Handling of Customers' Personal Information
Please see below for information regarding the personal information we collect ("Personal Information"): the purpose of use, specific details of how it is handled, and how to contact us with inquiries.
1. Personal Information We Collect
1-1. How we use your information
We only collect Personal Information where necessary to inform our business objectives or where needed to carry out business activities, and this Personal Information is used for the following purposes.
(1) Requests to do business with customers and business partners, internal confirmation of business activities with customers and other associated parties, evaluating and deciding on these business activities, entering into agreements, fulfilling, managing, and terminating agreements, and procedures after contract termination
(2) Providing information about our products and services or those of our group companies
(3) Checks and inquiries for products and services provided to our business partners
(4) Publicizing and confirming attendance for our seminars, exhibitions, etc., or those held by our group companies, communicating with speakers, sending reports to people who attended events or took part in surveys
(5) Confirming visits and entry to our premises
(6) Sending our publications to people who request them, and sending emails to people who sign up to our email service
(7) Asking customers to fill out customer satisfaction surveys
(8) Responding to inquiries or requests from customers and business partners
(9) Exercise of our shareholders' rights and fulfillment of our obligations under company law, as well as implementing various other measures to ensure effective communication with our shareholders, properly identifying our shareholders and promoting mutual understanding including through the creation of standards-compliant data as stipulated by relevant laws and regulations
(10) Communicating with employees of affiliated organizations and providing information that meets their objectives
(11) Communicating our research and development activities to members of research institutions, discussion of matters subject to (1) above under joint development agreements or development contracts, attendance at research meetings, and nomination for academic prizes
(12) Patent applications and management of patent applications with joint applicants
(13) Communicating with journalists, analysts, etc. for PR activities
(14) Receiving job applications when recruiting, communicating with applicants, notifying success/failure of applications, etc.
(15) Communicating with certified public accountants, lawyers, patent attorneys, etc. as required in the course of our business activities
(16) Communicating with group companies for business activities other than the above
(17) Notices to retired employees and other parties
(18) Communicating with the families of our employees
(19) Sharing of information for contracts and as necessary for business activities with subcontractor workers, contract employees, dispatched employees, part-time employees, and temporary employees
(20) Information provision from our company and our group companies incidental to the purposes of use described above
Note: Group companies are companies inside or outside Japan in which we directly or indirectly hold 20% or more of total shareholder voting rights.
1-2． Subcontracting to third parties
To ensure the smooth operation of the business, we may subcontract certain activities to third parties inside or outside Japan and entrust them with the Personal Information required to carry out these activities, only as required for the stated purpose. In such cases, we select the third party only after verifying that they handle Personal Information appropriately, enter into an agreement for handling Personal Information, and ensure that they are appropriately monitored.
1-3. Joint use
We sometimes make joint use of Personal Information together with our group companies, agents, dealerships, and vendors. In such cases, Personal Information subject to joint use will be limited to the individual's name, place of work, home and business addresses, phone number, fax number, and email address, and its use will be limited to providing information on joint products and services and announcements for joint seminars, exhibitions, etc. We are responsible for managing Personal Information subject to joint use.
Note: Agents and dealerships are companies that have entered into agreements with us and are allowed to present themselves as our agents or dealerships, and vendors are companies other than agents or dealerships who are directly authorized by us to sell our products.
1-4. Use for other purposes
If it becomes necessary to use Personal Information for purposes other than those described in "1-1. How we use your information", the individual will be notified or the use will be publicly announced or put in a format readily accessible to the individual, except where the individual has already given permission or where required by law. Changes to how we use Personal Information will only be made to the extent that there is reasonably acknowledged to be a connection with the previous purposes.
1-5. Provision of personal information to third parties
We will not provide Personal Information to third parties except in the following circumstances.
