(4) Purposes of Use applicable to other personal information and retained personal data which the Company may acquire or retain

(i) To communicate or offer to you information and guidance associated with products of the Company
(ii) To advertise exhibitions, events and other activities
(iii) To inform you about after-sale services and other updates for products of the Company
(iv) To conduct market surveys on products of the Company and other surveys and researches
In terms of information, guidance and advertisements which the Company may provide per each category of (i) through (iii) listed above, the Company may have marketing representatives of the Company’s sales agents and its distributors approach you to offer information, guidance and advertisements of relevant products and services based on personal information provided by you, provided that we first request you as the principal to consent thereto in advance.

The Company will not provide personal information it may retain to any third party except in cases where the consent has been given by the principal of the information or where applicable laws and regulations permit disclosure to a third party.

On its website, the Company may in an automatic fashion acquire information, such as webpage browsing history and IP addresses at the time of and during your visit, for the purposes of use as follows.
(1) To understand, and improve, how you use and experience our website and our e-mail newsletters
(2) To draw up statistical records and materials regarding how the website is run and conduct investigation to identify the cause of unauthorized access etc.
(3) To run promotional activities and market analyses regarding the Company’s business and products which it deals in

(4) Person responsible for managing personal information to be used jointly

General Manager, General Affairs Headquarters, NITTO KOHKI CO., LTD.

The Company will put in place reasonable security measures by implementing, among others, monitoring and control of access to rooms in the offices and security control of its computer system, and will further strive to prevent incidents such as unauthorized access to personal information, and the loss, destruction, manipulation and leakage of personal information.
Furthermore, the Company will promptly rectify any problem if and when there may arise the need to make improvements after or as a result of the Company’s internal audit, the request by the principal of relevant personal information, or publicly known security breach incidents, or other reasons.

The Company will educate its directors, officers, employees and other concerned persons about relevant matters, in particular, how they should treat personal information appropriately and will further strive to ensure that every possible preparation is done for its security. Furthermore, the Company will review its management system for personal information on a continuous basis and will strive to make improvements.
In cases where the Company engages a trustee outside and independent of the Company to deal with any personal information, the Company will do so only with selected trustees who it has already ascertained are safe ones based on the Company’s security standards relating to the protection of personal information. The Company will conduct supervision, as required and adequately, over its trustees so engaged.

In cases of requests (hereinafter referred to as “requests for disclosure etc.”) for notification of purposes of use of the Company’s retained personal data, correction, addition or deletion of its retained personal data, suspension or cessation of use of, or erasure of, its retained personal data, or suspension or cessation of provision to a third party of its retained personal data, the Company will, after having ascertained that the person who brings forward the request is the principal of the relevant personal data or his/her agent or attorney-in-fact acting in behalf, respond to such request pursuant to applicable provisions of laws and regulations and other relevant rules as follows.

(1) How We Accept Your Requests For Disclosure Etc. / Where They Should Be Addressed

(2) Documents and other annexures necessary when making requests for disclosure etc.

(3) How We Respond to Requests For Disclosure Etc.

(4) Purposes of use of personal information acquired in connection with requests for disclosure etc.

General Manager, General Affairs Headquarters, NITTO KOHKI CO., LTD.

As stated above in the General Clauses under the heading of “Introduction – The Applicable EU and the EU Member States’ Regulations”, the provisions set out hereafter shall apply cumulatively to, and shall override any conflicting aspect of, the aforementioned General Clauses. This allows us to assure our use and processing of personal information will be in compliance with data protection regulations applicable in the EEA and Switzerland, and other peripheral countries or regions as well, in particular the General Data Protection Regulation (“GDPR”).
For the purpose of these Special Provisions, when we refer to personal information, the term shall encompass personal data as defined in the GDPR.
Furthermore, except where otherwise specifically noted, the term “personal information” as used in these Special Provisions will refer to such personal information to which the Special Provisions will apply, rather than personal information in general.

