Privacy Policy

Personal Information Protection Policy

Saison Technology Co., Ltd., Saison Technology China Co., Ltd., Saison Technology Singapore Pte. Ltd. and Saison Technology Intermational, Inc.  (collectively, the "Saison Technology Group") retain various types of data in the course of their businesses. Among such data, the Saison Technology Group recognizes that personal information, specific personal information (which is defined under the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures as personal information which contains individual numbers) and personally referable information (which is defined under the Act on the Protection of Personal Information as information relating to a living individual which does not fall under personal information, pseudonymously processed information or anonymously processed information) are extremely important matters which need to be handled with care.

Problems such as information leakage from the Saison Technology Group would not only cause significant inconvenience to the individuals concerned, but would also impair such individuals’ rights as information subjects. Therefore, the Saison Technology Group places the highest priority on the protection of personal information, specific personal information and personally referable information.

The Saison Technology Group has established the following provisions for processing personal information, specific personal information and personally referable information, and strives to properly protect personal information through the implementation of these provisions.

Any reference to personal information in the following provisions for processing the same shall include reference to specific personal information.

[Acquisition, Use and Provision of Personal Information]

The Saison Technology Group shall clarify the purposes of use of personal information and acquire the same through proper methods. Such personal information shall be processed within the scope of the purposes of use thereof, and shall not be provided to any third parties without the prior consent of the individuals concerned.

[Security Management of Personal Information]

The Saison Technology Group shall appoint an administrator responsible for information security and shall implement security management measures to prevent unlawful access to, or unauthorized use, provision, loss, destruction, alteration, or leakage of, personal information. When consigning the processing of personal information to any third party, the Saison Technology Group shall exercise the necessary and proper supervision over such consignee.

For details concerning the system for the acquisition of personal information by the Saison Technology Group and measures taken in relation thereto, please make contact at the contact point set forth in "Contact Point for Inquiry on the  Personal Information Protection Policy" below.

[Compliance with Laws and Regulations and Other Standards]

The Saison Technology Group shall comply with any provisions concerning the protection of personal information and any other applicable laws and regulations.

[Responses to Complaints and Consultations]

The Saison Technology Group shall clarify in advance how to respond to, and the contact point for, complaints and consultations concerning the processing of personal information, and shall sincerely respond to the same.

[Continual Improvement]

In order to prevent its policies from becoming outdated due to changes in the environment and to respond to new threats, the Saison Technology Group shall revise such policies on a regular basis.

Prepared: July 5, 1999
Revised: June 21, 2022
Makoto Hayama
President

Contact Point for Inquiry on the  Personal Information Protection Policy

Contact:

Takashi Katagiri,
Data Protection Officer

Saison Technology Co., Ltd.
Quality Management Department
19F, Akasaka Intercity AIR, 1-8-1 Akasaka, Minato-ku, Tokyo 107-0052, Japan
Email Address : is_receipt@saison-technology.com
Telephone Number : +81 3 6370 2000

Efforts Toward Personal Information Protection

Publication matters based on the Personal Information Protection Act

Purposes of Use of Personal Information Acquired

The purposes of use of personal information acquired by Saison Technology Co., Ltd. ,Saison Technology China Co., Ltd. ,Saison Technology Singapore Pte. Ltd. and Saison Technology International, Inc.(Hereinafter referred to as "the Saison Technology Group")  (the "Purposes of Use") shall be as follows:

Type of Personal Information Purpose of Use

1.Customers

  • To provide the Saison Technology Group’s products and maintenance services based on a contract;
  • To make contact as necessary in the course of business based on a contract;
  • To provide various notices relating to exhibitions and seminars, etc. held by the Saison Technology Group;
  • To provide various notices and conduct questionnaire surveys relating to the Saison Technology Group’s products and services; and
  • To respond to inquiries and requests from customers.

*In the case of inquiries made by telephone, the call may be recorded in order to ensure an accurate response is provided. 

2.Shareholders

  • To make confirmation and send materials in accordance with the Companies Act.

3.Investors and analysts

  • To provide various notices, such as notices of financial results briefings.

4. Employment applicants

  • To make confirmation of applicants and to provide notices of an interview, notices of the results of employment examinations and notices relating to preparations for joining the company.

