Japan Brand Auction Privacy Policy

Operator and personal information management

JBA is operated by the following company:

合同会社JBA
Legal name: 合同会社JBA
Registered head office: 〒323-0827
934 Hitotonoya, Oyama, Tochigi, Japan
Emerald Garden Oyama 302

Tokyo sales office: 〒140-0013
6-24-1 Minami-Oi, Shinagawa-ku, Tokyo, Japan
Seven Star Mansion No. 5 Omori 206

Representative Director and person responsible for personal information management: 吴剑伟

For questions or requests concerning personal information, contact the official JBA privacy enquiry desk at privacy@japanbrandauction.jp.

Information we collect

To provide membership review, auction sourcing and related services, JBA may collect the following information to the extent necessary:

• Member and applicant information
  Name, email address, telephone number, country or region, address and information related to account authentication.
• Company and business information
  Company name, trading name, corporate registration information, business address, official website, business activities and other business-related information.
• Qualification and identity verification documents
  Company registration certificates, business licences, proof of business activity, and representative or applicant identity and address documents required for review.
• Transaction and auction information
  Buyer ID, bidding records, successful bid records, orders, items, invoices, payments, refunds, settlement, saved items and related transaction records.
• Logistics and delivery information
  Recipient name, address, telephone number, delivery method, tracking, international shipping and information required for customs clearance.
• Customer service records
  Membership applications, review results, enquiries and business communications between you and JBA.
• Website and security information
  Device, browser, Cookie, access, security and error log information necessary for website operation, authentication and security management.

Purposes for using information

JBA may use the information collected for the following purposes:

• Review membership and dealer applications.
• Verify applicant identity and business qualifications.
• Create, authenticate and manage member accounts.
• Provide auction browsing, bidding and sourcing services.
• Process orders, successful bid confirmation, payments, refunds and settlement.
• Arrange domestic Japanese and international logistics and delivery.
• Provide customer service and business support.
• Prevent fraud, improper transactions, account abuse and other unlawful conduct.
• Handle complaints, refunds and transaction disputes.
• Improve website functionality, member experience and service quality.
• Fulfil tax, accounting, import and export management and other obligations under applicable law.

JBA does not sell members' personal information and does not use identity documents or qualification review materials submitted by members for advertising unrelated to membership services.

Third-party provision and service providers

To complete auctions, payments, delivery and related services, JBA may provide relevant information to or commission its processing by service providers to the extent necessary.

Relevant service providers may include:

Providers of identity authentication, cloud hosting, file storage, payment processing, email, logistics, insurance, security, accounting, legal and other professional services.

JBA appropriately manages relevant service providers according to business needs and applicable law, and requires them to process information only to the extent necessary to provide the relevant services.

Before appointing a material service provider, JBA assesses the information involved, purpose, processing location, security measures, incident reporting, return or deletion arrangements and any use of subprocessors. Contracts or equivalent controls require appropriate protection, restrict use outside the service and allow JBA to understand material handling practices. JBA reviews material providers and processing routes when they change and, where appropriate, periodically thereafter.

As a rule, JBA does not provide your personal information to unrelated third parties except where:

• Your consent has been obtained.
• It is necessary to perform a transaction or service requested by the user.
• It is required by law or a lawful request from a court or administrative authority.
• It is necessary to protect life, property or other significant legitimate interests.
• It is otherwise permitted by law.

Auction and transaction information

When members use third-party auction channels, payment services, logistics or other partner services through JBA, we may process or provide item, order, payment and delivery information to the extent necessary to complete the relevant transaction.

Identity documents and company documents used for membership qualification review are not automatically provided to external auction operators as a result of ordinary bidding activity.

If a future service genuinely requires such materials to be provided to a new third party, we will handle this in accordance with applicable law and, where necessary, notify members in advance or obtain their consent.

International data transfers

Because JBA serves professional buyers worldwide, some information may be processed outside Japan for payment, cloud services, logistics, customer support or other business needs.

