Denyo Co., Ltd. (the “Company”), being conscious of the fact that appropriate protection of personal information is its social responsibility as a company, establishes the following global privacy policy (this “Policy”) with respect to the methods of processing the personal information of the data subject (“you”, “your”) that the Company collects in the course of business.
In addition to this Policy that applies to all personal information processing, the Company has prepared country-specific supplementary provisions that may apply depending on your place of residence or your location. In such case, please also refer to the supplementary provisions. The supplementary provisions shall prevail in the case of any discrepancy between this Policy and supplemental provisions.
1. The Company’s name, address, and name of representative
- Denyo Co., Ltd.
- 2-8-5 Nihonbashi-Horidomecho, Chuo-ku, Tokyo 103-8566
- Takanori Yoshinaga, President
2. Categories of personal information subject to processing
The Company obtains and processes the following personal information.
(1) Personal information relating to customers
- (Contact data) Names, email addresses, postal codes, addresses, telephone numbers, company names, departments, company telephone numbers, titles at companies, etc. and other information regarding contact details
- (Product & service data) The following information, etc. regarding products and services (including repairs, support, maintenance, after-sales service, etc.; Same hereinafter) purchased by customer
Product numbers, product information, information regarding warranties, product operation history, information regarding product condition and use, location information, service history, sales outlet where purchased
- (Product & service data) Information related to products and services customers plan to purchase or are considering purchasing
- (Customer request) The details of opinions, requests, replies to questionnaires, inquiries, and offers from customers
- (Data acquired or generated from products and services) Information concerning individuals that is acquired or generated in connection with products and services provided by the Company
- (Data acquired or generated from events) Information concerning individuals acquired or generated in connection with training, testing, investigations, or any type of event implemented by or in relation to the Company
- (Access data) Cookies and other terminal identifiers, IP addresses, provider information, terminal information, browser information, and access area information of customers that access the Company’s website
- Other personal information necessary to achieve the purpose of use in Section 4
(2) Personal information relating to business partners
- (Contact data) Names, email addresses, postal codes, addresses, telephone numbers, company names, departments, company telephone numbers, titles at companies, etc. and other information regarding contact details
- (Customer request) The details of opinions, requests, replies to questionnaires, inquiries, and offers from business partners
- Other personal information necessary to achieve the purpose of use in Section 4
(3) Personal information relating to shareholders
- (Shareholders’ data) Names, addresses, email addresses, number of shares held, share acquisition dates, shareholder numbers, dividend payment history, dividend payment account, and other information necessary to contact or manage shareholders in accordance with the Companies Act and other laws and regulations.
- Other personal information necessary to achieve the purpose of processing in Section 4
(4) Personal information relating to applicants for jobs at the Company and former employees of the Company
- (Applicants’ and former employees’ data) Names, addresses, ages, sex, email addresses, telephone numbers, academic background, qualifications, certificates of graduation from educational institutions attended, academic transcripts, bank account information, employment history, social insurance information, health condition, portrait photos, family information, etc.
- Other personal information necessary to achieve the purpose of processing in Section 4
3. Sources of personal information
The Company may obtain personal information directly from you as well as indirectly from third parties such as clients, service providers, business partners, server management companies, website management companies, and website traffic analytics service providers.
4. Purpose of processing personal information
The Company may process personal information for the following purposes.
