Privacy Policy

What data do we collect?

• When you create an account with us we collect information that you provide to us which allows us to open your account and deliver products (vehicles) to you. This includes personal identification information such as your name, email address, phone number, addresses for invoicing, shipping, and mailing.
• In some situations, we are required by Japanese law to collect data to authenticate your identity in order to comply with anti-money laundering obligations and the requirements of our dealer's license.
• When you use our service we may also collect device information such as IP addresses, browser type and settings, device type and settings, operating system, mobile network information.
• When you use our service we may also collect usage information such as the pages you viewed, the features you use, system activity, the date, time, and referrer URL of your request.

How do we collect your data?

You directly provide us with most of the data we collect, for example:

• Register online or place an order for products or services
• Data that you enter into forms via our website
• Voluntarily complete a customer survey or provide feedback
• Use or view our website via your browser

Sometimes, we collect your information from a third party, for example when you have an account with that party, to help us validate the accuracy of information you provide, or from our partners who provide business services to us.

How will we use your data?

• So that we can provide, protect, improve and deliver you with our products and services.
• Communicate with you and provide you with offers on other products and services.
• To protect Smile JV and other customers for the purposes of combating fraud.
• To comply with our legal obligations, for example, obtaining proof of identity.

Our legal bases for using your data

We rely on the following legal bases when processing your personal information:

• Performance of a contract — most of our processing is necessary to provide the services you request: operating your account, bidding, purchasing, shipping and delivering vehicles, and communicating with you about your transactions.
• Legal obligations — some processing is required by law, including identity verification, anti-money laundering checks, our dealer's licence requirements, and tax and export regulations.
• Legitimate interests — we process some data to prevent fraud, secure our systems, and improve our services, in ways that do not override your rights.
• Consent — where required, for example for marketing communications, we rely on your consent, which you can withdraw at any time.

When we share your information

Sometimes we need to share your information with third parties. We will share your information for the following reasons:

• To provide you with the products and services necessary for normal business (e.g. shipping companies).
• To our partners who provide business services (e.g. software, accounting, marketing partners).
• For legal reasons when required to comply with a subpoena, court order, or other applicable legal regulation.
• To enforce our terms and conditions and for debt collection.
• To our affiliates and subsidiaries.
• For mergers and acquisitions — we may provide your information to the relevant entity and its advisors.

How do we store your data?

Smile JV securely stores your data on computer devices and servers located within and outside of Japan. We also use third-party service providers to store data, for example accounting software, CRM databases and auction system software.

Where your data is transferred internationally, we take reasonable steps to ensure it remains protected. Japan holds an adequacy decision from the European Commission, meaning transfers between the EU and Japan are recognised as providing an adequate level of data protection. Where we use service providers in other countries, we choose reputable providers and apply appropriate safeguards.

How long we keep your data

We keep personal information only as long as needed for the purposes described in this policy, and to meet our legal obligations — for example, Japanese commercial and tax law requires us to retain transaction records for a number of years. When data is no longer needed, we delete it or anonymise it.

Marketing

Smile JV would like to send you information about products and services that we think you might like. If you have agreed to receive marketing, you may always opt out at a later date. You have the right at any time to stop Smile JV from contacting you for marketing purposes.

Your data protection rights

Smile JV would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

• The right to access — You have the right to request copies of your personal data.
• The right to rectification — You have the right to request correction of inaccurate information.
• The right to erasure — You have the right to request erasure of your personal data, under certain conditions.
• The right to restrict processing — You have the right to request restriction of processing, under certain conditions.
• The right to object to processing — You have the right to object to processing of your personal data.
• The right to data portability — You have the right to request data transfer to another organization.

You also have the right to lodge a complaint with your local data protection supervisory authority if you believe we have not handled your personal information properly — though we would appreciate the chance to address your concerns first.

If you make a request, we have one month to respond. Please contact us to exercise any of these rights.

Cookies

Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. Smile JV uses cookies to keep you signed in and understand how you use our website. You can set your browser not to accept cookies, however some website features may not function as a result.

Changes to our privacy policy

Smile JV keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated on 8 August 2026.

How to contact us

If you have any questions about Smile JV's privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.