Our Privacy Policy
Privacy Policy
PATLITE CORPORATION
October 25, 2022
1.Introduction
PATLITE CORPORATION and its subsidiaries (collectively, “Patlite,” “we,” or “us”) take the protection of your “Personal Data”, data that can be used to personally identify you, very seriously. This Privacy Policy (“Policy”) explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected. Hence, we handle your personal data in compliance with the statutory data protection regulations and this Privacy Policy.
2.Personal Data we collect
Whenever you use this website, a variety of Personal Data will be collected. For example, we collect your Personal Data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form. Other Personal Data will be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g. web browser, operating system or time the site was accessed). This information is recorded automatically when you access this website. The following is an example of Personal data we collect.
(1) Data provided by you
Our website offers you the possibility to (i) make inquiries, request, or complaint to us; (ii) make job application, (iii) make subscription of our newsletter; (iv) interact with social medias; (v) purchase of our products and/or services as well as making of payment; and/or (vi) any other means and opportunity to provide us with your Personal Data directly. Through these means, we may obtain your Personal Data including but not limited to name, title, private and professional address, age, gender, date of birth, occupation, nationality, e-mail address, phone number, fax number provided therein. Please also note the following:
- If you submit job applications to us (e.g. via e-mail, via postal services on by submitting the online job application form). The information provided as well as any contact information will be stored by us. If your job application should result in your recruitment, the data you have submitted will be archived for the purpose of implementing the employment relationship in our data processing system. If we are unable to make you a job offer or you reject a job offer or withdraw your application, we reserve the right to retain the data you have submitted on the basis of our legitimate interests for up to 6 months from the end of the application procedure (rejection or withdrawal of the application) unless there is mandatory requirement under the laws applicable for us to retain such Personal Data. Within our company, your personal data will only be shared with individuals who are involved in the processing of your job application.
- If you enter information to the newsletter subscription form, information such as e-mail address and any other information you enter the form will be collected by us. After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings.
(2) Server log files
We automatically collect and store information in so-called server log files, which your browser communicates to us automatically. The information comprises but not limited to the following:
- The type and version of browser used
- The used operating system
- Referrer URL
- The hostname of the accessing computer
- The time of the server inquiry The IP address
This information is not merged with other data sources. Furthermore, this website is hosted by an external service provider (host). Personal data collected on this website are stored on the servers of the host. In order to guarantee processing in compliance with data protection regulations applicable, we have concluded an order processing contract with our host.
(3) Cookies
Our websites and pages use what the industry refers to as “cookies.” Cookies are small text files that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser.
In some cases, it is possible that third party cookies are stored on your device once you enter our site (third party cookies). These cookies enable you or us to take advantage of certain services offered by the third party (e.g. cookies for the processing of payment services).
Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of the cookies (e.g. the shopping cart function or the display of videos). The purpose of other cookies may be the analysis of user patterns or the display of promotional messages.
You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.
If third party cookies are used or if cookies are used for analytical purposes, we will separately notify you in conjunction with this Policy and, if applicable, ask for your consent.
(4) Personal Data from Social Media
We maintain publicly available profiles in social networks:
- We have a LinkedIn profile. The provider is the LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. LinkedIn uses advertising cookies. If you want to disable LinkedIn advertising cookies, please use the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out. For details on how they handle your Personal Data, please refer to LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy.
- We have a profile on YouTube. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Details on how they handle your personal data can be found in the YouTube privacy policy: https://policies.google.com/privacy?hl=en.
Social networks such as Facebook, Google+ etc. can generally analyze your user behavior comprehensively if you visit their website or a website with integrated social media content (e.g. like buttons or banner ads). When you visit our social media pages, numerous data protection-relevant processing operations are triggered. In detail:
- If you are logged in to your social media account and visit our social media page, the operator of the social media portal can assign this visit to your user account. Under certain circumstances, your personal data may also be recorded if you are not logged in or do not have an account with the respective social media portal. In this case, this data is collected, for example, via cookies stored on your device or by recording your IP address.
- Using the data collected in this way, the operators of the social media portals can create user profiles in which their preferences and interests are stored. This way you can see interest-based advertising inside and outside of your social media presence. If you have an account with the social network, interest-based advertising can be displayed on any device you are logged in to or have logged into.
