1. Our Privacy Statement
2. How Do We Use Your Personal Data?
We will always process your personal data based on one of the legal basis provided for in the GDPR (Articles 6 and 7). In addition, we will always process your sensitive personal data, for example, concerning your trade union membership, religious views, or health condition, in accordance with the special rules provided for in the GDPR (Articles 9 and 10).
We may collect and process your personal data for the purposes detailed below, which are required so that we can pursue our legitimate interests and provide you with adequate services and products:
- to ensure that content from our site is presented in the most effective manner for you;
- to notify you about changes to our service(s);
- to manage your customer account;
- to offer you products and services;
- to inform you about our policies and terms;
- to promote safety and security, such as by monitoring fraud and investigating suspicious or potentially illegal activity or violations of our terms or policies;
- to provide, improve, and develop our products, services, and advertising;
- to use personal information for purposes such as data analysis, research, and audits;
- to ensure business continuity.
Also, subject to obtaining your express prior consent, we may also collect and process your personal data for the following purposes:
- to provide you with information which we feel may be of your interest;
- to allow you to participate in interactive features of our services, when you choose to do so;
- to manage your subscription to the newsletter;
- to share your personal information with third-party partners who may send you marketing communications in relation to their products and services;
- for making business analysis.
Please be aware that you are entitled to withdraw your consent at any time, without affecting the lawfulness of processing based on your consent before withdrawal thereof.
We will process your data for these specified, explicit and legitimate purposes, and will not further process the data in a way that is incompatible with these purposes. If we intend to process personal data originally collected for one purpose in order to attain other objectives or purposes, we will ensure that you are informed of this. We will keep your personal data for as long as it is necessary for us to comply with our legal obligations, to ensure that we provide an adequate service, and to support its business activities (Article 5 and 25(2) GDPR).
3. What Types of Personal Data Do We Use?
- Name, Surname
- Home Address
- Identification number (e.g., customer number)
- Location data
- Email address (personal / professional)
- Telephone number (personal / professional)
- Online identifiers (IP address / cookie identifiers)
- Credit card / bank account information
- Recorded customer phone calls
- Video surveillance (CCTV footage)
- Record of employee performance assessment
- Recruitment information (e.g., CV, certificates, marital status, date of birth, reference letters).
We can obtain such personal data either directly from you when you decide to communicate such data to us (i.e., when you fill in forms displayed on the Website) or indirectly where such personal data is provided to us by your electronic communication terminal equipment or your Internet browser. We ensure that the personal data processed is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
4. How Do We Share Your Personal Data?
We may share your personal data with Company Group entities and with third parties in accordance with the GDPR. Where we share your data with a data processor, we will put the appropriate legal framework in place in order to cover such transfer and processing (Articles 26,28 and 29 GDPR). Furthermore, where we share your data with any entity outside the EEA, we will put appropriate legal frameworks in place, notably controller-to-controller (2004/915/EC) and controller-to-processor (2010/87/EU) Standard Contract Clauses approved by the European Commission, in order to cover such transfers (Articles 44 ff. GDPR).
- Strategic Partners
- Subject to your prior consent, your personal data may be transferred to, stored, and further processed by strategic partners that work with us to provide our products and services or help us market to customers. Your personal data will only be shared by us with the partners in order to provide or improve our products, services and advertising.
- Service Providers
- We may share your personal data with companies which provide services on our behalf, such as hosting, maintenance, support services, email services, marketing, auditing, fulfilling your orders, processing payments, data analytics, providing customer service, and conducting customer research and satisfaction surveys.
- Corporate Affiliates and Corporate Business Transactions
- We may share your personal data with all Company’s affiliates. In the event of a merger, reorganization, acquisition, joint venture, assignment, spin-off, transfer, or sale or disposition of all or any portion of our business, including in connection with any bankruptcy or similar proceedings, we may transfer any and all personal data to the relevant third party.
