1. Types of Personal Data We Process

The types of personal data we process are as follows:

Customers’ Personal Data

We will process the personal data collected from customers including: name, organization, job title, address, email address, phone number, contact history, order history, information selection choices, and product usage information and other information necessary for customer management.

Business Partners’ Personal Data

We will process the personal data collected from business partners including: name, company name, address, department, job title, contact preferences, and other information necessary for management of business partners.

Personal Data of Officers, Employees, etc.

We will process the personal data collected from officers, employees, etc., including: name (including legal and preferred names), date of birth/age, gender, contact details (home address, home phone number, personal mobile phone number and personal email address), passport details, interview feedback, position within organization and working arrangement, employment history, travel and expenses information, and other information necessary for employment management.

Website Visitors and Online Users

We will process the personal data that is automatically collect when you visit our websites or use our online services including: internet protocol (IP) address, your login data; browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our websites or online services. To learn more about our use of cookies or similar technologies, please reference ourcookie policy.

2. How is Your Personal Data Collected?

We will collect your personal data in the following ways:

1.Information that you provide to us:This includes information about you that is provided by you when filling in forms or when you are communicating with us, whether face-to-face, by phone, email or otherwise;

2.Information we collect or generate about you:This includes data from and about you through automated technologies or interactions. As you interact with our websites, we will automatically collect technical data about your equipment as well as your browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see ourcookie policy for further details; and

3.Information we obtain from other sources:This includes data provided to us by our affiliates and subsidiaries, third-party service providers, agencies or other publicly available sources where applicable.

Please note that any personal data that you are required to provide is indicated in the relevant forms that you complete. In cases where the provision of personal data is mandatory, we are not able to provide our products and/or services to you if the relevant information is not provided.

3. Purposes and Legal Bases for Processing

The purposes of processing personal data we assume and legal basis for the processing are as follows:

Customers’ Personal Data

We will process customers’ personal data for the following purposes and on the legal bases:

Business Partners’ Personal Data

We will process business partners’ personal data for the following purposes and on the legal bases:

Personal Data of Officers, Employees, etc.

We will process the personal data of officers, employees, etc., for the following purposes and on the legal bases:

For more details regarding our legitimate interests, please contact us via the contact information provided below.

Please note that we do not make decisions that may affect you legally or in a similarly significant manner based solely on automated processing.

Website Visitors and Online Users

We will process the personal data of our website visitors or users of our online services for the following purposes and on the legal bases:

4. Sharing of Personal Data with Third Parties

We will share your personal data with the following persons and entities in order to achieve the purposes of processing described in “3. Purposes and Legal Bases for Processing” above:

· Service providers, including IT infrastructure service providers, customer relationship management service providers, website hosting and security service providers and payment service providers; and

· Third parties that provide information collection modules to analyze your visits and other activities on our websites.

5. International Transfer

We may transfer your personal data to countries/territories outside the EEA/UK, where the third parties listed in “4. Sharing of Personal Data with Third Parties” above are located, including Japan and the US.

When we transfer personal data to countries that are not deemed by the EU and/or the UK to provide an adequate level of data protection, we will protect your personal data through appropriate safeguards based on: the European Commission’s Standard Contractual Clauses (EU SCC) for the EU, the International Data Transfer Agreement (IDTA) or the International Data Transfer Addendum to the EU SCC (Addendum) for the UK, etc.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA and/or the UK.

6. Retention Period

We will retain your personal data until the purpose of processing thereof has been achieved. When the purpose of processing has been achieved, we shall delete the relevant personal data without delay. However, we will retain your personal data beyond such period where we are required to do so by applicable laws and regulations.

7. Your Rights

You have the right to ask us: for a copy of your personal data, to correct or delete your personal data, to restrict (stop any active) processing of your personal data and to send you a copy of the personal data you have provided to us in a structured, machine readable format. Please note that these rights are subject to exceptions under the applicable laws.

You also have the right to object at any time to the processing of your personal data that is based on our legitimate interests, including “profiling” (analyzing or predicting behavior based on your information). When we process your personal data for direct marketing purposes, you have an absolute right to opt out of such processing.

Wherever we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. Such withdrawal does not affect the lawfulness of any processing performed pursuant to the consent given prior to the withdrawal.

To exercise any of these rights, please contact us via the contact information provided below.

In addition, you also have the right to lodge a complaint with a supervisory authority in the member state of the EEA or the UK where you have a habitual residence or a place of work or where the alleged infringement of the applicable data protection laws took place.

8. Cookies and Similar Technologies

We will use “cookies”, which are a mechanism to collect, record and manage the information of users when they visit websites, in order to enhance your convenience on the websites operated by us. You are advised to understand in advance that, if your computer is set to block cookies, some of the various services provided may be unable to be used.

To learn more about our use of cookies or similar technologies, please check ourcookie policy.

9. Contact

If you have any comments or questions concerning this Policy or our processing of personal information, etc., please contact us using the following form.

Contact Us

1. Categories and Sources of Personal Information We Collect

The categories and sources of personal information we have been collecting and using within the past twelve (12) months are as follows:

Customers’ Personal Information

We will process (i) the identifiers collected from customers including: name, organization, job title, address, email address, phone number and (ii) commercial information collected from customers and/or Technology Partners including: contact history, order history, information selection choices, and product usage information.

Business Partners’ Personal Information

We will process the identifiers collected from business partners including: name, company name, address, department, job title, contact preferences, and other information necessary for management of business partners.

Personal Information of Officers, Employees, etc.

