Handling of Customers' Personal Information

For visitors from EEA (European Economic Area), please click here for our privacy policy.

UPDATE: April 20, 2020

(1) Cookies, web beacons and IP addresses

On our site, cookies, web beacons and IP addresses are used for the purposes listed below. Users can disable our cookies and web beacons by disabling cookies in their browser settings, but this may prevent use of some or all functionality on web pages.

① To identify and resolve causes of server failure or other server issues

② To improve site and email content

③ To customize site and email content for individual users

④ For members-only services where personal information has already been registered, browsing history, questionnaire responses, etc. are used for marketing purposes

⑤ To use anonymized information for statistics

(2) Google Analytics

We use the Google Analytics service from Google, Inc. ("Google") on some pages on our site to understand how visitors use our site. Using Google Analytics on our site means that Google collects, records, and analyzes the browsing history of visitors to our site based on the cookies we issue. We receive the results of the analysis from Google and use it to understand how users visit our site. No data about users collected, recorded, or analyzed by Google Analytics contains personally identifying information. This data is also managed by Google in accordance with their privacy policy.
Users can disable Google Analytics in browser add-on settings, preventing Google Analytics from collecting their data. Google Analytics can be disabled by downloading the "Google Analytics Opt-out Browser Add-on" from the Google opt-out browser add-on download page, installing the add-on, and configuring the browser add-on settings. If a user disables Google Analytics, it will disable Google Analytics on all sites and not just ours, but it can be re-enabled at any time by changing browser add-on settings.

Please see the Google Analytics site for an explanation of the Google Analytics Terms of Service, and the Google site for an explanation of their Privacy Policy.

Google Analytics Terms of Service:

www.google.com/analytics/terms/us.html

Google Privacy Policy:

policies.google.com/privacy?hl=en

Google Analytics Opt-out Add-on:

tools.google.com/dlpage/gaoptout?hl=en

Note: "Google Analytics" is a registered trademark of Google.

(3) Other

We have no liability or responsibility for the protection of Personal Information on websites that are linked from our site. Please direct any questions or inquiries about the handling of Personal Information on other websites directly to the site owners.

UPDATE: April 3, 2020
PLEASE READ THIS PRIVACY POLICY CAREFULLY

1. OUR PRIVACY POLICY

The protection of your personal data is of great importance to THK CO., LTD. (the “Company”) and the subsidiaries and affiliates that compose the THK Group (the “Company Group” or “we”). This privacy policy (this “Privacy Policy”) explains to business partners, customers, suppliers and other third parties outside the Company Group who are located in the European Economic Area (the “EEA”; each of the aforementioned persons is referred to as “you” throughout this Privacy Policy) how the Company Group, which adopt this Privacy Policy, acting as data controller, collects and processes your personal data submitted or disclosed to us by you. We also act as data controller when we process your personal data received or obtained through a third party. We process your personal data in accordance with the applicable EEA Member States’ regulations on data protection, in particular the General Data Protection Regulation 2016/679 (the “GDPR”).

We encourage you to read this Privacy Policy carefully. If you do not wish your personal data to be used in the manner set out in this Privacy Policy, please do not provide us with your personal data. Please note that, in that case, we will not be able to provide you with our services, you will not be able to access or use some features of our websites, and the level of your satisfaction when interacting with us will be impacted.

The Company Group that adopt this Privacy Policy consist of the companies set out below.

(1) THK CO., LTD.

(2) THK INTECHS CO., LTD.

(3) Talk System CO., LTD.

(4) THK RHYTHM CO., LTD.

(5) THK Europe B.V.

(6) THK GmbH

(7) THK France S.A.S.

(8) THK Manufacturing of Europe S.A.S.

(9) THK Manufacturing of Ireland Ltd.

2. Processing of Your Personal Data

For the purposes specified in this Privacy Policy, we process the personal data obtained from you directly (when you decide to communicate such data to us, i.e., when you contact us, or when you fill in forms displayed on our websites) or indirectly (data provided to us by a third-party). We ensure that the personal data processed are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. We will always process your personal data based on one of the legal bases provided for in the GDPR (Articles 6 and 7).

We may collect and process your personal data for the following purposes:

Ⅰ. Purpose: Provision and receipt of products and services between Company Group and business partners (including customers and suppliers) and communication of the products and services.
We may have legitimate interest in collecting, directly or/and indirectly, and processing your personal data for the purposes, which is required to offer to customers the products and services of the Company Group, to receive from suppliers the products and services of suppliers and to ensure communication with business partners regarding relevant matters for conducting the business.