(1) Personal information relating to customers
- Responding to inquiries from customers
- Provision of information regarding the Company’s products and services
- Development of the Company’s products and services
- Handling of services
- Implementation of sales promotion activities for the Company’s products and services, such as promotional campaigns
- Direct marketing
- Performance of contracts with customers
- Handling business discussions and meetings, etc. with customers
- Analyzing use of the Company’s website
- Compliance with laws and regulations
- Other purposes permitted pursuant to applicable laws and regulations
(2)Personal information relating to business partners
- Performance of contracts with business partners
- Responding to inquiries from business partners
- Handling of communications, reports, and business discussions required for business operations
- Business partner information management, expenditure and income management
- Compliance with laws and regulations
- Other purposes permitted pursuant to applicable laws and regulations
(3) Personal information relating to shareholders
- Shareholder and share management operations
- Exercise of rights or performance of obligations pursuant to the Companies Act and other laws and regulations
- The Company’s provision of all types of benefits to shareholders
- Preparation of documents, records, or data pursuant to laws and regulations
- Other purposes permitted pursuant to applicable laws and regulations
(4) Personal information relating to applicants for jobs at the Company and former employees of the Company
- The Company’s recruitment activities, HR and safety management after hiring, and operations in connection therewith
- Information provision and communications, etc. to persons who leave the Company
- Compliance with laws and regulations
- Other purposes permitted pursuant to applicable laws and regulations
5. Legal basis, etc. for processing
The Company processes personal information in accordance with applicable personal information protection laws and regulations. Please see the supplementary provisions with respect to the Company’s legal basis for processing.
The Company may request the provision of particular personal information if the provision of personal information is required by law or under a contract, is a requirement for the execution of a contract, or on other grounds. If you are unable to provide personal information, you may not be able to use the Company’s services.
6. Personal information retention period
The Company retains personal information for the period necessary to achieve the processing purpose of personal information or the period prescribed by applicable laws and regulations. In order to determine an appropriate retention period for personal information, the Company takes into account the quantity, nature, and characteristics of the personal information, the risk of potential damage due to unauthorized use or disclosure of the personal information, the purposes for which the Company processes the personal information, and whether such purposes can be achieved by other means, as well as applicable legal requirements.
7. Sharing and disclosure of personal information
The Company may share personal information with or disclose personal information to the following third parties in order to achieve the purposes of processing personal information stated in Section 4. We may share all personal data relating to the following categories with the following third parties
(1) Sharing with processors
(i) Personal information relating to customers
- Server management companies
- Website management companies
- Website traffic analytics service providers (Google LLC, etc.)
- Sales outlets, service providers (e.g. forwarders, delivery companies, etc.), business partners, and clients in relation to the provision of the Company’s products and services
- Lawyers, certified public tax accountants, and certified public accountants
- Other service providers providing services necessary for the Company’s business activities
(ii) Personal information relating to business partners
- Server management companies
- Sales outlets, service providers, business partners, and clients in relation to the provision of the
Company’s products and services
- Lawyers, certified public tax accountants, and certified public accountants
- Other service providers providing services necessary for the Company’s business activities
(iii) Personal information relating to shareholders
- Server management companies
- Transfer agents
- Japan Securities Depository Center
- Lawyers, certified public tax accountants, and certified public accountants
- Other service providers providing services necessary for the Company’s business activities
(iv) Information relating to applicants for jobs at the Company
- Server management companies
- Organizations affiliated with the educational institution the applicant belongs to and recruiters
- Other service providers providing services necessary for the Company’s business activities
(2) Sharing with group companies
The Company shares personal information with the parties designated below pursuant to provisions regarding joint use in the Act on the Protection of Personal Information (Japan). In such case, the Company will be responsible for the management of personal information.
(i) Categories of shared personal information
- Names, email addresses, postal codes, addresses, telephone numbers, company names, departments, company telephone numbers, titles at companies, etc., and other information regarding contact details
- The following information, etc. regarding products and services purchased by customers
Product numbers, product information, information regarding warranties, product operation history, information regarding product condition and use, location information, service history, sales outlet where purchased
- Information regarding products and services customers plan to purchase or are considering purchasing
- The details of opinions, requests, replies to questionnaires, inquiries, and offers from customers
- Other personal information necessary to achieve the purposes of processing set forth in Section 4
(ii) Scope of shared users
(iii) Purpose of use of shared users
Processing purposes set forth in Section 4.
