- Time of issue:2022-02-21 10:50:24
Revised April 1, 2019
1-1. Comply with laws and regulations
Tsubakimoto Group, including Tsubakimoto Chain Co., Ltd. and its domestic subsidiaries and affiliates(hereinafter referred to as“Group of companies”)，Recognize the importance of protecting personal information ("Personal Information") as defined in Japan's Personal Information Protection Act ("APPI"). The Group of Companies complies with APPI and other applicable laws and regulations related to your personal information. (Including the adequacy decision-based transfer of personal data processing by EU law on the protection of personal information.) The company group uses generally accepted fair and appropriate processing methods when processing personal information.
1-2. Employee education
The Group of Companies has clear rules for the handling of your personal information and endeavours to ensure that all employees of the Group of Companies (including administrative, part-time and informal staff) properly handle your personal information.
1-3. Collection and processing
The company group collects and processes your personal information in an appropriate manner only for the purposes listed in Articles 1-4.
1-4. Processing purpose
The company group processes your personal information collected only within the scope of the following processing purposes. The company group may change the purpose of processing personal information in accordance with applicable laws and regulations. If the purpose of processing is changed, the company group will notify you via email, this website or any other appropriate means.
- Product (including software) manufacture, production, sale, installation, repair and inspection, after-sales service, maintenance, construction, product development and other services provided by the Group of Companies (including outsourcing of any of the above);
- Announcement of products and services (including direct mail and e-mail magazine distribution), public relations events, exhibitions, seminars, promotional events, promotions;
- Questionnaire surveys, data collection and analysis;
- respond to inquiries and send information (including documents);
- Procedures for exercising shareholder rights;
- Procedures for recruiting employees (including internship positions) and Matters relating to the implementation of any of (i) to (vi) above.
1-5. Safety management
The company group takes necessary measures to prevent unauthorized acquisition, loss, destruction, modification and disclosure of your personal information, and is committed to ensuring the safe management of your personal information. The Group of Companies continuously checks the handling of your personal information.
1-6. Provide to third parties
Our group of companies will not provide your personal information to any third party except in the following cases:
- With your consent;
- Provide your personal information in a way that does not identify you, such as statistical data;
- Provide your personal information to outsourced units that assist in the operations of our group of companies. In this case, the company group will enter into an agreement related to the processing of your personal information with outsourced units that process your personal information, and conduct appropriate supervision of such outsourced units;
- Provide your personal information for business continuity in a merger or other reorganization;
- Provide your personal information as required by laws and regulations;
- Providing your personal information is necessary to protect human life, person or property but it is difficult to obtain your consent;
- The Company Group is required to cooperate with national or local public functions in the performance of their public duties, but obtaining your consent may prevent the performance of such public duties;
- Sections 1-7 or 1-8 apply; and as permitted by applicable laws and regulations to provide your personal information.
For the processing purposes described in Articles 1-4, the Company Group may share your personal information to the extent necessary and within the scope of the following provisions:
- The content of your personal information to be shared
・Name, address, phone number, email address, affiliation, department, title, etc.
・Contents of negotiations and transactions with our group companies, participation in exhibitions, etc.
- Scope of sharing your personal information
・Group members of the company
・Member sales agents and distributors responsible for their customers
- Shared purpose
・As described in clauses 1-4
- The member of the company group responsible for the management of your personal information
・The first member of our group to receive your personal information
1-8. Request for disclosure, correction, etc.
If, in relation to your personal information held by the company group, you request the company group to: (i) inform the purpose of processing; or (ii) disclose, correct, add, suspend or delete your personal information, the company group will confirm After you have been identified, respond to this request to the extent required by applicable laws and regulations or to the extent that the Company Group deems reasonable.
1-9. Policy revision
The Group of Companies receives inquiries about the processing of your personal information through the "Contact" page.
(Personal information/data collected from each website)
2-1. The company group website
2-2. Personal information/data obtained through the website
The Group of Companies obtains your personal information/data in two cases, directly when you provide it and automatically when you visit the website.
- You provide personal information/dataThe Group of Companies obtains your personal information/data such as your name, email address, physical address and telephone number through the contact form on the website or any other form.
2-3. Processing purpose
- Our group of companies processes your personal information/data recorded on the website contact form or any other form for the following purposes: (i) to respond to your requests or inquiries; (ii) to provide services in relation to the circumstances in which you have provided your personal information/data ; or (iii) to develop and improve our Group's products or services.
- The company group will process personal information/data automatically collected through cookies, web analytics services and other technologies for the purpose of facilitating your use of the website, analyzing visitor usage, improving user experience and providing better services.
2-4. Transfer to overseas affiliates
The Group of Companies operates globally. In order to better respond to inquiries received through the website, the company group will transfer such inquiries, including your personal information/data, to affiliates of the company group outside Japan (hereinafter referred to as "overseas affiliates"). In this case, the company group will take necessary measures to protect your personal information/data in accordance with the applicable laws and regulations of the countries where the overseas affiliates are located and the privacy policies of the overseas affiliates. Regarding the privacy policies of overseas affiliates, please visit their respective websites.
2-5. Children's Personal Information/Data
The website is not intended for children, and the company group does not knowingly collect personal information/data from children under the age of 16 without the prior consent of their parents or guardians.
Articles 1-10 apply to inquiries regarding the processing of your personal information/data.
2-7. Personal data of EEA data subjects
In addition to the foregoing, the Group of Companies processes individuals of the EEA (European Economic Area: Member States of the European Union and the three countries of Iceland, Liechtenstein and Norway, whichever is most recently amended) data subjects obtained through the website in accordance with these Articles 2-7 Data (“EEA Personal Data”).
(i) Legal basis for processing
Legal basis for the processing of EEA personal data by our group of companies:
- The consent you give is free, specific, informed and unequivocal. You have the right to withdraw your consent at any time without affecting the lawfulness of processing based on your consent prior to your withdrawal;
- Necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract;
- Necessary for compliance with legal obligations of the Company Group; and for the purpose of pursuing legitimate interests of the Company Group, including the introduction of new products.
(ii) Retention period
The Group of Companies will retain your EEA Personal Data until you request deletion or withdrawal of your retention consent or until the purpose of retention no longer exists (for example, after your request has been fulfilled). However, if any applicable laws and regulations require the Company Group to continue to retain EEA Personal Data, the Company Group may continue to retain EEA Personal Data beyond the above-mentioned period.
(iii) Transfers outside the EEA
Our Group will transfer your EEA Personal Data to members of our Group or overseas affiliates outside the EEA. If such transfers are made to companies located in countries outside the EEA that the European Commission considers not to provide adequate data protection, such transfers will be subject to contractual terms approved by the European Commission, which directly impose data protection obligations on these companies.
(iv) Your rights
You have the following rights:
- The right to obtain confirmation from the Group of Companies as to whether your EEA Personal Data is being processed and, if so, to obtain information about your EEA Personal Data and its processing;
- the right to rectify inaccurate EEA personal data about you;
- the right to delete your EEA personal data;
- The right to restrict the processing of your EEA personal data under certain conditions;
- The right to receive your EEA personal data in a structured, commonly used machine-readable format and to transfer this data under certain conditions;
- The right to object to the processing of your EEA personal data pursuant to Article 2-7 (i) subparagraph d.; and any other rights under the GDPR, for reasons relevant to your particular situation.
To exercise any of the above rights, please email your request to firstname.lastname@example.org.
Please also note that you have the right to lodge a complaint with a supervisory authority.
TSUBAKIMOTO AUTOMOTIVE (SHAGNHAI) CO., LTD.
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