About Personal Information Protection

Astemo, Ltd. (henceforth, "Astemo" or “our Company”) provides total solutions and handles various information as a global supplier, including its technical information and information provided by customers. Hence, Astemo has strived to establish and fully enforce an information management system to respect the value of said information.

With this background, Astemo endeavors to create rules and establish a management system to protect personal information protection in Astemo, as well as to set a personal information protection policy and spread it among board members and employees. Moreover, Astemo will take measures to make its personal information protection policy easily accessible to the general public.

Astemo will strive to protect personal information appropriately based on this policy.

Astemo complies with Japan's Act on the Protection of Personal Information, as well as other applicable personal information protection and privacy protection laws and regulations in countries or regions—including but not limited to the EU General Data Protection Regulation (EU GDPR), UK General Data Protection Regulation (UK GDPR), and California Consumer Privacy Act (CCPA) (hereinafter collectively referred to as the “Applicable Laws”)—and strives to handle personal information appropriately.

Establish rules for managing personal information protection and make continual improvements.Astemo will make sure that executive staff and workers recognize the importance of personal information protection, establish rules for personal information management to appropriately use and protect personal information, and ensure that the implementation of the management system. These rules will be maintained and improved upon continually.

This "About Personal Information Protection" page establishes Astemo's procedures for handling personal information.

This policy applies to all personal information acquired and managed by our Company, both within and outside Japan. We will comply with the Applicable Laws and implement appropriate protective measures. We will also handle the rights of persons in accordance with the Applicable Laws.

Astemo shall define that personal information means information about an individual that is defined as personal information under the Applicable Laws.

Astemo protects and manages the personal information by establishing a manager on a department basis with the greatest care and the best effort based on the“Astemo personal information protection policy.”
In addition, from the viewpoint of the protection of the rights and interests of the Data Subjects, Astemo shall make efforts to consider the following points.

Prompt and appropriate response to the exercise of rights by the Data Subjects.

Whether information is entrusted to others or not, promoting the clarification of outside processing, such as clarifying the details of work done outside the business by outsourcers.

Clarifying the purpose of use more to the Data Subjects through activities such as the business voluntarily limiting the purpose of use based on the selections of the Data Subjects, or the business limiting and showing the purpose of use by type with consideration to the details of the work.

Specifying as concretely as possible where the personal information was acquired from and the method of acquisition (the type of acquisition source, etc.) for the exercise of rights by the Data Subjects.

In relation to Astemo's business activities, Astemo will collect and use personal information only to achieve the following:

• (a)

  Execution of a contract concluded between Astemo and a customer.

• (b)

  Contacts for business negotiations and meetings with a customer.

• (c)

  Delivery of after-sales service on products, and sending information regarding events and new products.

• (d)

  Execution of business, including system development, operation and maintenance, which are entrusted by customers.

• (e)

  Delivery of various membership services.

• (f)

  Business matters pertaining to stocks.

• (g)

  Response to various customer inquiries.

• (h)

  Analysis based on questionnaires to improve products and services.

• (i)

  Provision of personal information to the group company in instances of co-operation with the group company.

• (j)

  Security and safety management by using security cameras and/or any other equivalent devices.
  For each of the above items, when Astemo requests that a person provides personal information directly in writing (including electronic means such as the web or email), Astemo will clearly state the purpose of collection and use in advance.

Astemo may provide personal information to third parties in the following cases:

• (a)

  Disclosure to Group Companies
  • Astemo may provide the personal information, such as a name, workplace and home addresses, telephone number, fax number, and email address, to Astemo’s group companies when necessary for conducting joint business activities. In such cases, the personal information will be provided via print or electronic media. The person may request Astemo to stop the provision of the personal information to Astemo’s group companies.

• (b)

  Disclosure to Third Parties Outside the Group Companies
  Astemo may disclose personal information to third parties as required by the Applicable Laws, or to Astemo’s employees, contractors, designated agents (including attorneys and accountants), or third-party service providers.

• (c)

  Disclosure to third parties other than those specified in (a) and (b) above
  •Astemo may disclose personal information for the following purposes when permitted or required by the Applicable Laws:
  •To protect Astemo's rights and assets
  •When necessary to protect human safety in an emergency
  • When a business transfer or change in company ownership occurs, and disclosure is necessary to complete the transaction
  •For other purposes where consent is required by laws and regulations and the person has provided consent

To operate as an organization that ensures proper handling of personal information, top executives have formulated the Personal Information Protection Policy and developed internal rules such as Regulations and Guidelines for Personal Information Management, in accordance with the basic policies stipulated in the Personal Information Protection Policy. Moreover, Astemo has established a system to confirm and evaluate whether its rules conform to the Applicable Laws. Besides developing such regulations, Astemo is taking concrete safety management measures from four specific aspects (systematic, personal, physical, and technical) in handling personal information.
Astemo retains personal information only for the period necessary to process such information. However, if the Applicable Laws require retention for a longer period, Astemo will retain the personal information for the period specified by such Applicable Laws.

Astemo will implement appropriate safeguards in accordance with the Applicable Laws when transferring a person's personal information outside the country or region where the person resides.

For convenience of use, Astemo uses cookies^*1 and web beacons (clear GIFs)^*2 in the website.
A person can refuse to receive a cookie, or can change the web browser settings to have a warning message displayed when receiving a cookie. For more details, please refer to the instructions of the web browser a person is using. Moreover, a person can reject a web beacon by refusing the receipt of a cookie.
However, please note a person may not be able to use part or all of our　Company’s services provided in the website when rejecting a cookie.

*For individuals residing in countries or regions where the Applicable Laws require the explicit prior consent for the use of cookies (including but not limited to the European Union), Our company has implemented a mechanism to obtain such explicit consent in advance of any cookie usage

Regarding the personal information Astemo holds about a person: If the person wants to exercise his/her rights (as defined by the Applicable Laws, which may include disclosure, correction, addition, deletion, suspension of use, cessation of provision to third parties, notification of the purpose of use, or disclosure of records of provision to third parties) or submit a complaint, please follow the procedures below.

• Exercising rights regarding personal information that a person submitted to an Astemo's sales department: Please contact the relevant sales department.

While most of Astemo's services can be used without disclosing personal information, please note that some services are only available with the submission of the personal information.

Please note that Astemo is not responsible for the security of personal information of any non-Astemo web site whose link is included in the Astemo's web site.

If a person enters personal information on Astemo's website, he or she is required to agree upon the provisions in the "About Personal Information Protection" page, otherwise the person will not be able to use our Company’s services (including response to inquiries). Also, if a person is age 14 or younger, please enter the personal information with the consent of a parent or guardian.

Astemo may revise the "About Personal Information Protection" page to improve the handling of personal information and/or due to the revision of laws or ordinances, or other rules or regulations.

The implementation of this "About Personal Information Protection" page shall be after the issued date (or revised date).

If each Astemo website has its own personal information policy, this policy shall supersede the provisions of any other policies in the Astemo websites.

For inquiries about this page (About Personal Information Protection), please fill out the inquiry form in the linked page below.

For residents in Japan, please see the following in addition to the above