EU Personal Data Protection Policy

When the personal data of an individual (hereafter, the ‘Data Subject’) protected by the ‘European General Data Protection Regulation (2016/679)’ (hereafter, the ‘GDPR’) is directly or indirectly acquired by Wakabayashi Butsugu Mfg. Co., Ltd. (hereafter, the ‘Company’), the data controllers shall process the relevant data appropriately in accordance with the principles relating to processing of personal data referred to in GDPR Article 5.

Personal data shall be:

(a) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);

(b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (‘;purpose limitation’);

(c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimization’);

(d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);

(e) stored in such a way that individuals cannot be identified beyond the scope of the purposes for which they are handled (‘storage limitation’);

(f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures (‘integrity and confidentiality’).

The Company may collect and process your personal data for the purposes detailed below and keep personal data for as long as it is necessary for the Company to support its business activities.

・ Planning and development of the Company's products
・ Accommodating visitors to the Company and making inquiries to suppliers who cooperated in questionnaires and other surveys conducted exhibitions and events, etc.
・ Making inquiries to suppliers in regard to products and executing transactions
・ Making contacts related to the fulfillment of agreements
・ Responding to the details of inquiries and sending responses
・ Considering hiring and making clerical contacts to prospective employees
・ Implementing measures for shareholders
・ Employment management, labor management, accounting and HR policies implementation

Undertaking any other actions that will help the smooth flow of business and improve the products and services of the Company

The Company may collect and process your personal data if the Company has obtained your express prior consent. Please be aware that you are entitled to withdraw your consent at any time, and this without affecting the lawfulness of processing based on your consent before withdrawal thereof.

The Company may share personal data with its group companies and third parties in some cases. When sharing personal data with such entities, the Company shall handle the data appropriately in accordance with GDPR Articles 45 (Transfers on the basis of an adequacy decision). When sharing personal data with companies located outside the EEU, the Company shall implement safeguards to legally transfer the personal data outside of the region in accordance with GDPR Article 46 (Transfers subject to appropriate safeguards).

The Company do not collect and process personal data of children under 16 years old if consent is not given or authorized by the holder of parental responsibility over the child in accordance with GDPR Article 8 (Conditions applicable to child's consent in relation to information society service). Thus, please contact the Company if it has unknowingly processed the personal data of a child under 16 years old without these consents.

In case of breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access of personal data, incorrect transmission or recording, the Company shall make the necessary notification to the supervisory authorities, contact the Data Subjects, and take other appropriate measures in accordance with GDPR Article 33 (Notification of a personal data breach to the supervisory authority) and Article 34 (Communication of a personal data breach to the data subject).

The Data Subject holds the following rights in regard to personal data that are collected and processed by the Company. If the Data Subject will exercise such rights, please contact the address set forth Article 8 below. If the Data Subject is dissatisfied with the response made to their request by the Company, or the Data Subject has a complaint regarding the personal data processing methods used by the Company, the Data Subject can lodge a complaint with the data protection supervisory authorities in accordance with GDPR Article 13(2)(d) and Article 14(2)(e).

1. Right of access by the Data Subject
You may have the right to obtain confirmation from the Company as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and certain related information (Article 15 GDPR).

2. Right to rectification
You may have the right to obtain the rectification of inaccurate personal data from the Company, and to complete any incomplete personal data (Article 16 GDPR).

3. Right to erasure
You may have the right to obtain from the Company the erasure of your personal data where the Data Subject withdraws consent, and where the Data Subject objects to the processing, and where the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed (Article 17 GDPR).

4. Right to restriction of processing
You may have the right to obtain from the Company the restriction of processing of personal data, where the accuracy of the personal data is contested by the Data Subject, and where the Data Subject objects to the processing (Article 18 GDPR).

5. Right to data portability
You may have the right to receive your personal data in a structured, commonly used and machine-readable format, and have the right to transmit those data to another controller (Article 20 GDPR).

6. Right to object
You may have the right to object on grounds relating to your particular situation, at any time to processing of personal data concerning you, when certain legal conditions apply (Article 21 GDPR).

7. Right not to be subject to automated decision-making
You may have the right not to be subject to a decision based solely on automated processing including profile, which produces legal effects concerning you similarly significantly affects you (Article 22 GDPR). The Company does not employ automated decision-making, including profiling, using personal data provided by Data Subjects.

For any questions or requests relating to this EU Personal Data Protection Policy, you can direct to the following. Please note that the Company may revise or update this Policy from time to time. Any changes to this Policy will become effective upon posting of the revised Policy via the Website.

Wakabayashi Butsugu Mfg. Co., Ltd.

General Affairs Department (GDPR Personal Data Handling inquiry)

147 Nishisakai-cho, Shimogyo-ku, Kyoto, Japan 600 8218