Privacy Policy

Tsubaki Nakashima One Team Management System – Website and Software

Last Updated: November 2018

Tsubaki Nakashima Co. LTD. and its subsidiaries (Legal Entities, Functions, Regional and Divisional Organizations, Plants) (“TN”) respect your concerns about privacy, all the applicable Privacy’s regulations, in perfect compliance with the international and local Laws. This Website and Software Privacy Policy applies to personal information we collect on Tsubaki Nakashima website, software and mobile applications (collectively, the “Sites”), how we use the information, with whom we share it, and the choices available to users of our Sites regarding our use of the information. We also describe the measures we take to protect the security of the information and how users can contact us about our privacy practices.

Information We Collect

The types of personal information users of our Sites may submit include:

• Contact information (such as picture, name, organizational position, job title, location, postal address, telephone number, and email address)
• Login credentials for the Sites
• Information relating to HR and Sustainability processes or others strictly related to the business
• Other personal information found in content that users provide (including through surveys)

Tsubaki Nakashima will not collect and/or consider information regarding an associate’s ethnicity, race or gender, or religious credo.

Only Associates authorized (by HR Team) can use the Sites, with specific organizational restrictions.

Information We Collect

When you visit/use TN Sites, we may collect certain information by automated means, using technologies such as cookies, web server logs, web beacons, and JavaScript. Our Sites are not designed to respond to “do not track” signals from browsers. We do not knowingly allow other parties to collect personal information about our associates’ online activities over time and across third-party Sites when visitors use our Sites.

In conjunction with gathering information through cookies, our web servers may log information such as the country and time zone where your device is located. They also may log information about your interaction with the Sites, such as which pages you visit.

When you use our mobile apps, we may collect data such as unique device identifiers or their equivalents.

We may use third-party web analytics services on our Sites, such as those of Google Analytics. These service providers help us analyse how users use the Sites. The information collected for this purpose (including your IP address and other information collected by automated means) will be disclosed to or collected directly by these service providers.

How We Use the Information We Collect

We may use the information described above exclusively to

• Manage HR & Sustainability Processes or other connected to the TN’s business.
• Perform data analyses (including anonymization and aggregation of personal information)
• Operate, evaluate, and improve our business (including enhancing and improving our processes, services, websites, software and mobile apps; managing our communications; analysing our services; and performing evaluations, auditing and other internal functions)
• Meet our legal obligations, such as to comply with and enforce applicable legal requirements.

In addition, where required by applicable law, we may seek your consent (which we obtain when you provide your information or use or subscribe to the services) to:

• Send you communications
• Manage HR and Sustainability Processes (or others), including by assessing competencies and qualifications, verifying information, conducting reference or other employment-related checks, and notifying you of future opportunities that might be of interest to you.
  

Information We Share

We do not sell or otherwise disclose personal information we collect about you, except as described in this Website Privacy Policy. We may share personal information with service providers in connection with the operation of this Website and our company, including website hosting, the provision of our services. We do not authorize these service providers to use or disclose the information except as necessary to perform services we asked them to perform or comply with legal requirements.

In addition, we may disclose information about you

1. if we are required to do so by law or legal process,
2. to law enforcement authorities or other government entities, and
3. when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).
   

Your Rights and Choices

To the extent provided by the law of your jurisdiction, you may request access to the personal information we maintain about you or request that we correct, amend, delete, block, or move the information by contacting us as indicated below. Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your personal information, and we will apply your preferences going forward.

Data Transfers

We may transfer the personal information we collect about you to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries (such as the U.S.), we will protect that information as described in this policy.

How We Protect Personal Information

We maintain administrative, technical and physical safeguards designed to protect the personal information you provide on the Sites against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure, or use.

Your information will be retained for as long as necessary for the purpose(s) for which it was collected and as required by applicable laws or regulations.

If you have any questions or comments about this Website and Software Privacy Policy, you can contact us as indicated below. You also have a right to lodge a complaint with the supervisory authority for data protection in your country.

Updates to Our Website Privacy Notice

This Website and Software Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a prominent notice on our Sites to notify you of any significant changes to our Website Privacy Policy and indicate at the top of the notice when it was most recently updated.

How to Contact Us 

If you would like us to update information we have about you or your preferences, please contact your local HR Department.