(1) Where the individual has consented
(2) When sharing statistical or other data that does not contain information that is personally identifiable
(3) When providing Personal Information to subcontracted third parties when subcontracting certain business activities to third parties, to the extent required to carry out the business activities, and only as required for the stated purpose (see 1-2. "Subcontracting to third parties")
(4) When using Personal Information jointly with group companies, agents, dealerships or vendors, only as required for the stated purpose (see 1-3. "Joint use")
(5) As required by law
(6) Where it is difficult to get permission from the individual, but providing the information is necessary to preserve life, ensure personal safety or protect property
(7) Where it is difficult to get permission from the individual, but providing the information is essential to improving public health or promoting sound child development
(8) Where required to assist national agencies, regional public bodies or their representatives in the course of carrying out their duties as defined by law, and where obtaining permission from the individual might obstruct said duties
2. Procedures for Disclosure, Amendment, Suspension of Use, Deletion, etc. of Personal Information
2-1. Requests for disclosure, amendment, suspension of use, deletion, etc. of Personal Information
Please use the specified form for requesting disclosure, amendment, suspension of use, deletion, etc. of Personal Information (download the form from the following link and print out to use: [Link]), fill in the required fields, attach one piece of personal identification (copy of official document such as driving license or passport) for the individual concerned ("Personal ID"), and send it to the address below together with return postage. Writing "Enc. request for disclosure" in red on the envelope will help us expedite your request.
Alternatively, if information was registered through our site by our technical support or email newsletter staff, requests for disclosure, amendment, suspension of use, deletion, etc. of Personal Information can be made as specified on the site, subject to our ability to properly confirm that the requester is the individual concerned.
Personal Information Protection Officer
Risk Management Office, THK Co., Ltd.
4-5-37 Kamiosaki, Shinagawa, Tokyo
2-2. Requests for disclosure, amendment, suspension of use, deletion, etc. of Personal Information made by a representative
Anyone requesting disclosure, amendment, suspension of use, deletion, etc. of Personal Information must be a legal representative of the individual concerned, or if charged with requesting disclosure, amendment, suspension of use, deletion, etc. of Personal Information by the individual concerned and acting as their representative, must enclose Personal ID with the request along with the other documents listed below.
(1) If a legal representative (both documents listed below are required.)
・One document proving status as a legal representative (for minors, copy of entire Japanese family register (copy of health insurance document showing the individual concerned is a dependent is acceptable if the representative has parental authority), or for adult wards, a copy of document proving registered details)
・One document proving the identity of the legal representative (copy of official document such as driving license or passport belonging to the legal representative)
(2) If appointed to represent the individual (both documents listed below are required.)
・When requesting disclosure, amendment, suspension of use, deletion, etc. of Personal Information, one document proving that the individual concerned has delegated the request, stamped with their registered seal (letter of attorney or equivalent)
・One seal registration certificate for the individual concerned
2-3. Fees for requests for disclosure, amendment, suspension of use, deletion, etc. of Personal Information
There is no charge for these requests. However, the requester is responsible for postage (including return postage).
2-4. Response to requests for disclosure, amendment, suspension of use, deletion, etc. of Personal Information
We will reply by post to the address given by the requester on the request form.
2-5. Reasons for not disclosing retained Personal Information
We will not disclose personal information in the following cases. If we decide not to disclose information, we will communicate that decision along with the reason why.
(1) Where the individual cannot be positively identified, for example if the address on the request form or the Personal ID does not match the address we hold
(2) Where authority as a representative cannot be verified in the case of a request from a representative
(3) Where there is insufficient information, for example omissions in the specified request form
(4) Where we do not hold the Personal Information subject to a request for disclosure, etc.
(5) Where doing so might involve a risk to the life, personal safety, property, or other right or benefit of the individual concerned or a third party
(6) Where doing so might seriously obstruct the appropriate performance of our business activities
(7) Where doing so would violate other laws or regulations
3. Contact for Questions About Personal Information
If you have any questions about our personal information protection policy or how we protect personal information, suggestions for improvements to our safeguarding of personal information, or if you want to talk to someone about requesting disclosure, amendment, suspension of use, deletion, etc. of Personal Information, please contact our personal information handling service at the contact details given below. Please note that we cannot accept requests in person at our offices.
Personal Information Handling Service
Office hours: Weekdays 9:00 am - 5:00 pm
Personal Information Protection Officer
Risk Management Office, THK Co., Ltd.
