Compliance

Agreement on handling of personal information

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Rubycon Group Privacy Policy

Originally Issued: February 11, 2019
Amended:

In recognition of the importance of the responsibility for Rubycon Corporation and Rubycon Group (hereinafter called “Rubycon”) to establish an environment in which personal data is being handled safely and appropriately, Rubycon hereby prescribes a guideline for handling of personal data (the “Privacy Policy”).

Definition of Personal Data

The term “personal data” in this Privacy Policy means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Collection and Use of Personal Data

Rubycon may collect and process your personal data directly or indirectly i) when you visit our website, ii) when we provide services to you, iii) when you contact us and/or iv) other occasions in connection with the maintenance and development of the relationship with you as a customer or a business partner.

The personal data which Rubycon may collect and process are : your name, (e-mail) address, telephone number, IP-address and any other personal data which are reasonably required for the above-mentioned purposes.

Lawfulness of Processing

Rubycon only processes your personal data on the basis of the following legal grounds: (i) if the processing is necessary for the performance of a contract with you, (ii) if the processing is necessary to comply with our legal obligations, (iii) if the processing is necessary for the purposes of our legitimate interests, except where such interests are overridden by your interests or fundamental rights and freedoms and/or (iv) if you have given consent to the processing of your personal data for one or more specific purposes.

Data Protection Officer

Rubycon has not appointed a Data Protection Officer (DPO), designated by the General Data Protection Regulation of EU, as none of the cases where DPO is required does not apply to us.

Compliance

When processing personal data, Rubycon shall comply with applicable laws and regulations including, but not limited to, the Personal Information Protection Law of Japan, the General Data Protection Regulation of EU and all applicable agreements with customers, suppliers, and/or other concerned parties.

Security Management Measures

Rubycon shall endeavor to keep contents of personal data accurate and up to date in line with the purpose of their use.

Rubycon shall take necessary and appropriate security management measures regarding the risks such as unauthorized access, leakage, falsifying, loss and/or damage of personal data.

Provision of the Personal Data to a Third Party

Rubycon shall endeavor to keep contents of personal data accurate and up to date in line with the purpose of their use.Rubycon shall not provide any personal data to a third party without obtaining the prior consent of the individual from whom the personal data has been obtained except for the following parties:

Rubycon shall take necessary and appropriate security management measures regarding the risks such as unauthorized access, leakage, falsifying, loss and/or damage of personal data.

1. Rubycon may share your personal data among affiliated entities or disclose to the
   contractors and agents for the purpose described in this Privacy Policy and as required
   by law;
2. Rubycon may disclose your personal data to third-party service providers, such as IT-service
   providers, distributors that support Rubycon’s operations; and
3. If Rubycon is under a legal obligation to do so.

For residents of EEA
When Rubycon shares your personal data with any of above mentioned recipient, and such recipient is located outside the European Economic Area in a country which the European Commission has not determined to have an adequate level of protection of personal data, Rubycon will only transfer your personal data on condition that the recipient ensures appropriate safeguards to protect your personal data. Besides, in that case, the data transfer shall only take place by applying the EU Commission approved Standard Contractual Clauses. A copy of the Standard Contractual Clauses can be requested using the contact details given below.

Your Rights

When processing personal data, Rubycon shall comply with applicable laws and regulations including, but not limited to, the Personal Information Protection Law of Japan, the General Data Protection Regulation of EU and all applicable agreements with customers, suppliers, and/or other concerned parties.You have the right to access, correct, and delete your personal data which Rubycon holds, as well as the right to object to certain types of processing of your personal data. Furthermore, where the processing of your personal data is based on your consent, you are entitled to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Please note that the withdrawal of you consent may have a result that we are not able to provide certain services to you for which the use of such data is necessary.

If you wish to exercise any of your rights described above, please contact us using the contact details given below. Rubycon shall respond without delay and appropriately to meet your requests, as well as to handle comments and/or inquiries regarding the personal data.

If you live in one of the EU countries where the General Data Protection Regulation of EU is applicable and if you are not happy with how Rubycon processes your personal data and we could not provide you with a satisfactory resolution to your request, you have a right to lodge a complaint with the a competent data protection authorities in your country.

Development of Operation Control Structure

To ensure an appropriate handling of your personal data, Rubycon shall endeavor to continuously develop internal operation structures, including the establishment of the internal regulations and education programs, providing its employees with appropriate trainings and conducting of internal audits.

Contact
To ensure an appropriate handling of your personal data, Rubycon shall endeavor to continuously develop internal operation structures, including the establishment of the internal regulations and education programs, providing its employees with appropriate trainings and conducting of internal audits.If you have any question or request regarding the collection, processing or use of your personal information, as well as this Privacy Policy, please contact us using “Inquiry on Web Form” provided through the below link:
Inquiry
Otherwise, you may contact our sales office covering your country.
Overseas Sales Branches