Supercar and Classic Car Sales | TPE Ltd.

Privacy policy

ABOUT US

TPE Ltd, a company incorporated in Japan (corporate registration no. 0111-02-021568) whose registered office is at 1201, 6-12-7, NishiShinjuku, Shinjuku-ku, Tokyo (hereinafter referred to as “we”, “us”, "our”) is the controller and responsible for the collection, use and protection of personal information of individuals (i.e. information from which a person can be identified) when:

  1. you use our website: https://www.tpejapan.com/en/;
  2. you make an enquiry (including through our inquiry form);

including any data you may provide when you register with us, sign up to our marketing, and/or purchase our products or services.

1. COLLECTION AND PURPOSE OF USE OF PERSONAL INFORMATION

We may collect, use, store and transfer the following kinds of personal information about you:

  1. full name;
  2. contact details which include phone number and email address;
  3. physical address;
  4. communication details which include correspondence between you and us in relation to any inquiries, requests, complaints, or other information you provide us when you contact us;
  5. transaction details which includes information about payments to and from you and other details of products and services you have purchased from us;
  6. [technical details which include internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access our website. We collect this personal information by using cookies and other similar technologies but only if you accept the relevant cookies via the cookie controls available when you land on our website;]
  7. [usage details which include information about how you interact with and use our website, products and services;]
  8. marketing details which include your preferences in receiving newsletters and/or marketing from us and your communication preferences, any feedback and responses to surveys sent by us (these are optional and you do not have to respond to us).

The personal information listed above and entrusted to us by you will be used for the following reasons:

  1. performance of a contract – to send you e-mails and documents regarding the products and/or services you have purchased;
  2. performance of a contract or in our legitimate interests to properly administer our business - to contact you and answer your questions including when you make inquires or request quotations for our products or services;
  3. where you have consented to receiving marketing from us, to inform you about our business, products and/or services; and
  4. to comply with our legal obligations where necessary.

2. Disclosure or provision of personal information to third parties

We will properly manage personal information entrusted to us by you and will not disclose such personal information to third parties except we may do so (to the extent necessary) in the following cases:

  1. disclosing to our third party service providers, agents or sub-contractors to provide parts of our services to you on our behalf (e.g. our customer relationship management platform provider, to host our website, and/or to send you marketing communications);
  2. in the event that we sell or buy any business or assets, in which case we may share your personal information to the prospective seller or buyer of such business or assets; or if we or substantially all of our assets are acquired by a third party, in which case personal information held by us about you will be one of the transferred assets. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this privacy policy;
  3. when disclosure is required by law and/or to comply with our legal obligations;
  4. in order to enforce or apply or terms and conditions of business or other agreements;
  5. to protect the rights and property of TPE Limited, our website, our customers, suppliers, and service providers that we have engaged;
  6. when your consent is required and it has been obtained with regard to the specific information.

3. Marketing

  1. Direct marketing You will receive marketing communications from us if you have:
    1. requested information from us or purchased goods or services from us; or
    2. provided us with your details and/or ticked the box at the point of entry of your details for us to send you marketing communications, and
  2. Third-party marketing We do not share your personal information with third parties. If we intend to do so, we will get your express consent before we share your personal information with any third party for their own direct marketing purposes.
  3. Opting out of marketing If you do not or no longer want us to use your personal information for marketing, please either unsubscribe using the process set out in the relevant marketing communication or inform us at any time by contacting us using the details set out in section 10 below. If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations, updates to our terms and conditions of business, checking that your details are correct.

    4. 4. Storage and safety measures for personal information

    All personal information collected and used by us is stored in [Japan].

    [Japan has received a full adequacy decision for the European Economic Area (EEA) from the European Commission and a partial adequacy decision for the United Kingdom (UK) from the Information Commissioner’s Office approving private sector organisations as adequate. This means that personal information receives an adequate level of protection when transferred from the EEA and/or UK to Japan.]

    We will ensure to keep your personal information accurate and up-to-date, and in order to prevent unauthorised access to, accidental loss, damage, falsification, unauthorised disclosure or alteration, etc. of personal information; and we will take adequate and appropriate data security measures to securely manage your personal information.

    We limit access to your personal information to those employees, agents, contractors and/or other third parties who have a business need to know. They will only use your personal information on our instructions and they are subject to a duty of confidentiality.
    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 

    5. Data subject rights

    You have a number of rights under data protection laws in relation to your personal information.

    1. You have the right to: You will receive marketing communications from us if you have:
      1. Request access to your personal information (commonly known as a "subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully collecting and using it.
      2. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
      3. Request erasure of your personal information in certain circumstances. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to use it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have used your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
      4. Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your information (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to use your information which override your right to object.
      5. Opting out of marketing - you also have the absolute right to object any time to the use of your personal information for direct marketing purposes (see section 3.3 for details of how to object to receiving direct marketing communications).
      6. Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
      7. Withdraw consent at any time where we are relying on your consent to collect and use your personal information (see section 1 for details of when we rely on your consent as the legal basis for using your information). However, this will not affect the lawfulness of any use carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
      8. Request restriction of processing of your personal information. This enables you to ask us to suspend the use of your personal information in certain limited circumstances.
      If you wish to exercise any of the rights set out above, please contact us using the details in section 6.
    2. No fee usually requiredYou will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
    3. What we may need from youWe may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
    4. Time limit to respondWe try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

      5. 6. Retaining your personal information

      We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

      To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

      By law we have to keep basic information about our customers for at least [six] years after they cease being customers for tax and legal purposes.

      In some circumstances you can ask us to delete your information: see section 5 above for further information.

      In some circumstances we will anonymise your personal information (so that it can no longer be associated with you) including for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

      7. CHANGES TO THE PRIVACY POLICY

      We keep our privacy policy under regular review. Any changes we make to this privacy policy in the future will be notified to you and made available via our website. You should ensure you are happy with any changes to this privacy policy and your continued use of our website and services shall be deemed as your acceptance of the varied privacy policy.

      8. YOUR DUTY TO INFORM US OF CHANGES

      It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us (for example a new address or email address) using the contact details in section 10 below.

      9. THIRD-PARTY LINKS

      Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share personal information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

      10. Contact Us

      For inquiries or complaints regarding our privacy policy and our handling of your personal information, please contact us at the following: TPE Ltd.
      6-12-7 Nishi-Shinjuku, Shinjuku-ku, Tokyo 160-0023 Storck Shinjuku 1201
      TEL: 03-5990-5915 FAX: 03-5990-5916
      Email: info@tpejapan.com

      We hope that we are able to deal with any complaints you may have. However if you remain unsatisfied, you may contact the Personal Information Protection Commission which is primary regulatory body responsible for compliance with data protection regulations in Japan.

      This privacy policy was last updated in: June 2025