[ ShinFlow JAPAN K.K. ], with its address at [ shinflow.com ], is the entity which collects and processes your data under this Policy.

2.1Definition of Personal Data:
We collect both personal and non-personal data when you visit our Website. "Personal Data" refers to any information relating to an identified or identifiable natural person ("Data Subject"). This includes identifiers that allow an individual to be identified directly or indirectly, such as a name, an identification number, or location data.

2.2 Categories of Data Collected:
We collect and process the following data categories for the specific purposes outlined below. Please note that if you decline to provide the requested personal data, we may be unable to deliver the corresponding services or respond to your inquiries.

3.1Under the Egyptian Personal Data Protection Law, certain types of information—such as race, ethnicity, religious beliefs, or health data—are classified as Sensitive Personal Data and require enhanced protection.

3.2 The Website does not collect, process, or request any Sensitive Personal Data. We kindly ask that you do not provide such information to us through any communication channels on this site.

4.1 Collection Methods: We collect your data through various interactions, including when you browse the Website, submit information via our online forms, communicate with us via email, or interact with our customer support channels.

4.2 Processing Methods: Your personal data is processed using both automated (electronic) and manual systems. We adhere to the core principles of the Egyptian PDPL, ensuring that data is:

Processed lawfully, fairly, and transparently.

Collected for specified, explicit, and legitimate purposes.

Limited to what is necessary for the purposes for which they are processed (Data Minimization).

We process your data based on the legal grounds identified in the table above (Section 2.2). The following provides further detail on your rights under these grounds:

5.1 Consent
Where we rely on your consent, you have the right to withdraw it at any time. This will not affect processing that has already occurred.

5.2 Contractual Necessity
This applies when the processing is indispensable for delivering the services you requested.

5.3 Legal Obligation & Public Interest
We may process data to comply with Egyptian laws or respond to requests from official regulatory or judicial authorities.

5.4 Legitimate Interests
We may process data for our legitimate business purposes (e.g., website security), provided it does not harm your privacy rights.

The Website uses cookies and similar technologies to deliver essential and additional functions. Please see our Cookie Policy for more information. You may also manage your cookie settings on the Website.

The Website may include links to third-party websites, plug-ins and applications. Clicking on those links may allow you to visit websites, plug-ins and applications of third parties and how those third parties collect and use your personal data will be governed by their respective privacy policies.

8.1 We may disclose your personal data to our affiliates for the purposes stated in this Policy.

8.2 We may engage a data processor to process your personal data for the purposes of this Policy, in which case we will request the data processor to keep your personal data in strict confidence and only process your data to the extent it is necessary to perform its contractual or statutory obligations.

8.3 We may disclose your personal data when required by Egyptian law enforcement, judicial authorities, or for national security purposes, provided such disclosure is based on a lawful order or statutory requirement.

8.4 We may also disclose your personal data to other third parties where you have provided explicit consent or when required to protect our legal rights in accordance with the law.

9.1 We may choose to store your personal data on a local server or a server located in a foreign country depending upon the IT configurations of the Website, which may be adjusted from time to time due to regulatory requirements or our business needs.

9.2 If your personal data is stored on a server in a foreign country, we will take organizational and technical measures to keep your data secure and give your data a level of protection which is comparable to the level of protection required by the law of the country where you reside.

10.1 We will only retain your personal data for as long as necessary to fulfil the purposes set out in this Policy or as required by law. Unless otherwise agreed with you, we expect to retain your personal data for the duration of our service provision and for a reasonable period afterwards.

10.2 Upon the expiration of the retention period, we will delete or anonymize your personal data.

11.1 Under the Egyptian PDPL, you have the following rights regarding your personal data:

• Access & Rectification: To access your data and request the correction of any inaccuracies.

• Deletion (Erasure): To request the deletion of your data when it is no longer needed for the purposes collected.

• Objection & Restriction: To object to or request the restriction of data processing, especially for marketing purposes.

• Consent Management: To give or withdraw your consent at any time.

• Data Portability: To receive a copy of your personal data in a readable format.

• Knowledge & Breach Notification: To be informed about how your data is processed and notified of any data breaches.

• Claims & Compensation: To file complaints with the supervisory authority and claim damages for any law violations.

11.2 To exercise these rights, please contact us at [auxdatacompliance@auxgroup.com].

11.3 If we decline your request, we will provide a written explanation. You have the right to lodge a formal complaint with the supervisory authority if you are unsatisfied with our response.

The Website does not collect children’s data. If parents or legal guardians suspect that their children have provided us with personal data inadvertently, they may request such personal data be removed by contacting us at [auxdatacompliance@auxgroup.com].

13.1 We are committed to keeping your personal data secure. We take appropriate organizational and technical measures in accordance with applicable laws to ensure that your personal data is adequately protected against undesirable consequences and damage that may occur, including unauthorized access, loss, alteration, and unlawful disclosure.

13.2 In the case that a data incident occurs, we will take immediate actions to contain its impact and investigate the cause of the incident. If we are required to notify you or any supervisory authority under the applicable law, we will notify the relevant parties pursuant to the requirements.

This Policy may be changed from time to time and we will notify you of the updated Policy by posting it on the Website.

If you have any questions about this Policy, including any requests to exercise your legal rights, please contact us at [auxdatacompliance@auxgroup.com].