Privacy Policy

Understanding the importance of personal information, we will appropriately acquire, use, and safely manage personal information that you provide by complying with laws related to the protection of personal information,

1. Acquisition

We shall acquire personal information within the scope of the purpose of use, and such acquisition shall be conducted by lawful and fair means.

2. Purpose of use

We shall use the obtained personal information only for the following purposes, and shall not use it for any other purposes.
In addition, any change made to the purpose of use shall be notified on this website. In the event the purpose of use is separately notified or publicly announced, the information shall be used within that scope of purpose.

(1)Related to business activities

①For the manufacture and sales activities of our products and services

②For our sales activities and provision of our products, services and after-sale services

③To disseminate, publicize, and provide information and advertising materials concerning our products and services

④For marketing research and analysis in the planning, development and manufacture of our products and services

⑤For sales activities of our products, services and for marketing research and analysis to provide information

⑥For maintenance of our products and services, implementation of technical support, and operation management

⑦To respond to inquiries about our products and services, and introduce 　contact information.

⑧For the purpose of demonstrating, verifying and researching our products and services in order to conduct promotional activities and sales activities through planning, development and manufacture of our products and services

⑨For planning, holding, guiding, and operating exhibitions, seminars, events, promotions, and other events

⑩To communicate with us and provide us with information

(2)Related to shareholders

①To deliver publications, and to offer benefits, etc.

②To implement various measures to facilitate our relationship with shareholders

③To fulfill rights and obligations under the law

(3)Related to hiring

①For the purpose of recruitment screening

②To give notification and invitation on recruitment events, and to send materials

③For your identity verification

④For guidance on medical examinations, submission of necessary documents, and communication in recruitment procedures

(4)Related to employment management

①For employment management

(5)Others that are common to above items

①For contacting and responding to inquiries and questions to us

②For the use when it is necessary to retain or acquire personal information to fulfill our legal obligations (Performance of various contracts, negotiations, claims, brokerage, mediation, etc)

③For the optimization of quality and content of our website

④For responding to requests from public organizations such as the national government, local governments, courts, and police stations

3. Management and Protection

We will appropriately manage the obtained personal information according to the purpose of use, and take necessary and appropriate safety management measures to prevent leakage, loss, or damage.
In addition, access to the retained personal data shall be restricted to those who have access rights and shall be managed so that unauthorized use will not occur internally.

4. Entrustment of handling personal data

We may outsource the handling of personal data to business support partner companies.
In such case, we shall select a contractor to handle personal data appropriately and entrust to the company.
In addition, we shall conclude a contract concerning the handling of personal data and manage the entrustment.

5. Provision to third party

Acquired personal data will not be disclosed or provided to any third party without advance consent from you.
Though, in the following cases personal data may be disclosed or provided.

When there is consent from you
When disclosing or providing Pseudonymized Processed Information or Anonymously Processed Information created in relation to demonstration, verification and research.
When required by laws and regulations
When it is necessary to protect the life, body or property of a person, but obtaining the consent is difficult
When it is particularly necessary for improvement of public health or promotion of sound growth of children, but obtaining the consent is difficult
When there is a need to cooperate to the government agencies, local public entity, or a person entrusted by them performing affairs based on laws and regulations, but there is a possibility that obtaining the consent may interfere with the performance of the said affairs

The above provisions shall also apply in the event that we disclose or provide individual-related information (limited to that which constitutes an individual-related information database, etc.) to a third party, and the third party to whom the individual-related information is disclosed or provided is expected to acquire such individual-related information as personal data.

6. Joint use

We may share your personal data to the extent necessary to achieve the purpose of use.

