NITTO BOSEKI Co. Ltd. and our group companies ("we", "us" or "our"), in connection with the processing of personal data relating to data subjects ("you" or "your") in the European Economic Area (the "EEA"), shall comply with the EU General Data Protection Regulation (the "GDPR"), the GDPR guidelines, the applicable national laws, guidelines, etc. ("applicable laws"), and therefore hereby establish this Privacy Policy in order to appropriately process your personal data in the EEA.
- 1. Processing personal data
- (1) Definitions
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"Personal data" means any information relating to an identified or identifiable natural person, including, without limitation, your names, addresses, birth dates, telephone numbers, and e-mail addresses.
"Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- (2) Types of personal data to be collected
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The types of personal data to be collected are as follows:
your name, department, title, birth date, address, telephone number, fax number, e-mail address, nationality, purchase history of our goods or services
- (3) Purposes of processing of personal data and legal basis for processing
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The purposes of processing of your personal data collected by us are as follows:
(a) To pursue our legitimate interests as required by us, in particular:
- to provide our goods or services to you;
- to provide information on our goods or services to you;
- to maintain, repair, support and protect our goods or services;
- to research, improve and develop our goods or services;
- to respond to inquiries, consultations, requests, opinions, impressions, suggestions, etc. concerning our goods or services; and
- in addition to the above, to conduct our business;
(b) To fulfill obligations under a contract or take steps linked to a contract; and
(c) To comply with legal obligations to which we are subject.
In the case of processing of your personal data for purposes other than the above, we will notify you in advance of such new purposes of processing and other matters as required by applicable laws.
If processing of your personal data is based on your consent, by manifesting your intention to consent to Privacy Policy, you will be deemed to have consented to the processing of your personal data by us within the scope of the explicit purposes of processing, and we will process your personal data based on your consent; provided, however, that you may withdraw such consent at any time. Even in that case, this will not affect any legitimate processing performed pursuant to consent before your withdrawal thereof.
The personal data that you are to provide is necessary in order for us to provide our goods or services to you or to do business with you, and if you have not provided such data, you may be unable to use such goods or services or to do business with us.
- (4) Retention period
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We will retain your personal data as long as we require such data for achieving the purposes of processing specified in 1(3) above, but will promptly delete the same in the case that such data is no longer necessary. The criteria used to determine our retention periods include:
(a) the length of time we have an ongoing relationship with you; and
(b) whether there is any legal obligation to which we are subject.
- (5) Source of personal data
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In addition to directly obtaining your personal data, we may obtain your personal data from third parties such as our group companies and our business partners.
- (6) Transfer
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We may provide your personal data to third parties such as our group companies, professional advisors, information processing service providers, cloud vendors and outside contractors, etc., to implement the purposes of processing specified above. Third parties located in the countries outside the EEA (including, without limitation, Japan, China, Taiwan, Macau and the USA, the same shall apply hereafter) are among the third parties to whom we will disclose your personal data, and you shall be deemed to have consented to the following matters by consenting to this Privacy Policy:
(a) In the case that the country in which the third party is located is outside the EEA, such country does not have the same data protection laws as the EEA, i.e., many of the rights provided to you in the EEA are not given;
(b) Your personal data will be provided and processed for the purposes specified in 1(3) above by third parties located outside the EEA; and
(c) Your personal data will be provided to third parties located outside the EEA.
In addition to the above, in the case that we provide your personal data to a third party located outside the EEA, we will ensure that adequate measures are taken concerning the protection of your personal data by executing standard contract clauses based on the GDPR, etc.
For further information, including obtaining a copy of such adequate measures, please contact us by sending an email to the contact point set forth in “2. Contact” below.
- (7) Your rights
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You may request us for access to, rectification or erasure of, and restriction of processing of your personal data, may object to the processing of your personal data under a certain condition set forth in "1.(8) Your right to object to processing" below, and may request for data portability. We accept your requests at the contact point set forth in "2. Contact" below.
We may refuse your requests if we deem that there is no basis for your requests, if your requests are deemed excessive, if fulfilment of your request may infringe upon the rights of a third party (including our rights), or if you ask us to delete information which are required by law to keep or which we have compelling legitimate interests in keeping.
- (8) Your right to object to processing
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You have the right to object at any time to the processing of your personal data which is based on our legitimate interests. We accept your objection at the contact point set forth in "2. Contact" below.
In addition to the above, you may raise objections with the data protection authorities having jurisdiction over the location of your domicile with regard to the processing of your personal data.
- 2. Contact
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In the event of your having any questions or concerns regarding this Privacy Policy or the processing of your personal data by us, or having any requests concerning the access to, rectification of, erasure of, or restriction of processing of your personal data, or regarding data portability, please contact us.
The contact information for us is as follows:
[NITTO BOSEKI Co. Ltd.]
privacy@nittobogrp.com
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