5.Dispatched workers

  • To accept workers in accordance with the Act for Securing the Proper Operation of Worker Dispatching Undertakings and Improved Working Conditions for Dispatched Workers.

6.Employees/Boards/Officers

  • To business communication, various procedures based on laws and regulations, payroll-related operations, social insurance-related procedures, provision of welfare benefits, and other labor management.
  • To responding to inquiries and requests after retirement.

7.Personal information received upon consignment of processing

  • To implement information processing services based on a consignment agreement with a consignor.

*Items 1 through 6 are retained personal data of the Saison Technology Group.

Provision to Third Parties

The Saison Technology Group shall not provide personal information to any third party without the prior consent of the individuals concerned, unless any of the following applies or such provision is otherwise permitted by applicable laws or regulations:

  • Such provision is conducted in accordance with applicable laws or regulations;
  • Such provision is necessary for the protection of the life, body or property of any individual, and it is difficult to obtain the consent of such individual;
  • Such provision is specifically necessary for improving public health or promoting the sound growth of children, and it is difficult to obtain the consent of the relevant individual; or
  • Such provision is necessary for cooperating with a state organ or local government, or its third-party service provider in executing any affairs prescribed by applicable laws or regulations, and obtaining the consent of the relevant individual threatens to impede the execution of such affairs. 

Consignment of Personal Information Processing

The Saison Technology Group may consign the processing of personal information acquired thereby to any third-party service provider within the scope necessary for achieving the Purposes of Use. The Saison Technology Group shall consign such processing to third-party service providers who meet the Saison Technology Group’s standards for selecting consignees, and shall exercise the necessary and proper supervision over such consignees.

Personal Information Retention Period

Where you have entered into a contract with the Saison Technology Group concerning the Saison Technology Group’s products or maintenance services, etc., the Saison Technology Group shall retain your personal information for five (5) years after the termination of such contract, or otherwise for five (5) years after the last communication between you and the Saison Technology Group; provided, however, that the same shall not apply if a longer retention period is obligated or permitted by any applicable laws or contracts, etc.

Procedures in Response to Requests for Disclosure, etc.

The Saison Technology Group shall sincerely respond to any request you make for the following, in accordance with applicable laws and regulations: (i) notification of the Purposes of Use; (ii) disclosure, revision or suspension of use of the retained personal data that can identify you; or (iii) disclosure of records provided by third parties. The procedures are as follows:

  1. Make contact at the contact point for inquiries and complaints.
  2. We will send you the prescribed documents as necessary. Please fill them in and send them back to us.
  3. After confirming your request, we will respond either in writing or by email. 

Processing of Personal Information of EEA Residents

Personal information (meaning information relating to an identified or identifiable natural person (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) of residents in the European Economic Area (the "EEA") shall be processed in accordance with the General Data Protection Regulation (the "GDPR"), and the following provisions shall also apply thereto.

1.Legal Basis for Processing Personal Information

The Saison Technology Group shall process your personal information within the scope necessary for achieving the Purposes of Use based on your consent to this Personal Information Protection Policy. The Saison Technology Group shall also process your personal information within the scope necessary for achieving the Purposes of Use in the case where the Saison Technology Group’s processing of your personal information meets any of the following requirements:
(1) Such processing is necessary for the performance of a contract to which you are a party or in order to respond to your request prior to entering into a contract; or
(2) Such processing is necessary for the purposes of the legitimate interests pursued by the Saison Technology Group or any third party (including, without limitation, interests such as those pertaining to the provision of services by the Saison Technology Group, consideration of whether to employ employment applicants, and labor management).

Where provision of your personal information is mandatory and you choose not to provide the same, then the Saison Technology Group will not be able to provide you with the relevant services.

You may withdraw your consent via the contact point for inquiries and complaints provided below; provided, however, that the consent which you have provided for the Saison Technology Group’s collection, use and provision of your personal information will remain valid until such time as this consent is withdrawn by you.

2.Disclosure of Personal Information

Companies in the Saison Technology Group may disclose your personal information to other companies within the Saison Technology Group, in order to achieve the Purposes of Use. Companies in the Saison Technology Group which the Saison Technology Group discloses your personal information to may be located outside the EEA (including, without limitation, Japan and the U.S.; the same shall apply hereinafter). In this case, you shall be deemed to have agreed to the following matters by providing consent to this Personal Information Protection Policy:
(1) In the case where the recipient of your personal information is located in a country outside the EEA, such country does not have any data protection laws which are equivalent to those in the EEA, i.e., many of the rights granted to data subjects in the EEA are not granted in such country; 
(2) Your personal information shall be acquired and processed by the recipients for achieving the Purposes of Use; and
(3) Your personal information shall be disclosed to the recipients located outside the EEA.