NITTO KOHKI CO., LTD. collects and uses personal information relating to individuals concerned for the purpose of executing and fulfilling a contract for sales and provision of services with its customer or client, and for the purpose of executing and fulfilling a contract with its suppliers and other business partners. Furthermore, it may also do so to create and maintain relations with customers and clients, and business partners.
In processing personal information for these purposes, NITTO KOHKI CO., LTD. and its wholly owned subsidiary based in The Federal Republic of Germany, NITTO KOHKI EUROPE GMBH (hereinafter referred to as “NKG”), work closely together. These two (2) companies jointly engage in operations and processes of their business by using a certain sales management system introduced and maintained by NITTO KOHKI CO., LTD. to monitor and analyze sales activities by itself and its affiliated entities. The sales management system will facilitate the above-mentioned two (2) companies passing on to the other a limited set of categories of personal information set out in section 3, which comes immediately after this section. The legal basis to share personal information as above is Article 6(1)(f) GDPR. These two (2) companies have a legitimate interest in transmitting personal information within the group of undertakings for internal administrative purposes, as stipulated in Recital (48) of the GDPR. The European Commission adopted an adequacy decision on Japan enabling data transfers to Japan without any further specific authorization. In the following sections, we describe details of our processing and management of personal information insofar as this sales management system we put in place may be involved.
As part of their joint controllership under data protection law, NITTO KOHKI CO., LTD. and NKG have agreed which of them fulfills which obligations under the GDPR. They shall immediately inform each other of any legal positions asserted by the parties concerned. They shall provide each other with all information necessary to respond to requests for information. In exercising your rights as a data subject, please kindly be requested to refer it to NKG whose contact details are shown below in section 7 below.
Notwithstanding the contact point for the exercise of their rights designated as above, data subjects may receive the information from NITTO KOHKI CO., LTD., rather than exclusively from NKG to whom their request are referred.

NITTO KOHKI CO., LTD. and NKG collect, possess and manage, and process personal information of the following individuals as listed below:

Group A (Customers and Clients)	Group B (B-to-B Partners)
Customers and clients, whether existing or potential, who are natural persons; and ­Employees, officers, and other members of personnel of, and/or representing, customers and clients, whether existing and potential, who are entities or corporations	Suppliers, vendors, service providers and agents, whether existing and potential, who are natural persons; and ­Employees, officers, and other members of personnel of, and/or representing, suppliers, vendors, service providers and agents, whether existing and potential, who are entities or corporations

As a rule, NITTO KOHKI CO., LTD. collects and possesses, and will process and pass on to NKG where necessary or required, the following personal information:

Group A (Customers and Clients)	Group B (B-to-B Partners)
­Name, Residential address, Telephone number, Fax number, Email address, Credit card details, Employed-by/Assigned-to, Title, Business address, Contact details for Skype/Teams or other similar interactive communication services; and Logs of inquiry/transactions/complaints from and responses to them and details of communication involved

NITTO KOHKI CO., LTD. processes the personal information as specified above for the following purposes:

Group A (Customers and Clients)

Group B (B-to-B Partners)

­To send or provide, via email or by post or otherwise, marketing and promotional communications for or concerning NITTO KOHKI's goods, services, products, offerings and events and/or those of other businesses partnering with NITTO KOHKI, including catalog, flier, brochure, direct mail, publications, periodicals and other information, that might interest the recipient ­To fulfill, and manage and facilitate necessary transactions associated with, purchase orders placed for NITTO KOHKI's goods and services and other kinds of merchandise (including those purchased or otherwise sourced from other businesses partnering with NITTO KOHKI), including, for example, sending, via email or by post, order acknowledgement, invoice and statement for billing, and other documents ­To make contact, via email or by post or fax, or otherwise, to provide and offer aftersales services, including, but not limited to, maintenance, repairment, and provision of supplies, of goods and services sold or rendered, and to fulfill, manage and facilitate, and respond to requests associated with, such aftersales services ­To enhance and improve the quality and performance of goods and services, develop new goods and services, and customize and recommend existing goods and services ­To analyze sales and other transactional results and performance, to educate and train NITTO KOHKI's employees, and to conduct surveys and researches as related to goods, services, products, offerings and events ­To produce internal statistical data to rely on and refer to as basic information resources for reference for developing new products, improving services and evaluating markets ­To respond to and communicate with inquiries ­To ask for product review and for survey by questionnaire, and recruit testers for products ­To comply with legal obligations and requirements as applicable and cooperate with regulators and law enforcement bodies regarding, for example, anti-money laundering, regulations on anti-social forces and anti-corruption, customs regulations and trade restrictions