(3) Compliance, etc. with laws and regulations
The Company may disclose personal information to government agencies, regulatory authorities, law enforcement organizations, and the Company’s professional advisors if disclosure is mandatory pursuant to laws or regulations or if necessary to protect the Company’s legitimate interests in compliance with applicable laws and regulations.
(4) Other
In addition to the foregoing, the Company may also share personal information in the following cases.
- Sharing as part of a sale or merger of the Company or acquisition by the Company, or other transfer of all or part of the Company’s assets
- When necessary to protect the life, body, or property of a person and it is difficult to obtain the consent of the relevant person
- With the consent of the relevant person
- Other cases permitted under applicable laws and regulations
8. Overseas transfer of personal information
Information may be transferred to the following countries due to the sharing and disclosure in the preceding section. Appropriate personal information protection measures required by applicable personal information protection laws and regulations will be taken in the event of transfer.
- USA
- Netherlands
- Singapore
- Vietnam
- Indonesia
9. Security management measures
In order to prevent unauthorized access, loss, destruction, falsification, leaks, etc. of personal information, the Company has taken necessary and appropriate security management measures, including developing rules regarding personal information and information security, clarifying the authority of those responsible, implementing employee training, controlling entry into and exit from controlled areas, implementation of access control and virus countermeasures, and execution of non-disclosure agreements with outside service providers.
In the unlikely event of a personal information leak incident, etc., the Company will investigate the facts and causes, and promptly implement secondary damage prevention measures and recurrence prevention measures.
10. Cookies
The Company’s website uses cookies to collect information regarding the history of customer access to and use of the Company’s website. The Company may also obtain and analyze cookie data on the Company’s website in order to gain an understanding of customer visits to the Company’s website.
- About the use of Google Analytics
The Company uses an access analytics tool provided by a third-party company (Google Analytics) to gain an understanding of the use of the Company’s website. Therefore, the Company uses cookies provided by Google Analytics. This data is collected anonymously and does not identify the individual. For this function, you can refuse collection by turning cookies off, so please check your browser settings. Please see “How Google uses information from sites or apps that use our services” for an explanation of the use of cookies and the details of information collected using cookies.
11. Links to third-party websites or apps
The Company’s website may provide links to third-party websites or apps. The Company does not control the privacy policies of those third parties, and they are not covered by this Policy. Please review the privacy policies of other websites and apps that you use to learn about the data practices of such third parties.
12. Rights of data subjects
The Company will respect the rights you hold regarding personal information protection laws and regulations applicable to you. You may demand the disclosure, correction, addition, or deletion of details, suspension of use, or deletion of your personal information that we retain, as well as the suspension of provision to third parties and disclosure of records of provision to third parties, in accordance with the Act on the Protection of Personal Information (Japan). In addition, you may be granted various rights under applicable personal information protection laws and regulations, etc. The Company will respond appropriately in accordance with the provisions of applicable laws and regulations, etc. If you wish to exercise your rights, please make an inquiry to the point of contact stated in Section 13 of this Policy.
13. Contact details
For inquiries regarding this policy, please contact us >here.
- Denyo Co., Ltd.
- Planning and Coordination Office
- 2-8-5 Nihonbashi-Horidomecho, Chuo-ku, Tokyo 103-8566
14. Changes to this Policy
The Company may amend, revise, add, or delete the details of this Policy from time to time due to the necessity of responding to changes to laws or regulations and due to business necessity, etc. If the Company makes a substantive or material change to this Policy, we will publish it on the Company’s website, and if necessary, contact you using a method that will make you aware of the change.
Last updated: January 20, 2025
Supplementary Provisions Related to Privacy in the EEA and UK
1. Applicability
These supplementary provisions will apply if EEA or UK data protection law applies. These supplementary provisions also describe your data protection rights, including the right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the “Rights of data subjects” section.
2. Categories of personal information subject to processing
Sometimes, we receive information about you from third parties. In particular, the company for whom you work may share your contact details and role with the Company.
