Privacy Policy

This Policy applies to the processing of personal data by Aisin Corporation (hereinafter, “Company”) pursuant to the applicable data protection laws, regarding the users’ personal data collected by our Company in relation to the use of Lug THRU (hereinafter, “Services”).
If the provisions of this Policy contradict with those of other privacy policies stipulated by our Company, the provisions of this Policy prevail to the extent of such contradiction.

1.    Controller of the Processing of Personal Data
The controller of the processing of users’ personal data is our Company. Please refer to Section 9 below for our Company’s contact.

2.    Category of Collection and Purpose of Processing the Personal Data
Regardless of the means of collection, whether through website of the Services or email, etc., our Company directly collects from users and processes the personal data of the following category for the following purposes:
(1)    For the purpose to provide Services to users:
Users’ name, email address, phone number, date and time of reservation, place of pick up and drop off (including the delivery destination of luggage), number of luggage, number of people for reservation, and any other information of the users that users have entered in the comment section when reserving the Services, etc.
(2)    For the purpose to respond to the inquiries from users:
In addition to the information provided in (1) above, any other information regarding the inquiries from the users, etc.
(3)    For the purpose to comply with applicable laws and regulations, or respond to the court order and legal procedures:
Information provided in the above (1) and (2), etc.
In using the Services, users are required to provide a certain personal data. Users may refuse to provide personal data to our Company, but in this case, the Services provided by our Company may be restricted.

3.    Lawful Basis of Processing Personal Data
Our Company processes users’ personal data pursuant to the following lawful basis:
(1)    Agreement: There is a necessity to process users’ personal data in order to perform the agreement executed between our Company and users (including the Terms of Use of the Services), or implement the measures according to the users’ request before the execution of agreements.
(2)    Legitimate interest: Processing users’ personal data is necessary for the legitimate interest of our Company or a third party (for example, responding to users’ inquiries), and the users’ interest and basic rights do not prevail such legitimate interest.
(3)    Consent: Users have agreed to the processing of personal data by our Company.
(4)    Legal obligation: Processing the users’ personal data is necessary to comply with the legal obligation of our Company.
The lawful basis which our Company relies on for each purpose of processing personal data as described in Section 2 above are as follows:
(i)     For the purpose to provide Services to users: agreement or consent
(ii)     For the purpose to respond to the inquiries from users: legitimate interest or consent
(iii)    For the purpose to comply with applicable laws and regulations, or respond to the court order and legal procedures: legitimate interest or legal obligation

4.    Disclosure of Personal Data
Our Company may disclose to the following parties the users’ personal data, within the scope of the purpose of processing as described in Section 2 above.
(1)    Accommodation business to which the luggage will be delivered to and taxi business under collaboration.
In providing the Services, our Company may disclose the users’ personal data to the accommodation business to which the luggage will be delivered to and taxi business under collaboration with our Company.
(2)    Employee
Our Company may disclose the users’ personal data to our Company’s employee with the authority and necessity to access to the users’ personal data.
(3)    Service provider
Our Company may disclose the users’ personal data to a third party providing a certain service, such as IT service providers (including developers and operators of the system regarding the Services, data server and cloud service providers), etc.

5.    Overseas Transfer of Personal Data
The users’ personal date may be transferred to a third country outside the country and region where users are located. When our Company transfer users’ personal date to a third country outside the country and region where the users are located, our Company will comply with applicable data protection laws by assuring either of the followings or obtaining the users’ consent.
(1)    The transferred country and region are designated, under the applicable data protection laws, as the country and region where the adequate level of protection of the users’ right and freedom regarding the personal data is assured.
(2)    The transferred third party has executed with our Company the agreement regarding the transfer of personal data as required under the applicable laws.
By contacting our Company’s contact in Section 9 below, users may check further details regarding the protection provided to users, in case the personal data is transferred to the countries and regions outside where users are located.

6.    Time Period of Storage of Personal Data
Our company will store users’ personal data for such period necessary for the purpose of using such personal data. Precisely, the personal data processed in order to provide the Services are stored for 60 days after the completion of delivery of the users’ luggage; the personal data processed in order to respond to users’ inquiries are stored for 60 days after the inquiry. Provided, if a longer storage period is required under applicable laws and regulations, such personal data will be stored for such longer period required by laws and regulations.

7.    Rights of Users
Users are entitled to plural legal rights on the users’ personal data stored by our Company. These rights may vary depending on where users are located, which data protections laws are applicable between users and our Company, but typically include the followings:
(1)    Right to obtain information regarding the processing of the users’ personal data, and access to users’ personal data stored by our Company;
(2)    If the users’ personal data is incorrect or insufficient, the right to request our Company to rectify personal data;
(3)    Under specific circumstances, the right to request our Company to delete the user’s personal data;
(4)    Under specific circumstances, request our Company to restrict the processing of personal data by our Company;
(5)    Right to object to our Company regarding the processing of the user’s personal data;
(6)    Right to receive the personal data in a structured, commonly used and machine-readable format, and/or right to request the personal data transmitted directly from our Company to a receiver, where technically feasible; and
(7)    If the processing of the user’s personal data is based on the user’s consent, the right to withdraw such consent at any time. (Provided, that withdrawal of consent shall not affect the lawfulness of the processing of personal data before the withdrawal).
Users may contact our Company as described in Section 9 below to exercise users’ rights. If users believe their rights are infringed by our Company, users may also lodge a complaint with the competent data protection authority.

8.    Security Control Measures
In addition to the establishment of rules on personal data processing, in order to prevent leakage, loss, or destruction of personal data to be processed and safety control of personal data, our Company provides periodical training to employees engage in processing of personal data, takes preventive measures against theft and loss of devices used for processing of personal data, restrict access control, etc., and takes other necessary and proper measures.
By contacting our Company’s contact in Section 9 below, users may check further details of security control measures that our Company takes regarding the processing of personal data.

9.    Our Company’s Contact
For questions regarding this Policy, rights of users, or other matters related to the personal data protection, please contact the following: 

Date of regulations establishment: October 1, 2024

Aisin Corporation
2-1 Asahi-machi, Kariya, Aichi, Japan
Email: lug-thru@aisin.co.jp
Web Form: https://lug-thru.com/booking/en/contact/