Ⅱ. Purpose: Introduction of products and services, sending greeting cards
We may have legitimate interest in collecting, directly or/and indirectly, and processing your personal data for the purposes, which is required to introduce our products and services to customers, and to send greeting cards.

Ⅲ. Purpose: Response to and management of queries from customers
We may have legitimate interest in collecting, directly or/and indirectly, and processing your personal data for the purposes, which is required to respond to and manage customers' queries, handle their requests and provide technical support when needed.

Ⅳ. Purpose: General Operations
We may have legitimate interest in collecting, directly or/and indirectly, and processing your personal data for the purposes, which is required to organize and conduct business, exchange essential information with interested parties and operate management systems.

Ⅴ. Purpose: Human Resources and labor management of employees of Company Group
We may have legitimate interest in collecting, directly or/and indirectly, and processing your personal data for the purposes, which is required to ensure functioning of our relationship with our employees, deal with their requests, fulfill our obligations towards them, e.g. salary, bonus, maternity leave, holiday, company cars, entry cards etc.

Ⅵ. Purpose: Operations and management of information systems of Company Group
We may have legitimate interest in collecting, directly or/and indirectly, and processing your personal data for the purposes, which is required to organize and operate the Company Group's information system, e.g. data backup, technical trainings, handle technical problems etc.

If you would like to further access to more detailed information, such as more specific purposes and legal basis in accordance with GDPR (Article 13 or 14), please click here.

We will process your personal data for all these legitimate purposes listed above as well as further detailed purposes indicated on the webpage accessible from here, and will not further process your personal data in a way that is incompatible with these purposes. If we intend to process personal data originally collected for one purpose in order to attain other objectives or purposes, we will ensure that you are informed of such processing purposes.

We may process your personal data based on legal obligation, as indicated on the webpage accessible from here.

We may process your sensitive personal data based on your consent, as indicated on the webpage accessible from here. Please be aware that you are entitled to withdraw your consent at any time without affecting the lawfulness of processing based on your consent before withdrawal thereof.

We will keep your personal data only for as long as it is necessary for us to comply with our legal obligations to ensure that we provide an adequate service, and to support its business activities (Article 5 and 25(2) GDPR).

3. Sharing of Your Personal Data

We may share your personal data with Company Group entities and with third parties in accordance with the GDPR. If we share your personal data with a service provider (processor), we will establish the appropriate legal framework in order to cover such transfer and processing (Articles 26, 28 and 29 GDPR). Furthermore, if we share your personal data with any entity outside the EEA, we will establish appropriate legal frameworks, notably controller-to-controller (2004/915/EC) and controller-to-processor (2010/87/EU) Standard Contract Clauses approved by the European Commission, in order to cover such transfers (Articles 44 GDPR).

The categories (and some examples of each category) of recipients of your personal data are specified bellow in accordance with the requirement under the GDPR.

Strategic Partners (controller)

Your personal data may be transferred to, stored and further processed by our strategic partners that work with us to provide our products and services or help us conduct business with you and provide assistance with managing our relationship with our employees. We may currently share your personal data with the following categories of strategic partners:

accounting services (Sweden, France Germany), insurance services (Germany, France), legal services (Italy), IT services (Germany, USA, Japan), public authorities (Germany, France, Switzerland, Netherlands) risk consulting services (UK, Germany, France), travel agencies (Germany), tax offices (France, Netherlands), business companies (France, Germany ,Japan), mover custom clearance (France), suppliers(Germany, France, UK), leisure companies (France, Germany), web hosting services/website services (Japan, USA), fire/rescue services (France), payroll services (Italy), manufacturing companies (Japan, China), pension services company (Japan), commercial service companies, warehouse/transfer companies (Germany), sales companies (Switzerland, Germany), parcel/forwarding services (Germany , Netherlands)

Your personal data will only be shared by us with these companies for the purposes specified above in this Privacy Policy.

Service Providers (processors)

We may share your personal data with companies which provide services on our behalf, such as printing services (Germany) and IT system operational assistance (Germany).

Your personal data will only be shared by us with these companies for the purposes specified above in this Privacy Policy.

Corporate Affiliates and Corporate Restructuring

We may share your personal data with all affiliates in the Company Group. In the event of a merger, reorganization, acquisition, joint venture, assignment, spin-off, transfer, or sale or disposition of all or any portion of our business, including in connection with any bankruptcy or similar proceedings, we may transfer any and all personal data to the relevant third party.

