Privacy Notice

Date Last Updated:  April 1, 2022

 

Kawasaki Kisen Kaisha, Ltd. (the “Company”) considers the processing of personal information it obtained or it holds, in an appropriate manner and under protections, pursuant to the Act on the Protection of Personal Information and the purpose of applicable laws and regulations regarding data protection of respective countries as an important social responsibility of the Company. Therefore, the Company shall process your personal information following the privacy notice below pursuant to the provisions of the “Individual Policy IV Data Protection Law”.

 

1.           Basic Ideas

 

The Company deeply understands the importance of personal information, and in the case of processing personal information in the course of business, responds to the trust and expectations of society by properly protecting personal information it processes pursuant to the laws and regulations applicable at that time, and ensuring compliance by all employees with such laws and regulations, and the internal rules regarding personal information protection.

 

The information constituting the grounds for processing all personal information provided to the Company or obtained by the Company from other sources under applicable laws and regulations are provided in this privacy notice (the “Notice”).

 

There are cases where more specific policies apply in processing personal information, in addition to the Notice. If the details provided by specific policies contradict the details of the Notice, the specific policies shall prevail to such extent.

 

 

2.           Controller Information

 

The information regarding the controller of personal information is as follows.

 

  Kawasaki Kisen Kaisha, Ltd.

 

  Address:   Iino Building, 1-1, Uchisaiwaicho 2-Chome, Chiyoda-ku, Tokyo 100-8540, Japan

 

  Contact:  Corporate Legal Risk & Compliance Group

 

 

3.           Acquisition of Personal Information

 

The personal information obtained by the Company shall be as follows. Obtaining personal information shall be conducted by legal and fair means.

 

(a)  Personal information provided to the Company: 

Includes personal information provided through the Company’s inquiry forms, or communications with the Company by email, letter or other means (names, addresses, email addresses, company names/organization names, telephone numbers and occupations, etc.)

 

(b)  Personal information provided by a third party to the Company: 

Includes personal information provided by third parties through the Company’s inquiry forms, or communications with the Company by email, letter or other means (names, addresses, email addresses, company names/organization names, telephone numbers and occupations, etc.)

 

(c)  Personal information obtained by the Company: 

Includes information such as access logs, web beacons (also referred to as pixel tags), and cookies, which are automatically obtained by accessing the Company’s website. There are cases where these may remain on the computer and further data may be obtained. For the details, please see the Company’s Cookies Policy (https://www.kline.co.jp/en/cookies_policy.html).

 

 

4.           Legal Basis for Personal Information Processing

 

The Company shall process personal information on the following legal bases, as long as it is not in contradiction with applicable laws and regulations.

 

(a)  Agreement:

In cases necessary for the performance of the agreements to be concluded with the Company

 

(b)  Obligations under laws and regulations:

In cases necessary for compliance with the obligations under laws and regulations

 

(c)  Legitimate interests:

In cases necessary to realize legitimate interests sought by the Company or any third party, and in cases where the individuals’ interests and basic rights do not override the foregoing

 

(d)  Consent: 

In cases where there is consent to the processing of personal information (however, even in cases where there is consent, there are cases where personal information will be processed based on other grounds). The withdrawal of consent shall not  affect the legality of the processing conducted on the basis of the consent before such withdrawal.

 

 

5.           Purpose of Use of Personal Information

 

The Company shall process personal information pursuant to and only to the extent necessary to achieve the purposes below.

 

(a)  Purposes of management of contact information of business contacts, etc. (legal basis: agreements, legitimate interests, consents)

 

(b)  Sales and marketing purposes for the Company’s products or services  (legal basis: agreements, legitimate interests, consents)

 

(c)  Purposes of provision and enhancement of the Company’s website, the Company group’s products and services, and responses to the inquiries made to the Company group (legal basis: legitimate interests)

 

(d)  Purposes of analyzing the Company’s website (for details, please see the Company’s Cookies Policy (https://www.kline.co.jp/en/cookies_policy.html) (legal basis: legitimate interests, consents)

 

(e)  Purposes of compliance with the obligations under applicable laws and regulations, the Company’s internal rules, or industry standards, or prevention of dishonest acts or illegal acts (legal basis: obligations under laws and regulation, legitimate interests)

 

(f)  Purposes of solutions to disputes, execution of the Company’s contractual agreements, or securing, exercising or defending legal claims (legal basis: obligations under laws and regulation, legitimate interests)

 

If the provision of personal information is refused, there are possibilities that you may incur disadvantages such as not being able to use some of the Company’s services.

