PRIVACY POLICY

Published: April 1, 2020
Last updated: October 15, 2024

We, EPOCH COMPANY, LTD., respect your privacy. As we operate this website and provide you with our services, we process personal data about you, we undertake to comply with applicable data protection laws, including the Personal Information Protection Act of Japan (the “PDPA”), the General Data Protection Regulation of the European Union (the “GDPR”), California Consumer Protection Act (the “CCPA”), and Children’s Online Privacy Protection Act of the United State of America (the “COPPA”). This is our privacy policy on how we process and protect your personal data.
We may revise this privacy policy from time to time. You can obtain the latest version of this policy at the following link:
https://epochtoys.com/policy/

If you have any questions or concerns about this privacy policy or your personal data, including any requests to exercise your legal rights, please contact us using the following contact information:

Privacy Manager
EPOCH COMPANY, LTD.
2-2-2, Komagata Taito-ku, Tokyo 111-8618, Japan
privacy@epoch.jp

PART I:FOR OUR GUESTS FROM EUROPE
PART II:FOR OUR GUESTS FROM THE STATE OF CALIFORNIA
PART III:CHILDREN’S PRIVACY (FOR GUESTS FROM THE UNITED STATES)

PART I: FOR OUR GUESTS FROM EUROPE

This section of our privacy policy is addressed to our guests who live in the countries of the European Union, Iceland, Norway, Lichtenstein and the United Kingdom.

1. PERSON IN CHARGE

This privacy policy is issued by us, EPOCH COMPANY, LTD., a company registered in Tokyo, Japan. When we process your personal data, we are the data controller in the meaning of GDPR and are responsible for protecting your rights with personal data.

2. HOW WE PROCESS YOUR PERSONAL DATA

As we provide you with our services on this website, we collect, use, store, generate or disclose to third-parties (hereinafter collectively referred to as “process”) your personal data for the following purposes:

