cloudflare security.
LS_CSRF_TOKEN	To verify that requests sent by users are legitimate requests from users themselves	Delete at session end	Zoho Corporation Pvt. Ltd https://www.zoho.com/privacy.html	Legitimate interest (Article 6(1) (f) of the GDPR): To provide you with smooth customer support on our website using the Zoho CRM platform.
uesign	To verify the client ID when loading chats from a user’s previous visits to the website	1 month at session end	Zoho Corporation Pvt. Ltd https://www.zoho.com/privacy.html	Legitimate interest (Article 6(1) (f) of the GDPR): To provide you with smooth customer support on our website using the Zoho CRM platform.
zalb…	To achieve load balancing and session persistence	Delete at session end	Zoho Corporation Pvt. Ltd https://www.zoho.com/privacy.html	Legitimate interests (Article 6(1) (f) of the GDPR): To provide seamless customer support on our website using the Zoho CRM platform.

Cookie name	Purpose of use	Retention period	Recipient and Privacy Policy	Legal basis	Opt-out
_ga _ga_HS21GSCLPV	To identify unique users by assigning a randomly generated ID and to measure visitor, session and campaign data	The IP address portion of the log data will be deleted after 9 months, and cookie information will be deleted after 18 months.	Google LLC https://policies.google.com/privacy?hl=en	Consent (GDPR Article 6.1(a))	https://tools.google.com/dlpage/gaoptout?hl=en
_clck	To analyze user session data and help us improve website performance and user experience	1 year	Microsoft Corporation https://www.microsoft.com/en-gb/privacy/privacystatement	Consent (GDPR Article 6.1(a))	https://optout.aboutads.info/
_clsk	To associate a user’s multiple page views and for session recording and analysis	1 day	Microsoft Corporation https://www.microsoft.com/en-gb/privacy/privacystatement	Consent (GDPR Article 6.1(a))	https://optout.aboutads.info/
MUID	To identify unique web browsers that access Microsoft sites for advertising, site analytics, and other operational purposes	1 year	Microsoft Corporation https://www.microsoft.com/en-gb/privacy/privacystatement	Consent (GDPR Article 6.1(a))	https://optout.aboutads.info/
CLID	To identify whether a user is visiting the website for the first time	1 year	Microsoft Corporation https://www.microsoft.com/en-gb/privacy/privacystatement	Consent (GDPR Article 6.1(a))	https://optout.aboutads.info/
_td	To record website activity, provide targeted advertising on external sites, and analyze its effectiveness	1 year	Treasure Data, Inc. https://www.treasuredata.com/privacy-statement/	Consent (GDPR Article 6.1(a))	https://www.treasuredata.com/list-of-cookies/
_td_global	To record website activity, provide targeted advertising on external sites, and analyze its effectiveness	1 year	Treasure Data, Inc. https://www.treasuredata.com/privacy-statement/	Consent (GDPR Article 6.1(a))	https://www.treasuredata.com/privacy-statement/
_juicer_sesid_	To understand website visit status, analyze data, and improve website services	1 year	Logly Co., Ltd. https://juicer.cc/privacy/	Consent (GDPR Article 6.1(a))	https://juicer.cc/privacy/
_juicer_session_referrer_… en_tpc	To understand website visit status, analyze data, and improve website services	1 year	Logly Co., Ltd. https://juicer.cc/privacy/	Consent (GDPR Article 6.1(a))	https://juicer.cc/privacy/
_juicer_peach_id_…	To understand website visit status, analyze data, and improve website services	1 year	Logly Co., Ltd. https://juicer.cc/privacy/	Consent (GDPR Article 6.1(a))	https://juicer.cc/privacy/
AP	To analyze user behavior data on the website and use it to improve convenience	1 year	User Local Co., Ltd. https://www.userlocal.jp/privacy/	Consent (GDPR Article 6.1(a))	https://www.userlocal.jp/privacy/
NID	To record a unique ID for each user, personalize Google services, and save settings	6 months	Google LLC https://policies.google.com/technologies/cookies?hl=en	Consent (GDPR Article 6.1(a))	https://policies.google.com/privacy?hl=en
UULE	Sending precise location information from your browser to Google services so that Google can show you search results relevant to your current location	1 day	Google LLC https://policies.google.com/technologies/cookies?hl=en	Consent (GDPR Article 6.1(a))	https://policies.google.com/privacy?hl=en

