We will properly collect, use and safeguard personal data provided by you in the European Union-member countries and the three EEA/EFTA states – Iceland, Liechtenstein and Norway (the “EU”), by understanding the importance of personal data and by complying with EU General Data Protection Regulation (the “GDPR”)

1．Categories of personal data

We will collect and process the following personal data in the context of our services:

2．Purpose of use and legal basis for handling

Based on a legal basis, we will handle your personal data for the following purposes.

• Related to business activities
  
  • For the manufacture and sale of our products and services
  • For our sales activities and provision of our products, services and after-sales services
  • To disseminate, publish, and provide information and advertising materials concerning our products and services
  • For marketing research and analysis in the planning, development and manufacture of our products and services
  • For sales activities of our products, services and for marketing research and analysis to provide information
  • For maintenance of our products and services, implementation of technical support, and operation management
  • To make inquiries about and respond to inquiries about our products and services, and to introduce contact points
  • For the purpose of demonstrating, verifying and researching our products and services in order to conduct promotional activities and sales activities through the planning, development and manufacture of our products and services
  • For planning, holding, guiding, and operating exhibitions, seminars, events, promotions, and other events
  • To communicate with us and provide us with information
• Related to shareholders
  
  • To send publications, offer benefits, etc.
  • For the purpose of implementing various measures to facilitate relations between shareholders and us
  • For the fulfillment of rights and obligations under the law
• Related to hiring
  
  • For the purpose of recruitment
  • To guide recruitment events, to communicate, and to send materials
  • For the purpose of identity confirmation
  • For guidance on medical examinations, submission of necessary documents, and communication in recruitment procedures
• Related to employment management
  
  • For employment management
• Others that are common to above items
  
  • For responding to and communicating inquiries and questions to us
  • For use when it is necessary to retain or acquire personal information in order to fulfill our legal obligations (Performance of various contracts, negotiations, claims, brokerage, mediation, etc)
  • For optimization of quality and content of our website
  • For responding to requests from public organizations such as the national government, local governments, courts, and police stations

3．Recipients of personal data

We will process your personal data through the following recipients:

• TOA Corporation’s subsidiaries and affiliates (the “TOA Group Companies”)
  

  We will use the personal data described above jointly with TOA Group Companies and responsibly manage the joint use for the purposes described above. Please find the URL for domestic and overseas TOA Group Companies. https://www.toa.jp/profile/oversea.html

• Business support partners
  

  We will consign the handling of personal data after concluding a　 memorandum for business support with business support partner companies. Business support partner companies include, for example, companies that provide maintenance and technical support for our products and services, agencies consigned to manage employees’ personal information, recruitment agencies and shareholder registry agencies, etc.

• Business partners
  

  We will provide personal data to partner companies such as distributor partners and dealer partners.

4．Sources of personal data

We will collect your personal data directly from you. However, in some cases, your personal data that we collect are provided by the TOA Group Companies, business support partners and business partners.

5．Transfers to recipients in Third countries

In order to provide our services, we will need to transfer your personal data to countries outside of the EU, including countries that are not recognized by the European Commission as providing an adequate level of data protection. Please be advised that we only transfer personal data to these countries when we have been able to implement suitable safeguards that assure the protection of your personal data, such as standard data protection clauses under Article 46.2 of the General Data Protection Regulation (EU) 2016/679 (the “GDPR”).
For further information, including obtaining a copy of the documents used to protect your personal data, please contact us by sending an email or by calling or faxing TOA Network（https://www.toa.jp/profile/oversea.html）.

6．Retention period

We will store your personal data for as long as necessary in light of the purposes described above. The criteria used to determine our retention periods include:

• whether we have an ongoing relationship with you;
• whether there is any legal obligation that we are subject to
• whether there is a need to perform a contract that you are party to.

7．Your rights

You have the right to request for a copy of your personal data; to correct, delete or restrict（or stop） handling of your personal data; and to obtain the personal data that you provided to us, based on a contract or with your consent, in a structured and machine-readable format（i.e. the right of data portability）.
In addition, you can object to the processing of your personal data under certain conditions （for further information, see the section below entitled “8. Your right to object to processing”）.
These rights may be limited, for example, if the fulfilment of your request would reveal personal data about another person, where it would infringe upon the rights of a third party （including our rights） or if you ask us to delete information that we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and local EU laws on privacy.