To organize and manage our popularity poll event on the characters of Sylvanian Families or Calico Critters.
1. Categories of your personal data we process: your favorite character(s), gender, age, area of residence and such meta-data collected by use of cookie(s) as are necessary in order to effectively manage the event including your web browser identifier, IP address, timestamp.
2. Lawful basis: processing is necessary for the performance of a contract between you and us whereby you join the event. The metadata described above are necessary to effectively enforce the voting rule of one-vote-per-day.
3. Period for which we store your personal data: during the period of the event through the end of March 2022.
4. Recipients we disclose your personal data to: our contractors that assist us in the data processing in this event.
To provide you with entertainment like fortune-telling on our website:
1. Categories of your personal data we process: your gender, month of birth, email address and such meta-data collected by use of cookie(s) as are necessary in order to effectively manage such entertainment including your web browser identifier, IP address, timestamp.
2. Lawful basis: processing is necessary for the performance of a contract between us whereby you request such entertainment.
3. Period for which we store your personal data: one year from your last use of such service
4. Recipients we disclose your personal data to: our contractors that assist us in the data processing in such services.
To manage our personalized advertising to those of you 16 years of age or older.
1. Categories of your personal data we process: your month of birth, gender, email address, hobby/favorite pastime and your browsing record on our website collected by use of cookie(s) including your web browser identifier, IP address, timestamp and your interaction with our website.
2. Lawful basis: your consent. You can withdraw your consent at any time here. Your withdrawal of consent does not affect the lawfulness of our processing of your personal data based on consent before its withdrawal.
3. Period for which we store your personal data: We retain your browsing record for one year from the time when the relevant cookie is set, or until you withdraw your consent.
4. Recipients we disclose your personal data to: We disclose your personal data to our advertising partners, i.e. Google, etc. They may combine your personal data with other data they hold for the purpose of targeted advertisement. For more information about how they process your personal data, see the following pages:
  Google: https://policies.google.com/privacy?fg=1&hl=en#whycollect
To facilitate social communication among our customers and us by interacting with our customers on social media including Instagram & Twitter.
1. Categories of your personal data we process: content of your postings, your account name and such other account information as you allow to be shared with us on your privacy settings with such social media.
2. Lawful basis: your consent. Your posting of comment to our article is deemed to constitute a clear and affirmative action to signify your agreement to our processing of your personal data in such a way as described above. You can withdraw your consent at any time by deleting your article. Your withdrawal of consent does not affect the lawfulness of our processing of your personal data based on consent before its withdrawal.
3. Period for which we store your personal data: Until you delete your article.
4. Recipients we disclose your personal data to: None
To analyze your use of our website in order to generate insight that is useful for improving our services, products and marketing:
1. Categories of your personal data we process: your interaction with our website collected by use of cookie(s), including your browsing record on our website together with IP address and other information about your terminal device.
2. Lawful basis: processing is necessary for the purpose of our legitimate interest, i.e. improving our services, products and marketing. Data collected about your interaction with our website are analyzed in anonymized, statistical and aggregated manner, so that such processing does not affect your privacy by any means.
3. Period for which we store your personal data: log data is deleted after 60 days.
4. Recipients we disclose your personal data to: our contractors that assist us in analyzing web traffic data, e.g. Google.
To protect your privacy and security, integrity and availability of this website:
1. Categories of your personal data we process: your browsing record on our website collected by web access logging, including your IP address, type and version of your web browser, web browser plugins, operating system and other information about your terminal device and technologies you use when accessing our website.
2. Lawful basis: processing is necessary for the purpose of our legitimate interest, i.e. protecting your privacy and this website from fraudulent or unlawful access by monitoring web access traffic.
3. Period for which we store your personal data: 60 days (60 days for Calico Critters website).
4. Recipients we disclose your personal data to: our contractors that assist us in monitoring web access traffic.
To provide you with support, to gain insights on how we can improve our products and services, and to act according to applicable law in responding to consumer complaints.
1. Categories of your personal data we process: your identity data and contact data, technical data and information about technical issues, your product questions/complaints, your general questions, other information or content regarding the reason for your inquiry.
2. Lawful basis: (i)Legitimate interest, i.e. optimizing our customer services and products, (ii) Legal obligation, i.e. compliance with legislation, and (iii) Your consent i.e. when you contact our customer support and provide us with information about your support request.
3. Period for which we store your personal data: we do not store the personal data for longer than is legally permitted and necessary for the related processing purposes.
4. Recipients we disclose your personal data to: the Japanese manufacture of our products that assist us in the data processing in optimizing our customer services and products, our customer support, and compliance with legislation.

3. SENSITIVE PERSONAL DATA

We usually don’t collect and/or use sensitive categories of your personal data as defined in Articles 9 or 10 of GDPR on our website.

4. COOKIES

Cookie is a small text file that our website sends to your terminal device for the purpose of keeping certain records.

By using cookies:

Your terminal devices (e.g. browsers) remember your preferences (e.g. language used) and activities (e.g. login status, items in cart, etc.) on our website, so that we can deliver a personalized and better user experience on our website (essential cookies);
We keep track of your interaction with our website, giving us useful and important insight for improving our website (performance cookies); and
Based on your consent, our Adtech partners keep track of your browsing records across internet, so that we can deliver personalized advertisement that is more likely to be of your interest (advertising cookies).

The cookie identifies your terminal device, typically your web browser, but it cannot identify your individual identity. You can choose whether to allow us or third-parties (our Adtech partners) to set performance cookies and advertising cookies. When we use cookies for the purpose of personalizing our advertisement or analyzing web access, we request your prior consent thereto.
For more information and to change your cookie settings, including withdrawal of your consent, visit our Cookie Setting page from link at the bottom of every webpage.

We do not set and use cookies for the purpose of advertisement or web access analytics for our users under 16 years of age. To ensure this policy, we request you to declare you are 16 years of age or older when we obtain your consent to our setting cookies for these purposes.

5. TRANSFER TO NON-EU COUNTRIES

We do not transfer your personal data to any entities located in any third countries outside of the European Economic Area (EEA) or Japan. In the event that we transfer your data to an entity located outside the EEA or Japan, we either ask for your prior consent thereto or protect your rights with personal data by virtue of a data transfer contract with the relevant recipient in accordance with GDPR and PDPA, which impose on such recipients contractual obligations to ensure adequate level of data protection equivalent to those laid down by GDPR and PDPA.