­To place purchase orders for, make requests and provide instructions as to, fulfill, manage and facilitate transactions relating to or associated with, purchase, supply, and provision of goods and services, products, consumables and other offerings, such as by sending order details and communicating for the status of payment process via email or by post or fax, or otherwise, and by arranging for payment by way of bank wire-transfer ­To analyze sales and other transactional results and performance, to educate and train employees, and to conduct surveys and researches as related to goods, services, products, offerings and events ­To produce internal statistical data to rely on and refer to as basic information resources for reference for improving business performance and workflow efficiency ­To respond to and communicate with inquiries ­To comply with legal obligations and requirements as applicable and cooperate with regulators and law enforcement bodies regarding, for example, anti-money laundering, regulations on anti-social forces and anti-corruption, customs regulations and trade restrictions

According to Article 6(1)(b) GDPR, data processing is required for the aforementioned purposes in order to fulfill contractual and pre-contractual obligations. Failure to provide this information may result in a contract not being concluded. Moreover, the above data processing is in the legitimate interest within the meaning of Article 6(1)(f) GDPR. Where the processing of personal information is based on Article 6(1)(f) GDPR, our legitimate interest is to carry out our business in favor of the well-being of all the employees and the shareholders of NITTO KOHKI CO., LTD.
Please note that, under certain circumstances, processing may be necessary for compliance with a legal obligation to which the controller is subject pursuant to Article 6(1)(c) GDPR.
If data processing requires consent within the meaning of Article 6(1)(a), and Article 7, GDPR, this consent shall be obtained separately. Pursuant to Article 7(3) GDPR, consent may be withdrawn at any time without affecting the lawfulness of processing based on consent before its withdrawal.

NITTO KOHKI CO., LTD. obtains personal information directly from individuals subject to these Special Provisions and may also obtain their personal information from external sources including websites published by private companies and similar sources which publicly disclose profile information and contact information such as employer and organization where they are employed or associated with. We may also rely on public registers as indirect sources.

NITTO KOHKI CO., LTD. only passes on personal information to third parties if and to the extent that legal permission within the meaning of Article 6(1) GDPR exists for this respective purpose. This includes in particular the passing on of information to shipping companies and payment service providers as well as to public bodies and institutions in the event of a legal or official obligation to pass on such personal information.
Insofar as NITTO KOHKI CO., LTD. uses external service providers to process personal information, these service providers have been carefully selected, commissioned in writing and are bound by instructions. The service providers shall process and retain personal information provided to them only to the extent and within the period effectively same as NITTO KOHKI CO., LTD. may process and retain pursuant to the provisions of these Special Provisions.

NITTO KOHKI CO., LTD. stores personal information for the periods set out below, unless there is consent to storage going beyond them.

Group A (Customers and Clients)

Group B (B-to-B Partners)

­Until such time when relevant relationship with the customers/clients/suppliers finally ceases to exist any longer in relation to both of NITTO KOHKI CO., LTD. and NKG; provided, however, that the duration of processing survives such cessation and lasts thereafter for and during such period whichever is longer of either of the following periods: applicable data or document retention periods as required under relevant laws, regulations, commonly observed standards and binding orders or requirements from the competent authorities; or the period to the extent as may be necessary to appropriately address and respond to possible requests by the customers or clients as data subjects for disclosure or otherwise; and ­The period during which any legitimate interest of NITTO KOHKI CO., LTD. and/or NKG exists to retain data

Where these Special Provisions will apply to your personal information, you as data subject have, under the respective legal requirements, the following rights regarding personal information processed by us.

Obtaining information regarding processing of data

Access to personal information

Rectification or erasure of personal information

Restriction on processing of personal information

Objection to processing of personal information

Data portability of personal information

Not to be subject to automated decision-making

If you intend to exercise any of the aforementioned rights, please inquire using the following contact details:

You can lodge a complaint in relation to NITTO KOHKI CO., LTD.’s processing of your personal information with the Data Protection Supervisory Authority of the Member State of your habitual residence, place of work or place of the alleged infringement.

We amend this privacy policy from time to time. We will contact you through this website and by e-mail if necessary, where we make any substantive or material amendments.

For contact to NITTO KOHKI CO., LTD., please use our contact details as provided above in the General Clauses. You also find the complete details of identity of NITTO KOHKI CO., LTD. as Controller of personal information.