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SolidGear Privacy Policy

[SolidGear Corporation, Kanagawa, Japan] (“SolidGear”) is committed to the protection of personal data and privacy rights.

This SolidGear Privacy Policy consists of the SolidGear Personal Data Protection Basic Policy and the Policy for the Handling of Personal Data on SolidGear Websites. It describes how SolidGear processes personal data in compliance with applicable data protection and other laws and globally accepted data protection principles including the [Japanese Act on the Protection of Personal Information] and the Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation, “GDPR”).

This Privacy Policy applies to all activities where SolidGear processes personal data of individuals excluding SolidGear’s personnel, which is governed by internal regulations. Data are personal, if the information contained therein relates to an identified individual or an individual that can be identified, directly or indirectly, by reference to an identifier or a combination of identifiers. Processing means any operation or set of operations on personal data whether or not by automated means and regardless whether electronically, physically in paper or any other form.

This Privacy Policy supplements the applicable data protection and other laws without replacing them. In case of a conflict or where an applicable law has stricter or additional requirements the law will take precedence over this Privacy Policy.

By accessing, browsing, or using SolidGear’s website, you agree to the Terms of Use of the SolidGear Website, this SolidGear Privacy Policy and the SolidGear Cookie Policy that supplements this Privacy Policy in respect of the use of Cookies on the SolidGear Website.

SolidGear Personal Data Protection Basic Policy

1. Scope of Application

This SolidGear Personal Data Protection Basic Policy is part of SolidGear’s Privacy Policy and describes the general rules how [SolidGear Corporation, Knagawa, Japan] (“SolidGear”) processes personal data.

2. Personal Data Processing Principles

SolidGear processes personal data in accordance with the following principles:

  1. Lawfulness, Fairness and Transparency
    Personal data are processed on basis of the applicable legal permission and in compliance with applicable laws (lawfulness), in consideration of the interests of the affected individual (fairness) and together with reasonable provision of information including the identity of the legal person that controls and is accountable for the processing of personal data (data controller), the purpose of the processing, associated risks, and necessary safeguards (transparency).
  2. Purpose Limitation
    Personal data are processed for a specified, explicit and legitimate purpose and are no further processed in a manner that is incompatible with that purpose.
  3. Data Minimization
    Personal data are adequate, relevant and limited to what is necessary in relation to the purpose for which they are processed.
  4. Accuracy
    Personal data are kept accurate and, where necessary, up to date; every reasonable step is taken to ensure that personal data that are inaccurate in respect to the purpose for which they are processed, are erased or rectified without delay.
  5. Storage Limitation
    Personal data are kept in a form which permits identification of the affected individual for no longer than necessary for the purpose for which the personal data are processed.
  6. Integrity and Confidentiality
    Personal data are processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures. Personal data protection is taken into account when new processes are planned and implemented. Technical and organizational measures at SolidGear are continuously adjusted.

3. Business Partner Data

In course of its business operations, SolidGear processes data of its customers, suppliers, agents, providers, sub-contractors, consultants, advisors, journalists, users that access, browse or otherwise use SolidGear’s website or third party websites on which SolidGear has posted advertisements and other current and potential business partners (“Business Partners”). These data may also include personal data of Business Partners and in case Business Partners are corporations, of individuals affiliated with Business Partners.

  • 3.1 Data Categories

    Data processed include first, middle and last name, academic title, professional status, position, postal address, e-mail address, telephone number, login-in data, online identifiers, IP addresses and other personal data reasonably related to the business relationship with SolidGear.

  • 3.2 Data Sources

    Personal data are obtained through direct and indirect online and offline sources. Direct sources include business cards, e-mails, facsimiles, letters, surveys, data collected via active entries on SolidGear’s website and other electronic or non-electronic communication and interaction between SolidGear and an individual in course of a potential or existing business relationship. Indirect sources include publicly available data collected by SolidGear, data of users that access, browse or otherwise use SolidGear’s website or third party websites on which SolidGear has posted advertisements and data received from third parties including TDK Group Companies and other Business Partners in compliance with applicable laws.