Tel: +81 3-5730-3839 Fax: +81 3-5730-3915
4. Use of Personal Information on Our Site
(1) Cookies, web beacons and IP addresses
On our site, cookies, web beacons and IP addresses are used for the purposes listed below. Users can disable our cookies and web beacons by disabling cookies in their browser settings, but this may prevent use of some or all functionality on web pages.
① To identify and resolve causes of server failure or other server issues
② To improve site and email content
③ To customise site and email content for individual users
④ For members-only services where personal information has already been registered, browsing history, questionnaire responses, etc. are used for marketing purposes
⑤ To use anonymized information for statistics
(2) Google Analytics
Users can disable Google Analytics in browser add-on settings, preventing Google Analytics from collecting their data. Google Analytics can be disabled by downloading the "Google Analytics Opt-out Browser Add-on" from the Google opt-out browser add-on download page, installing the add-on, and configuring the browser add-on settings. If a user disables Google Analytics, it will disable Google Analytics on all sites and not just ours, but it can be re-enabled at any time by changing browser add-on settings.
- Google Analytics Terms of Service:
- Google Analytics Opt-out Add-on:
Note: "Google Analytics" is a registered trademark of Google.
We have no liability or responsibility for the protection of Personal Information on websites that are linked from our site. Please direct any questions or inquiries about the handling of Personal Information on other websites directly to the site owners.
If you have any questions about this statement, please contact us using our Contact Form.
Created: August 1, 2018
1. OUR PRIVACY Statement
(1) THK Co., LTD.
(2) THK INTECHS Co., LTD.
(3) Talk System Co., LTD.
(4) THK RHYTHM Co., LTD.
(5) THK Europe B.V.
(6) THK GmbH
(7) THK France S.A.S.
(8) THK Manufacturing of Europe S.A.S.
(9) THK Manufacturing of Ireland Ltd.
2. Processing of Your Personal Data
We always process your personal data based on one of the legal bases provided for in the GDPR (Articles 6 and 7). We collect and process, for the purposes set out below, the personal data of customers (purposes (1), (2), (4), (5), (6), (7), (8), (16), (17), (18), (19), (20), (21), and (22) below), trading partners (purposes (1), (2), (3), (4), (5), (6), (8), (11), (12), (15), (16), (17), (18), (19), (20), (21), and (22) below), and other related persons (purposes (5), (8), (9), (10), (13), (14), (16), (18), and (22) below). This collection and processing is required so that we can pursue our legitimate interests and provide you with adequate services and products.
(1) Requests for transactions between Customers, Etc. and the Company Group; verification of Customers, Etc.; deliberation and judgments concerning transactions; agreement execution; and performance, management, termination, and processing after termination of agreements
(2) Guidance related to products and services handled by the Company Group
(3) Verification and inquiries regarding products and services provided by trading partners
(4) Guidance regarding seminars, exhibitions, etc. held by the Company Group; verification of participation; communication with lecturers; and report of results, etc. to persons who cooperate in or participate in investigations or events
(5) Verification of visit or entry by persons visiting the Company Group
(6) Sending Company Group publications to persons requesting them; and sending emails to persons who subscribe to the Company Group’s email delivery services
(7) Requests regarding participation in customer satisfaction surveys and other similar surveys
(8) Responses to inquiries and requests from Customers, Etc.
