Privacy Policy

Who we are

Ushio Inc. is the controller and responsible for your personal information (collectively referred to as "Ushio", "we", "us" or "our" in this privacy policy). We are a company registered in Japan and our registered office is at 31F Sumitomo Fudosan Tokyo Mita Garden Tower, 3-5-19, Mita, Minato-ku, Tokyo, 108-0073 Japan.

You can contact us:

• By email at: compliance@ushio.co.jp
• By phone at: +81-3-5657-1000
• By post at: 31F Sumitomo Fudosan Tokyo Mita Garden Tower, 3-5-19, Mita, Minato-ku, Tokyo, 108-0073 Japan / Attn: Compliance Committee

Changes to this privacy policy

We may make changes to this privacy policy from time to time. You should therefore check this privacy policy whenever you return to our website to see whether any changes have been made, as these will be binding on you.

Our processing principles

We will process your personal information in compliance with the following principles:

1. We will establish practices concerning the protection of personal information and by educating our employees (including officers, permanent employees, part-time staff, temporary staff and agency workers) and other relevant parties and will implement, improve and maintain those practices.
2. We will use fair and lawful means to acquire personal information and will publish on our website the information required, such as purpose of use and whether we will be obtaining consent from the data subject of the personal information.
3. If we acquire personal information indirectly, we will publish the purpose of use on our website.
4. We will only use personal information from the data subject to the extent necessary in the course of business and within the scope published on our website and only by parties who have been granted authorization for specific duties.
5. We will adopt reasonable security measures concerning personal information to prevent risks such as unauthorized access, loss, destruction, modification or disclosure, and will also take appropriate corrective actions.
6. If we entrust personal information to a subcontractor, we will enter into the necessary contracts with a suitable subcontractor and also adopt any other necessary legal measures.
7. We will not allow, in principle, personal information to be provided to third parties other than under the terms of this privacy policy and applicable law.
8. We will put in place systems to respond to a request from a confirmed data subject to disclose, amend, cease using or delete personal information in our possession, in line with the applicable law.
9. We will implement the above, conduct ongoing revisions, and endeavour to improve and optimize them.

Collecting personal information

We use different methods to collect personal information from and about you including through:

1. Personal information you give us.
   You may give us your personal information including name and contact details, by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you ask us about, or apply for, our products or services; subscribe to our services or publications; request marketing to be sent to you, or give us some feedback.
2. Personal information we collect.
   As you interact with our websites, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.

Using personal information

We will limit the use of personal information to the extent necessary to achieve the purpose of use. We will not use personal information for any unspecified purpose without the consent of the data subject.

Purposes for which personal information is used

1. To fulfil agreements, to provide after-sales services, to process accounts such as invoices etc.
2. To respond to queries, suggestions and requests.
3. To conduct campaigns, surveys and monitoring processes, as well as to analyse the results and send out prizes and gifts.
4. To inform customers about our products, goods and services.
5. To inform customers about any exhibitions, presentations, seminars and other events organized by us (solely or jointly, including with our cooperation or support).
6. To provide information and services to shareholders and investors.
7. To administer shareholder records and perform duties related to share management.
8. To submit notifications, reports or applications to the competent authorities.
9. To send business-related communications, newsletters and courtesy letters.
10. To decide whether to accept or reject applications for full-time and part-time positions, and to provide information and communicate regarding this.
11. For other purposes to which the data subject has given prior consent.

Disclosing and providing personal information to third parties

We will not disclose or provide personal information to third parties except in cases where we subcontract part of our business operations to an external vendor, such as for website production and web server services, data storage, maintenance services, database management, email, newsletters, web analytics and payment services, or, where an Ushio Inc. subsidiary group company is involved in responding to a query, suggestion or request from you or in fulfilment or performance of any contract (or otherwise for the purposes set out above) or in any of the following cases:

1. When we have obtained consent from the data subject;
2. When it will be disclosed or provided in a format, such as statistical data, where individuals cannot be identified;
3. When we have been asked to disclose or provide the personal information pursuant to laws and regulations;
4. When it is necessary to protect human life or to prevent physical injury or damage to property, and it is difficult to obtain consent from the data subject;
5. When it is necessary to cooperate with the public duties of national or local government bodies and there is a risk that obtaining consent from the data subject could obstruct the performance of those duties.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

We are headquartered in Japan, with subsidiary group companies with operations also in the United States, Canada, United Kingdom, Germany, France, Poland, the Netherlands and other countries/regions (“Ushio Countries”). Your personal information will be accessed by us or transferred to us in Japan and/or one or more of the Ushio Countries and will be accessed by our Japan-based employees (and those in the Ushio Countries). If you are visiting our website from outside Japan, be aware that your personal information will be transferred to, stored, and processed in Japan where our servers are located, and our central database is operated and/or in one or more of the Ushio Countries. By using our website, you consent to this transfer of your personal information.

Retention of personal information

We will store your personal information, in a form which permits us to identify you, for no longer than is necessary for the purpose for which the personal information is processed. We will also store and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and rights, or if it is not technically and reasonably feasible to remove it. Otherwise, we will seek to delete your personal information within a reasonable timeframe upon request.

Data anonymization

1. Producing anonymized data

We will adhere to the following if we produce anonymized data (information concerning an individual that has been produced by processing personal information using measures prescribed by laws and regulations so that the specific data subject is no longer identifiable, and that cannot be restored back to its original identifiable form):

• Use appropriate anonymization techniques that meet the standards prescribed by laws and regulations;
• Put in place security measures that meet the standards prescribed by laws and regulations to prevent the disclosure of deleted information or information relating to anonymization techniques;

Publish the type of information that is included in the anonymized data;

• Refrain from doing anything that would identify the original data subject.

2. Providing anonymized data

If we provide anonymized data to third parties, we will publish the type of information that is to be included in the anonymized data and how it will be provided, and expressly state to the third party that the information to be received is anonymized data.

Measures to protect personal information

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where, and in the manner, we are legally required to do so.

European residents

If you are based in the EU, we will only process your personal information for a purpose described in the privacy policy if (1) you have provided your consent, (2) the processing is necessary for the performance of a contract we are about to enter into or have entered into with you, (3) we are required by law, or (4) the processing is necessary for the purposes of our legitimate commercial interests (except where such interests are overridden by your rights and interests).

If you are based in the EU, in certain circumstances you have rights under data protection laws in relation to personal information we hold about you—specifically:

Request access to your personal information.
You may have the right to request access to any personal information we hold about you as well as related information, including the purposes for processing the personal information, the recipients or categories of recipients with whom the personal information has been shared, where possible, the period for which the personal information will be stored, the source of the personal information, and the existence of any automated decision making.

Request correction of your personal information.
You may have the right to obtain without undue delay the rectification of any inaccurate personal information we hold about you.

Request erasure of your personal information.
You may have the right to request that personal information held about you is deleted.

Request restriction of processing your personal information.
You may have the right to prevent or restrict processing of your personal information.

Request transfer of your personal information.
You may have the right to request transfer of personal information directly to a third party where this is technically feasible.

Where you believe that we have not complied with our obligation under this privacy policy or European data protection law, you have the right to make a complaint to an EU Data Protection Authority.