  • 3.3 Processing Purposes

    Personal data are processed for SolidGear’s business operations, including Business Partner relationship management, research and development, manufacturing, enterprise resource planning, data analysis for supply, online and offline marketing and sales activities, market observance and orientation, provision of product and service information, making and answering requests and inquiries, making and accepting quotes, offers, and any communication, cooperation, and other activities reasonably related to SolidGear’s business operations.
    Data analysis activities may comprise automated processing including the profiling of individuals affiliated with Business Partners. SolidGear may in particular combine data from the above-described direct and indirect online and offline sources and analyze or predict preferences, interests, reliability, behavior, location, movements and other activities of Business Partners and in case Business Partners are corporations, of individuals affiliated with Business Partners. SolidGear conducts such analysis activities to understand the needs of its Business Partners, in particular to enhance, develop, present and provide new products to them, online and offline.
    Online activities include targeted advertisements on SolidGear’s website and in user accounts, online newsletters by e-mail or other electronic means, promotional campaigns and other activities reasonably related to SolidGear’s business operations.
    Offline activities include the delivery of marketing and other promotional material including samples by mail and other activities reasonably related to SolidGear’s business operations.

  • 3.4 Permission

    Personal data are processed in compliance with applicable laws on basis of the applicable legal permission, in particular the initiation and performance of a contract, where the individual has given consent to the processing, where the processing is necessary for compliance with a legal obligation to which SolidGear is subject to and where the processing of personal data is in the legitimate interest of SolidGear. Legitimate interests are the development, nurturing and enhancement of existing and initiation of new business relationships and any activities related thereto to pursue SolidGear’s business operations.

4. Recruitment Data

In course of its business operations, SolidGear processes data related to the recruitment of new personnel. These data may also include personal data of individuals.

  • 4.1 Data Categories

    Data processed include first, middle and last name, academic title, professional status, position, birth date, personal status, work history, current position and former positions, education, postal address, e-mail address, telephone number, login-in data, online identifiers, IP addresses and other personal data reasonably related to the recruitment of new personnel.

  • 4.2 Data Sources

    Personal data are obtained through direct and indirect online and offline sources. Direct sources include business cards, job applications, e-mails, facsimiles, letters, meetings, entries on SolidGear’s website and other electronic or non-electronic communication and interaction between an individual and SolidGear in course of a job application. Indirect sources include publicly available data, data of users that access, browse or otherwise use SolidGear’s website or third party websites on which SolidGear has posted advertisements and data received in compliance with applicable laws from third parties including TDK Group Companies and other Business Partners in course of a recruitment process, e.g. recruiting agencies and HR service providers.

  • 4.3. Processing Purposes

    Personal data are processed for searching and recruiting new personnel for SolidGear’s business operations including any activities reasonably related thereto.

  • 4.4. Permission

    Personal data are processed in compliance with applicable laws on basis of the applicable legal permission, in particular where necessary for the job application and the initiation of an employment relationship with SolidGear, where the individual has given consent to the processing, where the processing is necessary for compliance with a legal obligation to which SolidGear is subject and where the processing of personal data is in the legitimate interest of SolidGear. Legitimate interests are the processing of the job application to find and recruit skilled personnel for SolidGear and TDK Group Companies and any activities related thereto.

5. Website Data and Cookies

For information about the processing of personal data on SolidGear’s website and third party websites, please refer to Policy for the Handling of Personal Data on SolidGear Websites and to the SolidGear Cookie Policy.

6. Retention Periods

Personal data will be removed from SolidGear’s systems and records and/or steps are taken to anonymize data if processing is no longer required for the original purpose unless it is necessary to keep personal data to comply with a legal obligation to which SolidGear is subject, e.g. statutory retention periods under applicable laws including commercial and tax laws or where SolidGear has a legitimate interest to retain information in compliance with applicable laws, e.g. for filing, enforcing or defending legal claims. SolidGear has installed and maintains retention policies in compliance with applicable data protection and other laws.

7. Transfer of Personal Data

SolidGear is part of the TDK Group of Companies with joint business operations (https://www.tdk.com/corp/en/worldwide/index.htm). SolidGear may transfer data including personal data to other TDK Group Companies, Business Partners, courts, law enforcement agencies, government authorities, other public bodies and other third parties, which may have access to and/or process personal data. Transfers are made on a need to know basis in compliance with applicable laws and agreements with Business Partners.