The Saison Technology Group complies with its legal obligations and takes proper measures for the protection of your personal data. With regard to the transfer of your personal data to countries outside the EEA, the Saison Technology Group protects your personal data by using the Standard Contractual Clauses. For copies of the Standard Contractual Clauses, please make contact with the Saison Technology Group via the contact point for inquiries and complaints.

Your Rights Under the GDPR

You have the right to request the Saison Technology Group: (i) for a copy of your personal information; (ii) to revise, delete or restrict the processing (suspend the use) of your personal information; and (iii) to provide you with the personal information you have provided to the Saison Technology Group for a contract or based on your consent, in a structured, machine-readable format.

In addition, you may object to the processing of your personal information in certain circumstances (in particular, where the Saison Technology Group is processing the information for direct marketing purposes).

However, these rights may be limited, for example if fulfilling your request would reveal personal information of a third party or would infringe upon the rights of a third party (including the Saison Technology Group’s rights), or if the Saison Technology Group is required by law to retain or has legitimate interests in retaining your personal information. Relevant exemptions are included in applicable laws on privacy. The Saison Technology Group will inform you of the relevant exemptions which the Saison Technology Group relies upon when responding to any request you make.

If you wish to exercise any of these rights, please contact the Saison Technology Group via the contact point for inquiries and complaints provided below. If you have any unresolved concerns, you may lodge a complaint with an EU data protection authority having jurisdiction over the area in which you live or work, or where you believe a breach may have occurred.

Processing of Personal Information of U.S California Residents

The following supplementary provisions apply to the processing of personal information (any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household; the same shall apply to these supplementary provisions hereinafter) of U.S. California residents in accordance with the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA; collectively, the “California Privacy Laws”).

 

Information Collected by the Saison Technology Group

The Saison Technology Group has collected in the last twelve (12) months and will continue to collect the following categories of personal information from you for the purposes stated in “Purposes of Use of Personal Information Acquired.”

Category Examples

Identifiers

Name, email address, telephone number, domain information, ID and password, internet protocol address, JSON Web Token, cookies

Commercial information

Payment information for usage fees (credit card information, etc.) and inquiries sent to the Saison Technology Group

Internet or other electronic network activity information 

Request history

Professional or employment-related information 

Information regarding the department in or company by which you are employed (company name, address, telephone number) 

Sensitive personal information 

ID and password 

Disclosure of Personal Information

The Saison Technology Group may disclose your personal information (including sensitive personal information; the same shall apply to these supplementary provisions hereinafter) to third parties for business or commercial purposes. When disclosing personal information to a service provider or contractor for such purpose, the Saison Technology Group executes an agreement that indicates such purposes and requires that the service providers or contractors keep such personal information confidential and not use personal information for any purpose except performing such agreement.

The Saison Technology Group has shared or disclosed personal information to the following categories of third parties for business or commercial purposes during the last twelve (12) months: 

  • Saison Technology Group companies (https://www.saison-technology.com/company/group.html);
  • Third parties that provide services to the Saison Technology Group (such as providers of cloud services in which data of the Saison Technology Group services is processed and stored);
  • Competent authorities as set forth under applicable laws and regulations (including courts and other public authorities that have jurisdiction over the Saison TechnologyGroup); and
  • Any other third parties who may reasonably require access to your personal information in connection with the foregoing purposes.

Sale or Sharing of Personal Information

The Saison Technology Group has not sold or shared any personal information in the preceding twelve (12) months.

In these supplementary provisions, the term “sale” means disclosing, etc. your personal information to a third party for monetary or other valuable consideration, and the term “sharing” means disclosing your personal information to a third party for cross-text behavioral advertisements, regardless of monetary or other valuable consideration.

Retention of Personal Information

The Saison Technology Group will retain your personal information to the extent necessary for the purposes stated in “Purpose of Use of Personal Information to be Acquired.”

