Privacy Protection Policies
Issued: 20 January, 2025
Mitsui O.S.K. Lines, Ltd.
Wellbeing＆Lifestyle Business Management Division
Mitsui O.S.K. Lines, Ltd. (hereinafter referred to as the “Company”, “we”, “our”, “us”) collects, uses, and discloses personal information of our customers (users of MOL CART, hereinafter referred to as the “Customers”). As our business grows globally, we are processing Customer's personal information (“Personal Information”) both inside and outside of Japan. In order to protect Personal Information in countries outside of Japan, we have established this MOL CART International Privacy Policy (“Policy”). This Policy applies to any and all of our processing of Personal Information collected outside Japan. If you are a resident of the state of California, United States, “Supplementary provisions regarding the handling of personal information of California residents” shall also apply to processing of your Personal Information.
Processing of Personal Information obtained from Customers located in Japan by us is governed by our Privacy Policy [https://www.mol.co.jp/privacy/].
In the processing of Personal Information, we will comply with this Policy, the laws and regulations applicable to our processing of Personal Information (“Applicable Laws”).
1. Processing of Personal Information
(1) Acquisition of Personal Information
We acquire Personal Information by legal and ethical methods, and at the same time, devotes its utmost attention to making sure it is used for purposes that are clearly specified in advance. When we ask Customers to provide their Personal Information, we will inform the purposes of acquisition and the details of use of such Personal Information in advance. Processing of Personal Information will be conducted within the scope of our legitimate business purposes and only processed to the extent necessary to achieve the purposes set forth in “(2) Purposes of Processing” below.
Personal Information we collect from the Customers includes, but is not limited to, the following information:
Name, gender, birth date, occupation, e-mail address, address, postal code, telephone number, identification document to authenticate your identity (including ID or other identifying information and picture of the appearance), account ID, password, information relating to payment settlements, such as credit card information, bank account information, and electronic or virtual currency related account information, usage history, purpose of service usage, inquiry details, and any other information Customers provide us within the purposes and means set forth in “(2) Purposes of Processing”.
Some of the Personal Information is necessary for us to enter into a contract with Customers or companies to which Customers belong. In case Customers could not provide us certain information when requested, we may not be able to provide them with our full support with respect to our services.
We collect personal information of the Customers by the following methods:- (i) When you enter information into the MOL CART website for your membership registration, ordering and shipping;
- (ii) When you contact our customer service or correspond with us via phone, email or otherwise;
[enter any other ways MOL generally collects personal information, including from third parties]
(2) Purposes of Processing
Personal Information provided to us will be used within the scope of our legitimate business purposes and to the extent necessary to achieve those purposes set out below:
- (i) To manage MOL CART membership registration;
- (ii) (subject your consent) To contact Customers as necessary via your selected methods such as direct email or telephone number for the use of MOL CART;
- (iii) With your consents in writing, or as otherwise permitted under the Applicable Laws, to notify and apply for campaigns, projects and surveys regarding MOL CART and related services;
- (iv) Subject your consent in writing for us to use your information for research, analysis and any other marketing operation for the planning, development and sales of services;
- (v) To pack and ship goods, etc.;
- (ⅵ) To process payments, refunds, etc.;
- (ⅶ) Subject your consent in writing for us to use your information to plan, research, develop, improve, market for, and sell our products and services;
- (ⅷ) To respond to inquiries or requests etc. from Customers and provide after-sale services for Customers; and
- (ix) To respond to governmental and/or administrative authorities for law enforcement purposes in accordance with the provisions of Applicable Laws.
(3) Provision and Cross-border Transfer of Personal Information
Subject to your consent, we will disclose Personal Information listed in “(1) Acquisition of Personal Information” to our group companies and to other business partners, such as local logistics service providers, credit card or payment processors, cloud storage providers, customer support tools or IT and security service providers, so long as such disclosure is conducted within the purposes and means set forth in “(2) Purposes of Processing” above. As a result of the disclosure, Personal Information may be transferred to locations outside of the countries/regions in which the Customers are located including Japan. Personal information protection laws in such transferred locations may not have the same standard of protection with that of Customers' location. In such cases, we will thoroughly examine the eligibility of the party to which the Personal Information is provided or entrusted and confirm that appropriate security measures are taken in the processing of Personal Information from the perspective of security of Personal Information and take reasonable steps to ensure the party complies with Applicable Laws.
