Privacy Policy(for EU/EEA users)

We shall process EU Personal Data within the scope necessary to achieve the Purpose of process provided herein, unless otherwise permitted or required by applicable laws and regulations.
Please note that, as EU Personal Data is indispensable for fulfilling our contractual obligations, the scope of some services may be limited depending on the EU Personal Data provided.

We may process the following categories of EU Personal Data;

• （1）Customer information
  [personal data including: name; business contact information; occupation/employment/title; information relating to sales; survey information and responses;]
• （2）Business partner information
  [personal data including: name; business contact information; manager/principal's title; information relating to sales and transactions;]
• （3）Stockholder information
  [personal data including: name; contact information]
• （4）Recruitment applicants, internship applicants and former officers and employee information
  [personal data including: name; contact information]

We may process EU Personal Data for the following purposes;

• （1）Regarding customer information, we may process it;
  • 1）to provide information on our products and services by catalog delivery, e-mail, etc.
  • 2）to answer various inquiries including consultation on our products and services.
  • 3）to conduct surveys such as customer satisfaction surveys.
  • 4）for proper and smooth business execution of dealings with customers.
• （2）Regarding business partner information, we may process it;
  • 1）for various contact necessary for our business.
  • 2）for proper and smooth operation of business with business partners
  • 3）for maintaining and protecting security of our products, services
  • 4）for resolving disputes, enforcing our contractual agreements and to establish, exercise or defend legal claims.
• （3）Regarding stockholder information, we may process it;
  • 1）to provide various services from us based on your status as a stockholder.
  • 2）for the management of stockholders, such as preparing data of stockholders according to prescribed standards based on applicable laws and regulations.
  • 3）to respond to inquiries from stockholders
• （4）Regarding recruitment applicants, internship applicants and former officers and employee information, we may process it;
  • 1）for carrying out duties related to information provision and hiring activities.
  • 2）for recruitment management in our group companies.
  • 3）for providing information and communicating to retirees.

We shall keep record of the processing in writing or data form, and maintain the record as required.

Each customer, business partner or other data subjects concerned have the following rights regarding his/her EU Personal Data.

• （1）Right to access to his or her own EU Personal Data and other information relating to its personal data.
• （2）Right to have inaccuracies of his or her EU Personal Data rectified without undue delay
• （3）Right to have his or her EU Personal Data erased without undue delay
• （4）Right to restrict processing of his or her EU Personal Data
• （5）Right to receive the provided EU Personal Data provided in a general format that is readable on computers, and have the said data transferred to other organizations (i.e. data portability).
• （6）Right to object to processing based on the specific situation
• （7）Right not to be profiled through an automatic method.

• *We do not perform profiling.

• （8）Right to lodge a complaint with a supervisory authority

We may process EU Personal Data in any one of the following case.

• （1）When the processing is necessary for the execution of the contract with customers or other data subjects, or when necessary to respond to a request from a customer or other subject before the execution a contract.
• （2）When the processing is necessary to comply with our obligations prescribed by applicable laws or regulations; for example, when following information disclosure orders based on applicable laws and regulations from government agencies etc.
• （3）When the processing is necessary to protect the serious interests of customers and other data subjects.
• （4）When it is deemed appropriate to investigate, prevent, or take measures against illegal acts or suspicious acts.
• （5）When the processing is necessary to pursue legitimate interests, to the extent that it does not infringed rights, interests, and/or privacy of a customer or other subject concerned.
• （6）When the customer or other data subjects have given us their consent. The customer or other data subjects have the right to withdraw the consent at any time, without affecting the lawfulness of processing prior to the withdrawal. If the consent is withdrawn, we may only process EU Personal Data if there are any other applicable legal grounds.

We shall obtain prior consent from customers and other subjects concerned for processing special types of EU Personal Data such as health conditions and physical characteristics for purpose.

EU Personal Data will be transferred within our group companies, and to outsourcing contractors such as cloud providers and IT service vendors which may be located outside the EU/EEA. We have taken necessary measures required under the applicable laws including entering into a data transfer agreement containing Standard Contractual Clauses issued by the European Commission.

In order to appropriately manage EU Personal Data of customers and other subjects concerned and prevent leakage, loss and damage of those EU Personal Data, including other safety management approaches, we shall implement technical, physical, organizational and human related safeguards.

• Name;
• Address;
• Email address;
• Phone number;
• Contract details;
• Any other items necessary in accordance with the Purpose of process (*)

• *For details, please refer to the above section 1, "Purpose of Processing EU Personal Data Acquired from Customers and Other Subjects Concerned".