(9) Implementation of measures that contribute to efficient communication between the Company Group’s shareholders and the Company Group in relation to exercise of rights and performance of duties under the Companies Act and other matters; creation, etc. of data in accordance with criteria prescribed by various laws and regulations; promotion of awareness and mutual understanding among the Company Group’s shareholders
(10) Communication with members of organizations that belong to the Company Group; and guidance from the Company Group in line with the purpose of activities by those organizations
(11) Communication with research institutions, etc. involved in the Company Group’s research and development activities; joint development agreements; matters corresponding to those in (1) above in relation to development services agreements; participation in academic societies; and recommendations for academic awards
(12) Patent applications together with joint applicants; and patent application management
(13) Communication with journalists, analysts, etc. in relation to the Company Group’s public relations activities
(14) Reception of candidate applications within the Company Group’s recruitment activities; communication with candidates; and notification of results of applications
(15) Communication, etc. with certified public accountants, attorneys, and patent attorneys necessarily related to the Company Group’s business activities
(16) Communication, etc. related to execution of duties within the Company Group apart from matters listed above
(17) Reliable presentation of contents on the Company Group’s websites using effective means
(18) Notification of policies and rules
(19) Monitoring of improper activities in order to improve safety and security; investigation of suspect actions, potentially suspect actions, or actions in violation of policies or rules
(20) Data analysis, research, auditing, etc.
(21) Account management for information systems used to achieve the purposes listed above
(22) Guidance from the Company Group incidental to the purposes listed above
We process your data for these specified, explicit, and legitimate purposes and do not further process the data in a way that is incompatible with these purposes. If we intend to process personal data originally collected for one purpose in order to achieve other objectives or purposes, we will ensure that you are informed of this. We keep your personal data for as long as necessary in order for us to comply with our legal obligations, to ensure that we provide an adequate service, and to support our business activities (Article 5 and Article 25(2) of the GDPR).
3. Types of Personal Data Used
- Telephone number
- Fax number
- Email address
- Name of employer
- Type of business
- Position title
- Native language
- IP address
- Provider information
- Browser information
- Access history
- Cookie data
- User ID and password
We obtain your personal data either directly from you when you provide that data to us (i.e., when you fill in forms displayed on our websites) or indirectly when that personal data is provided to us by your electronic communication terminal equipment or your Internet browser. We ensure that the personal data processed is adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.
4. Sharing of Your Personal Data
We share your personal data with companies in the Company Group and with third parties in accordance with the GDPR. If we share your data with a data processor, we will establish an appropriate legal framework for that transfer and processing (Articles 26, 28, and 29 of the GDPR). Furthermore, if we share your data with any company outside the EEA, we will establish appropriate legal frameworks, notably controller-to-controller (2004/915/EC) and controller-to-processor (2010/87/EU) Standard Contract Clauses approved by the European Commission, for that transfer (Articles 44. of the GDPR).
If you consent in advance, your personal data will be transferred to, stored, and further processed by strategic partners that work with us to provide our products and services or to assist in marketing for Customers, Etc. We currently share your personal data with the following strategic partners: [agents/distributors, suppliers]. Your personal data will only be shared by us with these companies in order to provide or improve our products, services, and advertising.
We share your personal data with companies that provide services on our behalf, such as hosting, maintenance, support services, email services, marketing, auditing, fulfilling your orders, processing payments, data analytics, providing customer service, and conducting customer research and satisfaction surveys. We currently share your personal data with vendors that provide the following services:
- Server maintenance
- IT system maintenance
- IT system development
- IT system operational assistance
- Planning for new companies
- Website planning and production
Corporate Affiliates and Corporate Restructuring
We share your personal data with all affiliates in the Company Group. In the event of a merger, corporate reorganization or civil rehabilitation, acquisition, joint venture, assignment, spin-off, transfer, sale, or disposal of all or any portion of our business, including in connection with any bankruptcy or similar proceedings, we will transfer any and all personal data to a relevant third party.
Legal Compliance and Security
In some instances, it will become necessary for the Company Group to disclose your personal data in accordance with law, legal proceedings, litigation, or requests from public and governmental authorities within or outside your country of residence. We will also disclose your personal data if we determine that, due to purposes of national security, law enforcement, or other issues of public importance, the disclosure is necessary or appropriate.
We will also disclose your personal data if we determine in good faith that disclosure is reasonably necessary to protect our rights, to pursue available remedies, to enforce our terms and conditions, to investigate fraud, or to protect our business or users.
