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Privacy Policy for Overseas Residents

Established on 1st January, 2020
Last revised on 1st October, 2024

We, Goonet Exchange Co., Ltd and Proto Corporation, appreciate you visiting our websites and your interest in our services. We take the protection of personal data of data subjects residing in the European Economic Area, California, and any other country and region other than Japan under the terms and conditions set forth in this Privacy Policy for Overseas Residents (this “Privacy Policy”) as well as the terms and conditions set forth in our General Privacy Policy
If there is any discrepancy or inconsistency between this Privacy Policy and the General Privacy Policy, this Privacy Policy shall prevail.

Joint Controllers Proto Corporation is responsible for the operation of this Goonet Exchange website and the management of personal data provided through this Goonet Exchange website, and Goonet Exchange Co., Ltd. is responsible for responding to your requests (including entering into a used vehicle sales contract with you) using such personal data. As Proto Corporation and Goonet Exchange Co., Ltd jointly determines the purposes and means of the processing personal data provided through this Goonet Exchange website, Proto Corporation, and Goonet Exchange Co., Ltd become joint controllers of personal data provided through this Goonet Exchange website as set forth in Article 26 of the EU General Data Protection Regulation (“GDPR”).

Compliance with Laws We comply with applicable laws and regulations for the protection of personal data. All personal data collected by us will be used for the purposes set forth herein only.

Categories of Personal Data, Purpose of Use, and Legal Grounds of Collection and Process

Categories of Personal Data Categories of Sources Purpose of Use Legal Grounds Third Parties to whom Personal Data is Disclosed
1 Name, Company Name, Address, Phone Number, and Email Address Data Subjects him/herself 1. To answer your inquiries with regards to our services
2. To implement your requests with regards to our services
3. To implement contractual obligations
4. To provide information with regards to our services
5. To provide or improve our services, and to develop new services
6. To implement marketing activities 		- Contract performance
- Legitimate interest
- Consent 		- Freight forwarders
- Shipping companies
- Courier Service Companies
- Clearing Agents
- Our Distributors
- Service Providers which support our management of personal data
- External Specialists who are bound by confidentiality obligations under the relevant laws and regulations such as lawyers or tax accountant
- Officers and Employees of our group companies managing personal data for our business
2 Bank Account Information Data Subjects him/herself 1. To implement your requests made with regards to our services
2. To implement contractual obligations 		- Contract performance
- Consent 		- Service Providers which support our management of personal data
- External Specialists who are bound by confidentiality obligations under the relevant laws and regulations such as lawyers or tax accountant
- Officers and Employees of our group companies managing personal data for our business
3 IP Address, Cookies, Web Browser Information (type, version, browser language, browser screen size, scroll information, etc.) and Browsing Activities Data Subjects him/herself 1. To provide or improve our services, and to develop new services
2. To implement marketing activities 		- Legitimate interest
- Consent 		- Service Providers which support our management of personal data
- Officers and Employees of our group companies managing personal data for our business

Our “legitimate interests” set forth above are as follows: - To manage personal data so as to provide our service to data subject timely and effectively; and,
- To manage personal data so as to ensure the safety of personal data. Note that we will not collect or process your personal data if your interests or fundamental rights and freedoms which require protection of personal data shall override our interest

Transfer to Third Countries Your personal data may be transferred for the purpose set forth in this Privacy Policy to a controller or processor in a third country only where such transfer is legitimate under the applicable laws and regulations. If you are a resident in EEA, legitimate cases are as follows: (a) The EU Commission has decided that such a third country ensures an adequate level of protection;
(b) We and such controller or processor have entered into standard contractual clauses or standard data protection clauses adopted by the EU Commission;
(c) Such transfer is necessary for the performance of a contract between you and us or for the implementation of precontractual measures taken at your request;
(d) Such transfer is necessary for the conclusion or performance of a contract concluded in your interest between another natural or legal person and us; or,
(e) You have explicitly consented to the proposed transfer after having been informed that such transfer might cause the leakage of or any other risks to your personal data due to the absence of an adequacy decision and appropriate safeguards.

Quotation Request and Inquiry Any personal data written in the quotation request form on the inquiry form on the website and sent by you will be collected and processed by us only when you explicitly consent to our collection and process of such personal data. You are deemed to consent to our collection and process of your personal data when you put the send button after putting a check in the consent check box in these forms. Your personal data will not be provided to any third party without your consent unless the provision of such personal data is required for the implementation of your request.

Not to Sell Personal Data We have not sold and will not sell any personal data

Data Security We implement various technical and organizational security measures to protect your personal data from misuse, unauthorized access, rectification or erasure or any other risks.

Data Storage Period The data storage period is as follows: (a) The retention period for personal information in the Privacy Policy collected through the request for quotation form or inquiry form on this website shall be 5 years from the date of receipt of the inquiry, except in (b) : Until you make a request to erase such personal data;
(b) Any data set forth in Item “Server log files”: For 90 days after receipt of such data; and,
(c) Any cookie data: as set forth in our cookie policy.
 Notwithstanding the foregoing, when any provisions of applicable laws and regulations stipulate the limitation of the data storage period, we follow such limitation.