Please also note that we cannot retrace all processing operations on the social media portals. Depending on the provider, additional processing operations may therefore be carried out by the operators of the social media portals. Details can be found in the terms of use and privacy policy of the respective social media portals.
If you visit one of our social media sites (e.g., Facebook), we, together with the operator of the social media platform, are responsible for the data processing operations triggered during this visit. You can in principle protect your rights (information, correction, deletion, limitation of processing, data portability and complaint) vis-à-vis us as well as vis-à-vis the operator of the respective social media portal (e.g. Facebook).
Please note that despite the shared responsibility with the social media portal operators, we do not have full influence on the data processing operations of the social media portals. Our options are determined by the company policy of the respective provider.
Please also note that we cannot retrace all processing operations on the social media portals. Depending on the provider, additional processing operations may therefore be carried out by the operators of the social media portals. Details can be found in the terms of use and privacy policy of the respective social media portals.
3. Legal Basis
If the laws and regulation applicable allows us to process the Personal Data, we rely on consent as legal basis of processing. You can also revoke at any time any consent you have already given us. This will be without prejudice to the lawfulness of any data collection that occurred prior to your revocation. Nonetheless, when GDPR or UK GDPR are applicable, or if consent is not sufficient as legal basis of processing in question, we rely on the following basis.
Data collected in relation to | Purpose | Legal Basis |
---|---|---|
Inquiries, request or complaint | For managing your inquiries, request or complaint |
|
Job Application | For making a decision concerning the establishment or an employment relationship; implementing the employment relationship in our data processing system. | For execution of the contract or for pre-contractual measures if it is necessary to carry out such. |
Server log files | For technically error free depiction and the optimization of our website | Legitimate interest in the technically error free depiction and the optimization of our website. |
Hosting | The host is used for the purpose of fulfilling the contract with our potential and existing customers and in the interest of secure, fast and efficient provision of our online services by a professional provider. |
|
Cookies | For the performance of electronic communication transactions (required cookies) or the provision of certain functions you want to use (functional cookies, e.g. for the shopping cart function) or the optimization of the website | Legitimate interest in the storage of cookies to ensure the technically error free and optimized provision of our services. |
Data Collected from social media | For improving our market presence on the Internet | Legitimate interest in making our social media appearances ensure the widest possible presence on the Internet. |
Google Analysis | For analyzing user patterns to optimize both, the services offered online and our advertising activities | Legitimate interest in the analysis of user patterns to optimize both, the services offered online and our advertising activities. |
4. Who is the responsible party for the processing of data on this website?
The data controller on this website is:PATLITE CORPORATION
4-1-3, Kyutaromachi, Chuo-ku, Osaka 541-0056 Japan
Phone: +81-6-7711-8953
E-mail: overseas@patlite.co.jp
5. Retention Period
Personal Data processed in accordance with this Policy will remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.
6. Protection of your Personal Data
For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.
If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.
7. Your rights
To the extent granted under the laws and regulations applicable, you have the following right in relation to Personal Data we handle.
(1) Right to be informed and access
Within the scope of the applicable statutory provisions, you have the right to at any time demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data.
(2) Right to rectify and eradicate data
You have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time at the address provided in section “Information Required by Law.”
(3) Right to demand processing restrictions
You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time at the address provided in section “Information Required by Law.” The right to demand restriction of processing applies in the following cases:
- In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
- If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data in lieu of demanding the eradication of this data.
- If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
- If you have raised an objection, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.
If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.
(4) Right to data portability
You have the right to demand that we hand over any data we automatically process on the basis of your consent or in order to fulfil a contract be handed over to you or a third party in a commonly used, machine readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.
(5) Right to object to the collection of data in special cases; right to object to direct advertising
You have the right to at any time object to the processing of your personal data based on grounds arising from your unique situation. This also applies to any profiling based on these provisions. To determine the legal basis, on which any processing of data is based, please consult this privacy policy.
If you log an objection, we will no longer process your affected personal data, unless we are in a position to present compelling protection worthy grounds for the processing of your data, that outweigh your interests, rights and freedoms or if the purpose of the processing is the claiming, exercising or defence of legal entitlements.