 

 

6.           Disclosure of Personal Information

 

The Company may disclose personal information to persons falling under the categories below, pursuant to applicable laws and regulations.

 

(a)  Each company of the Company group (including employees authorized to process your personal information)

  (https://www.kline.co.jp/en/corporate/group_industry.html

 

(b)  Contractors appointed by the Company such as other service providers and internet service providers

 

In accordance with Japanese law, the Company may share personal information among the Company and the Company’s subsidiaries and affiliates following the framework of data sharing under the Act on Protection of Personal Information, the details of which are specified as follows.

 

•   Entity with which personal information is shared: The Company and the Company’s subsidiaries and affiliates

   (https://www.kline.co.jp/en/corporate/group_industry.html)

 

•   Purpose of sharing:  Purposes in (a) through (f) stated in Section 4 of the Notice

 

•   Personal information to be shared: Names, addresses, email addresses, company names/organization names, telephone numbers, occupation

 

•   Party responsible for management of personal information: Kawasaki Kisen Kaisha, Ltd.

   (Address: Iino Building, 1-1, Uchisaiwaicho 2-Chome, Chiyoda-ku, Tokyo 100-8540, Japan, Representative: Yukikazu Myochin)

 

 

7.           Cross-Border Transfer of Personal Information

 

Personal information held by the Company may be transferred to or stored in third countries.

 

 

8.           Retention Period

 

Unless a specific retention period is provided under applicable laws and regulations, personal information held by the Company shall be retained only for the period necessary for the processing of such personal information.

 

 

9.           Rights

 

Even though it may differ depending on the location of individuals and applicable laws and regulations, rights such as the following may be recognized as rights in relation to personal information processed by the Company.

 

(a)  the right to obtain information regarding the processing of your personal information and access to the personal information which the Company holds about you;

 

(b)  the right to request that the Company rectify your personal information if it is inaccurate or incomplete;

 

(c)  the right to request that the Company erase your personal information;

 

(d)  the right to request that the Company restrict the Company’s processing of your personal information;

 

(e)  the right to object to the Company about the Company’s processing of your personal information;

 

(f)  the right to receive any personal information which the Company processes about you on the basis of your consent or on a contract in a structured, commonly used and machine-readable format and/or request that the Company transmit such personal information to other persons where this is technically feasible (However, any of the above rights shall be limited to personal information which you provided to the Company and relate to you).

 

(g)  the right to withdraw your consent to the Company’s processing of your personal information.

 

 

If the rights above are recognized, you can exercise these rights by contacting the Company through the contact address indicated in Section 12 below. Even though it may differ depending on the location of individuals and applicable laws and regulations, you can also lodge a complaint with the personal information protection supervisory authority if you think that any of your individual rights have been infringed by the Company.

 

 

10.           Security Measures

 

The following is the outline of the security measures the Company has implemented for personal information.

 

(a)  Formulation of Basic Policy
We formulate Basic Policy for ensuring the proper handling of personal information, including compliance with laws, and contact point for inquiry and complaint processing.

 

(b)  Organized Safety Management Measures
We established internal rules for appropriate handling of personal information, a person responsible for personal information, and a system for reporting to the person responsible where necessary.

 

(c)  Human Safety Management Measure
We provide periodical trainings to our employees about the proper handling of personal information.

 

(d)  Physical Safety Management Measures
We have implemented security measures for store personal information and measures to prevent loss or theft.

 

(e)  Technical Safety Management Measures
We have implemented security measures to protect against unauthorized access or malware.

 

(f)  Understanding the External Environment
When handling personal information overseas, we have implemented safety measures based on our understanding of the legal system of the relevant foreign country.

 

 

11.         Revision of the Notice

 

The Company may revise the Notice from time to time, and the revisions shall come into effect on the “Date Last Updated” at the beginning of this Notice. Significant changes to the Notice shall be provided in an appropriate manner, such as by posting such changes on our website. Please review the Notice periodically.

