Tomoegawa Europe B.V. (“the Company”) complies with the General Data Protection Regulation (GDPR) and applicable laws and ordinances, including related laws enforced in the Netherlands (“Privacy Laws and Ordinances”), in handling the personal information collected from you, as well as collects and uses personal information appropriately.
This Privacy Notice explains the types of personal information the Company gathers from you, why the Company uses personal information and its legal grounds, businesses that share personal information with the Company, storage of personal information, security measures taken by the Company, the rights you can exercise regarding the use of personal information by the Company, how changes may be made to this Privacy Notice, and who to contact at the Company.
The definition of the terms used in this Privacy Notice is as follows.
| Tomoegawa Group | Companies which TOMOEGAWA CORPORATION has 50% or more of direct or indirect voting rights (excluding holding companies) |
| Personal information | Means any information relating to an identified or identifiable natural person which will be used by the Company. |
| GDPR | General Data Protection Regulation |
| Use | Means any operation or set of operations which is performed on personal information, whether or not it is performed by automated means. The operations refer to 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. |
| Company’s website | https://www.tomoegawa.nl/ |
| You | Means users who provide personal information to the Company, etc. through the inquiry form on the Company’s website or another method, pertaining to the products and services of the Company, etc. or the recruitment activities of the Company, etc. |
| Adequacy decision | Means that the European Commission recognizes that a specified third country, territory, international organization, etc. ensures an adequate level of protection of personal information. |
| Cookie | A system by which information about the user who accesses the Company’s website is temporarily recorded on the user’s device. This technology allows the Company to collect data, such as the history of the user’s visit to the website and history of the user’s activity on the website. |
The Company may collect your personal information in a variety of situations, including receiving inquiries or orders from you regarding the Company’s products and services. The Company collects the following personal information:
・Name of your group or organization, your address, your name, your contact information such as e-mail address
・History of access of the Company’s website (including name of internet service provider, access date and time, and IP address). The Company’s website uses cookies.
The Company does not collect sensitive personal information, such as genetic and health data.
The Company will use the personal information it collected from you on the following legal grounds and for the following purposes:
・The Company needs to handle the information to implement a contract to which it is a party, or the Company needs to handle the information to execute procedures based on your request prior to concluding a contract:
For example, the Company will use your personal information for delivering the Company’s products (including product samples), providing services, or for purposes related to the payment of the Company’s products and services.
・The Company needs to handle the information for legitimate interests pursued by the Company or a third party:
For example, the Company will use your personal information for providing information on the Company’s products, services or exhibits, responding to complaints regarding the Company’s products and services, for the Company’s marketing activities, or for responding to people who have applied for jobs with the Company.
Notwithstanding the above, the Company may use your personal information if the Company gathers your information based on your consent, or if the Company needs to handle the information in order to comply with its legal obligations.
If the Company uses your personal information for purposes other than the above, it will provide additional information related to such purposes.
Your personal information that the Company collected will be shared within the Tomoegawa Group and among its partner businesses in order to support the above purposes. For example, your personal information will be shared when the Tomoegawa Group or its partner business directly delivers to you the Company’s product that you ordered, or when the Company and the Tomoegawa Group jointly respond to your complaint.
The Tomoegawa Group and its partner businesses to which your personal information will be transferred are located in Japan, the United States of America (“USA”), the People’s Republic of China (“PRC”), and the Republic of China (“ROC”). While Japan and the European Commission have agreed that an adequacy decision would enter into force for Japan, the date of entry into force is undecided. At this point in time, there are no prospects for an adequacy decision for the USA, PRC, and ROC. The Company will transfer personal information to these countries (for Japan, until the adequacy decision enters into force) upon taking appropriate protective measures sought by Article 46 of GDPR.
The Company will not retain the personal information it collected for a period beyond the limit necessary for fulfilling the purposes for which it was collected. In addition, if the personal information becomes unnecessary in light of the purposes for which it was collected, the Company will erase the relevant personal information.
If the use of personal information is based on consent, you have the right to withdraw at any time your consent regarding your personal information.
You have the right to request access to your personal information. Accordingly, you may receive a copy of the personal information the Company maintains about you.
You have the right to request corrections to your personal information that the Company collected. Accordingly, you may correct incomplete or inaccurate personal information about you that the Company collected.
You have the right to request deletion of your personal information that the Company collected. Accordingly, you may delete or remove personal information that the Company has continued to use without a legitimate reason.
You have the right to lodge an objection to the Company’s use of your personal information for legitimate interests. In such cases, the Company will terminate the use of your personal information, unless there are compelling legitimate reasons which precede your interests, rights and freedoms, or which relate to establishing, exercising or defending a legal claim.
You have the right to request restrictions on the use of your personal information.
You have the right to request the transfer of your personal information to you or a third party. The Company will provide your personal information in a structured, commonly used and machine-readable format to you or a third party designated by you. This right applies only to information that the Company processed by automated means with your consent regarding the use of personal information or based on a contract between the Company and you.
No fees will be incurred for exercising the above rights. The Company will provide without delay information regarding your request within one (1) month of receiving your request in any circumstances; provided, however, that the period may be extended by up to an additional two (2) months in view of the complexity or numerousness of your request. In such cases, the Company will notify you accordingly within one (1) month of receiving your request.
If your request is clearly unfounded or excessive, or, in particular, if you have made your request repeatedly, the Company will charge a reasonable fee to you or refuse to comply with your request.
In addition to the above rights, you are at any time entitled to file a complaint to a supervisory authority (in particular, a supervisory authority of an EU member state in which you have your address or place of work, or where the GDPR violation took place); provided, however, that the Company asks you to please contact the Company in advance before you seek to make contact with a supervisory authority so that it may have an opportunity to respond to your complaint.
This Privacy Notice may be subject to change due to revisions of Privacy Laws and Ordinances or the circumstances of the Company’s website. If changes are made to this Privacy Notice, they will be posted on the Company’s website to notify you of the changes. The changes will be indicated at the top using track changes. A summary of the changes will also be posted if significant changes are made.
If you have any questions or complaints, or if you wish to exercise your rights in Article 6 of this Privacy Notice, please contact us at the following e-mail address or fax number.
E-mail address: p_privacy@tomoegawa.co.jp
Fax: +81-54-256-4201