If your personal data is being processed in order to engage in direct advertising, you have the right to at any time object to the processing of your affected personal data for the purposes of such advertising. This also applies to profiling to the extent that it is affiliated with such direct advertising. If you object, your personal data will subsequently no longer be used for direct advertising purposes.
(6) Right to log a complaint with the competent supervisory agency
In the event of violations of the laws and regulations applicable, you are entitled to log a complaint with a supervisory agency. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.
8. Transfer of Personal Data
- Your Personal Data may be stored to our server located in Japan. Your Personal Data may become accessible by our subsidiaries around the world which are listed at our website https://www.patlite.com/company/network.html. We will transfer or jointly use such Personal Data for the purpose stated in Section 3 of this Policy of which we will supervise appropriate use of such Personal Data by our subsidiaries. We will transfer Personal Data only in compliance with laws and regulations applicable.
- Our website uses, in particular, tools from companies based in the USA. When these tools are active, your Personal Data may be transferred to the US servers of these companies. We must point out that the USA is not a safe third country within the meaning of EU data protection law. US companies are required to release personal data to security authorities without you as the data subject being able to take legal action against this. The possibility cannot therefore be excluded that US authorities (e.g. secret services) may process, evaluate and permanently store your data on US servers for monitoring purposes. We have no influence over these processing activities.
9. Google Analytics
This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics enables the website operator to analyze the behavior patterns of website visitors. To that end, the website operator receives a variety of user data, such as pages accessed, time spent on the page, the utilized operating system and the user’s origin. Google may consolidate these data in a profile that is allocated to the respective user or the user’s device.
Google Analytics uses technologies that make the recognition of the user for the purpose of analyzing the user behavior patterns (e.g. cookies or device fingerprinting). The website use information recorded by Google is, as a rule transferred to a Google server in the United States, where it is stored.
(1) IP anonymization
On this website, we have activated the IP anonymization function. As a result, your IP address will be abbreviated by Google within the member states of the European Union or in other states that have ratified the Convention on the European Economic Area prior to its transmission to the United States. The full IP address will be transmitted to one of Google’s servers in the United States and abbreviated there only in exceptional cases. On behalf of the operator of this website, Google will use this information to analyze your use of this website to generate reports on website activities and to render other services to the operator of this website that are related to the use of the website and the Internet. The IP address transmitted in conjunction with Google Analytics from your browser will not be merged with other data in Google’s possession.
(2) Browser plug-in
You can prevent the recording and processing of your data by Google by downloading and installing the browser plugin available under the following
link: https://tools.google.com/dlpage/gaoptout?hl=en.
For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en.
(3) Contract data processing
We have executed a contract data processing agreement with Google and are implementing the stringent provisions of the German data protection agencies to the fullest when using Google Analytics.
(4) Demographic parameters provided by Google Analytics
This website uses the “demographic characteristics” function of Google Analytics, to be able to display to the website visitor compatible ads within the Google advertising network. This allows reports to be created that contain information about the age, gender and interests of the website visitors. The sources of this information are interest-related advertising by Google as well as visitor data obtained from third party providers. This data cannot be allocated to a specific individual. You have the option to deactivate this function at any time by making pertinent settings changes for advertising in your Google account or you can generally prohibit the recording of your data by Google Analytics as explained in section “Objection to the recording of data”. Archiving period
Data on the user or incident level stored by Google linked to cookies, user IDs or advertising IDs (e.g. DoubleClick cookies, Android advertising ID) will be anonymized or deleted after 26 month. For details please click the following
link: https://support.google.com/analytics/answer/7667196?hl=en
10. Amendment
We reserve the right to amend this Policy from time to time.
JURISDICTION-SPECIFIC ADDENDUM – SINGAPORE
April 18, 2024
This Addendum is applicable in a subsidiary manner for the processing of Personal Data
of users in Singapore, in accordance with the data protection law and other applicable
regulations.
This Addendum forms part of the Privacy Policy.
If there is any consistency between the terms in this Addendum and the Privacy Policy, the former
prevails.