8．Right to object to processing

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

9．Right to withdraw consent

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

10．Personal data that you need to provide

Necessary personal data is indicated in the relevant forms that you complete.
Where provision of personal data is necessary, we are not able to provide our services to you if the relevant information is not provided.

11．Right to complain to a supervisory authority

You have the right to make a complaint to a supervisory authority, including the supervisory authority of the EU Member State of your habitual residence or place of work, or in the place where the alleged infringement of the GDPR took place.

12．Revision

We reserve the right to amend this privacy policy at any time. The revised privacy policy will be available on our websites.

13．Contact details

For any inquiries about your personal information, please contact:

TOA Corporation
Email address:[email protected]

We will properly collect, use and safeguard personal data provided from you by understanding the importance of personal data and by complying with United States data protection regulations.

1．Categories of personal information

We have been collecting and handling following personal information within the past twelve (12) months

2．Sources of personal information

We have been collecting your personal information within the past twelve (12) months in the following ways.

• Directly collecting the information in person, by email, or using the forms on our websites;
• Indirectly collecting the information from subsidiaries and affiliates of TOA Corporation（the “TOA Group Companies”）, business support partners, and business partners
• Automatically collecting the information from your history of use with our website through analytical tools such as cookies, web beacons, etc.

Notice regarding the “Do Not Track(DNT)” setting: this setting allows for certain privacy settings that can be established by users on their specific web browsers.
Although we work to provide meaningful choices about the information collected from our websites for third parties, currently we do not support DNT signal responses of web browsers.

3．Purpose of use

We will handle personal data for the following purposes

• Related to business activities
  
  • For the manufacture and sale of our products and services
  • For our sales activities and provision of our products, services and after-sales services
  • To disseminate, publish, and provide information and advertising materials concerning our products and services
  • For marketing research and analysis in the planning, development and manufacture of our products and services
  • For sales activities of our products, services and for marketing research and analysis to provide information
  • For maintenance of our products and services, implementation of technical support, and operation management
  • To make inquiries about and respond to inquiries about our products and services, and to introduce contact points
  • For the purpose of demonstrating, verifying and researching our products and services in order to conduct promotional activities and sales activities through the planning, development and manufacture of our products and services
  • For planning, holding, guiding, and operating exhibitions, seminars, events, promotions, and other events
  • To communicate with us and provide us with information
• Related to shareholders
  
  • To send publications, offer benefits, etc.
  • For the purpose of implementing various measures to facilitate relations between shareholders and us
  • For the fulfillment of rights and obligations under the law
• Related to hiring
  
  • For the purpose of recruitment
  • To guide recruitment events, to communicate, and to send materials
  • For the purpose of identity confirmation
  • For guidance on medical examinations, submission of necessary documents, and communication in recruitment procedures
• Related to employment management
  
  • For employment management
• Others that are common to above items
  
  • For responding to and communicating inquiries and questions to us
  • For use when it is necessary to retain or acquire personal information in order to fulfill our legal obligations (Performance of various contracts, negotiations, claims, brokerage, mediation, etc)
  • For optimization of quality and content of our website
  • For responding to requests from public organizations such as the national government, local governments, courts, and police stations

4．Recipients of personal information

We have been sharing your personal information within the past twelve (12) months to following recipients:

• TOA Group Companies
  

  We use the personal information described above jointly with the TOA Group Companies and responsibly manage the joint use for the purposes described above. “TOA Group Companies” includes the domestic and overseas group companies. ( https://www.toa.jp/profile/oversea.html);

• Business support partners
  

  We consign the handling of personal data after concluding a memorandum for business support with business support partner companies. Business support partner companies include, for example, companies that provide maintenance and technical support for our products and services, agencies consigned to manage employees’ personal information, recruitment agencies and shareholder registry agencies, etc.

• Business partners
  

  We provide personal information to partner companies, such as partner distributors and partner dealers; and

• Law enforcement agencies
  

  We provide personal information to law enforcement agencies to the minimum extent when necessary to fulfill legal obligations or in response to requests from the government or investigative agencies.

Notwithstanding the above, we have not sold your personal information to third parties in the past twelve (12) months.