Personal data to be sharedName, and personal identification information such as appearance, voice, voice print, and other individual-related information such as address, company name, department name, title, telephone number, e-mail address, details of inquiry, online identifier（cookie, IP address）, device information (language, location data, etc.), usage status of the website, various questionnaire information, and transaction details （purchase history, delivery/delivery destination）.
Range of joint users
・TOA Corporation and its subsidiaries and affiliates（the “TOA Group Companies”）
https://www.toa-global.com/en/profile/company/network
・TOA Labor union
With the exception of a few cases, we will not, in principle, transfer personal data acquired in Japan outside of Japan for shared use.
Purpose of use of joint users
Please see 2. Purpose of Use above.
Name of responsible entity for the management of said personal data
7-2-1 Minatojima-Nakamachi, Chuo-ku, Kobe, Hyogo, Japan
TOA Corporation

7. Disclosure, Correction, Deletion, and Suspention of use

Upon receipt of a request from you for disclosure, correction, or deletion of personal data, after the identity verification, the information will be disclosed, corrected, or deleted.
Please check the following for procedures to change shareholders’ personal data in the shareholder registry.
https://www.toa-global.com/en/ir/stockinfo/stock

In the event of a request from you for notification, disclosure, correction, or deletion of the purpose of use of personal data that identifies that person, we will disclose, correct, or delete the purpose of use of the retained personal data pertaining to that person after confirming the identity of the person.
Upon request from you, and if the person specified in the following items is located in a foreign country, we will provide the name of the country in which the person is located, information on the regulations regarding the protection of personal information in that country, and information on the measures taken by that person to protect personal information.

Consignee as specified in 4.
Third parties to whom personal data is provided as specified in 5.
Third parties with whom personal data is used jointly as specified in 6.

We will notify you of the details of our response to the above requests by providing an electromagnetic record (e.g., by sending it as an attachment to an e-mail), by delivering a written document, or by any other method you choose.
In addition, in case shipment of document is chosen, a charge equivalent to the actual cost of shipping may be charged as a service charge. Also if you wish to make payment by remittance, a bank transfer charge shall be borne by you.
If we delete or suspend the use of your personal data upon your request, we will not be able to provide you with our products (products and services) thereafter.

8. Revision

We will review and update the contents of the above items regarding the handling of your personal information as appropriate.
When changes are made to this privacy policy, update notice will be posted on the website and will be effective as of the posted date.

9. Contact details

For any inquiries about your personal information, please contact below
Please note that we cannot accept any inquiries on direct visits.

TOA Corporation
Email address: [email protected]

Special Provisions (for the GDPR)

We will properly collect, use and safeguard personal data provided by you in the European Union-member countries and the three EEA/EFTA states – Iceland, Liechtenstein and Norway (the “EU”), by understanding the importance of personal data and by complying with EU General Data Protection Regulation (the “GDPR”)

1. Categories of personal data

We will collect and process the following personal data in the context of our services:

Customer data, including name, address, company name, title, phone number, email address, online identifier (cookie, IP address), device information (language, location data, etc.), usage status of the website, various questionnaire information, transaction details （purchase history, delivery/delivery destination）, subject, voice, voiceprint, etc.
Recruitment data, including the candidate's name, gender, address, telephone number, e-mail address, nationality, educational background, career, qualifications, and health checkup information, etc.
Employment management data, including the employee’s My Number information, employment insurance or social insurance number, information on companies that the employee has worked at in the past and information on awards and punishments.

2. Purpose of use and legal basis for handling

Based on a legal basis, we will handle your personal data for the following purposes.

Related to business activities ①For the manufacture and sale of our products and services②For our sales activities and provision of our products, services and after-sales services ③To disseminate, publish, and provide information and advertising materials concerning our products and services ④For marketing research and analysis in the planning, development and manufacture of our products and services ⑤For sales activities of our products, services and for marketing research and analysis to provide information ⑥For maintenance of our products and services, implementation of technical support, and operation management ⑦To make inquiries about and respond to inquiries about our products and services, and to introduce contact points ⑧For the purpose of demonstrating, verifying and researching our products and services in order to conduct promotional activities and sales activities through the planning, development and manufacture of our products and services ⑨For planning, holding, guiding, and operating exhibitions, seminars, events, promotions, and other events ⑩To communicate with us and provide us with information
Related to shareholders ①To send publications, offer benefits, etc. ②For the purpose of implementing various measures to facilitate relations between shareholders and us ③For the fulfillment of rights and obligations under the law
Related to hiring ①For the purpose of recruitment ②To guide recruitment events, to communicate, and to send materials ③For the purpose of identity confirmation ④For guidance on medical examinations, submission of necessary documents, and communication in recruitment procedures
Related to employment management ①For employment management
Others that are common to above items ①For responding to and communicating inquiries and questions to us ②For use when it is necessary to retain or acquire personal information in order to fulfill our legal obligations (Performance of various contracts, negotiations, claims, brokerage, mediation, etc) ③For optimization of quality and content of our website ④For responding to requests from public organizations such as the national government, local governments, courts, and police stations