  • 7.1 Transfer to TDK Group Companies

    Purpose of data transfers to other TDK Group Companies (https://www.tdk.com/corp/en/worldwide/index.htm) is the support the business operations of SolidGear within the TDK Group of Companies and the joint utilization of data. This may include joint business operations and the outsourcing of internal functions and the utilization of external resources, e.g. procurement and manufacturing, marketing, data analysis, Business Partner relationship management, research and development, education, administration, IT functions, HR functions, compliance with corporate organization and corporate governance rules and other activities reasonably related to SolidGear’s business operations. Categories of personal data transferred are described in 3.1 and 4.1 above.

    TDK Group Companies that act as service providers are contractually bound to take appropriate technical and organizational security measures to safeguard and process personal data only as instructed by SolidGear. The same applies to any sub-providers of SolidGear’s service providers.

  • 7.2 Transfer to Business Partners

    Purpose of data transfers to Business Partners is to outsource internal functions and utilize external resources, e.g. IT services, HR, recruiting, marketing activities, marketing data analysis, administration of campaigns, offline and online advertisement, publishing, design, legal, tax, financial advisory services and other activities reasonably related to SolidGear’s business operations.

    Business Partners that act as service providers for SolidGear are contractually bound to take appropriate technical and organizational security measures to safeguard and process personal data only as instructed by SolidGear. The same applies to any sub-providers of Business Partners’ service providers.

  • 7.3 Transfer to government authorities, courts, law enforcement agencies

    Purpose of data transfer to government authorities, courts, law enforcement agencies and other public bodies is to comply with obligations to which SolidGear is subject to under applicable laws, e.g. -transfer and disclosure obligations under social security law, civil procedure law, tax, import and export laws.

8. Transfer of Personal Data to other Countries

To the extent personal data are transferred to and processed in other countries than where SolidGear is established, SolidGear transfers personal data in compliance with applicable laws and has established appropriate safeguards by means of data processing and data transfer agreements that oblige the recipient in the other country to establish and adhere to an adequate level of data protection.

9. Information Obligations

In compliance with applicable laws, SolidGear informs individuals about its personal data processing activities as described in the SolidGear Privacy Policy and the TSolidGear Cookie Policy. SolidGear provides amongst others on and offline references to the SolidGear Privacy Policy on SolidGear’s website, electronic or non-electronic communication with individuals and electronic or non-electronic business documents to promote its data privacy activities.

10. Consent and Withdrawal of Consent

Where required under applicable data protection and other laws, SolidGear processes any data only after consent. Providing consent and data is voluntary. Before obtaining consent, SolidGear will duly inform each individual about the respective processing activity. Without providing data, an individual may not be able to engage with SolidGear in respect of SolidGear’s business operations.

A consent can be withdrawn at any time with future effect by e-mail to sg_info@tdk.co.jp or by sending a withdrawal notice to the contact stated under 12. below. A withdrawal will not affect the lawfulness of the processing prior to the withdrawal.

11. Rights of Individuals

Where SolidGear processes personal data of individuals, each individual may exercise its rights under applicable laws.

Any rights can be exercised by sending an e-mail to sg_info@tdk.co.jp or to the contact details stated under 12. below.

In addition, each individual may lodge a complaint with a competent data protection supervisory authority.

Under the applicability of the Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation, “GDPR”) any individual may exercise towards SolidGear the following rights:

  • Right of Access,
  • Right of Rectification,
  • Right to Erasure,
  • Right to restriction of processing,
  • Right to object to processing,
  • Right to data portability,
  • Where SolidGear processes personal data for direct marketing purposes, each individual has the right to object at any time to the processing of its personal data for direct marketing purposes, which includes profiling to the extent related to marketing purposes.

12. SolidGear Personal Data Protection Organization

[SolidGear Corporation 2-3-9 ShinYokohama Kohoku-ku, Yokohama, Kanagawa, 222-0033 Japan] controls and is accountable for the processing of personal data within its operations (data controller).

SolidGear maintains a personal data protection organization, which serves as point of contact for all inquiries regarding the processing of personal data by SolidGear.

[Information Security Office of SolidGear Corporation
2-3-9 ShinYokohama
Kohoku-ku
Yokohama
Kanagawa 222-0033
Japan
sg_info@tdk.co.jp

13. Change Management

SolidGear may change the SolidGear Personal Data Protection Basic Policy, the Policy for the Handling of Personal Data on SolidGear Websites and the SolidGear Cookie Policy at any time and without explicit notice. The enactment date and the date of the last revision is shown in the respective document and any prior versions can be requested from SolidGear.

