ASAHI INTECC EUROPE B.V. and its affiliates companies (hereinafter referred to as “Company”, “we”, “our” and “us”), part of the ASAHI INTECC Group (“ASAHI INTECC Group”, “we” or “us”) are committed to protect and respect your personal data and your privacy. THIS PRIVACY POLICY (hereinafter referred to as “Privacy Policy”) applies where we are acting as a data controller with respect to your personal data.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

A　Introduction

1. Improvement of internal organization:
   ・We comply with the applicable laws and regulations related to the protection of personal data and the processing of personal data including the General Data Protection Regulation.
   ・We develop the organizations and internal rules to protect the personal data.
   ・We educate all our officers and employees regarding proper management and protection of personal data and thoroughly manage the safety of personal data.
2. Collection and use of personal data:
   ・We will disclose in advance the purpose for collecting and the method of using personal data.
   ・We will collect personal data only to the extent that is necessary to accomplish the purpose for which we are collecting the personal data, which will be explicitly disclosed.
3. Disclosure of personal data to third parties:
   ・We will not disclose your personal data to a third party without unless otherwise specified by law or regulations or based on the consent of that person.
4. Queries regarding personal data:
   ・Where an individual wishes us to have his/her personal data disclosed, corrected, ceased to be used, deleted, or otherwise, we will take prompt action to the extent reasonable after verifying the requesting individual.
5. Continuous improvement:
   ・We continuously review the Privacy Policy by implementing new regulations, internal audit, etc., to assure the safety and correct use of personal data.

B　Purposes of use of personal data

1. Personal data of doctors and other medical practitioners, as well as those affiliated with research institutes are being processed by the Company for the purposes of:
   ・Providing and collecting information about uses of products manufactured and sold by the Company;
   ・Providing and collecting information about quality, safety, and efficacy of products manufactured and sold by the Company;
   ・Researches and studies in the fields of medicine, medical device and industrial machinery;
   ・Providing, collecting, and reviewing medical and other academic information;
   ・Requesting and implementing clinical studies and post-marketing surveillance; and
   ・Notification and reporting to the public offices.
2. Personal data of personnel of business partners are being processed by the Company for the purposes of:
   ・Communication, negotiation, order placement/order acceptance, and payment for conducting business transactions.
3. Personal data of shareholders are being processed by the Company for the purposes of:
   ・Performing legally stipulated duties and responding to execution of shareholders’ rights;
   ・Delivering business reports and other materials, and performing proper communication; and
   ・Management of shareholders, including compilation of shareholder data according to designated criteria as specified in the relevant laws and regulations.
4. Personal data of those who have made inquiries about the Company in its website are being processed by the Company for the purposes of:
   ・Reviewing, investigating, and handling the inquiries and contact information; and
   ・Reviewing, investigating, and handling information for inquirer’s identification.
5. Personal data of lawyers, accountants, tax accountants, and judicial scriveners are being processed by the Company for the purposes of:
   ・Request and consultation required for performing the Company business.
6. Personal data of those of industrial organizations of which the Company is a member are being processed by the Company for the purposes of:
   ・Various communication and reports for performing activities promoted by the organizations.
7. Personal data of job applicants are being processed by the Company for the purposes of:
   ・Selection process and decision of successful/unsuccessful applicants; and
   ・Provision of the Company information, recruitment information, and screening results, and other relevant communication.
8. Personal data of officers, employees, retirees, and their family members are being processed by the Company for the purposes of:
   ・Work attendance, salary payment, proper personnel assignment, performance evaluation, work competence development, welfare system, and other labor management issues;
   ・Reception, implementation, and management of various procedures specified in the internal regulations;
   ・Notification concerning business affairs; and
   ・Notification and reporting to the public offices.
9. Your personal data will be shared between ASAHI INTECC Group to the extent necessary for the aforementioned purposes.

C　Legal basis for using your personal data

1. We are not allowed to process personal data if we cannot rely on a valid legal ground. Therefore, we will only process your personal data when:
   ・we have obtained your prior unambiguous consent for the specific purposes;
   ・the processing is necessary to perform our contractual obligations towards you or to take pre-contractual steps at your request;
   ・the processing is necessary to comply with our legal or regulatory obligations;
   ・the processing is necessary to protect your vital interests or those of another natural person;
   ・the processing is necessary to perform the task carried out in the public interest or in the exercise of official authority vested; and/or
   ・the processing is necessary for our legitimate interests except where they are overridden by your interests or fundamental rights and freedoms.Examples of such legitimate interests include:
   1. to meet our corporate and social responsibility objectives;
   2. to protect the security of our IT systems, architecture and networks;
   3. to perform analytics so that we can improve, maintain and manage our products and services to meet market expectations;
   4. to engage in product development to better our products and services and will use your feedback from surveys;
   5. to enable us to make corporate transactions, such as any merger, sale, reorganization, transfer of our assets or businesses, acquisition, bankruptcy or similar event; or
   6. for other legitimate business purposes permitted by the applicable laws.
2. Personal data that we obtain from third parties:
   Most personal data we have received from you. From time to time, we may receive your personal data from third parties who treat you, but only where we have confirmed that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal data to us.