(4) Procedures for Access, Issuance of copy, Disclosure, Correction, etc. of Personal Information
If Customers wish to request access, issuance of copy, disclosure, correction, addition, deletion, suspension of use, or suspension of provision to a third party, objection, or data portability, etc., of Personal Information as permitted under the Applicable Laws, or lodge a complaint about our compliance with Applicable Laws, please contact us using the contact channel as shown in “6. Contact Us” below. The Company will usually respond to such request regarding Personal Information within a reasonable period of time, once when we can confirm that the request or complaint is made by the data subjects of the Personal Information and the data subjects are eligible to exercise the right under the Applicable Laws. Should we not be able to respond to Customers' request of access, issuance of copy and disclosure within fifteen (15) days after receiving the requests, we will be able to extend the term within fifteen (15) days. Should we not be able to respond to Customers' request other than access, issuance of copy and disclosure within thirty (30) days after receiving the requests, we will be able to extend the term within thirty (30) days. If we extend the term as above, we shall generally inform the Customer in writing of the reasons why we are unable to do so and of the time by which we will respond to the request (except where we are not required to do so under the Applicable Laws).
Customers may at any time you wish also request to withdraw their consent for the Company to collect, use or disclose their Personal Information for any purposes, without affecting the lawfulness of processing based on your consent before withdrawal thereof, by contacting us in the manner set forth in “6. Contact Us” below. In some cases, withdrawing consent may hinder the Company's ability to facilitate, process, administer, provide, or maintain services to the requester. In some cases, we may continue to collect, use or disclose Personal Information if we have the legal right to do so. Customers may exercise their rights before and after the Company discloses Personal Information to third parties in accordance with “(3) Provision and Cross-border Transfer of Personal Information” if it is allowed under the Applicable Laws. Upon receipt of Customers' written request to withdraw their consents, we may require reasonable time for the request to be processed and for us to notify the Customer of the outcome, including any legal consequences which may affect Customers' rights and our liabilities. In general, we shall seek to process the request within ten (10) business days of receiving it.(5) Filing a Complaint
Customers may have the right to complain to their local data protection authority, or to a court of law under the Applicable Laws, if their data protection rights are violated. They may be entitled to claim compensation for damages or distress incurred or suffered in consequence of unlawful processing of their Personal Information.
2. Security Measures and Retention Period
(1) Security Measures
We have established a management system and implemented appropriate security measures to protect Personal Information from unauthorized access, loss, destruction, falsification, leakage, etc., and to ensure the accuracy and safety of Personal Information. In addition to restricting the entry of unauthorized persons into the office where we process Personal Information and conducting educational activities for all directors, employees, and other staff involved in the protection of Personal Information, we will appoint a person responsible for the management of Personal Information and strive to manage personal data appropriately. For details of the security measures taken by the Company, please contact from “6. Contact Us” below.
(2) Retention Period
The Company will retain Personal Information for those periods necessary to fulfil the purposes to process unless a longer retention period is required or permitted under the Applicable Laws. If the Company no longer needs Personal Information to fulfill such purpose, the Company will delete or anonymize the Personal Information from our databases in accordance with the Applicable Laws.
3. Age Restrictions
(1) Age Restrictions to Children under the Age of 15
If you are under the age of 15, you should not use the services of MOL CART. MOL CART is not directed to children who are under the age of 15.