We will process (i) the identifiers collected from officers, employees, etc. including: name (including legal and preferred names), date of birth/age, gender, contact details (home address, home phone number, personal mobile phone number and personal email address), passport details, and other information necessary for employment management and (ii) professional or employment-related information collected from officers, employees, etc. including: interview feedback, position within organization and working arrangement, employment history, travel and expenses information, and other information necessary for employment management.

Website Visitors and Online Users

We will process internet or other similar network activities collected automatically from your devices when you access our websites or online services, including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices that you use to access our websites or online services.

2. Purposes of Use of Personal Information

The purposes of use we assumed for each category of personal information are as follows:

Customers’ Personal Information

We will use customers’ personal information acquired from such customers, for the following purposes:

1. Communicating with customers about their account, product updates and information;
2. Improving customers user experience;
3. Performing services pertaining to sale, delivery, billing, payment, etc., of products or services;
4. Preparing statistical information through aggregating information such as address, application history or use history of the relevant services, to improve products or services, as well as to develop and market new products and services; and
5. Responding to customers who make inquiries or comments regarding products, advertisements, or others.

Business Partners’ Personal Information

We will use business partners’ personal information acquired from such business partners, for the following purposes:

1. Fulfilling obligations and exercising rights pertaining to transactions;
2. Making announcements regarding products, services or events;
3. Sending products, samples, documents, or information;
4. Preparing statistical information through aggregating information such as address, application history or use history of the relevant services, etc., to improve the products and services, as well as to develop and market new products and services; and
5. Responding to business partners who make inquiries or comments regarding products, advertisements, or others.

Personal Information of Officers, Employees, etc.

We will use the personal information of officers, employees, etc., acquired from such officers, employees, etc., for the following purposes:

1. Performing screening for recruitment of and administrative procedures for the people who have applied for recruitment or internships;
2. Performing labor and employment management of employees and other procedures required by us to conduct its business;
3. Providing information and sending items for distribution to the family members of employees;
4. Corresponding with, providing information to, and sending items for distribution to retired employees; and
5. Responding to officers, employees, etc., who make inquiries or comments.

Website Visitors and Online Users

We will process personal information automatically collected when you visit our websites or use our online services for the following purposes:

1. Allowing us to deliver our websites to you and to provide specific services that you request from us;
2. Collecting information about how visitors use our websites which helps us with site analysis and improvements;
3. Remembering your choices or preferences, such as information on online forms or previous orders; and
4. Building a profile of your interests in order to show you relevant adverts on any other website.

3. Disclosure of Personal Information to Third Parties

We have disclosed personal information for business purposes within the past twelve (12) months to the following parties:

*We have not shared or sold personal information to third parties in the past twelve (12) months.

4. Selling or Sharing Personal Information of Persons Under 16 Years of Age

Our websites or service is not intended for use by children under the age of 13. If the personal information we collect is found to contain the information of children under the age of 13, we will immediately delete the personal information.

We do not have actual knowledge that we sell, share, have sold or have shared the personal information of any persons between 13 and 16 years of age; however, if we plan to do so in the future, the selling or sharing of personal information will not be done unless the consumers between 13 and 16 years of age have affirmatively authorized it.

5. Our Use and Disclosure of Sensitive Personal Information

Without your consent, we do not use or disclose your sensitive personal information for purposes other than those specified in Section 7027, subsection (m) of the CCPA Regulation.

6. Your Rights Under the CCPA

Under the CCPA, you have the following rights:

1. The right to know about personal information collected, disclosed, or sold:
   You have the right to request that we disclose the following information to you regarding our collection and use of your personal information over the past 12 months:
   • Categories of personal information we collect about you;
   • Categories of sources of collection;
   • Business or commercial purposes for collecting or selling personal information;
   • Categories of third parties to which we share personal information;
   • Specific personal information we collect about you; and
   • Categories of personal information sold or disclosed by us and the category of recipients.
2. The right to request deletion of personal information:

   You have the right to request that we delete any of your personal information that we have collected from you. Please note that such right is subject to certain exceptions under the CCPA. When we determine to maintain your personal information after your request, we will inform you of the exception applied to your case.

3. The right to correct inaccurate personal information:

   You have the right to request that we correct inaccurate personal information that we maintain about you.

4. The right to opt-out of the sale of personal information:

   We have not sold your personal information in the previous twelve (12) months, but, if we decide to do so in the future, we will inform you that your personal information will be sold and that you have the right to opt out of that sale.

5. The right to opt-out of the sale of personal information:

   We do not use or disclose sensitive personal information for reasons other than those set forth in section 7027, subsection (m) of the CCPA Regulation, but, if we decide to do so in the future, you have the right to limit the use or disclosure of sensitive personal information by us.

6. The right to non-discrimination for exercising your rights:

   We do not discriminate against you due to the exercise of any of your rights under the CCPA.

7. Procedures for Request to Exercise Your Rights

To exercise any of your rights, please contact us via the contact information provided below.

However, please note that, when we process your request, we will need information from you to confirm you are a California resident and to verify your identity.

If you decide to submit a request through an authorized agent, you are required to provide us with a power of attorney directly or via the agent.

When exercising the right to opt-out of sharing, please contact us using any of the following methods or through the link below. Once we receive such a request, it will be handled according to the related laws and regulations within a reasonable timeframe and manner.

8. Cookies and Similar Technologies

We will use “cookies”, which are a mechanism to collect, record, and manage the information of users when they visit websites, in order to enhance your convenience on the websites operated by us. You are advised to understand in advance that, if your computer is set to block cookies, some of the various services provided may be unable to be used.

To learn more about our use of cookies or similar technologies, please check ourcookie policy.

9. Contact

If you have any comments or questions concerning this Policy or our processing of personal information, etc., please contact us using the following form.

Contact Us