- Legal Compliance and Security
- It may be necessary for us – by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence – to disclose your personal data. We may also disclose your personal data if we determine that, due to purposes of national security, law enforcement, or other issues of public importance, the disclosure is necessary or appropriate.
We may also disclose your personal data if we determine in good faith that disclosure is reasonably necessary to protect our rights and pursue available remedies, enforce our terms and conditions, investigate fraud, or protect our operations or users.
- Data Transfers
- Such disclosures may involve transferring your personal data out of the European Union to the following country: Japan, and United States of America. These countries may change due to changes in the business environment.
Such transfer may take place for the purpose such as personnel evaluation of employees, processing of salaries and reimbursement expenses, and contracts with business partners. For each of these transfers, we make sure that we provide an adequate level of protection to the data transferred, in particular by entering into standard contract clauses as defined by the European Commission decisions 2001/497/EC, 2002/16/EC, 2004/915/EC and 2010/87/EU.
5. Our Records of Data Processes
We handle records of all processing of personal data in accordance with the obligations established by the GDPR (Article 30), both where we might act as a controller or as a processor. In these records, we reflect all the information necessary in order to comply with the GDPR and cooperate with the supervisory authorities as required (Article 31 GDPR).
6. Security Measures
We process your personal data in a manner that ensures their appropriate security, including protection against unauthorised or unlawful processing, accidental loss, destruction or damage.
We use appropriate technical or organisational measures to achieve this level of protection (Article 25(1) and 32 GDPR).
7. Notification of Data Breachea to the Competent Supervisory Authorities
In case of breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed, we have the mechanisms and policies in place in order to identify it and assess it promptly. Depending on the outcome of our assessment, we will make the requisite notifications to the supervisory authorities and communications to the affected data subjects, which might include you (Articles 33 and 34 GDPR).
8. Processing Likely to Result in High Risk to Your Rights and Freedoms
We have mechanisms and policies in place in order to identify data processing activities that may result in high risk to your rights and freedoms (Article 35 GDPR). If any such data processing activity is identified, we will assess it internally and either stop it or ensure that the processing is compliant with the GDPR or that appropriate technical and organizational safeguards are in place in order to proceed with it.
In case of doubt, we will contact the competent Data Protection Supervisory Authority in order to obtain their advice and recommendations (Article 36 GDPR).
9. Your Rights
You have the following rights regarding personal data collected and processed by us.
- Information regarding your data processing: You have the right to obtain from us all the requisite information regarding our data processing activities that concern you (Articles 13 and 14 GDPR).
- Access to personal data: You have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and certain related information (Article 15 GDPR).
- Rectification or erasure of personal data: You have the right to obtain from us the rectification of inaccurate personal data concerning you without undue delay, and to complete any incomplete personal data (Article 16 GDPR). You may also have the right to obtain from us the erasure of personal data concerning you without undue delay, when certain legal conditions apply (Article 17 GDPR).
- Restriction on processing of personal data: You may have the right to obtain from us the restriction of processing of personal data, when certain legal conditions apply (Article 18 GDPR).
- Object to processing of personal data: You may have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you, when certain legal conditions apply (Article 21 GDPR).
- Data portability of personal data: You may have the right to receive your personal data in a structured, commonly used and machine-readable format, and have the right to transmit those data to another controller without our hindrance, when certain conditions apply (Article 20 GDPR).
- Not to be subject to automated decision-making: You may have the right not to be subject to automated decision-making (including profiling) based on the processing of your personal data, insofar as this produces legal or similar effects on you, when certain conditions apply (Article 22 GDPR).
If you intend to exercise such rights, please refer to the contact section.
If you are not satisfied with the way in which we have proceeded with any request, or if you have any complaint regarding the way in which we process your personal data, you may lodge a complaint with a Data Protection Supervisory Authority.
11. Links to Other Sites
We may propose hypertext links from the website on which this policy is stated to third-party websites or internet sources. We do not control and cannot be held liable for third parties’ privacy practices and content. Please read carefully their privacy policies to find out how they collect and process your personal data.
[Teijin Frontier Group GDPR secretariat]