The criteria for determining the Saison Technology Group retention period includes, but is not limited to: (i) the duration of the contractual relationship between you and the Saison Technology Group; (ii) the legal obligations assumed by the Saison Technology Group; and (iii) a need to perform an agreement to which you are a party.

Your Rights and Choices Under the California Privacy Laws

The California Privacy Laws grant rights regarding personal information to consumers who are residents of California. The following describes your rights and how to exercise those rights under the California Privacy Laws.

(1) Right to Access Specific Information

You have the right to request that the Saison Technology Group disclose certain information to you in relation to the collection, sharing, disclosure, or use of your personal information by the Saison Technology Group over the twelve (12)months preceding the date of your request. Upon receipt and confirmation of your verifiable consumer request, the Saison Technology Group will disclose to you any or all of the following information:

  • The categories of your personal information that the Saison Technology Group has collected;
  • The categories of sources of your personal information from which the Saison Technology Group has collected;
  • The business or commercial purpose of the Saison Technology Group for the collection, sale, or sharing of such personal information;
  • The categories of third parties the Saison Technology Group discloses, sells, or shares such personal information;
  • The categories of your personal information that the Saison Technology Group has disclosed, sold, or shared to each; and
  • The specific pieces of your personal information that the Saison Technology Group has collected.

(2) Right to Request Deletion

You have the right to request that the Saison Technology Group delete any of your personal information that the Saison Technology Group has collected from you and retained, subject to certain exceptions. Upon receiving your verifiable consumer request, the Saison Technology Group will delete your personal information from our records and will notify any service providers and contractors, as well as third parties to which the Saison Technology Group has sold or with which the Saison Technology Group has shared personal information, that they must delete such personal information from their records, unless an exception applies.

The Saison Technology Group may deny your request to delete your personal information if it is necessary for the Saison Technology Group or the Saison Technology Group’s service providers or contractors to retain your personal information in order to: 

  • Complete the transaction for which the Saison Technology Group collected the personal information, fulfill requirements for a product recall conducted in accordance with a written warranty or federal law, provide a good or service that you requested, enable you to take measures reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform an agreement between the Saison Technology Group and you;
  • Provide support to ensure the security and integrity of your personal information to the extent reasonably and proportionally necessary for the purpose of use;
  • Debug products to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of other persons to exercise their free speech rights, or exercise other rights provided by law;
  • Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres or adapts to all other applicable ethics and privacy laws, where the Saison Technology Group’s deletion of such information may render impossible or seriously impair the ability to compete such research, if you previously provided informed consent;
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with the Saison Technology Group and compatible with the context in which you provided the information; or
  • Comply with legal obligations.

(3)Right to Request Correction of Inaccurate Personal Information

You have the right to request that the Saison Technology Group correct any inaccuracies in your personal information that the Saison Technology Group collected from you. Upon receipt and confirmation of your verifiable consumer request, the Saison Technology Group will correct your inaccurate personal information from our records and will notify any service providers and contractors, as well as third parties to which the Saison Technology Group has sold or with which the Saison Technology Group has shared such personal information, that they must correct such personal information from their records. We may deny your correction request if we determine that the contested personal information is more likely than not accurate based on the totality of the circumstances.

(4)Right to Opt-Out of Share or Sharing

The Saison Technology Group has not and will not sell or share any personal information collected from you.

(5)Right to Request to Limit the Use of Sensitive Personal Information

The Saison Technology Group will not use or disclose sensitive personal information collected from you for purposes other than the following:

  • To provide products and services that are reasonably expected by average consumers;
  • To provide support for ensuring security and integrity;
  • For short-term temporary use (except for any use involving profiling or modification to future consumer experiences);
  • To provide services on behalf of the Saison Technology Group; and
  • To maintain or improve the quality and safety of the Saison Technology Group’s services and devices.

(6)Right of Non-Discrimination

The Saison Technology Group shall not discriminate against California residents for exercising any of their rights under the California Privacy Laws. Moreover, unless permitted by the California Privacy Laws, the Saison Technology Group will not engage in any of the following acts:

  • Deny goods or services to you;
  • Charge you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Provide you with a different level or quality of goods or services;
  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services; or
  • Retaliate against you if you are our employee, applicant for employment, or independent contractor.

(7)Exercising Your Rights to Access, Delete, and Correct

To exercise your rights to access, delete, and correct described above, please submit a verifiable consumer request to the Saison Technology Group by contacting us via the information in “Contact Point for Inquiries and Complaints.”

