Panasonic Automotive Systems Co., Ltd.　 (“PAS”, “we”, “us” or “our”)
4261, Ikonobe-cho, Tsuzuki-ku, Yokohama-shi, Kanagawa-ken 224-8520, Japan

For the purposes of this Privacy Notice "Personal Information" consists of any information that relates to you and/or information from which you can be identified, directly or indirectly. For example, information which identifies you may consist of your name, address, telephone number, photographs, payment details, a specific Panasonic product/device identification number, location data, an online identifier (e.g. cookies identifiers and your IP address) or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity. When we combine other information (i.e. information that does not, on its own, identify you) with Personal Information, we treat the combined information as Personal Information.

A. Personal Information you provide directly

Currently we don’t offer you the option to provide us with your Personal Information directly.

B. Information about your use of the Services

We may collect information about your use of our Services through software on your Panasonic device/product and other means, or your use of our online applications. For example, we may collect:

I. Device/product information - such as your hardware model, device/product IMEI(International Mobile Equipment Identifier)number, the MAC address of the device’s wireless network interface and the mobile phone number used by the device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, and other unique device identifiers, IP address, operating system details, and settings of the device you use to access the Services.

II. Log information - such as the time and duration of your use of the Service, search query terms you enter through the Services, and any information stored in cookies that we have set on your product/device or our application. Cookies only on Panasonic Automotive Systems Global site.

III. Location information - such as your product or device’s GPS signal or information about nearby Wi-Fi access points and cell towers that may be transmitted to us when you use certain Services. Some of our location-enabled Services require your Personal Information for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by altering the settings in your device/product.

We will only process Personal Information if we can rely on a valid lawful basis to do so. Therefore, we will only process your Personal Information when:

I. We have obtained your prior unambiguous consent;
II. The processing is necessary to perform our contractual obligations towards you or to take pre-contractual steps at your request;
III. The processing is necessary to comply with our legal or regulatory obligations;
IV. the processing is necessary to protect your vital interests or those of another natural person; or
V. The processing is necessary for our legitimate interests except where they are overridden by your interests or fundamental rights and freedoms. Examples of such ‘legitimate interests’ include:
a) to benefit from cost-effective services (e.g. we may opt to use certain platforms offered by suppliers);
b) to protect the security of our IT systems, architecture and networks; and
c) to meet our corporate and social responsibility objectives.

We may use the Personal Information we collect for the following purposes:

I. Provide our Services - to provide our Services or any specific feature that you request, including to enable us to fulfil our obligations under any contract with you;
II. Analysis Purposes - for assessment and analysis of our market, customers, products, devices and other Services;
III. Statistics – to create anonymous, aggregated statistics about the use of our Services. This anonymized data may be shared with third parties;
IV. Service Improvement – to develop and improve new and existing PAS Services;
V. Customer Support Services - to provide customer support services to deal with any support queries you may have (such as complaint handling);
VI. Crime Prevention - for the prevention or detection of fraud or crime;
VII. Business Purposes - for business monitoring and internal record keeping;

VIII. Legal Obligations - to comply with our legal obligations;
IX. Training – for staff training and quality assurance purposes, particularly in relation to our customer support;

We will not disclose your Personal Information to third parties for their own independent marketing or business purposes , unless you have given your explicit consent to do so. However, we may disclose your information to the following entities:

I. PAS Affiliates

We may need to transfer your Personal Information to other PAS Affiliates to provide the Services you require or any other services/assistance you request. All PAS Affiliates are required to follow the privacy practices set forth in this Privacy Notice, or such other privacy notice that they may notify to you.

II. Service Providers

We use third party service providers to help us to administer certain activities and services on our behalf, such as call center providers used by PAS to service our customers, data supply, data cleaning, analyzing usage of our Services, providing fraud checking services and customer support services. We may share Personal Information about you with such third party service providers solely for the purpose of enabling them to perform services on our behalf and they will operate only in accordance with our instructions. Here are examples of third-party service providers we use:
a) Analytics Service Providers – analytics providers are used to assist us in understanding the usage of our website and other Services to enable us to improve our Services. For further information see our Cookie Policy.

III. Third parties when required by Law or to Protect our Services

We will disclose your Personal Information to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies; to protect our customers (e.g. to prevent spam or attempts to defraud users of our Services); to operate and maintain the security of our Services (e.g. to prevent or stop an attack on our systems or networks); or to protect the rights or property of PAS, including enforcing any terms or agreements governing the use of our Services.

Ⅳ. Other Parties in Connection with Corporate Transactions

We may disclose your Personal Information to a third party (or other PAS Affiliate) as part of a reorganization, merger, transfer, sale, joint venture, assignment or other disposition of all or any portion of PAS's business, assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding.

Ⅴ. International Transfer of Personal Information

The Personal Information that we collect from you will be transferred to, stored at or otherwise processed outside your country of residence, including, in respect of residents of a country within the European Economic Area (the "EEA"), to a country outside the EEA to Japan and where PAS or its affiliates or service providers, maintain facilities. Your Personal information may also be processed by staff operating inside or outside your country of residence, including staff located outside of the EEA, who work for us or for one of our suppliers or service providers. Where we transfer, store or process your Personal information outside the EEA, we will ensure that suitable safeguards are in place to help ensure that PAS or our third party service providers provide an adequate level of protection to your Personal Information.