3. Purposes of processing and legal basis for processing
(1) Personal information relating to customersbr
(2) Personal information relating to business partners
(3) Personal information relating to shareholderss
(4) Personal information relating to applicants for jobs at the Company and former employees of the Company
As explained above, sometimes we process your data because we have a legitimate interest in doing so. Our legitimate interest will vary depending on what we are using your data for, and we explain above what our interest is that we wish to achieve. You can obtain more information about balancing test, which determines whether individual interests outweigh our interests in the processing, by using the contact details at the end of the notice.
4. Overseas transfer of personal information
As a Japanese headquartered company, most of the Company’s IT systems are provided in Japan. The personal information held by the Company is also processed in Japan. The European Commission and UK government have found that Japan offers an adequate level of protection. The Company relies on these findings for transfers between the EEA and Japan and between the UK and Japan. The Company also transfers some personal information outside of the EEA or the UK. In the event that it is transferred to a country which is not subject to an adequacy finding by the European Commission or UK government or judged to not provide adequate protection pursuant to applicable data protection laws, the Company will use the approved Standard Contractual Clauses and take reasonable steps to ensure your personal information is adequately protected in accordance with the details prescribed by the GDPR or other applicable laws or regulations, etc. In particular, we may use the Standard Contractual Clauses, module 1 (or other relevant modules if any) when we transfer your personal data to group companies in the USA, Indonesia, Vietnam, or Singapore. You may obtain a copy of the relevant mechanism we use to protect your data by using the contact details below.
5. Rights of data subjects
You have the following rights against the Company with respect to your personal information.
- Right to access personal information: You have the right to obtain confirmation from the Company as to whether or not personal information concerning you is handled, and, where that is the case, the right to access personal information and certain related information
- Right to correction of personal information: If your personal information held by the Company is inaccurate, you have the right to demand provision of the personal information.
- Right to deletion personal information (right to be forgotten): You have the right to demand deletion of your personal information that is held by the Company when certain conditions are met.
- Right to restrict handling of personal information: You have the right to restrict handling of your personal information that is held by the Company when certain conditions are met.
- Right to object to handling of personal information: You have the right to object to the Company’s handling of your personal information when certain conditions are met.
- Right to object to direct marketing: You have the right to object to the processing of personal information for the purpose of direct marketing.
- Right of personal information portability: You have the right to receive personal information that you have provided to the Company in a structured and machine-readable format, and to transmit those data to another controller without hindrance from the Company, when certain conditions are met.
- Withdrawal of consent: Even when you have consented at the request of the Company, you have the right to withdraw your consent at any time. However, even if you withdraw your consent, it will not affect processing that has already been conducted at that time.
- Right to not be subject to automated decision-making: You have the right to not be subject to decisions based on automated data processing that would have a legal or similarly significant effect on you (including profiling, etc.), when certain conditions are met.
- French nationals only – Right to instruct the Company regarding the use of personal information after you have died: You have the right to instruct the Company regarding the processing (retention, deletion, and disclosure) of personal information after you have died. You may change or withdraw such instructions at any time.
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep.
6. Complaints to supervisory authorities
You have the right to lodge a complaint about the Company’s handling of your personal information with the supervisory authority of the member state where you live or work or where the GDPR violation took place. The authority for lodging complaints in the UK is the Information Commissioner of the United Kingdom. The authorities in your country of residence for lodging complaints in the EEA are the data protection supervision organizations at the following URL.
https://www.edpb.europa.eu/about-edpb/about-edpb/members_en
7. Contact details of representative
The contact details of the Company’s EEA representative are as follows.
EEA representative: Denyo Europe B.V.
Contact details:
- denyo-europe@denyo.co.jp
- Naamrijk 1, 3454 PX De Meern, The Netherlands
- Tel: 31-30-666-8314
- Fax: 31-30-662-2150
Last updated: January 20, 2025