5．Retention period

We store your personal information for as long as necessary in light of the purposes described above. The criteria used to determine our storage periods include:

• whether we have an ongoing relationship with you;
• whether there is any legal obligation that we are subject to
• whether there is a need to perform a contract that you are party to.

6．Your rights

You have the following rights:

• Right to request disclosure
  

  Disclosure of personal information we collect

  You have the right to request that we disclose the categories and specific information we have collected about you.
  Please note that we will respond to your disclosure request only if we can verify your identity.
  In some cases, we are not required to provide such information to you more than twice in a 12-months period.

  • 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
    If you exercise this right to request disclosure, please contact the inquiries address listed in this privacy policy.

  Disclosure of personal information we sell or share

  You have the right to ask us to provide information on the following matters when we sell your personal information or disclose it for business purposes. Please note that we will respond to your disclosure request only if we can verify your identity.

  • Categories of personal information we collect about you
  • For each category of personal information received by each third party to which the personal information is sold, the category of the personal information sold and the category of the third party
  • Categories of personal information disclosed by us for business purposes
    If you exercise this right to request disclosure, please contact the inquiries address listed in this privacy policy.

  Sharing with third parties for direct marketing purposes

  You may have the right to request the content of personal information that we share with third parties for the purpose of third-party direct marketing once a year.
  If you exercise this disclosure request right, please state "Requests under the Shine the Light Law of California" and contact the inquiries address listed in this privacy policy.

• Right to delete
  

  You have the right to request that we delete any of your personal information that we have collected from you. Please note that we will respond to your deletion request only if we can verify your identity.

  Notwithstanding the foregoing, we may not be able to respond to your request for deletion primarily in the following cases:

  • To complete the transaction between you and us, to provide our products and service requested by you, or to perform a contract with you;
  • To detect security incidents, to protect against illegal or inappropriate activity, or to prosecute those responsible for such activity;
  • To debug to identify and repair errors that impair intended functionality;
  • To exercise free speech, to ensure the right of another consumer to exercise his or her right of free speech, or to exercise another right provided for by law;
  • For internal use, when reasonably meeting with your expectations or in appropriate manner consistent with the purpose for which you provided the information.
  • To comply with legal obligations.

  If you exercise this right to request deletion, please inquire to contact details listed in this privacy policy.

• Opt-out rights
  

  You have the right to instruct us not to sell your personal information.
  We have not sold your personal information in the previous twelve (12) months, but, if we plan to do so in the future, in accordance with the law, we will inform you that your personal information may be sold and you have right to opt out of that sale.

• Non-discrimination rights
  

  Prohibition of discrimination due to exercise of rights

  We do not discriminate against you due to the exercise of any of your rights under the laws and regulations, including, but not limited to, by:

  • Denying goods or services to you;
  • Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Providing a different level or quality of goods or services to you
  • Suggesting that you will receive a different price or rate, level or quality of goods or service.
  • For internal use, when reasonably meeting with your expectations or in appropriate manner consistent with the purpose for which you provided the information.
  • To comply with legal obligations.

  Financial incentive program

  We may offer financial incentives to you as compensation for the collection, sale, or deletion of personal information only if the important terms of the financial incentive program are clearly stated and the consent, which may be withdrawn at any time, is obtained.
  We do not offer financial incentives at present; however, if we do so in the future, notifications regarding the financial incentives will be provided in accordance with the law.

7．Link to the opt-out page

We have not sold your personal information in the previous twelve (12) months, but, if we plan to do so in the future, in accordance with the law, we will install the following link on our websites: “Do Not Sell My Personal Information”.

8．Rights of children

This website 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 have not sold the personal information of consumers between 13 and 16 years of age; however, if we plan to do so in the future, the sale of personal information will not be done unless the consumers between 13 and 16 years of age have affirmatively authorized it.

9．Revision

We will review and improve the contents of the above items regarding the handling of your personal information as appropriate.
When changes are made to this privacy policy, an update notice will be posted on the website and will be effective as of the posted dated.

10．Contact details

For any inquiries about your personal information, please contact:

TOA Corporation（TOA Electronics, Inc.）
Toll-free number: 010‐1‐（650）452‐1200 / （800）‐733‐7088 ,
[email protected]