Only you, a natural person authorized by you, a person registered with the California Secretary of State, a person entrusted by you, or your conservator may submit a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

A “verifiable consumer request” must:

  • Provide sufficient information that allows the Saison Technology Group to reasonably verify that you are the person whose personal information the Saison Technology Group has collected or an authorized representative thereof; and
  • Describe your request with sufficient detail that allows the Saison Technology Group to properly understand, evaluate, and respond thereto.

Processing of Personal Information of Individual Customers Residing in China

These Supplementary Provisions shall apply to the handling of personal information of individual customers residing in China (“you”) in accordance with the provisions of the Act on the Protection of Personal Information in China and other related laws and regulations (the “China Related Laws and Regulations”).

1. Types of Personal Information

In these Supplementary Provisions, personal information refers to various types of information relating to a natural person that is recorded, identified or identifiable by electronic or other means.

The personal information we collect about you is as follows:

(i) Your name, address, telephone number, email address, company name, department name, title, etc. that you have provided upon account/user registration for our products and services;

(ii) Your name, address, telephone number, email address, company name, department name, title, details of inquiry, product serial information, etc. that you have provided through the inquiry form on our website; and

(iii) Your name, address, telephone number, email address, company name, department name, title, answer to questionnaire, etc. that you have provided through the prescribed event application form or questionnaire answer form on our website.

2. Purposes of Handling Personal Information

We will handle your personal information for the following purposes:

(i) Account registration or user registration, responding to technical support requests for products and services, distribution, etc. of e-mail newsletters;

(ii) Responding, etc. to inquiries via web forms; and

(iii) Responding to applications or answers via web forms.

3. Provision of Personal Information (Domestic and Cross-Border Transfers)

We will not provide your personal information to any entities in or outside of China without your consent.

4. Security Control Measures and Consignment of Personal Information Handling

We will handle your personal information in an appropriate manner after implementing safety control measures in accordance with the China Related Laws and Regulations. Personal information obtained by us shall be stored only to the extent and for the period necessary in light of 2. “Purposes of Handling Personal Information” above.

We may consign the handling of your personal information, in whole or in part, to any third party within the scope necessary to achieve the purposes stipulated in 2. “Purposes of Handling Personal Information” above, after implementing necessary protective measures.

5. Exercise of Rights

You may exercise the following rights with respect to the handling of your personal information in accordance with the China Related Laws and Regulations:

(i) Requesting confirmation of the status of handling of personal information;

(ii) Requesting inspection and copying of personal information;

(iii) Requesting correction or supplementation of personal information;

(iv) Requesting deletion of personal information;

(v) Requesting the withdrawal of consent (which shall not affect the legality of the handling of personal information conducted prior to the withdrawal of consent); and

(vi) Other rights of a personal information subject as stipulated in the China Related Laws and Regulations.

6. Inquiries

If you wish to request us to perform any procedures based on the rights stipulated in 5. “Exercise of Rights” above, or if you wish to consult with us or make inquiries regarding the handling of your personal information, you may contact us at our contact point listed in the “Contact Point for Inquiries and Complaints” section of this Privacy Policy.

7. Changes to this Privacy Policy

In the event of any changes to this Privacy Policy, we will notify you in advance of such changes, and if it is necessary to once again obtain your consent, we will obtain your consent before handling your personal information in accordance with the revised Privacy Policy.

Contact Point for Inquiries and Complaints

Please make contact at the following for inquiries or complaints about the processing of your personal information:

Contact:

Takashi Katagiri,
Data Protection Officer

Saison Technology Co., Ltd.
Quality Management Department
19F, Akasaka Intercity AIR, 1-8-1 Akasaka, Minato-ku, Tokyo 107-0052, Japan
Email Address : is_receipt@saison-technology.com
Telephone Number : +81 3 6370 2000

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Registration No. 1182059(13)
Acquired: December 3, 1999
Designated Organization: Japan Information Technology Service Industry Association
Applicable Standard: JISQ15001:2017

The contact information for our representatives in the EEA Region is as follows.
PLANIT // LEGAL Rechtsanwaltsgesellschaft mbH
Jungfernstieg 1, 20095 Hamburg, Germany
Email address : mail@planit.legal

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