3. Recipients of personal data

We will process your personal data through the following recipients:

TOA Corporation’s subsidiaries and affiliates (the “TOA Group Companies”)
We will use the personal data described above jointly with TOA Group Companies and responsibly manage the joint use for the purposes described above. Please find the URL for domestic and overseas TOA Group Companies.
https://www.toa-global.com/en/profile/company/network
Business support partners
We will consign the handling of personal data after concluding a　 memorandum for business support with business support partner companies. Business support partner companies include, for example, companies that provide maintenance and technical support for our products and services, agencies consigned to manage employees’ personal information, recruitment agencies and shareholder registry agencies, etc.
Business partners
We will provide personal data to partner companies such as distributor partners and dealer partners.

4. Sources of personal data

We will collect your personal data directly from you. However, in some cases, your personal data that we collect are provided by the TOA Group Companies, business support partners and business partners.

5. Transfers to recipients in Third countries

In order to provide our services, we will need to transfer your personal data to countries outside of the EU, including countries that are not recognized by the European Commission as providing an adequate level of data protection. Please be advised that we only transfer personal data to these countries when we have been able to implement suitable safeguards that assure the protection of your personal data, such as standard data protection clauses under Article 46.2 of the General Data Protection Regulation (EU) 2016/679 (the “GDPR”).
For further information, including obtaining a copy of the documents used to protect your personal data, please contact us by sending an email or by calling or faxing TOA Network（https://www.toa-global.com/ja/profile/company/network）.

6. Retention period

We will store your personal data for as long as necessary in light of the purposes described above. The criteria used to determine our retention periods include:

whether we have an ongoing relationship with you;
whether there is any legal obligation that we are subject to
whether there is a need to perform a contract that you are party to.

7. Your rights

You have the right to request for a copy of your personal data; to correct, delete or restrict（or stop） handling of your personal data; and to obtain the personal data that you provided to us, based on a contract or with your consent, in a structured and machine-readable format（i.e. the right of data portability）.
In addition, you can object to the processing of your personal data under certain conditions （for further information, see the section below entitled “8. Your right to object to processing”）.
These rights may be limited, for example, if the fulfilment of your request would reveal personal data about another person, where it would infringe upon the rights of a third party （including our rights） or if you ask us to delete information that we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and local EU laws on privacy.

8. Right to object to processing

You have the right to object at any time to the processing of your personal data that is based on our legitimate interests, including “profiling”（i.e. analyzing or predicting your behavior based on your information）.
When we process your personal data for direct marketing purposes, you have an absolute right to opt out of direct marketing or the profiling we carry out for the direct marketing.

9. Right to withdraw consent

Wherever we rely on your consent, you have the right to withdraw the consent at any time.
Such withdrawal does not affect the lawfulness of any processing performed pursuant to the consent given prior to the withdrawal.

10. Personal data that you need to provide

Necessary personal data is indicated in the relevant forms that you complete.
Where provision of personal data is necessary, we are not able to provide our services to you if the relevant information is not provided.

11. Right to complain to a supervisory authority

You have the right to make a complaint to a supervisory authority, including the supervisory authority of the EU Member State of your habitual residence or place of work, or in the place where the alleged infringement of the GDPR took place.

12. Revision

We reserve the right to amend this privacy policy at any time. The revised privacy policy will be available on our websites.

13. Contact details

For any inquiries about your personal information, please contact:

TOA Corporation
Email address: [email protected]

Special Provisions (for the United States)

We will properly collect, use and safeguard personal data provided from you by understanding the importance of personal data and by complying with United States data protection regulations.