Before providing personal data to a third party outside Japan, JBA will, where required by applicable law, identify the destination country, provide information about its personal information protection system and the recipient's safeguards, and obtain the individual's prior consent. Where consent is not required because a statutory exception or legally recognised equivalent safeguards apply, JBA will maintain the required safeguards and provide information on request as required by law.

JBA also assesses the external environment of countries where personal data is handled and implements reasonable administrative, contractual and security measures appropriate to the relevant service.

Information security

JBA takes reasonable and necessary technical and organisational measures to protect members' personal information and business data, including:

• Authentication and account security management.
• System access control.
• Separate management of identity materials and public item information.
• Secure file upload and storage.
• File format and size validation.
• System operation and security logs.
• Necessary security monitoring and risk management.

Member identity and qualification review materials are accessible only to authorised personnel whose job responsibilities require access.

No internet service can guarantee absolute security. If a leakage or other incident may harm an individual's rights or interests, JBA will investigate and contain the incident and, where required by applicable law, report it to the Personal Information Protection Commission and notify affected individuals without undue delay.

Information retention and deletion

JBA retains information only for the period necessary to achieve the relevant business purpose and fulfil legal obligations. The detailed schedule is set out in our Data and Document Retention Policy.

• Declined, withdrawn or abandoned applications and supporting documents are deleted three months after the review or withdrawal is completed, unless a documented legal hold applies.
• Approved dealer application, identity and business verification documents are retained during the dealer relationship and deleted three months after it ends, subject to a documented legal hold.
• Contracts, accepted order terms, invoices, receipts and tax-relevant transaction records are retained for the period required by Japanese law, generally at least seven years where applicable.

A retention period may be extended only where an unresolved transaction, dispute, fraud investigation, regulatory request or other legal obligation requires it. When the reason ends, the information is deleted or irreversibly anonymised in accordance with the retention policy.

Member rights

Under applicable Japanese law and related regulations, you may, to the extent permitted by law, request:

• Enquiry or disclosure.
• Confirmation of the purpose of use.
• Correction, supplementation or updating of information.
• Suspension of use.
• Suspension of provision to third parties.
• Deletion of eligible personal information.

To prevent unauthorised access, we may require identity verification before processing these requests.

We may be unable to delete information immediately where it must be retained for tax, accounting, incomplete transactions, payments, dispute handling or other legal obligations.

Cookies and website analytics

JBA may use cookies and similar technologies for account login, authentication, security protection, language settings and basic website functionality.

We may also collect necessary website usage data to:

• Analyse website visits.
• Improve search and auction browsing.
• Optimise the membership application process.
• Detect system errors and security risks.
• Improve the overall quality of JBA services.

If we use advertising tracking or personally identifiable marketing analytics in the future, we will provide the relevant explanation under applicable law and obtain user consent where required.

Revisions to this Privacy Policy

JBA may revise this Privacy Policy due to changes in laws and regulations, service content, system functions or personal information handling practices.

If material changes occur, we will publish the updated policy and effective date on the JBA website and, where required by applicable law, notify members by appropriate means.

Contact us

For questions about this Privacy Policy or to request disclosure, correction, suspension of use, suspension of third-party provision or deletion, email the official JBA privacy enquiry desk at privacy@japanbrandauction.jp with the subject “Privacy Request”.

Please include your name, registered email address, application or Buyer ID if available, and a clear description of the request. Do not attach a passport or identity document to ordinary email. JBA will first confirm the request and provide a secure method if identity evidence is required.

After identity verification, JBA will respond within a reasonable period. If all or part of a request cannot be fulfilled because of an unresolved transaction or legal obligation, JBA will explain the applicable reason to the extent permitted by law.

Operating company: 合同会社JBA (合同会社JBA)
Service name: Japan Brand Auction (JBA)

Your trust is the foundation of every transaction.

JBA uses your information only to the extent necessary and continuously protects your personal data, business information and transaction data.