In some instances, the disclosures stated above will involve transferring your personal data out of the EEA to the following countries: [Japan, USA, Canada, Brazil, Mexico, Taiwan, China, South Korea, Singapore, India, Thailand, Vietnam, Malaysia, Switzerland, Turkey, and Russia]. Those transfers are conducted for the following purposes: [(i) server maintenance; (ii) IT system maintenance; (iii) IT system development; (iv) IT system operational assistance; (v) planning for new companies; (vi) website planning and production; and (vii) alliances within the Company Group and with agents and distributors]. For each of these transfers, we provide an adequate level of protection for the data transferred, in particular by entering into standard contract clauses as defined by the European Commission decisions2004/915/EC and 2010/87/EU.
5. Company Group’s Records of Data Processes
We handle records of all processing of personal data in accordance with the obligations established by the GDPR (Article 30 of the GDPR), both when we act as a controller or as a processor. We reflect in these records all the information necessary in order to comply with the GDPR and cooperate with the supervisory authorities as required (Article 31 of the GDPR).
6. Security Measures
We process your personal data in a manner that ensures their appropriate security, including protection against unauthorised or unlawful processing, accidental loss, destruction, or damage. We use appropriate technical or organizational measures to achieve this level of protection (Article 25(1) and Article 32 of the GDPR).
7. Notification of Data Breaches to the Competent Supervisory Authorities
In case of breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed, we have established mechanisms and policies in order to identify the breach and assess it promptly. Depending on the outcome of our assessment, we will conducts the requisite notifications to the supervisory authorities and communications to the affected data subjects, which might include you (Articles 33 and 34 of the GDPR).
8. Processing Likely to Result in High Risk to Your Rights And Freedoms
We have established mechanisms and policies in order to identify data processing activities that result in high risk to your rights and freedoms (Article 35 of the GDPR). If any such data processing activity is identified, we will assess it internally and either stop it or ensure that the processing is compliant with the GDPR or that appropriate technical and organizational safeguards are established in order to proceed with that processing.
If there is any doubt, we will contact the competent Data Protection Supervisory Authority in order to obtain their advice and recommendations (Article 36 of the GDPR).
9. Your Rights
You have the following rights regarding personal data collected and processed by us.
- Information regarding processing of your data: You have the right to obtain from us all the requisite information regarding our data processing activities that concern you (Articles 13 and 14 of the GDPR).
- Access to personal data: You have the right to obtain from us confirmation as to whether personal data concerning you are being processed, and, if so, then access to the personal data and certain related information (Article 15 of the GDPR).
- Rectification or erasure of personal data: You have the right to have us rectify inaccurate personal data concerning you without undue delay and the right to have us complete any incomplete personal data (Article 16 of the GDPR). Also, if certain legal conditions are satisfied, you will have the right to have us erase personal data concerning you without undue delay (Article 17 GDPR).
- Restriction on processing of personal data: If certain conditions are satisfied, you will have the right to have us restrict processing of personal data concerning you (Article 18 of the GDPR).
- Objection to processing of personal data: If certain conditions are satisfied, you will have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you (Article 21 of the GDPR).
- Data portability of personal data: If certain conditions are satisfied, you will have the right to receive your personal data in a structured, commonly used, and machine-readable format and the right to transmit those data to another controller without our hindrance (Article 20 of the GDPR).
- Not to be subject to automated decision-making: If certain conditions are satisfied, you will have the right not to be subject to automated decision-making (including profiling) based on the processing of your personal data, insofar as such decision-making would produce legal or similar effects on you (Article 22 of the GDPR).
If you are not satisfied with the way in which we have handled any request, or if you have any complaint regarding the way in which we process your personal data, you can lodge a complaint with a Data Protection Supervisory Authority.
11. Links to Other Sites
We propose hypertext links that jump from our websites to third-party websites or other Internet sources. We do not control and cannot be held liable for third parties’ handling of personal data protection and their contents. Please read carefully their privacy policies to find out how they collect and process your personal data.
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- Web beacons
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IP addresses are discrete strings of digits that are assigned to an individual computer for the purpose of identifying that computer. It is used to specify the transmission source and recipient when sending and receiving data.
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- To improve the contents of websites, email, etc.
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- To use as statistical data in a form that does not identify individuals
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In addition, you can visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of browsers.
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