 

 

12.          Contact Address

 

Any questions regarding this Notice, and any questions or inquiries regarding the Company’s personal information protection, including the exercise of rights indicated in Section 9, will be accepted at any time through the Company’s inquiry form (https://www.kline.co.jp/en/contact/personal.html)

 

Contact:  Company’s Corporate Legal Risk & Compliance Group

 

 

 

Privacy Policy for Residents of EEA countries or UK

Date Last Updated:  April 1, 2022

 

“Privacy Policy for Residents of EEA countries or UK” (the “GDPR Policy”) establishes provisions to supplement the Privacy Notice to comply with the European Union’s General Data Protection Regulation (the “EU GDPR”) or the domestic laws of the UK, to be enforced after the addition of necessary wording revisions in the text of the EU GDPR in order to apply details similar to the EU GDPR as applied to the UK as part of EU Law before the exit of the UK in connection with the UK’s exit from the EU (the “UK GDPR”), and applies to residents of EEA countries or the UK.

 

1.           Rights

 

You may exercise the respective rights below in relation to the personal information the Company holds about you.

 

(a) the right to obtain information regarding the processing of your personal information and access to personal information that the Company holds about you;

 

(b) the right to request that the Company rectify your personal information if it is inaccurate or incomplete;

 

(c) the right to request that the Company erase your personal information in the circumstances below.

(i) it is no longer necessary for the Company to retain your personal information for the purposes for which the Company collected it;

(ii) the Company is entitled to process your personal information only with your consent, and you withdraw your consent; or

(iii) you object to the Company’s processing of your personal information for the Company’s legitimate interests, and individuals’ interests, rights, and freedoms override the Company’s legitimate interests;

 

(d) the right to request that the Company restrict the Company’s processing of your personal information in the circumstances below.

(i) you dispute the accuracy of your personal information (but only for the period of time necessary for the Company to verify its accuracy);

(ii) the Company no longer need to use personal information except for the establishment, exercise, or defence of legal claims; or

(iii) you object to our processing of your personal information for our legitimate interests (but only for the period of time necessary for the Company to assess whether individuals’ interests, rights, and freedoms override the Company’s legitimate interests);

 

(e) the right to object to the Company about the Company’s processing of your personal information.

 

(f) the right to receive any personal information that the Company process about you on the basis of your consent or on a contract in a structured, commonly used, and machine-readable format and/or to request that the Company transmit  such personal information to other persons where this is technically feasible (however, any of the above rights shall be limited to personal information that you provided to the Company and that relates to you).

 

(g) the right to withdraw your consent to the Company’s processing of your personal information at any time (however, the Company may still be entitled to process your personal information on the basis of grounds other than consent).

 

(h) the right to object to supervisory authority about the processing of your personal information.

 

You can exercise these rights by contacting the Company through the contact address indicated in Section 12 of our Privacy Notice. You also can lodge a complaint with the personal information protection supervisory authority if you think that any of your individual rights have been infringed by the Company.

 

2.           Cross-Border Transfers to Outside the EEA Countries and UK

 

The Company may transfer personal information to any third party in countries other than EEA countries and the UK. Specifically, the Company may transfer [the information] to any third party located in countries determined by the European Commission as securing an adequate level of data protection, including Japan. If personal information is transferred to any third party located in countries other than the foregoing, the Company will transfer personal information after concluding standard contractual clauses with the parties to whom the transfer will be made, pursuant to the provisions of the EU GDPR or UK GDPR.

 

For more specific information and information on measures that may be adopted, please direct inquiries to the contact address specified in Section 2 of our Privacy Notice.

 

 

 

Privacy Policy for Residents of California

Date Last Updated:  January 1, 2022

 

“Privacy Policy for Residents of California” (hereinafter, “CCPA Policy”) establishes provisions to supplement the Privacy Notice to comply with the California Consumer Privacy Act (hereinafter, “the CCPA”) and applies to consumers who are residents of California. This CCPA Policy does not apply to “K” Line job applicants, employees, owners, directors, officers or natural persons who provide services to “K” Line pursuant to a written contract, where the Personal Information “K” Line collects about those individuals relates to their current, former, or potential role(s) at “K” Line.