1. Overview
- 1.1
- We, PATLITE CORPORATION (references herein to “we”, “us” and “our” are to PATLITE CORPORATION, and its subsidiaries or related companies (including PATLITE(SINGAPORE) PTE LTD (“Patlite Singapore”)) and their service providers and agents collectively), are committed to ensuring the safety and security of your personal data.
- 1.2
- The purpose of this Privacy Policy and this Addendum is to inform you as to how we manage, collect, use and/or disclose personal data for compliance with the Personal Data Protection Act 2012 of Singapore (the "PDPA").This Addendum supplements the Privacy Policy to the extent that the PDPA applies in relation to our collection, use and/or disclosure of your personal data. We conduct our business in compliance with the PDPA and have implemented various measures to ensure that any personal data we collect, use and/or disclose remains safe and secure.
- 1.3
- Unless otherwise defined, capitalised terms used in this Addendum shall bear the same meanings ascribed to them in the Privacy Policy.
- 1.4
- Subject to paragraph 1.5 below, your continued access and use of our services ("Patlite Services") as our customer or client, or your continued employment with us as our employee (as the case may be) shall constitute your agreement to our collection, use and/or disclosure of your Personal Data in accordance with the Privacy Policy and this Addendum and any applicable laws.
- 1.5
- If you are under the age of 21, your parent or legal guardian’s consent shall be required to consent to our collection, use and/or disclosure of your Personal Data.
2. Personal Data
In the Privacy Policy and this Addendum, "Personal Data" refers to any data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.
3. Collection of Personal Data
The Personal Data that we may collect from you includes, without limitation, your Personal Data falling within the categories set out under section 2.(1) of the Privacy Policy, which consists of the following particulars:
- 3.1
- if you are a customer
- details of personal identification documents (NRIC, passport, etc); and
- any other Personal Data necessary for us to provide the Patlite Services.
- 3.2
- if you are our employee (in addition to the above)
- performance evaluation and grading information;
- health information (medical history, surgical history, medical examination result etc.);
- salary information and bank account details;
- details of next-of-kin, spouse and other family members; and
- any other Personal Data necessary for us to manage your employment relationship with us.
4. Use of Personal Data
- 4.1
- We may collect, use and/or disclose Personal Data for the following purposes which includes, without limitation, purposes set out under section 3 of the Privacy Policy:
- 4.1.1
- if you are a customer
- providing the Patlite Services;
- data analytics;
- security and risk management;
- legal, regulatory and other compliance requirements (including providing assistance to law enforcement, judicial, regulatory or other government agencies and statutory bodies);
- for marketing and advertising, and in this regard, to send you by various modes of communication marketing and promotional information and materials relating to products and/or services (including, without limitation, products and/or services of third parties) that we may be marketing or promoting, whether such products or services exist now or are created in the future;
- other work and business related requirements;
- any other purposes set out in the Privacy Policy; and
- any other purposes which we notify you of at the time of obtaining your consent,
- 4.1.2
- if you are our employee or a potential employee (in addition to the above, where applicable)
- assessing and evaluating your suitability for employment in any position with us;
- implementing the employment relationship in our data processing system;
- performing our obligations under or in connection with your employment/engagement with us, (including, without limitation, payment of remuneration, Central Provident Fund (CPF) contributions and tax (where appliable));
- administrative and human resources related matters within Patlite Singapore, (including, without limitation, application for or renewal of work passes with the Ministry of Manpower (MOM), administering payroll, granting access to Patlite Singapore’s premises and computer systems, processing leave applications, administering insurance and other benefits, processing of claims and expenses and developing human resource policies, etc);
- managing and terminating your employment relationship with us, (including, without limitation, investigating any acts or defaults (or suspected acts or defaults) and/or conducting disciplinary arrangements, etc);
- providing resources and assistance in connection with the performance of duties, including training and staff development programs;
- assessing and evaluating your performance and/or suitability for continued employment with us; and
- any other purpose reasonably related to the aforesaid purposes.
