Privacy Policy

Hitachi High-Tech's Approach to Personal Information Protection

Hitachi High-Tech Corporation ("HHT") aims to create regulations and establish management systems with respect to personal information protection in addition to instituting the personal information protection policy published below, keeping executives and employees fully briefed, and striving for the appropriate protection of personal information in keeping with this policy.

Definition of Personal Information

At HHT, personal information indicates information that identifies, or is capable of identifying, a specific individual by means of one or a combination of two or more of pieces of information corresponding to any of the following including the individual's name, date of birth, age, gender, address, telephone number, family composition, hobbies, preferences, email address, workplace, affiliation, workplace address, workplace telephone number, credit card number, bank account as well as any ID number or string of characters assigned to the individual, information about purchased goods and products or services, information about websites accessed, complaints, consultations or inquiries.

Scope of Application

This "About Personal Information Protection document" establishes how the personal information of customers is handled at HHT.

Personal Information Protection Policy of HHT

1. Collecting, Using and Providing Personal Information
   Bearing in mind that in the course of its business activity, HHT is entrusted with information about customers, we have established management structures tailored to operational status in order to protect personal information, and we handle the collection, use and provision of personal information appropriately and according to prescribed regulations.
2. Compliance with Laws and Ordinances and Standards
   When handling personal information, HHT complies with laws and ordinances and other standards applicable to personal information protection. In addition, we have produced and adhere to HHT rules for the management of personal information protection that conform to these laws and ordinances and other standards.
3. Implementing Security Measures
   In order to ensure the accuracy and security of personal information, HHT conforms to various regulations regarding information security, manages access to personal information, limits methods of carrying out personal information, implements measures to prevent illegal access from outside, and works to prevent the loss, destruction, falsification and leakage of personal information.
4. Respect for the rights of the person involved with the personal information
   With regard to personal information, when the person involved requests HHT to disclose, correct or delete information, or refuses its use or submission, we will respond in good faith and with respect for the rights of the person involved with the personal information.
5. Decisions on Rules for Personal Information Protection Management and Continuous Improvement
   HHT implements recognition of the importance of personal information protection among executives and employees, deciding on rules for personal information protection in order to safeguard and appropriately use personal information. In addition, we maintain and continuously improve the rules.

Purpose of Using Personal Information and Provision to Third Parties

1. HHT uses personal information only within the scope necessary to achieve the following aims. In addition, when a customer submits personal information, we disclose the purpose of use in advance and receive the agreement of the customer.
   1. Fulfilling a contract concluded between the customer and HHT
   2. Contacting the customer for appointments and negotiations
   3. Providing aftercare services for products
   4. Sending out information about events and new products
   5. Providing membership services
   6. Matters concerning stocks
   7. Responses to inquiries
   8. Questionnaire-based analysis to improve products and services
   9. Providing personal information to the relevant Group Company in case HHT undertakes business activities in collaboration with a Group Company
      • List of Group Companies
   10. Shipping products orders by a customer
2. HHT does not provide the personal information of a customer to a third party without obtaining the agreement of the customer in advance. However, exceptions apply in the event of any of the following:
   1. Matters based on laws and ordinances;
   2. It is difficult to obtain the agreement of the customer when necessary in order to protect human life, body or property;
   3. It is difficult to obtain the agreement of the customer, in particular, when necessary in order to improve public health or to further the sound development of children;
   4. Obtaining the agreement of the customer carries the risk of impeding official duties when necessary to cooperate with an organ of the state, local public bodies or any person entrusted with the execution of duties as determined in laws and ordinances;
   5. Being entrusted with the handling of personal information within the scope necessary to achieve the purpose of use:
   6. Providing personal information following a handover of the business due to a merger or other reasons.
3. For joint business activities undertaken with Hitachi, Ltd. or companies affiliated with Hitachi, Ltd. (that is, companies in which Hitachi, Ltd. owns 20% or more of total shares issued and outstanding), with dealerships in charge of selling HHT’s products, with suppliers, or with third parties contracted for work (“Partners”), HHT may provide to the Partners necessary personal data on customers, including name, workplace and home address, telephone number, fax number, and e-mail address. In this case, the personal information of customers will be provided in print or electronic media. Further, the customer may request HHT to stop the provision of personal information to Partners.