1. Categories of personal information

We have been collecting and handling following personal information within the past twelve (12) months

Customer data, including name, address, company name, title, phone number, email address, online identifier (cookie, IP address), device information (language, location data, etc.), usage status of the website, various questionnaire information, transaction details （purchase history, delivery/delivery destination）, subject, voice, voiceprint, etc.
Recruitment data, including candidate's name, gender, address, telephone number, email address, nationality, educational background, career background, qualifications, and health information; and
Employment management data, including employee’s My Number information, employment or social insurance number, information on companies for which the employee has worked in the past, and information on awards and reprimands.

2. Sources of personal information

We have been collecting your personal information within the past twelve (12) months in the following ways.

Directly collecting the information in person, by email, or using the forms on our websites;
Indirectly collecting the information from subsidiaries and affiliates of TOA Corporation（the “TOA Group Companies”）, business support partners, and business partners
Automatically collecting the information from your history of use with our website through analytical tools such as cookies, web beacons, etc.

In some cases, we use cookies, web beacons, and other analytical tools to collect information about how you visit, use, and interact with us.
Following are the third-party services that we use to analyze your history of use of our websites and opt-out instructions

Google Analytics
If you would like to prevent your data from being used by Google Analytics, please download and install the Google Analytics Opt-out Browser Add-on for your web browser:
https://tools.google.com/dlpage/gaoptout

Notice regarding the “Do Not Track(DNT)” setting: this setting allows for certain privacy settings that can be established by users on their specific web browsers.
Although we work to provide meaningful choices about the information collected from our websites for third parties, currently we do not support DNT signal responses of web browsers.

3. Purpose of use

We will handle personal data for the following purposes

Related to business activities ①For the manufacture and sale of our products and services ②For our sales activities and provision of our products, services and after-sales services ③To disseminate, publish, and provide information and advertising materials concerning our products and services ④For marketing research and analysis in the planning, development and manufacture of our products and services ⑤For sales activities of our products, services and for marketing research and analysis to provide information ⑥For maintenance of our products and services, implementation of technical support, and operation management ⑦To make inquiries about and respond to inquiries about our products and services, and to introduce contact points ⑧For the purpose of demonstrating, verifying and researching our products and services in order to conduct promotional activities and sales activities through the planning, development and manufacture of our products and services ⑨For planning, holding, guiding, and operating exhibitions, seminars, events, promotions, and other events ⑩To communicate with us and provide us with information
Related to shareholders ①To send publications, offer benefits, etc. ②For the purpose of implementing various measures to facilitate relations between shareholders and us ③For the fulfillment of rights and obligations under the law
Related to hiring ①For the purpose of recruitment ②To guide recruitment events, to communicate, and to send materials ③For the purpose of identity confirmation ④For guidance on medical examinations, submission of necessary documents, and communication in recruitment procedures
Related to employment management ①For employment management
Others that are common to above items ①For responding to and communicating inquiries and questions to us ②For use when it is necessary to retain or acquire personal information in order to fulfill our legal obligations (Performance of various contracts, negotiations, claims, brokerage, mediation, etc) ③For the optimization of the quality and content of our website ④For responding to requests from public organizations such as the national government, local governments, courts, and police stations

4. Recipients of personal information

We have been sharing your personal information within the past twelve (12) months to following recipients:

TOA Group Companies
We use the personal information described above jointly with the TOA Group Companies and responsibly manage the joint use for the purposes described above. “TOA Group Companies” includes the domestic and overseas group companies. (https://www.toa-global.com/profile/company/network);
Business support partners
We consign the handling of personal data after concluding a memorandum for business support with business support partner companies. Business support partner companies include, for example, companies that provide maintenance and technical support for our products and services, agencies consigned to manage employees’ personal information, recruitment agencies and shareholder registry agencies, etc.
Business partners
We provide personal information to partner companies, such as partner distributors and partner dealers; and
Law enforcement agencies
We provide personal information to law enforcement agencies to the minimum extent when necessary to fulfill legal obligations or in response to requests from the government or investigative agencies.。

Notwithstanding the above, we have not sold your personal information to third parties in the past twelve (12) months.

5. Retention period

We store your personal information for as long as necessary in light of the purposes described above. The criteria used to determine our storage periods include:

whether we have an ongoing relationship with you;
whether there is any legal obligation that we are subject to
whether there is a need to perform a contract that you are party to.

