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Privacy policy

 §1. General information 

 

Pursuant to Article 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “GDPR”) (and, where we obtain personal data from other sources, also Article 14 GDPR), we set out below information on how we process your personal data. 

 

This Privacy Policy contains information about the processing of your personal data by us. Detailed information on the use of cookies and other similar technologies is provided in the Cookies Policy, available below. 

 

§2. Who is the Controller of your personal data? 

The Controller of your personal data is FUJIEI Europa Sp. z o.o. with its registered office in Warsaw, NIP (Tax Identification Number): 5252723048, REGON: 368293244, entered in the Register of Entrepreneurs of the National Court Register under KRS number 0000693993 by the District Court for the Capital City of Warsaw, 12th Commercial Division of the National Court Register, share capital: PLN 1,000,000, contact address: ul. Wojska Polskiego 9/108, 01-524 Warsaw, Poland. 

 

You may contact the Controller by e-mail at: contact@subu-tokyo.eu.  

 

§3. For what purposes do we collect your data and how long do we retain it? 

We may process your personal data for the following purposes: 

1. Communication with you in order to resolve or finalise the matter to which the correspondence relates, including answering questions submitted via the contact form, e-mail message, etc. (Article 6(1)(f) GDPR) 

 

We process your personal data on the basis of the Controller’s legitimate interest consisting in communicating with you (Article 6(1)(f) GDPR). We will retain such data until you object or until the purpose has been achieved, whichever occurs first. Providing these data is voluntary; however, it is necessary to communicate with you. 

 

We may also retain the data for internal archiving purposes on the basis of the Controller’s legitimate interest (Article 6(1)(f) GDPR), until you object or until the purpose has been achieved, whichever occurs first. 

 

2. Entering into and performance of a contract, and pre-contractual communication in matters concerning the contract (Article 6(1)(b) GDPR) 

3. Establishing, pursuing or defending claims as the Controller’s legitimate interest (Article 6(1)(f) GDPR) 

4. Compliance with legal obligations incumbent on the Controller, including tax and archiving obligations (Article 6(1)(c) GDPR) 

Data necessary to enter into and perform the contract will be retained for the period of contract performance, including the period of exercising rights arising from the contract (Article 6(1)(b) and (f) GDPR). Providing these data is voluntary; however, it is necessary to enter into and perform the contract. 

Additional data provided, inter alia, to improve the performance of the contract will be retained no longer than until you object or until the purpose is fulfilled, on the basis of the legitimate interest consisting in customer service (Article 6(1)(f) GDPR).  

Your data will be retained for the limitation period for claims arising from applicable provisions, including, in particular, Article 118 of the Polish Civil Code, and thereafter for an additional period of 12 months, on the basis of the Controller’s legitimate interest in defending against claims as well as establishing and pursuing claims (Article 6(1)(f) GDPR). 

Where processing is necessary for compliance with legal obligations, your data will be retained for the period required by generally applicable laws. Where the data are necessary to comply with the Controller’s legal obligations (e.g. issuing and storing invoices; archiving obligations), the retention period is 5 years from the end of the calendar year in which the tax obligation arose, unless provisions provide otherwise (Article 6(1)(c) GDPR). In other cases of compliance with legal obligations, the retention period is determined by the provisions governing those obligations (Article 6(1)(c) GDPR). 

Your data may also be archived for internal and statistical purposes until you object or until the purpose is fulfilled, on the basis of the Controller’s legitimate interest (Article 6(1)(f) GDPR). 

 

5. Providing marketing/commercial information (hereinafter: “Marketing Information”)  (Article 6(1)(a) or (f) GDPR)  

 

We process your data on the basis of consent (Article 6(1)(a) GDPR) – where we request subscription to a newsletter or consent to commercial communications – or on the basis of legitimate interest (Article 6(1)(f) GDPR) within the limits permitted by law. The communication channel (e-mail/SMS/telephone) requires prior consent under applicable electronic communications laws. You may withdraw your consent at any time. 

Providing your data is voluntary; however, it is necessary to receive Marketing Information. If you opt out, we will no longer be able to send you Marketing Information. Your data may also be archived for the purposes of establishing, pursuing or defending claims, including to demonstrate that marketing activities were conducted lawfully, on the basis of Article 6(1)(f) GDPR. Data processed on the basis of Article 6(1)(f) GDPR will be retained until you object or until the purpose is fulfilled, whichever occurs first. 