Handling of Specific Personal Information

1. When handling specific personal information, our Company will comply with the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (hereinafter referred to as the "Act on the Use of Numbers"), Act on the Protection of Personal Information, and Guidelines for proper handling of Specific Personal Information (for private entities).
2. Our Company considers our "personal information protection policy" as the "basic policy for the proper handling of specific personal information", and will ensure the proper handling of specific personal information.
3. Our Company considers the performance of administrative procedures relating to social security, taxes, and countermeasures against disasters stipulated in each paragraph in Article 9 of the Act on the Use of Numbers to be the scope of use of specific personal information, and will obtain and use specific personal information to the extent necessary to achieve a purpose. The main scope of use of specific personal information handled by our Company is as follows:
   1. Clerical work in which upon receipt of specific personal information provided by, for example, our employees, our Company states such information in necessary documents, such as certificates of tax deducted for employment income and retirement income, payroll payment reports, unemployment insurance notifications, notifications of qualified persons covered by health insurance and corporate employees' pension insurance, and legal written records including claims pursuant to the Industrial Accident Compensation Insurance Act, and submits the aforementioned documents to the director of a taxation office, the mayor of a municipality, Japan Pension Service, or other organizations.
   2. Clerical work in which upon receipt of specific personal information, our Company states such information in various reports of payment, such as reports of payment of remuneration and fees; reports of payment of dividends, distribution of surplus, and interest on funds; reports of payment of rental charges, such as for real estate; and reports of payment in consideration of the transfer of, for example, real estate; and submits the aforementioned reports to the director of a taxation office.
   3. Performance of operations that involve clerical work entrusted to our Company by an administrative organization or other private entity for the handling of specific personal information.
4. Our Company will not provide specific personal information of a person to any third party, apart from cases stipulated by laws and regulations concerning specific personal information. Our Company will not jointly use such information. However, for any case that falls under any of the items stipulated in Article 19 (Restrictions on the Provision of Specific Personal Information) of the Act on the Use of Numbers, specific personal information may be provided.
5. Our Company may entrust handling of specific personal information within the scope of purpose of use stipulated by laws and regulations.
6. Request for disclosure, correction, addition, deletion, suspension of use, suspension of provision to third parties, or notification of purpose of use, or any complaint concerning specific personal information held by our Company will be made in accordance with our "Request to Disclose Personal Information and Accepting Complaints."

Usage of Cookies and Web Beacons

Cookies^*1 or web beacons (clear GIFs)^*2 are used on some HHT websites in order to make our websites more user-friendly for customers.
By changing the settings on the web browser, the customer may refuse to accept cookies or display a warning message when a cookie is accepted. For details, please refer to the instructions for your browser of choice. The customer may also refuse web beacons by refusing to accept cookies.
However, please be aware that all or some of the services provided on HHT websites may be unavailable in case of refusing to accept cookies.

*1

Cookies
Refers to information exchanged between the web server managing a website and the customer's web browser. Cookies may be stored as files on the hard disk of the customer's computer. By using cookies, the web server can record what pages on a website were viewed on a specific computer. However, HHT cannot pinpoint or identify the customer unless the customer enters their own personal information on the website.

*2

Web beacons
Refers to a technology that works with cookies to understand how many times a customer has accessed a specific page. However, HHT cannot pinpoint or identify the customer unless the customer enters their own personal information when accepting cookies.

Request to Disclose Personal Information and Accepting Complaints

In case of a request to disclose, correct, add, delete, stop using, stop provision to third parties or to notify the purpose of use ("Disclosure etc.") of the personal information of a customer held by HHT, or lodging a complaint, the following procedures apply.

1. Request to disclose personal information provided by the customer to a business department at HHT. Please contact the relevant business department.
2. Request to disclose personal information provided by the customer via an HHT website.
   Please contact the department in charge of the relevant webpage.
3. Request to disclose personal information other than the abovementioned points 1 and 2.
   For details on requests for Disclosure etc., please refer to Details regarding Requests for the Disclosure,etc.
   • Details regarding Requests for the Disclosure,etc.
4. Complaints about how HHT handles personal information.
   Please enter the required information in the Complaint Form regarding Handling of Personal Information (PDF format) and forward the form to the address below, or send us an inquiry using the Inquiry Form or by telephone.
   • Complaint Form regarding Handling of Personal Information (PDF Type,64kbytes)

Contact for Complaints

Legal Department, Hitachi High-Tech Corporation
Toranomon Hills Business Tower, 1-17-1 Toranomon, Minato-ku, Tokyo 105-6409, Japan
Tel: +81-3-3504-7089
Fax: +81-3-3504-5147

• Complaint Form regarding Handling of Personal Information (PDF Type,64kbytes)
• Inquiry Form

Request to Customers

1. Most services provided by HHT can be used without the personal information of the customer. However, please note that some services may not be available if the customer does not provide personal information to HHT.
2. Please note that HHT cannot assume responsibility for ensuring the security of personal information on external websites linked from HHT websites.

When a customer enters personal information on an HHT website, agreement with this Personal Information Protection document is presumed. If you do not agree with this Personal Information Protection document, you may not be able to use the services provided by HHT (including response to inquiries etc.).

Privacy notice for individual customers in the EEA

For customers located in the European Economic Area (EEA):

HHT implements measures to safeguard personal data (as used here, "personal data" shall have the same definition as "personal information" as defined under "Definition of Personal Information" above) in accordance with applicable laws and regulations. Provided below are HHT’s methods of controlling personal data and your privacy rights.

I. About HHT

See "Request to Disclose Personal Information and Accepting Complaints" above for information on contacting HHT. HHT’s representative in the EEA is as follows:

II. Purposes and legal basis of HHT’s processing of personal data

Specified below are the anticipated purposes of use of personal data concerning customers and the legal basis thereof.

