Privacy Policy

1. Introduction

New Summer Inc. ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website or use our services. Please read this policy carefully. By accessing or using our services, you acknowledge that you have read and understood this Privacy Policy.

We comply with applicable privacy laws and regulations, including Japan's Act on the Protection of Personal Information (APPI), the European Union's General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and other applicable regional privacy laws.

2. Information We Collect

We may collect the following categories of personal information:

• Identity Information: Name, job title, and company name.
• Contact Information: Email address, phone number, and mailing address.
• Communications: Messages or inquiries you send us through our contact form or by email.
• Usage Data: Information about how you interact with our website, including IP address, browser type, pages visited, and time spent on pages.
• Technical Data: Device information, operating system, and other technical identifiers collected through cookies and similar technologies.

We collect information directly from you when you submit a contact form, indirectly through automated technologies (such as cookies), and from third-party sources where applicable and permitted by law.

3. How We Use Your Information

We use the personal information we collect for the following purposes:

• To respond to your inquiries and communicate with you about our services.
• To provide, operate, and improve our website and services.
• To analyze usage trends and optimize our content and user experience.
• To send you relevant updates or marketing communications, where you have consented.
• To comply with our legal obligations and enforce our terms.
• To protect the security and integrity of our systems.

4. Legal Basis for Processing (EU/EEA Users)

If you are located in the European Economic Area (EEA), we process your personal data under one or more of the following legal bases:

• Consent: Where you have given clear consent for a specific purpose.
• Contract: Where processing is necessary to perform a contract with you or to take steps at your request before entering into a contract.
• Legal Obligation: Where processing is necessary to comply with a legal obligation.
• Legitimate Interests: Where processing is necessary for our legitimate business interests, provided those interests are not overridden by your rights.

5. Sharing Your Information

We do not sell your personal information. We may share your information in the following limited circumstances:

• Service Providers: Trusted third-party vendors who assist us in operating our website or delivering services (e.g., hosting, analytics, email services), subject to confidentiality agreements.
• Legal Requirements: When required by law, court order, or governmental authority.
• Business Transfers: In connection with a merger, acquisition, or sale of assets, subject to appropriate confidentiality protections.
• With Your Consent: For any other purpose with your explicit consent.

6. Cookies and Tracking Technologies

Our website may use cookies and similar tracking technologies to enhance your experience and collect usage data. You can control cookie settings through your browser preferences. Please note that disabling certain cookies may affect the functionality of our website.

Where required by applicable law (e.g., under EU ePrivacy rules), we will obtain your consent before placing non-essential cookies.

7. International Data Transfers

Your personal information may be transferred to and processed in countries other than the country in which you reside. These countries may have data protection laws that differ from those in your country. Where we transfer personal data internationally, we implement appropriate safeguards in accordance with applicable laws, such as standard contractual clauses approved by the European Commission or equivalent mechanisms under Japan's APPI.

8. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, or as required by applicable laws and regulations. When personal information is no longer needed, we securely delete or anonymize it.

9. Your Rights

Depending on your location and applicable law, you may have the following rights regarding your personal information:

• Access: The right to request a copy of the personal information we hold about you.
• Correction: The right to request correction of inaccurate or incomplete information.
• Deletion: The right to request deletion of your personal information, subject to certain exceptions.
• Restriction: The right to request that we restrict processing of your information in certain circumstances.
• Portability: The right to receive your personal information in a structured, commonly used format (EU/EEA users).
• Objection: The right to object to processing based on legitimate interests or for direct marketing purposes.
• Opt-Out of Sale: California residents have the right to opt out of the sale of their personal information (we do not sell personal information).
• Withdrawal of Consent: The right to withdraw consent at any time where processing is based on consent.

To exercise any of these rights, please contact us using the information provided in the "Contact Us" section below. We will respond to your request within the timeframe required by applicable law.

10. Data Security

We implement appropriate technical and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

11. Children's Privacy

Our services are not directed to individuals under the age of 16 (or a higher age threshold where required by local law). We do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a child, please contact us immediately.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last updated" date at the top of this page. We encourage you to review this policy periodically. Your continued use of our services after any changes constitutes acceptance of the updated policy.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of your personal information, please contact us at:

If you are located in the EU/EEA and are not satisfied with our response, you have the right to lodge a complaint with your local data protection supervisory authority.