 

6. Administration and management of our website and social media pages/profiles (including Instagram and other social media platforms), including communication and directing marketing content (Article 6(1)(f) GDPR)  

Data provided for the use of a platform will be retained no longer than until you object or until the purpose is fulfilled - whichever occurs first - on the basis of the legitimate interest consisting in managing and operating our social media pages and communicating with users. These data will be processed only if you decide to: like the page, choose the “Follow” option, or otherwise leave your data on the platform managed by us, e.g. by posting an entry or comment. Data will be retained for as long as the page exists or until you object, which may occur by unliking/unfollowing, deleting a comment/post, by other means available within the platform/page, or by contacting us directly. Please note that the rules relating to the page/fan page are set by the Controller, while the terms of use of the social media platform on which the page/fan page is hosted are set by the entity managing that platform. 

 

7. Analytical and statistical purposes (Article 6(1)(a) or (f) GDPR) 

We process personal data for analytical and statistical purposes to better understand how you use our products/services and how we can develop them. Such data may come from various sources – for example from analytics tools (if we use a website or application), from customer service systems, accounting software, booking or communication systems, as well as from statements and reports prepared for our internal purposes. 

Where we use cookies or similar technologies, tools other than strictly necessary are activated only after you have given consent (Article 6(1)(a) GDPR) in the cookies banner. Data necessary for proper operation, security and functionality of the service are processed on the basis of legitimate interest (Article 6(1)(f) GDPR). Where we do not use cookies, analytics data come from our own systems and are processed on the basis of legitimate interest (Article 6(1)(f) GDPR) to produce statistics, analyse trends and improve services. 

Where possible, we apply pseudonymisation or anonymisation, and reports are aggregated (e.g. number of enquiries, average contact time, most frequently selected service categories) without the possibility of attributing them to a specific person. We process such data until you object or until the purpose is fulfilled  – whichever occurs first – and, where consent is the legal basis, until consent is withdrawn. You have the right to object to processing based on our legitimate interest, and where consent is the legal basis – to withdraw it at any time. 

 

8. Promotion and marketing of products (Article 6(1)(a) or (f) GDPR) Where you provide us with your data, in particular in the form of reviews/opinions, such data will be processed on the basis of the Controller’s legitimate interest consisting in marketing, in order to improve the quality of services and products and to promote the Controller’s services and products. These data will be processed until you object or until the purpose has been achieved, whichever occurs first. Providing the data is voluntary. 

 

9. Recruitment (Article 6(1)(b) and Article 6(1)(c) GDPR) Data may be processed for the period necessary for recruitment and entering into a contract (Article 6(1)(b) GDPR). Data required by labour law are processed pursuant to Article 6(1)(c) GDPR in conjunction with Article 221 of the Polish Labour Code. For additional data provided voluntarily - the legal basis is your consent (Article 6(1)(a) GDPR). 

Your data may also be processed for future recruitment purposes – based on your consent - for a maximum of 3 years due to the recruitment cycle in the industry (this period is calculated from the end of the year in which the application was obtained). Providing personal data is voluntary, however providing certain data may be necessary to conduct recruitment and/or enter into a contract. Failure to provide such data will result in the inability to undertake the above actions. 

 

§4. To whom may we disclose your personal data? 

We disclose your personal data to other entities only where this is necessary to achieve the processing purposes referred to in §3 and only to the extent necessary to achieve those purposes. As a rule, we collect and process only the data that you provide to us, subject to data collected automatically or semi-automatically, such as online identifiers, system logs, cookies and similar technologies. More information on cookies is provided in §8. 

We may disclose your personal data to processors acting on our behalf and on our instructions. Personal data are disclosed to other companies or entities only where this is necessary. 

We entrust your personal data to entities that support us in conducting our business, in particular providers of hosting and electronic mail services, providers of IT and cloud tools, providers of the e-commerce platform, including Shopify International Limited, payment service providers, accounting and bookkeeping service providers, providers of ERP and invoicing software, courier companies and postal operators, the entity handling warehousing and shipment fulfilment, providers of marketing and analytical services, social media platforms, entities supporting the operation and maintenance of the Website, and legal advisers. 

Personal data may also be disclosed to entities authorised to receive them under applicable law, including courts, public administration authorities or other competent authorities. 

As a rule, personal data will not be transferred outside the European Economic Area, subject to the situations described below. In other cases, where personal data are transferred outside the European Economic Area, such transfer will take place on the basis of your consent, standard contractual clauses or other safeguards provided for under the GDPR, after the applicable information obligations have been fulfilled. 

