GDPR Privacy Policy

（１）Personal information relating to customers and trading partners

Purpose of the processing	Lawful basis of the processing
(a) To provide the products and services (including websites) of Suzumo Machinery Group Companies and perform executive agreements with regard to products and services of Suzumo Machinery Group Companies (b) To carry out necessary communication, including negotiations, meetings, and correspondence (c) To respond to inquiries (f) To provide information regarding products and services of Suzumo Machinery Group Companies (h) To manage and operate promotions and events	-　Legitimate interest (Art. 6.1 (f) GDPR) for service provision
(g) To conduct direct marketing activities, including the distribution of e-mail newsletters and e-mail advertisements	-　Legitimate interest (Art. 6.1 (f) GDPR) -　Consent (Art. 6.1 (a) GDPR) if necessary under applicable laws and regulations
(d) To develop and improve the products and services (including websites) of Suzumo Machinery Group Companies (e) To customize products and services, including the provision of products and services (including websites) that are personalized based on the preferences of customers (i) To conduct research and questionnaires (l) To generate statistical information and other non-personal information	-　Legitimate interest (Art. 6.1 (f) GDPR)
(k) To carry out audits, operate the internal reporting system, and to otherwise prevent and deal with unjust acts	-　Legitimate interest (Art. 6.1 (f) GDPR) for appropriate business operations
(j) To make reports to, make filings with, cooperate with, and carry out procedures for, government agencies, various industry associations, etc.	-　Legal obligation (Art. 6.1 (c) GDPR) for compliance with EEA, EEA member state, and UK laws
(m) To respond to urgent needs to process personal information to protect important rights and interests, such as human life and human rights, within the scope of applicable laws and regulations (n) To perform duties and exercise rights based on applicable laws and regulations	-　Legitimate interest (Art. 6.1 (f) GDPR) for compliance with other laws, including Japanese laws
(o) For any other purposes necessary in the course of business operations by Suzumo Machinery Group Companies	-　Legitimate interest (Art. 6.1 (f) GDPR); however, if another legal basis under Article 6 of the GDPR is communicated, then such legal basis

（２）Personal information relating to shareholders

Purpose of the processing	Lawful basis of the processing
(a) To perform tasks related to shares (b) To respond to the exercising of rights by shareholders (c) To fulfill obligations or exercise rights in accordance with applicable laws (including the Companies Act)	-　Legal obligation (Art. 6.1 (c) GDPR) for compliance with EEA, EEA member state, and UK laws -　Legitimate interest (Art. 6.1 (f) GDPR) for compliance with other laws, including Japanese laws
(d) To conduct communication as necessary	-　Legitimate interest (Art. 6.1 (f) GDPR)
(e) For any other purposes necessary in the course of business operations at Suzumo Machinery Group Companies	-　Legitimate interest (Art. 6.1 (f) GDPR); however, if another legal basis under Article 6 of the GDPR is communicated, then such legal basis

（３）Personal information relating to applicants for employment by Suzumo Machinery Group Companies

Purpose of the processing	Lawful basis of the processing
(a) For recruitment and screening of applicants for employment by Suzumo Machinery Group Companies (d) To conduct communication as necessary	-　Legitimate interest (Art. 6.1 (f) GDPR)
(b) To conclude an employment contract in the event of a job applicant being hired	-　Contractual performance (Art. 6.1 (b))
(c) To perform obligations and exercise rights under applicable laws	-　Legal obligation (Art. 6.1 (c) GDPR) for compliance with EEA, EEA member state, and UK laws -　Legitimate interest (Art. 6.1 (f) GDPR) for compliance with other laws, including Japanese laws
(e) For any other purposes necessary in the course of business operations at Suzumo Machinery Group Companies	-　Legitimate interest (Art. 6.1 (f) GDPR); however, if another legal basis under Article 6 of the GDPR is communicated, then such legal basis

*List of legal bases

-　Contractual performance – we have obligations under our service agreement with customers who are individuals, depending on the nature of the agreement. To fulfil these obligations we have to use the data of Data Subjects.

-　Consent – in certain limited cases, we ask for the consent of Data Subjects to use their data.

-　Legitimate interest – we process the data of Data Subjects when it is necessary for us to achieve a legitimate business purpose, or where this is necessary for someone else to achieve their legitimate purpose. For information regarding balancing tests for legitimate interests, please refer to the contact details in section “11.” of the main body of the Global Privacy Policy.

-　Legal obligation – as an organisation, we have obligations to comply with legal, regulatory and other requirements under EEA or UK laws. In certain cases we will have to use the data of Data Subjects to meet these obligations.

If we transfer personal information to a country or region outside of the EEA or UK, then the following applies for that transfer. (1) If it is to a country that offers an adequate level of data protection, such as Japan, an adequacy decision will be used as the basis for the transfer (click here for information regarding adequacy decisions for transfers to Japan, and click here for information regarding adequacy decisions for transfers to the UK). Additionally, transfers from the UK to the EEA are permitted (click here for details). (2) If it is to a country that does not offer an adequate level of data protection, we will establish appropriate safeguards through entry into standard contractual clauses approved by the country that the personal data will be delivered to and by the European Commission (Art. 46. 2 (c) and Art. 46.5) and UK addendums to those clauses approved by the UK government. However, as an exception, (3) the basis might also fall under a specific situation described in Article 49 of the GDPR. For further details regarding our justification of the transfer of personal information of Data Subjects, or for copies of relevant documents, please contact us using the contact details in section “11. Contact details)” of the main body of the Global Privacy Policy.

Each Data Subject has the right to do the following: ask us for a copy of the Data Subject’s personal information; ask us to correct, delete, or restrict processing of the Data Subject’s personal information; and request to acquire from us the personal information the Data Subject provides in a structured, machine-readable format. Each Data Subject also has the right to object where we are processing the Data Subject’s data for direct marketing.
In addition, a Data Subject can object to the processing of the Data Subject’s personal information in some circumstances (in particular, where we don’t have to process the information to meet a contractual or other legal requirement). Where we have asked for the consent of a Data Subject, the Data Subject may withdraw consent at any time. If a Data Subject asks to withdraw the Data Subject’s consent to our processing of the Data Subject’s information, this will not affect any processing which has already taken place at that time. When a Data Subject exercises the Data Subject’s rights, we will ask for information to check the Data Subject’s identity; this will only involve official ID documents if this is necessary given the risk posed by the data processed.
These rights may be limited, for example if fulfilling a Data Subject’s request would reveal personal information about another Data Subject, or if a Data Subject asks us to delete information which we are required by law or have compelling legitimate interests to keep. If a Data Subject has unresolved concerns, that Data Subject has the right to complain to a data protection authority. In the UK, this will be the Information Commissioner. In the EEA, this will be the Data Subject’s Data Protection Authority which can be found here.

当社による個人情報の取得、利用等については以下の通りです。

（１）個人情報の取得
当社は事業の運営に必要な範囲で、お客様や応募者等に係る個人情報を本サイトから取得することがあります。

（２）個人情報の利用目的
当社は当社が取得した個人情報について、法令で定める場合又は本人の同意を得た場合を除き、以下に定める利用目的の範囲を超えて利用することはありません。

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