Access, Rectification, Erasure, and Data Portability You have the right to access, rectify or erase your personal data, restrict or object to processing your personal data, and receive your personal data in a structured, commonly used, and machine-readable format. Also, you have the right to withdraw your consent to our collection and process of your personal data at any time and your withdrawal does not affect the lawfulness of our processing based on your consent before your withdrawal. If you make a such request, please provide us (a) your name, (b) contact information, (c) any information that helps us to identify personal data subject to such request, and (d) if the request is made through an authorized agent, the pdf of a document signed by you on which you authorize a such authorized agent to make such request on behalf of you by sending an email or a written request letter, and we will start to review promptly after receipt of your request and will reply to you: Attention: Goonet Exchange Co., Ltd. Management Department
Address: 543-16 Maruzuka-Cho, Chuo-Ku, Hamamatsu City, Shizuoka Prefecture 435-0046, Japan
Email: info@goo-net-exchange.com

No Discrimination You have a right not to receive any discriminatory treatment by the business for the exercise of the privacy rights conferred under the applicable laws and regulations.

Complaint You have the right to lodge a complaint to our process of your personal data with an applicable supervisory authority in your residential country under the applicable laws and regulations.

No Statutory or Contractual Requirement Unless otherwise agreed upon between you and us, the provision of your personal data is neither a statutory requirement nor a contractual requirement. If the provision of your personal data is neither a statutory requirement nor a contractual requirement, you will not suffer any disadvantages from the non-provision of your personal data.

Automate Processing Your personal data may be used for the purpose of (i) the provision of our services in line with your needs on our websites or (ii) making your use of our websites efficient through an automated decision-making process including profiling.

Use of Processor We may outsource the process of your personal data to certain processors for the purposes set forth herein. In such a case, we use only processors providing sufficient guarantees to implement appropriate technical and organizational measures in such a manner that processing will meet the requirements of the applicable laws and regulations and ensure the protection of your rights.

Personal data of Persons under 16 years old If you are located at EEA and under 16 years old, you need to obtain your guardian’s consent before providing your personal data. Please obtain your guardian’s consent before putting a check in the consent check box in the quotation request or inquiry form of our website.

Cookie Policies We use cookies on our websites to improve functionality, provide you with a better browsing experience, and tailor our social media advertising. For more details, please refer to the following cookie policies:
- Goo-net Exchange Cookie Policy: https://goo-net-exchange.com/policy/cookie.html

Server log files Our website automatically collects and saves information in the so-called server log files, which your browser automatically transmits to us. These are:

  • IP Address
  • Time of server request
  • Referrer URL
  • Methods to access
  • Returned HTTP status code
  • Processing time to return

These data will be used for the purpose of analysis and statistics only. These data are not merged with other data sources. We reserve the right to review these data at a later date, if concrete evidence of unlawful use becomes known to us.

Google Analytics Our website uses features of the web analytics service, Google Analytics, provided by Google Inc. (“Google”), 1600 Amphitheater Parkway Mountain View, CA 94043, USA. Google Analytics uses cookies. For more information about Google Analytics user data, see Google's website.
You can prevent the collection of your data by Google Analytics through the cookie setting (please refer to each Cookie Policy)
Also, you can prevent the collection of your data by Google Analytics by clicking on the following link and an opt-out cookie is set which prevents the collection of your data on future visits to this site: Disable Google Analytics:
https://tools.google.com/dlpage/gaoptout

Google Remarketing Our website uses the remarketing feature of Google. This function is used to present interest-based advertising to the visitors to the website as part of the Google advertising network. The website visitor's browser stores the cookies, which allow visitors to recognize them when they visit sites that are part of Google's advertising network. On these pages, visitors can then be presented with advertising that relates to content that the visitor previously accessed on websites using the remarketing feature of Google.
If you do not want the Google remarketing feature, you can always disable it (i) through the cookie setting (please refer to each Cookie Policy) or (ii) by making the appropriate settings at http://www.google.com/settings/ads. Alternatively, you can disable the use of cookies for interest-based advertising through the Advertising Network Initiative by following the instructions at http://www.networkadvertising.org/managing/opt_out.asp. For more information about Google's remarketing and data protection, please visit:
https://www.google.com/policies/technologies/ads/.

Contact Information The following is our contact information: 1. Data Protection Representative in EEA and UK (if you are residents in EEA or UK, please contact with us through Data Protection Representative)
Attention: Data Protection Representative Limited (trading as “DataRep”)
Address: 12 Northbrook Road, Dublin, D06 E8W5, Ireland
Email: info@datarep.com
How to contact Goonet Exchange Co. Ltd. via Data Protection Representative
How to contact Proto Corporation via Data Protection Representative
 2. Goonet Exchange Co. Ltd
Attention: Goonet Exchange Co., Ltd. Management Department
Address: 543-16 Maruzuka-Cho, Chuo-Ku, Hamamatsu City, Shizuoka Prefecture 435-0046, Japan
Email: info@goo-net-exchange.com
 3. Proto Corporation
Attention: Proto Corporation IT solution Department
Address: 23F Sumitomo Fudosan Shinjuku Central Park Tower, 6-18-1 Nishishinjuku, Shinjuku-Ku, Tokyo, Japan
Email: pdm@proto-g.co.jp