5. Disclosure of Personal Data
- 5.1
- We may share and disclose Personal Data with:
- the relevant parties and in the manner set out in the Privacy Policy;
- partners, licensors, vendors, agents, contractors or third party service providers who provide services to us including but not limited to insurance, consultancy, courier services, telecommunications, IT, payment, printing, billing, payroll processing, technical services, training, market research, call centre, security or other such services to us;
- in the event of an actual or prospective business asset transaction (such as any merger, acquisition or asset sale), any business partner, investor, assignee, or transferee for the purposes of facilitating such a transaction; and/or
- any relevant government regulators, statutory boards or authorities or law enforcement agencies as required by any laws, rules, guidelines and regulations or schemes imposed by any government bodies and/or authorities
6. Accuracy and Updating of Personal Data
You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Further, when you provide us with any Personal Data relating to a third party (including your next-of-kin, spouse, other family members and/or other employees), you represent and warrant to us that you have obtained the consent of the third party to provide us with their Personal Data unless otherwise provided in accordance with the PDPA.
7. Access to Personal Data and Respecting Individual’s Consent
- 7.1
- If you wish to access the Personal Data that we have relating to you, inquire about the way in
which Personal Data relating to you has been used or disclosed by us in the past year, or wish to
withdraw your consent to our collection, use or disclosure of such Personal Data, you may contact
our Data Protection Officer (whose contact is set out under section 4 of the Privacy Policy) and
we will seek to attend to your request as best as we reasonably can.
- in order for us to provide any personal data we will need to verify your identity and may request further information about your request;
- we may refuse access to your Personal Data if it would affect the privacy rights of other persons or if it breaches any confidentiality that attaches to that information;
- we may also refuse your request where we are legally permitted to do so and give you such reasons for our refusal;
- you should be aware that we may take a reasonable time to process your application for access as we may need to retrieve information from storage and review the information in order to determine what information may be provided; and
- we may have to charge you a reasonable administrative fee for to verify, investigate or review your request to access Personal Data relating to you. For the avoidance of doubt, we will not charge you a fee in respect of your request to correct and/or update your Personal Data.
- 7.2
- For the avoidance of doubt, if we refuse to grant you access to your Personal Data, we shall preserve a complete and accurate copy of the Personal Data for a period of 30 days after the date which we notify you of our refusal to do so.
8. Security of Personal Data
Safeguarding and respecting the confidentiality of Personal Data is important to us. We will use our best efforts to protect Personal Data. The Personal Data provided to us are stored on secure servers with security measures in place to protect against the loss, unauthorized access or alteration, or misuse of such information
9. Retention of Personal Data
- 9.1
- We will only retain Personal Data for only as long as:
- the retention of the Personal Data continues to serve any Purpose; and
- there is a business or legal need.
- 9.2
- In the event that retention of Personal Data is no longer necessary for any business or legal purposes or when the purpose for which the Personal Data was collected is no longer being served by the retention of the Personal Data or should you withdraw your consent to our use of the Personal Data in accordance with paragraph 7 above, we will remove, destroy or anonymise the Personal Data.
10. Transfer of Personal Data Outside Singapore
- 10.1
- Your Personal Data may be transferred to, stored or processed outside of Singapore.
- 10.2
- We will only transfer your information overseas in accordance with the PDPA and will ensure that overseas organisations we work with observe strict confidentiality and are subject to data protection obligations.
- 10.3
- In particular, we will ensure that the overseas organisations we transfer your Personal Data to will provide a standard of protection comparable to the protection under the PDPA, including by ensuring that such requirement is included in binding contracts with the recipients of the Personal Data so transferred or ensuring that such requirement is included in binding internal policies of Patlite where the recipient will be a Patlite group company.
11. Enquires and Making a Complaint
- 11.1
- If you believe that we have breached the Privacy Policy and this Addendum, or any other applicable privacy or data protection laws or regulations which may apply to us, you should make a complaint to us in the first instance. You should address your complaint in writing to our Data Protection Officer (whose contact is set out under section 4 of the Privacy Policy), and you should include as much detail as you can about the Personal Data affected, and the circumstances that you believe amount to a breach of the Privacy Policy, this Addendum or the PDPA.
- 11.2
- If you have any questions about the Privacy Policy and this Addendum or concerns about our commitment to your privacy, please feel free to email or write to the Data Protection Officer (whose contact is set out under section 4 of the Privacy Policy).