 

1.           “K” Line’s Prior Collection, Use, and Disclosure of Personal Information

 

The table below describes the categories of Personal Information (which means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.) that “K” Line may collect or have collected about you during the 12-month period prior to the effective date of this CCPA Policy. For Personal Information collected during that timeframe, this section describes: (i) the categories of the Personal Information; (ii) the business or commercial purposes for which “K” Line may have collected the Personal Information; and (ⅲ) the categories of sources from which “K” Line may have obtained the Personal Information;

 

Category Personal Information Collected
Identifiers Real name, e-mail address, business address, IP address, and unique personal identifier (such as cookies)
Additional data subject to the California customer records law (any categories of personal information described in subdivision (e) of Cal. Civ. Code Sec. 1798.80) Telephone number, mobile phone number, and facsimile number
Internet or network activity information Cookie information
Professional or employment-related information

Business position and company name

 

Business or Commercial purposes.

The following is a list of the business or commercial purposes for which the categories of Personal Information will be collected or used.

  • Performing services on “K” Line’s behalf or on behalf of another, including fulfilling transactions, processing payments, and other services
  • Undertaking activities to maintain the quality or safety of, or improve, a service which “K” Line may control or provide
  • Communicating with business partner contacts about the transportation services, including harbor operation, renting and selling terminals, terminal operation, and shipping operation
  • Building up and managing business relationships with actual and potential business partners
  • Complying with applicable laws and regulations
  • Evaluating and improving “K” Line’s website for sales and recruitment activities
  • Receiving and replying to inquiries

 

 

A. Sources of Personal Information

 

The following is a list of the categories of sources from which “K” Line collects Personal Information:

 

  • Actual or potential employees of “K” Line’s business partners, employees of competitors of “K” Line’s business partners, and supervisory authorities of “K” Line’s business partners
  • “K” Line’s agents and lawyers of “K” Line’s business partners
  • Website visitors and users

 

B. Sharing of Personal Information

 

 (A) Sale of Personal Information

 

“K” Line does not sell (which means the selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, your Personal Information by “K” Line to another business or a third party for monetary or other valuable consideration.) Personal Information and has not sold Personal Information during the 12-month period prior to the effective date of this CCPA Policy, including the Personal Information of consumers under 16 years of age.

 

 

 (B) Disclosure of Personal Information for a Business Purpose

 

The table below describes: (i) the categories of Personal Information that “K” Line may have disclosed and (ii) the categories of third parties to whom “K” Line may have disclosed such Personal Information, for “K” Line’s operational business purposes during the 12-month period prior to the effective date of this CCPA Policy.

 

Category Personal Information Disclosed Third Parties to whom Personal Information Was Disclosed in the Last 12 Months
Identifiers IP address and unique personal identifier (such as cookies) Data analytics providers
Internet or network activity information Cookie information Data analytics providers

 

2.           Your Rights and Requests

 

If you are a California consumer, you have certain choices regarding your Personal Information, as described below:

 

  1. Access: You have the right to request, twice in a 12-month period, that “K” Line disclose to you the following information it has collected, used, disclosed, and sold about you during the 12 months preceding your request:

 

    1. The categories of Personal Information “K” Line collected about you;

 

    1. The categories of sources from which “K” Line collected such Personal Information;

 

    1. The business or commercial purpose(s) for collecting such Personal Information about you;

 

    1. The categories of third parties with whom “K” Line shared such Personal Information;

 

    1. The specific pieces of Personal Information “K” Line has collected about you; and

 

  1. Deletion: You have the right to request that “K” Line delete certain Personal Information it collected from you.

 

 

How to Submit a Request. To make an access or deletion request (described above), please contact “K” Line by any of the following means:

 

 

Verifying Requests. To help protect your privacy and maintain security, “K” Line will take steps to verify your identity before granting you access to your Personal Information or complying with your deletion request. Upon receiving an access or deletion request from you, “K” Line will first verify your identity by requiring you to submit information necessary to verify your identity, such as your name and e-mail address, and by matching the information you provide with what “K” Line already has on file. In addition, if you ask “K” Line to provide you with specific pieces of Personal Information, “K” Line will require you to sign a declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request.

 

If you use an authorized agent to make an access or deletion request on your behalf, “K” Line may require you to (1) provide the authorized agent written permission to do so, (2) verify your own identity directly with “K” Line (as described above), and (3) directly confirm with “K” Line that you provided the authorized agent permission to submit the request.

 

Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by “K” Line. To the extent permitted by applicable law, “K” Line may charge a reasonable fee to comply with your request.