(2) Age Restrictions to Minors
If you are a minor 15 years of age and older (“Child”), you should not use the services of MOL CART without the permission and involvement of your parent or guardian. If you are a Child, you should not use MOL CART or otherwise provide us with any Personal Information either directly or by other means without the permission and involvement of your parent or guardian. A Child should get the permission and involvement of his/her parent or guardian when using MOL CART. If a Child has used MOL CART without the permission and involvement of his/her parent or guardian, and if we have obtained Personal Information about a Child, we encourage the Child's parent or guardian to contact from “6. Contact Us” below to request that we remove Personal Information from our systems. If we obtain actual knowledge that a Child has used MOL CART without the permission and involvement of his/her parent or guardian, and that we have obtained Personal Information about a Child, that information will be promptly deleted from our records.
4. Continuous Improvement
We will continuously review and improve our efforts to protect Personal Information in response to changes in laws and regulations, processing methods, and changes in the business circumstances.
5. Changes to the International Privacy Policy
As part of the Company's efforts to ensure that we properly manage, protect, and process Customers' Personal Information, we will be reviewing this Policy, procedures, and processes in using Personal Information from time to time.
Company reserves the right to amend and update the terms of this Policy at our absolute discretion. Customers are encouraged to visit this Policy from time to time to ensure that they are well informed of the Company's latest policies in relation to the protection of the Personal Information.6. Contact Us
Inquiries regarding our processing of Personal Information are welcomed at the following contact channel of our Data Protection Officer at:
Mitsui O.S.K. Lines, Ltd.
Hiroyuki Kakehashi
2-1-1, Toranomon, Minato, Tokyo, 105-8688, Japan
Email：support.molcart@molgroup.com
Business hours: 9:00 - 17:00 JST (excluding Saturdays, Sundays, holidays, and our Company Closing days)
Supplementary provisions regarding the handling of personal information of California residents
Information that identifies customers (hereinafter, “Customers”) or households residing in the state of California, United States, as well as information that relates to them, describes them, can reasonably be associated with them, or can reasonably be linked directly or indirectly to them (hereinafter, “Personal Information”) shall be handled according to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (hereinafter, “CCPA”) and be subject to the aforementioned privacy policy and these supplementary provisions. If provisions differ between these supplementary provisions and the aforementioned privacy policy, these supplementary provisions shall prevail.
These supplementary provisions provide information about how the Personal Information held by our company are processed.
1. Personal Information that were collected
The categories of Personal Information we have collected in the past 12 months as follows. We obtained these when Customers register or make changes on our website, etc.
Categories of Personal Information Examples A. Identifiers Name, telephone number, address, postal code, e-mail address, account ID or other similar identifiers, etc. B. Personal Information categories listed in the California Consumer Records statute (Cal. Civ. Code § 1798.80) Name, address, telephone number, credit card number, bank account number, or any other financial information, employment, etc. C. Protected classification characteristics under California or federal law Gender D. Internet or other electronic network activity information Usage history E. Audio, electronic, visual, thermal, olfactory, or similar information None F. Professional or employment-related information Employment G. Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99) None H. Sensitive Personal Information (Cal. Civ. Code § 1798.140(ae) None I. Commercial information Usage history 2. Purpose of collecting and handling of Personal Information
We may use the Personal Information for one or more of the following business purposes:
- (i) To manage MOL CART membership registration;
- (ii) (subject your consent) To contact Customers as necessary via your selected methods such as direct email or telephone number for the use of MOL CART;
- (iii) With your consents in writing, or as otherwise permitted under the Applicable Laws, to notify and apply for campaigns, projects and surveys regarding MOL CART and related services;
- (iv) Subject your consent in writing for us to use your information for research, analysis and any other marketing operation for the planning, development and sales of services;
- (v) To pack and ship goods, etc.;
- (ⅵ) To process payments, refunds, etc.;
- (ⅶ) Subject your consent in writing for us to use your information to plan, research, develop, improve, market for, and sell our products and services;
- (ⅷ) To respond to inquiries or requests etc. from Customers and provide after-sale services for Customers; and
- (ix) To respond to governmental and/or administrative authorities for law enforcement purposes in accordance with the provisions of Applicable Laws.