Policy for the Handling of Personal Data on SolidGear Websites

1. Scope of Application

This Policy for the Handling of Personal Data on SolidGear Websites is part of SolidGear’s Privacy Policy.

It describes how [SolidGear Corporation, Kanagawa, Japan] (“SolidGear”) processes data of users that access, browse or otherwise use SolidGear’s website or third party websites on which SolidGear has posted advertisements (“Users”). These data include also personal data that Users actively send, transmit or otherwise provide on SolidGear’s website and that SolidGear collects or otherwise obtains via cookies.

For detailed information about the use of cookies please refer to the SolidGear Cookie Policy.

2. Purposes

2.1 Services

SolidGear processes data including personal data for providing the following services in connection with its business operations (“Services”):

  1. 2.1.1 User Accounts

    After registration, SolidGear offers personalized User accounts that allow access to product information and services and other information reasonably related to SolidGear’s business operations.

  2. 2.1.2 Inquiries and Requests

    SolidGear offers the possibility to make online inquiries and requests regarding its products and services and strives to revert to the inquirer in due time.

  3. 2.1.3 Newsletters

    After registration, SolidGear offers online newsletters by e-mail or other electronic means. Newsletter comprise information about SolidGear’s products, services, events, seminars, exhibitions, campaigns and other information reasonably related to SolidGear’s business operations.

  4. 2.1.4 Information Download

    After registration, SolidGear offers information about products and services and other information reasonably related to SolidGear’s business operations.

  5. 2.1.5 Promotional Campaigns

    SolidGear invites Users to take part in online promotional and other campaigns to bring SolidGear’s products and services and other information reasonably related to SolidGear’s business operations to the attention of current and potential customers and the wider public. SolidGear asks individuals to provide their comments and opinions about SolidGear’s products and services. SolidGear may also send materials and samples and other giveaways and information offline to Users participating in the campaigns.

  6. 2.1.6 Recruitment

    SolidGear may offer information about job vacancies of any kind on its website and invite individuals to file applications via SolidGear’s website.

  7. 2.1.7 PC and Mobile Application Software

    SolidGear offers software for specific services and functions alone or in together with SolidGear’s products, services and other activities reasonably related to SolidGear’s business operations. SolidGear provides certain support services like software and firmware support. Software applications may create crash reports that help SolidGear and third party software developers to resolve any issues with the software.

Where required under applicable data protection and other laws, SolidGear processes data only after the consent of the User. Providing consent and data is voluntary. Before obtaining any consent, SolidGear will duly inform each individual about the respective processing activity. Without providing data, a User may still access, browse or otherwise use SolidGear’s website but may not able to benefit from some or all of the Services.

Regarding the withdrawal of a consent and other rights of Users, please refer to the SolidGear Personal Data Protection Basic Policy.

2.2 Marketing

For its marketing activities SolidGear processes data that Users have actively sent, transmitted or otherwise provided on SolidGear’s website for Services (see 2.1 above) and that SolidGear has collected or otherwise obtained via cookies from its and third party websites where SolidGear has posted advertisements. For detailed information about the use of cookies please refer to the SolidGear Cookie Policy.

SolidGear analyses such data alone or in combination or together with other data including personal data SolidGear has lawfully received. Data analysis activities may comprise automated processing including profiling. SolidGear may in particular combine data from the above-described direct and indirect online sources and offline sources and analyze or predict preferences, interests, reliability, behavior, location, movements and other activities of Users. SolidGear conducts such analysis to understand the needs of the Users, in particular to enhance, develop, present and provide new products to them, online and offline.

Online activities include targeted advertisements on SolidGear’s website and in User accounts, online newsletters by e-mail or other electronic means, promotional campaigns and other activities reasonably related to SolidGear’s business operations.

Offline activities include the delivery of marketing and other promotional material including samples by mail and other activities reasonably related to SolidGear’s business operations.

Where required under applicable data protection and other laws, SolidGear processes data only after the consent of the User. Providing consent and data is voluntary. Before obtaining any consent, SolidGear will duly inform each individual about the respective processing activity. Without providing data, a User may still access, browse or otherwise use SolidGear’s website but may not able to benefit from some or all of the Services.

Regarding the withdrawal of a consent and further rights of Users, in particular to object at any time to the processing of its personal data for direct marketing purposes, which includes profiling, please refer to the SolidGear Personal Data Protection Basic Policy.

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