6. Your rights

You have the following rights:

Right to request disclosure
<Disclosure of personal information we collect>
You have the right to request that we disclose the categories and specific information we have collected about you.
Please note that we will respond to your disclosure request only if we can verify your identity.
In some cases, we are not required to provide such information to you more than twice in a 12-months period.
①Categories of personal information we collect about you ②Categories of sources of collection ③Business or commercial purposes for collecting or selling personal information ④Categories of third parties to which we share personal information ⑤Specific personal information we collect about you
If you exercise this right to request disclosure, please contact the inquiries address listed in this privacy policy.
<Disclosure of personal information we sell or share>
You have the right to ask us to provide information on the following matters when we sell your personal information or disclose it for business purposes. Please note that we will respond to your disclosure request only if we can verify your identity.
①Categories of personal information we collect about you ②For each category of personal information received by each third party to which the personal information is sold, the category of the personal information sold and the category of the third party ③Categories of personal information disclosed by us for business purposes
If you exercise this right to request disclosure, please contact the inquiries address listed in this privacy policy.
<Sharing with third parties for direct marketing purposes>
You may have the right to request the content of personal information that we share with third parties for the purpose of third-party direct marketing once a year.If you exercise this disclosure request right, please state "Requests under the Shine the Light Law of California" and contact the inquiries address listed in this privacy policy.
Right to delete
You have the right to request that we delete any of your personal information that we have collected from you. Please note that we will respond to your deletion request only if we can verify your identity.

Notwithstanding the foregoing, we may not be able to respond to your request for deletion primarily in the following cases: ①To complete the transaction between you and us, to provide our products and service requested by you, or to perform a contract with you; ②To detect security incidents, to protect against illegal or inappropriate activity, or to prosecute those responsible for such activity; ③To debug to identify and repair errors that impair intended functionality; ④To exercise free speech, to ensure the right of another consumer to exercise his or her right of free speech, or to exercise another right provided for by law; ⑤For internal use, when reasonably meeting with your expectations or in appropriate manner consistent with the purpose for which you provided the information. ⑥To comply with legal obligations.
If you exercise this right to request deletion, please inquire to contact details listed in this privacy policy.
Opt-out rights
You have the right to instruct us not to sell your personal information.We have not sold your personal information in the previous twelve (12) months, but, if we plan to do so in the future, in accordance with the law, we will inform you that your personal information may be sold and you have right to opt out of that sale.
Non-discrimination rights
<Prohibition of discrimination due to exercise of rights>
We do not discriminate against you due to the exercise of any of your rights under the laws and regulations, including, but not limited to, by: ①Denying goods or services to you; ②Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; ③Providing a different level or quality of goods or services to you ④Suggesting that you will receive a different price or rate, level or quality of goods or service.
<Financial incentive program>
We may offer financial incentives to you as compensation for the collection, sale, or deletion of personal information only if the important terms of the financial incentive program are clearly stated and the consent, which may be withdrawn at any time, is obtained.We do not offer financial incentives at present; however, if we do so in the future, notifications regarding the financial incentives will be provided in accordance with the law.

7. Link to the opt-out page

We have not sold your personal information in the previous twelve (12) months, but, if we plan to do so in the future, in accordance with the law, we will install the following link on our websites: “Do Not Sell My Personal Information”.

8. Rights of children

This website is not intended for use by children under the age of 13.
If the personal information we collect is found to contain the information of children under the age of 13, we will immediately delete the personal information.
We have not sold the personal information of consumers between 13 and 16 years of age; however, if we plan to do so in the future, the sale of personal information will not be done unless the consumers between 13 and 16 years of age have affirmatively authorized it.

9. Revision

We will review and improve the contents of the above items regarding the handling of your personal information as appropriate.
When changes are made to this privacy policy, an update notice will be posted on the website and will be effective as of the posted dated.

10. Contact details

For any inquiries about your personal information, please contact:

TOA Corporation（TOA Electronics, Inc.）
Toll-free number: 010‐1‐（650）452‐1200 / （800）‐733‐7088 ,
[email protected]

Effective Date: April 1, 2020
Revision Date: April 1, 2022