6. YOUR LEGAL RIGHTS

Provided that certain conditions are met, you have legal rights to request from us the following:

Revocation of previously given consent to our processing of your personal data
Access to your personal data and to certain supplementary information covered by this policy;
Rectification of your personal data if inaccurate or incomplete;
Erasure of your personal data in certain circumstances;
Suspension of using your personal data in certain circumstances;
Stopping processing your personal data in certain circumstances; and
Obtaining your personal data in a structured, commonly used, and machine-readable format.

If you wish to exercise your right, please contact us.

7. COMPLAINT

Please contact us if you have any concern about how we collect and use your personal data. You also have right to lodge complaints with data protection supervisory authorities of your country of residence.

PART II: FOR OUR GUESTS FROM THE STATE OF CALIFORNIA

This section of our privacy policy explains how we collect, use, share, and protect personally identifiable information of California residents and any information related to it ("personal information") and non-personal information.

1. RIGHT TO KNOW ABOUT PERSONAL INFORMATION COLLECTED, DISCLOSED, OR SOLD

The CCPA states you have the right to request us to disclose what personal information we collect, use, disclose, and sell.
You can exercise your above-mentioned rights unless you have exercised the rights within preceding 12 months. We endeavor to respond to you within 45 days of receiving a verifiable request from you. If you intend to exercise such rights, please refer to section 6.
We use your information (mail address) to verify your request.
The categories of personal information we collected, business or commercial purpose, sources and category of third parties we share within preceding 12 months:

⇐ Scroll ⇒

	CATEGORY (stipulated in CCPA 1798.140(o))	DETAIL	BUSINESS OR COMMERCIAL PURPOSE FOR PROCESSING	SOURCES OF COLLECTED PERSONAL INFORMATION	CATEGORY OF THIRD PARTIES WE SELL (stipulated in CCPA 1798.140(w))
1	Identifiers.	Unique personal identifier (cookie(s)), Internet Protocol address.	To organize and manage our popularity poll event on the characters of Sylvanian Families or Calico Critters	Your activity on our website	None
2	Identifiers.	Unique personal identifier (cookie(s)), Internet Protocol address, email address.	To provide those who are 16 years of age or older with our services including small entertainment like fortune-telling on our website	Your activity on our site	None
3	Identifiers Internet or other electronic network activity information	Unique personal identifier (cookie(s)), Internet Protocol address, email address. browsing history, information regarding a consumer’s interaction with an Internet Web site, application	To manage our personalized advertising to those who are 16 years of age or older	Your activity on our site, ad agencies	ad agencies
4	Identifiers.	Alias (e.g. username with social media service) with content of posting	To facilitate social communication by interacting with our customers on certain social media including Instagram & Twitter	Your posting on social media (e.g. Instagram & Twitter)	None
5	Identifiers.	Unique personal identifier (cookie(s)), Internet Protocol address	To analyze your use of our website and generate insight to improve our service and marketing	Your activity on our site	None
6	Identifiers Internet or other electronic network activity information	Internet Protocol address browsing history, information regarding a consumer’s interaction with an Internet Web site, application	To protect your privacy and security, integrity and availability of this website	Your activity on our site	None

g. Disclosure or Sale of Personal Information

(1) We may disclose your identifiers (such as cookie(s) and email address) to the service providers and third parties below, to manage our personalized advertising to those who are 16 years of age or older and other services:

web service providers;
ad agencies.

We only allow our service providers to handle your personal information when we have confirmed that they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure that they can only use your personal information to provide services necessary to receive, handle and respond to your inquiries. We may also share personal information with external auditors.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our businesses or during a re-structuring. Usually, information will be anonymized but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We will not share your personal information with any other third party.

(3) We do not sell personal information about residents who we know are younger than 16 years old.
Under the CCPA, “sell” means disclosing by electronic or other means, a consumer’s personal information to a third party for monetary or other valuable consideration.