3. The length of time Personal Information is retained
We keep Customers' Personal Information for reasonably necessary period for achieving the purpose for which the personal information was collected. Such period shall be determined by (i) the length of time we have an ongoing relationship with Customers, (ii) whether there is any legal obligation to which we are subject and (iii) the purpose for which we collect Customers' Personal Information.
4. Disclosure of Personal Information
We disclose Customers identifiers including attribute information among the Personal Information collected in the past 12 months to our group companies to fulfill the business purposes outlined in these supplementary provisions.
We also disclose Customers' Personal Information to service providers or contractors only within the scope necessary for fulfilling the outsourced business. In such case, we carefully select the service providers and contractors, conclude necessary data processing agreement with them, and periodically monitor how they handle Personal Information.5. Sharing and Sale of Personal Information
We have not shared or sold any Personal Information in the past 12 months and will not do so in the future.
6. Customers' Rights
Under the CCPA provisions, Customers have the following rights regarding their Personal Information that we collect. The following parts of this Section describe Customer's rights and explain how to exercise those rights under the CCPA.
(1) The right to request disclosure of specific information
Customers have the right to request disclosure of the following information regarding Personal Information that we have collected. We shall disclose the following information to Customers after confirming that the received requests have been made by the Customers themselves.
- Categories of Personal Information that we have collected
- Categories of sources from which Personal Information is collected
- Business or commercial purposes for which Personal Information is collected, shared or sold
- Categories of third parties to whom we disclose Personal Information
- Specific pieces of Personal Information collected from Customers
- Categories of sold or shared Personal Information categorized by categories of third parties to whom the Personal Information were sold or shared
- Categories of Personal Information disclosed for business purpose
(2) The right to request deletion of Personal Information
Customers have the right to request the deletion of Personal Information collected from Customers and retained by us, except when it needs to be retained to fulfill agreements with Customers or for compliance with legal obligations or for certain other purposes as required by the CCPA. We shall delete the Personal Information from our records and instruct the same to our service providers or contractors after confirming that the received requests have been made by the Customers themselves.
(3) The right to request correction of Personal Information
Customers have the right to request the correction of inaccurate Personal Information collected from Customers and retained by us, taking into account the nature of Personal Information and the purposes of the processing of Personal Information. We will correct the inaccurate Personal Information and instruct the same to our service providers or contractors after confirming that the received requests have been made by the Customers themselves. We may deny the received requests if we determine that the Personal Information the Customers claim to be inaccurate is more likely than not accurate based on the totality of the circumstances.
(4) The right not to be discriminated against
We do not discriminate against Customers nor conduct any of the following as a result of Customers exercising their rights based on CCPA.
- Refuse to provide services and products to Customers
- Impose different prices for the services and products provided to Customers (including the application of discounts, rebates or other benefits or the imposition of penalties)
- Provide services and products of different levels or quality to Customers
- Suggest the provision of services and products at different prices, charges, levels, or quality to Customers
- Retaliate against an employee, applicant for employment, or independent contractor
To exercise the aforementioned rights to request disclosure, deletion or correction, please contact us at the following contact channel.
Mitsui O.S.K. Lines, Ltd.
Hiroyuki Kakehashi
2-1-1, Toranomon, Minato, Tokyo, 105-8688, Japan
Email：support.molcart@molgroup.com
Business hours: 9:00 - 17:00 JST (excluding Saturdays, Sundays, holidays, and our Company Closing days)
Customers may make requests pertaining to their Personal Information through an agent by authorizing someone registered with the California Secretary of State to act on their behalf, or a person who has power of attorney or is acting as a conservator for the Customer, and providing us with a document certifying this. Customers who are a minor can also make the request through their guardians as their agent.
The following requirements must be met for us to determine that requests have been legitimately made by the Customers themselves.
- The requester shall provide sufficient information so that we can reasonably verify that the requester is the Customer from whom the Personal Information was collected or an agent authorized by the Customer
- The requester shall explain the necessary details of the Customer's request in a way that we can appropriately understand, evaluate, and respond to the request
Enacted on 20 January 2025