Purposes and legal basis of HHT’s processing of personal data

Purpose/action	Legal basis (including details of legitimate interests)
Performance of contracts concluded between customers and HHT	Contractual performance
Communications related to business discussions and meetings with customers	Legitimate interest (business deployment and development)
Provision of after-sales service for products	Legitimate interest (provision of services to HHT customers)
Sending information on events and new products	Legitimate interest (provision of information on products and services and business deployment and development)
Provision of various membership-based services	Legitimate interest (provision of services to HHT customers)
Stock administration	Legitimate interest (business operations)
Responding to various inquiries	Legitimate interest (provision of information on products and services and business operations)
Questionnaire-based analysis intended to improve products and services	Legitimate interest (market research, improving products and services, and business deployment and development)
Sending products ordered by customers	Legitimate interest (provision of products and services to HHT customers)
Performance of obligations under laws and regulations other than EU law or the domestic laws of EEA member states, such as responding to orders by a court of law to submit documents or questions from employees of tax agencies and similar parties or answering inquiries concerning matters related to investigations	Legitimate interest (compliance with obligations under laws and regulations of countries outside the EEA countries)

III. Categories of personal data recipients

HHT may share personal data concerning customers with the third parties identified under "Purpose of Using Personal Information and Provision to Third Parties" above for the purposes listed under II above. HHT demands such third parties to safeguard the security of personal data concerning customers and to handle such data in accordance with applicable laws and regulations.

IV. Transfer of personal data outside the EEA

If a company within the EEA in which HHT holds more than 50% of voting rights transfers personal data concerning customers outside the EEA, HHT shall take measures to ensure that the data is protected to the same extent as in the EEA. HTT will ensure this objective through the following and other measures:

• Transfer to countries recognized by the European Commission to provide adequate levels of personal data protection
• Use of specific contracts, approved by the European Commission, on personal data protection of extent equivalent to that in Europe
• Transfer based on Privacy Shield if the recipient is located within the United States and participates in the Privacy Shield program (which requires provision of protection of extent equivalent to that in the EEA to personal data shared between Europe and the US)

If you provide your own personal data directly to HHT in Japan or an HHT subsidiary (i.e., a company in which HHT holds more than 50% of voting rights) located outside the EEA, your personal data will be handled in accordance with the personal information safeguards established in this Policy. However, note that Japan and other countries outside the EEA have different laws and protection levels for personal information and that the safeguards thereby provided may fall short of personal information safeguards deemed adequate by the European Commission and the European Union.

V. Retention period for personal data

HHT retains personal data concerning customers to the extent necessary to achieve the purposes of use of such data.
To determine appropriate retention periods for personal data concerning customers, HHT considers the volume of personal data, nature, sensitivity, potential risks of unauthorized use or disclosure, purpose(s) of use, whether other means may exist to achieve the purpose(s) of use, and applicable legal requirements.
In some cases involving research or statistical purposes, HHT may anonymize personal data concerning customers to render it impossible to connect it to the individuals concerned. In such cases, HHT may use such anonymized information for any length of time without notifying you.

VI. Legal rights

Generally, you have the following rights concerning your personal data:

• The right to demand access to your personal data
• The right to demand correction of your personal data
• The right to demand deletion of your personal data
• The right to demand restrictions on the processing of your personal data
• The right to file objections to the processing of your personal data
• The right to demand transfer of your personal data (data portability)
• The right to withdraw consent to the processing of your personal data

Contact HHT if you wish to exercise any of the above rights.

As a security measure to ensure that personal data are not disclosed to parties who lack the right to receive them, HHT may demand the provision of specific information as necessary to confirm your identity. To expedite our response, HHT may ask you to provide further information related to your exercise of the above rights.

HHT will strive to respond within one month to the exercise of legitimately grounded rights. However, in certain cases, it may take longer than one month to respond. Such cases may involve the particularly complex exercise of rights or the exercise of a large number of rights. We will notify you in such cases and keep you updated on the progress of our response.

You have the right to file complaints with data protection authorities at any time. However, we ask that you contact HHT first before contacting the authorities and to provide us an opportunity to respond to your concerns.

VII. When personal data are not provided

If HHT needs to obtain personal data pursuant to laws and regulations or pursuant to the provisions of contracts concluded between HHT and customers but such personal data is not provided, HHT may be unable to fulfill contracts concluded with customers or contracts HHT intends to conclude with customers.

VIII. Usage of Cookies and Web Beacons

See "Usage of Cookies and Web Beacons" concerning use of cookies and web beacons.

Special Instructions

1. HHT may revise this Personal Information Protection document due to revisions to laws and ordinances or other standards or to improve the handling of personal information.
2. This Personal Information Protection document applies as of the date of publication (including the date of revisions).
3. For content, if separate regulations for personal information protection are set, priority shall be given to those regulations.

For Enquiries Regarding This Website

Please use the Inquiry Form for other inquiries regarding this website than requests for disclosure of personal information or lodging complaints.

• Inquiry Form

Enacted on April 1, 2005
Last revised on June 19, 2018

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