2. RIGHT TO REQUEST DELETION OF PERSONAL INFORMATION

The CCPA states you have the right to request us to delete your personal information collected by us.
You can exercise your above-mentioned rights with your account of us, unless you have exercised the rights within preceding 12 months. We endeavor to respond to you within 45 days of receiving a verifiable request. If you intend to exercise such rights, please refer to section 6.
We use your information (mail address) to verify your request.

3. RIGHT TO OPT-OUT OF THE SALES OF PERSONAL INFORMATION

The CCPA states you have the right to opt-out of the sale of your personal information by us.
Under the CCPA, the activities, in which we share information collected from cookies or email address with advertising agencies to manage our personalized advertising to those of you 16 years of age or older based on your preferences, may be considered a “sale” of personal information.
Opt-out rights can be exercised by visiting our Cookie Policy or by going directly to our Cookie Settings page from link at the bottom of every webpage and deleting or preventing cookies from being used. You can also click on the “Do Not Sell My Personal Information” link at the bottom of every webpage.

4. RIGHT TO NON-DISCRIMINATION FOR THE EXERCISE OF A CONSUMER’S PRIVACY RIGHT

The CCPA states you have a right not to receive discriminatory treatment by us for the exercise of the privacy rights conferred by the CCPA.

5. AUTHORIZED AGENT

When you use an authorized agent to submit a request to know or a request to delete, we may require that you:

Provide the authorized agent with written permission to do so; and
Verify your own identity directly with us.
Directly confirm with us that you provided the authorized agent with permission to submit the request

We may deny a request from an agent that does not submit a proof that they have been authorized by you to act on your own behalf.

6. HOW THIS SITE RESPOND TO “DO NOT TRACK” SIGNALS

Some browsers incorporate a “Do Not Track” (DNT) feature, which when turned on signals to websites you visit that you do not want to be tracked. Because there is not yet an accepted standard for how to respond to a DNT signal, this site does currently not respond to DNT signals on this website or on websites where we provide advertisements, contents or other services.

7. YOUR CALIFORNIA PRIVACY RIGHTS

Pursuant to California Civil Code Section 1798.83, we only share Personal Information with third parties for those third parties’ direct marketing purposes if you specifically opt-in or are offered the opportunity to opt-out and elect not to opt-out from such sharing at the time you provide Personal Information or at the time you choose to participate in a feature. If you do not opt-in or if you opt-out at the applicable time, we do not share your information with those identified third parties for those third parties’ own direct marketing purposes. If you are a California resident, and we do not have a policy of providing choices regarding certain kinds of sharing, as described above, you have the right to receive from us: (a) information identifying any third party(ies) to whom we may have disclosed, within the preceding calendar year, your Personal Information for that third party’s own direct marketing purposes; and (b) a description of the categories of Personal Information disclosed. If you are a California resident, please write to the contact point referred in section 6 to obtain information free of charge regarding our compliance with this law. (Requests received by other means may result in a delayed response.) Please use "Your California Privacy Rights" in the subject line of your e-mail or letter. Please include your name, street address, city, state, and zip code. We are not responsible for requests that are not labeled or sent properly, or do not have complete information.
Please note that we are only required to respond to one request per customer each calendar year. We will respond to these requests within thirty (30) days.

PART III: CHILDREN’S PRIVACY (FOR GUESTS FROM THE UNITED STATES)

Some of our websites contain content appropriate for a wide range of audiences, including Children(in this provision, we call the children who are under 13 years old).
We do not collect and store personal information about Child if this information is submitted by a Child without prior parental consent or by the parent or guardian of the Child. If a Service is directed to children under COPPA, we may ask users to verify their dates of birth before collecting any personal information from them. Those users that indicate they are Children are either blocked from the activity or taken through a parental consent process.
We are prohibited by COPPA from conditioning a Child's participation in an activity - like contests - on the Child's disclosure of more personal information than is reasonably necessary to participate in the activity.

If we discover that we’ve unintentionally collected information from a child in a way that doesn’t meet COPPA requirements, we will delete the information immediately.
A parent who has already given our permission to collect and use his or her Child's personal information can, at any time, do the following: (1) review, correct, or delete the Child's personal information; and/or (2) discontinue further collection or use of the Child's personal information. To do so, please refer to the section 6.