The security of your Personal Information is of greatest importance to PAS. PAS has put in place a range of appropriate physical and technical measures and robust policies and processes. The purpose thereof is to safeguard the Personal Information we collect in connection with our Services and to protect it against accidental or unlawful destruction or alteration, accidental loss, unauthorized disclosure or access and against other unlawful forms of processing. These measures take into account the state of the art of the technology, the costs of its implementation, the nature of the Personal Information, and the risk of the processing. However, please note that although we take rigorous steps to protect your Personal Information, no website, online application or transmission of data, computer system or wireless connection is completely secure and therefore we cannot guarantee the security of your Personal Information.

Location of Personal Data

The Personal Information that we collect from you is stored and processed in Japan

Other security measures

Information security, including the protection of Personal Information is organized in a global PAS Program called Information Security Management (“ISM”). The aim, standards and implementation measures are organized in a globally valid policy, further standards and operational standards. All central PAS IT systems are externally assessed and fall under the regulation of ISO 27001 certification. The program and all its parts follow a strong yearly PDCA approach to secure the confidentiality, integrity and availability of all data (including your Personal Information) for the whole information lifecycle from collection to destruction of such information.

PAS will collect, store and process your Personal Information in accordance with your rights under any applicable data protection laws.

Your rights under applicable data protection laws may include, the right to be informed, the right to access a copy of your Personal Information, the right to request the deletion or updating of any inaccurate Personal Information, the right to obtain restriction of the processing of your Personal Information, the right to object, in some cases, to our processing of your Personal Information, and the right not to be subject to a decision based solely on automated processing. In addition, you may have the right to data portability in certain cases. This is the right to request the return of the personal data you have provided to us in a structured, commonly used and machine-readable format and to request the transmission of such personal data to a third party, without hindrance from us and subject to your own confidentiality obligations. You also may have the right not to provide consent and, where you have consented to our processing of your Personal Data, you have the right to withdraw such consent at any time without this withdrawal affecting the lawfulness of the processing prior to such withdrawal.

Your rights are further specified in Art. 7 and Chapter 3 of the GDPR and other applicable data protection legislation.

Enforcing your rights

If you wish to enforce any of your rights under applicable data protection laws, then please contact us using the details given at the end of this Privacy Notice. We will respond to your request without undue delay and by no later than one month from receipt of any such request, unless a longer period is permitted by applicable data protection laws, and we may charge a reasonable fee for dealing with your request which we will notify to you. Please note that we will only charge a fee where we are permitted to do so by applicable data protection laws.

Complaints

If you are concerned that we have not complied with your legal rights under applicable data protection laws, you may contact info.enquiries@ml.jp.panasonic.com.

If you are based in the European region and are not satisfied with how we process your Personal Information, you may file a complaint with the competent supervisory authority:
ーEEA/EU authorities: Members | European Data Protection Board (europa.eu)
ーUnited Kingdom (UK): Make a complaint | ICO    

We will retain your Personal Information for the period necessary to fulfil the purposes for which your Personal Information has been collected. This includes the purposes of fulfilling our contract with you, satisfying any legal, regulatory, reporting obligation we are subject to and the establishment and defense of legal claims.

Our services are not intended for children, and we do not knowingly collect or try to collect Personal Information from or about children without the consent of a parent or guardian. Where we do collect Personal Information from children, we will always use reasonable efforts to verify that consent has been given or authorized by the child's parent or guardian.

Our Services may contain links to other third-party websites that are not operated by PAS, and our websites may contain applications that you can download from third parties. These linked websites and applications are not under PAS's control and as such, we are not responsible for the privacy practices or the content of any linked websites and online applications. If you choose to use any third-party websites or applications, any Personal Information collected by the third party’s website or application will be controlled by the privacy policy of that third party. We strongly recommend that you take the time to review the privacy policies of any third parties to which you provide Personal Information.

What are cookies?
For information on what cookies are, how PAS and other third parties use cookies and similar technologies, and for details of how cookies can be disabled, please see our Cookie Policy.
Further information on cookies

It also is important that you check back often for updates to the Privacy Notice, as we may change this Privacy Notice from time to time. At the top of this page we state when this Privacy Notice was last updated. Any changes will become effective upon our posting of the revised Privacy Notice.

If these changes are material, we will provide notice by posting notice of the changes on the PAS website or through any relevant Services

If you have any questions regarding the collection, processing, or use of your Personal Information or if you wish to exercise any of your rights, please contact us:

Data Protection Contact Point:

Panasonic Automotive Systems Co., Ltd.

4261, Ikonobe-cho, Tsuzuki-ku, Yokohama-shi, Kanagawa-ken 224-8520, Japan
Email: info.enquiries@ml.jp.panasonic.com

For residents in the European Economic Area (EEA)

Please contact our EU Representative:
Panasonic Europe B.V. Zweigniederlassung Deutschland Wiesbaden Office
Hagenauer Strasse 43, 65203 Wiesbaden, Germany
Email:  Data_Protection@eu.panasonic.com