D　Providing your personal data to others

We may disclose your personal data to the following third parties, among others, for the purposes described here:

・Vendors or other subcontractors with whom we have a business relationship and who provide products and/or services to us so that we can provide our products and/or services to you (such as warehousing and delivery, maintenance and servicing partners, software development, website hosting and management);
・Payment processing companies, credit reference agencies and anti-fraud screening service providers in order to process payments and (where necessary) to carry out fraud-screening;
・With our professional accountants and legal attorneys for the purposes of obtaining commercial, financial or legal advice;
・In exceptional circumstances, personal data may be shared with third parties, such as the police and regulatory authorities, to protect our rights, property, or the safety of our customers, staff and assets;
・In the event that we sell any business assets, personal data may be disclosed to a potential buyer. In these circumstances, we will make reasonable attempts to ensure the buyer will be bound by the terms of the Privacy Policy; or
・We may also disclose your personal data if it is necessary to comply with a legal obligation in any jurisdiction, including where that obligation arises as a result of a voluntary act or decision by us.

E　Transfer of personal data to third countries

Your personal data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country. Specifically, our servers are located in Japan and third party service providers and partners operate around the world. This means that when we collect your personal data we may process it in any of these countries. However, we have taken appropriate safeguards to require that your personal data will remain protected in accordance with the Privacy Policy. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal data between us, which require the Company to protect personal data they process from the European Economic Area in accordance with European Union data protection law.

F　Storage time

We will keep your personal data for as long as we need it for the purpose set out in Section B of the Privacy Policy and in accordance with any retention periods required by the applicable laws and regulations, our internal rule and during the relevant statutes of limitation.
Provided, however, that:

・If you withdraw your consent on which a processing of your personal data is based, we will delete your personal data without undue delay to the extent that the collection and processing of the personal data was based on the withdrawn consent; or
・If you exercise a right to object to the processing of your personal data, we will delete your personal data that we processed for the purpose to which you objected without undue delay, unless another legal basis for processing and retaining this data exists or unless the applicable laws requires us to retain the data.

G　Security

We use appropriate technical and organizational measures to protect the personal data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal data. We take steps to limit access to your personal data to those persons who need to have access to it for one of the purposes in the Privacy Policy. Furthermore, we contractually ensure that any third party processing your personal data equally provide for confidentiality and integrity of your personal data in a secure way.

H　Your Rights

1. Right to withdraw the data protection declaration of consent.
   You have the right to change your mind and withdraw your consent for us processing your personal data at any time. The withdrawal of consent shall not affect the legality of the processing carried out on the basis of the consent until withdrawal.
2. Right to access
   You have the right to obtain confirmation from the Company as to whether or not we processes personal data from you and you also have the right to at any time obtain access to your personal data stored by the Company. To exercise this right you may at any time contact the Company as provided in Section Contacting data protection office of the Privacy Policy.
3. Right to erasure or rectification of your personal data or the right to restriction of processing
   You may have the right to request the erasure and/or rectification of your personal data or the restriction of processing of your personal data. To exercise these rights you may at any time contact us as provided in Section Contacting data protection office of the Privacy Policy.
4. Right to data portability
   You may have the right to receive the personal data concerning you and which you have provided to the Company, in a structured, commonly used and machine-readable format or to transmit those data to another data controller. To exercise this right you may at any time contact us as provided in Section M of the Privacy Policy
5. Right to object
   You have the right to object to the processing of your personal data as further specified in the Privacy Policy.
6. Right to lodge a complaint with supervisory authority
   You have the right to complain to a supervisory authority, in particular in your country where you are staying, working or suspect that an infringement of the applicable laws and regulations against you has taken place.
   In case of infringement in the European Economic Area, the relevant Data Protection Authority is the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

I　Use of this website by minors

We do not intend for our website or online services to be used by anyone under the age of eighteen (18).

J　Automated decision-making

The processing of your personal data is not being applied for automated decision-making (including profiling).

K　Contractual requirement

Providing your personal data is not a statutory or contractual obligation nor a condition to enter into an agreement with you. However, if you choose to not provide the Company with your personal data and/or provide incomplete personal data, please be aware that we may not be able to engage in or continue a contractual relationship with you if your personal data is required for administrative purposes and/or to fulfill statutory requirements of the Company.

L　Changes to the Privacy Policy

We will update the Privacy Policy from time to time to ensure you are promptly informed of our data processing activities. We will keep you updated on any changes to the Privacy Policy through the notice of our web site.

M　Contacting data protection office

If you have any queries about the Privacy Policy or our handling of your personal data in general, or if you want to exercise your rights, please email us at info-web@asahi-intecc.com.