Legal Compliance and Security

In some instances, it will become necessary for the Company Group to disclose your personal data in accordance with law, legal proceedings, litigation, or requests from public and governmental authorities within or outside your country of residence. We will also disclose your personal data if we determine that, due to purposes of national security, law enforcement, or other issues of public importance, the disclosure is necessary or appropriate.

We will also disclose your personal data if we determine in good faith that disclosure is reasonably necessary to protect our rights, to pursue available remedies, to enforce our terms of use, to investigate fraud, or to protect our business or users.

Data Transfers

In some instances, the disclosures stated above will involve transferring your personal data out of the EEA to the following countries:

Japan, Turkey, USA, China, Vietnam. Those transfers are conducted for the following purposes: (ⅰ) general business operations; (ⅱ) human resources; (ⅲ) IT system development; (ⅳ) IT system operational assistance; (ⅴ) planning for new companies and (ⅵ) webhosting services.

For each of these transfers, we provide an appropriate level of protection for the data transferred, in particular by entering into controller-to-controller (2004/915/EC) and controller-to-processor (2010/87/EU) standard contract clauses.

We will not use your personal data for online marketing purposes, unless you have expressly consented to such use of your personal data. You can change your marketing preferences at any time by using the contact details provided at the end of this Privacy Policy.

4. Company Group’s Records of Data Processes

We handle records of all processing of your personal data in accordance with the obligations established by the GDPR (Article 30), both when we might act as a controller or as a processor. In these records, we reflect all the information necessary in order to comply with the GDPR and cooperate with the supervisory authorities as required (Article 31).

5. Security Measures

We process your personal data in a manner that ensures their appropriate security, including protection against unauthorized or unlawful processing, accidental loss, destruction or damage. We use appropriate technical or organizational measures to achieve this level of protection (Article 25(1) and 32 GDPR).

We will retain your personal data for as long as it is necessary to fulfill the purposes outlined in this Privacy policy, unless a longer retention period is required or permitted by law.

6. Notification of Data Breaches to the Competent Supervisory Authorities

In case of breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed, we have the mechanisms and policies in order to identify it and assess it promptly. Depending on the outcome of our assessment, we will make the requisite notifications to the supervisory authorities and communications to the affected data subjects, which might include you (Articles 33 and 34 GDPR).

7. Processing Likely to Result in High Risk to Your Rights And Freedoms

We have mechanisms and policies in order to identify data processing activities that may result in high risk to your rights and freedoms (Article 35 GDPR: Data Protection Impact Assessment). If any such data processing activity is identified, we will assess it internally and either stop it or ensure that the processing is compliant with the GDPR or that appropriate technical and organizational safeguards are in order to proceed with it.

In case of doubt, we will contact the competent Data Protection Supervisory Authority in order to obtain their advice and recommendations (Article 36 GDPR).

8. Your Rights

You have the following rights regarding your personal data collected and processed by us.

- Information regarding processing or your personal data: You have the right to obtain from us all the requisite information regarding our data processing activities that concern you (Articles 13 and 14 GDPR).

- Access to your personal data: You have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed, and, if so, then access to your personal data and certain related information (Article 15 GDPR).

- Rectification or erasure of your personal data: You have the right to obtain from us the rectification of inaccurate personal data concerning you without undue delay, and to complete any incomplete personal data (Article 16 GDPR). You may also have the right to obtain from us the erasure of personal data concerning you without undue delay, when certain legal conditions apply (Article 17 GDPR).

- Restriction on processing of your personal data: You may have the right to obtain from us the restriction of processing of personal data concerning you, when certain legal conditions apply (Article 18 GDPR).

- Object to processing of your personal data: You may have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you, when certain legal conditions apply (Article 21 GDPR).

- Data portability of your personal data: You may have the right to receive your personal data in a structured, commonly used and machine-readable format, and have the right to transmit those data to another controller without our hindrance, when certain legal conditions apply (Article 20 GDPR).

- Not to be subject to automated decision-making: You may have the right not to be subject to automated decision-making (including profiling) based on the processing of your personal data, in so far as this produces legal or similar effects on you, when certain legal conditions apply (Article 22 GDPR).

- Withdrawal of your consent: You may withdraw your consent at any time without affecting the lawfulness of processing based on your consent before withdrawal thereof.

If you intend to exercise such rights, please refer to the contact section below.

If you are not satisfied with the way in which we have proceeded with any request, or if you have any complaint regarding the way in which we process your personal data, you may lodge a complaint with a Data Protection Supervisory Authority.