Services provided by Microsoft Ireland Operations Ltd, Meta Platforms Ireland Limited, Google Ireland Limited and Shopify International Limited are provided by entities established in the European Union or the European Economic Area. However, due to the global nature of the operations of these entities and their corporate groups, personal data may be transferred outside the European Economic Area, including to the United States, on the basis of standard contractual clauses or other legal safeguards compliant with the GDPR. These entities have implemented safeguards intended to protect personal data, including standard contractual clauses. Further information on the rules applicable to data processing by these providers can be found in their respective privacy policies. 

 

§5. What rights do you have? 

Under the GDPR you have the right to: access your personal data; rectify personal data; erasure of personal data; restrict processing; object to processing; data portability; and withdraw consent. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal. Detailed information on these rights is set out in the GDPR, i.e. Regulation (EU) 2016/679 of 27 April 2016. We respond to your requests as a rule within one month (Article 12(3) GDPR). 

If you believe that your personal data are processed in breach of applicable law, you have the right to lodge a complaint with the President of the Personal Data Protection Office (PUODO). In such a case, however, we encourage you to contact us first to clarify your concerns. 

 

§6. Are your personal data subject to profiling? 

The Controller may analyse personal data in an automated manner using tools provided by software vendors, in particular for statistical, analytical and marketing content adjustment purposes. Such activities do not constitute automated decision-making, including profiling, which would produce legal effects concerning you or similarly significantly affect your situation.  

 

§7. Applicable law 

In matters not regulated herein, the relevant provisions of law apply, including European law (in particular the GDPR). 

 

§8. Cookies Policy 

When you use the Website, technical information and online identifiers may be collected automatically, in particular via cookies and similar technologies. These data may constitute personal data. 

Cookies are small text files stored on a user’s device. Cookies usually contain the name of the website they originate from, the period for which they are stored on the end device and a unique number. 

Cookies are used in particular for the following purposes: 

- technical and functional - necessary for the proper operation of the Website and its functionalities (e.g. session maintenance, shopping cart, forms); 

- analytical and statistical – enabling analysis of how the Website is used, which helps improve its structure and content, e.g. Google Analytics 4; 

- marketing and advertising – enabling remarketing and the delivery of personalised advertising content, e.g. Google Ads; 

- communication and performance – supporting chat service, optimisation of website operation and service performance. 

The current list of cookies used on the Website, together with information on their categories, providers and retention periods, is available in the consent management tool (the cookies banner visible on the Website). 

You can change cookie settings in your web browser. In many cases, the browser allows cookies to be stored by default. Detailed information on the options and ways to manage cookies is available in your browser settings. Failure to consent to cookies may limit the operation of certain Website functionalities. 

The Controller uses technologies that track actions undertaken by the user within the Website: 

Google Analytics 4 To analyse and optimise the use of our Website, we use Google Analytics 4, provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics uses cookies and similar technologies to collect information about user activity on the Website (e.g. traffic source, pages visited, device type, web browser). We use this information to generate statistics that help improve the Website and tailor content to users’ needs. For strictly necessary technical purposes we rely on legitimate interest (Article 6(1)(f) GDPR). Analytics tools other than strictly necessary are activated only after consent is given via the cookies banner (Article 6(1)(a) GDPR). You can manage your consent at any time in the banner settings or by using Google’s browser add-on: https://tools.google.com/dlpage/gaoptout . Google privacy policy: https://policies.google.com/privacy. 

Google Ads We use Google Ads advertising tools on our Website, provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Ads enables advertising activities including remarketing, i.e. directing personalised ads to users who visited our Website or showed specific interests. Cookies and similar technologies are used to analyse user behaviour and tailor advertising content. The legal basis for processing for marketing tools is your consent (Article 6(1)(a) GDPR) given via the cookies banner; tools are activated only after consent is given. For strictly necessary technical functions we rely on legitimate interest (Article 6(1)(f) GDPR) consisting in ensuring security and proper operation of the service. Further information is available in Google’s privacy policy. 

 

§9. Social media plug-ins 

The Website uses plug-ins, widgets and other social tools provided by platforms such as Instagram. The rules concerning the processing of personal data are described directly on the websites of those service providers. 

 

§10. Joint controllership  

Data processed for the purposes of statistics collected within Instagram (Meta) are subject to joint controllership by the Controller and Meta Platforms Ireland Limited, with registered office at 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (the “Joint Controller”). Detailed rules on joint controllership, including information on your rights, are provided in the platform’s privacy policy. 

The allocation of responsibilities of the parties as joint controllers is governed by the arrangements referred to in Article 26 GDPR, published in the privacy policies of the relevant platform. 

In the event of any discrepancy between the Polish and English language versions of this Privacy Policy, the Polish language version shall prevail. 

This Privacy Policy is effective as of 12.10.2026.