Cookie name	Purpose of use	Retention period	Recipient and Privacy Policy	Legal basis	Opt-out
_gcl_au	To measure conversions (results) when users click on ads and analyze the effectiveness of ads	3 months	Google LLC https://policies.google.com/technologies/ads?hl=en	Consent (GDPR Article 6.1(a))	https://policies.google.com/technologies/ads?hl=en https://adssettings.google.com/anonymous
IDE	To enable the display of Google ads on non-Google websites	1 year	Google LLC https://policies.google.com/technologies/ads?hl=en	Consent (GDPR Article 6.1(a))	https://policies.google.com/technologies/ads?hl=en https://adssettings.google.com/anonymous
__Secure-3PAPISID __Secure-3PSID __Secure-3PSIDCC __Secure-3PSIDTS	To authenticate users, store session settings, protect data and prevent unauthorized access, measure advertising effectiveness, deliver personalized content, and store settings and information when using Google Maps	2 years	Google LLC https://policies.google.com/technologies/cookies?hl=en	Consent (GDPR Article 6.1(a))	https://policies.google.com/technologies/ads?hl=en https://adssettings.google.com/anonymous
_fbp fr c_user xs sb datr	To serve, measure, and improve the relevance of Facebook ads, facilitate login, identify users, and maintain security and site integrity	3 months to 2 years	Meta Platforms, Inc. https://www.facebook.com/privacy/policies/cookies/	Consent (GDPR Article 6.1(a))	https://www.facebook.com/privacy/policies/cookies/
_yjsu_yjad	To track conversions for Yahoo! JAPAN ads, improve ad performance, and collect behavioral data from multiple sites to display relevant ads and limit the number of times they are displayed	1 year	LINE Yahoo! Corporation https://www.lycorp.co.jp/en/company/privacypolicy/	Consent (GDPR Article 6.1(a))	https://terms.line.me/line_rules_optimize
A JV XA XB SSL T Y	For ad delivery and retargeting through Yahoo! Ads, personalized ad display using user attribute and behavioral data, and analysis of advertising effectiveness	6 months to 2 years	LINE Yahoo! Corporation https://www.lycorp.co.jp/en/company/privacypolicy/	Consent (GDPR Article 6.1(a))	https://terms.line.me/line_rules_optimize
SOC SOSYNC	To analyze user behavior history on websites and apps and deliver optimal advertisements to users	1 year	Supership https://supership.jp/privacy/	Consent (GDPR Article 6.1(a))	https://supership.jp/optout/
dmps uid f rtbs	For native advertising delivery and effectiveness measurement, content recommendations based on user interests, and advertising targeting	1 year	Logly Co., Ltd. https://juicer.cc/privacy/	Consent (GDPR Article 6.1(a))	https://juicer.cc/privacy/
TapAd_3WAY SYNCS TapAd_DID TapAd_TS	To identify and combine users across multiple devices to enable ad delivery optimization and cross-device targeting	2 months	Tapad https://www.tapad.com/privacy	Consent (GDPR Article 6.1(a))	https://crportal.tapad.com/#/
imid imid_secure imid_created imid_created_secure	To track user behavior on websites and target advertisements	1 year	i-mobile https://www.i-mobile.co.jp/privacy.html	Consent (GDPR Article 6.1(a))	https://www.i-mobile.co.jp/privacy.html
dc_id dcam_global_id dc_cl_id	To track user behavior on websites and target advertisements	1 and a half years		Consent (GDPR Article 6.1(a))
_im_vid	To track user behavior on websites and target advertisements	1 year	i-mobile https://www.i-mobile.co.jp/privacy.html	Consent (GDPR Article 6.1(a))	https://www.i-mobile.co.jp/privacy.html
NXID	To match external data and analyze user behavioral data	1 year	Interactive Circle https://www.interactive-circle.jp/privacy/	Consent (GDPR Article 6.1(a))	https://www.interactive-circle.jp/privacy/

Legal Area

Privacy Policy

About the Personal Data We Process

How We Collect Personal Data

Purposes and legal basis for processing personal data

How We Share Personal Data

1. Cloud Services Managing Your Information

2. Companies Providing Data Analysis Tools (Locations: Japan and the US)

3. Sharing among our group companies

Regarding transfer of personal data to countries outside the EEA:

Regarding disclosure of personal data to authorities and courts:

Regarding Your Rights

1. Right of Access

2. Right of Rectification

3. Right of Erasure

4. Right to Restriction of Processing

5. Right to Data Portability

6. Right to Object

7. Right to Object to Profiling

8. Right to Withdraw Consent

9. Right to File a Complaint with a Supervisory Authority

Automated Decision-Making

Privacy Policy Updates

Contact Us

Cookie Policy

1. What are Cookies?

2. Types of Cookies Used on Our Website

2.1 Strictly Necessary Cookies

2.2 Performance Cookies

2.3 Targeting or Advertising Cookies

3. Details of Cookies Used on Our Website

3.1 Strictly Necessary Cookies

3.2 Performance Cookies

3.3 Targeting or Advertising Cookies

4. Consent to Cookie Use

5. International Data Transfer

6. Other Information