9. Children

Our products and services are intended for adult customers. Thus, we do not knowingly collect and process any personal data of children under sixteen (16). If we discover that we have collected and processed the personal data of a child under sixteen (16), or the equivalent minimum age depending on the concerned jurisdiction, we will take steps to delete the personal data as soon as possible.

10. Links to Other Sites

We may propose hypertext links from our websites to third-party websites or Internet sources. We do not control and cannot be held liable for third parties’ data protection practices and content. Please read carefully their privacy policies to find out how they collect and process your personal data.

11. Updates to This Privacy Policy

We may revise or update this Privacy Policy from time to time. Any changes to this Privacy Policy will become effective upon posting of the revised Privacy Policy on our websites. If we make changes which we believe are significant, we will inform you through our websites to the extent possible and seek your consent if applicable.

Contact Details

For any questions or requests relating to this Privacy Policy, please email us (privacy-info@thk.co.jp).

The contact details of the Data Protection Officer are as follows:

［dpo@thk.co.jp］

Cookies, etc.

- Cookies

Cookies are small text files that are placed on your computer or mobile phone when you visit a website. They are widely used in order to make websites work or to work more efficiently.

- Web beacons

Web beacons are extremely small images that are embedded in a web page or an email formatted in HTML. It is used to convey to a server that a user has accessed that web page or read that email.

- IP addresses

IP addresses are discrete strings of digits that are assigned to an individual computer for the purpose of identifying that computer. It is used to specify the transmission source and recipient when sending and receiving data.

- Company Group’s use of cookies, etc.

We use cookies, web beacons, and IP addresses (“Cookies, Etc.”) in our websites for the following purposes:

- To track down and resolve errors and problems that arise in servers

- To improve the contents of websites, email, etc.

- To customize the contents of websites, email, etc. for individual users

- To use in marketing activities the browsing history details and survey results in membership services for which you register personal information in advance

- To use as statistical data in a form that does not identify individuals

Most browsers allow you to manage your cookies preferences by changing your browser settings. You can set your browser to do the following: (ⅰ) automatically accept or refuse all cookies; (ⅱ) automatically accept or refuse first-party cookies and/or third party cookies; or (ⅲ) notify you before any cookies are set on your terminal equipment so that you have the opportunity to accept or refuse those cookies.

Consequently, if you consent to our use of cookies but later wish to opt out, you can at any time through your browser settings delete the cookies that have been set and change your browser settings to block all or some of any other cookies that are set on your terminal equipment in the future. Please see the “Help” function in your browser. Alternatively, the following links provide instructions for managing cookie settings of commonly used browsers:

- Chrome (https://support.google.com/chrome/answer/95647?hl=en)

- Microsoft Edge (https://support.microsoft.com/en-us/help/4027947/microsoft-edge-delete-cookies)

- Internet Explorer (https://windows.microsoft.com/en-US/windows-vista/Block-or-allow-cookies)

- Mozilla Firefox (https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop)

- Safari (https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac)

In addition, you can visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of browsers.

Moreover, you can use another online service enabling you to manage the advertising cookies set in your devices: http://www.youronlinechoices.com/

Please note that if you block cookies, your experience on our websites will be impacted in that case as we will not be able to provide you with full access to all functions and contents of our websites.

- Google Analytics

Some pages on our websites use Google Analytics, a service by Google Inc. (“Google”), to understand the nature of visits made to those websites by you. Using Google Analytics on our websites allows Google to collect, record, and analyze your visit history at our websites, based on cookies issued us. We receive the results of this analysis from Google and gain an understanding of the visits made by you to our websites. This information is also managed based on the privacy policy of Google.

You can stop the collection of customer information conducted by us using Google Analytics by disabling Google Analytics in his or her browser’s “add-on” settings. You can opt out of Google Analytics by performing changes to your browser’s add-on settings by downloading and installing the Google Analytics opt-out add-on found on Google’s Opt-out page. If you opt out of Google Analytics, Google Analytics will become disabled on other websites visited by you, but Google Analytics can be enabled again by resetting the add-on in the browser. For an explanation of Google Analytics terms of service, please see the Google Analytics site, and for an explanation of Google’s privacy policy, please see Google’s site.

Google Analytics Terms of Service:

www.google.com/analytics/terms/us.html

Google Privacy Policy:

policies.google.com/privacy?hl=en

Google Analytics Opt-out Add-on:

tools.google.com/dlpage/gaoptout?hl=en

*“Google Analytics” is a registered trademark of Google.

- Retention period for cookies

We consider your consent to cookies valid for a maximum period of 26 months. When that period of time elapses, we will ask for your consent again.

THK Privacy policy