PRIVACY POLICY FOR EEA

September 25, 2020

We process the personal data of customers to whom those regulation apply (referred to as a “Customer” or “You” throughout this privacy policy) in accordance with the applicable EU and EU Member State’s regulation on personal data protection, in particular the General Data Protection Regulation 2016/679 (the “GDPR”). This privacy policy explains how we, as the data controller, process your personal data.

1. Legal Bases for Processing / Categories of Personal Data Subject to Processing
   We process the following categories of your personal data based on the legal bases provided for in the GDPR (Article 6 and 7). For clarity, we don’t process your personal data of a sensitive nature, including your religious belief and health status.
   We may obtain and process your personal data in the following cases :(a) if required in order to provide you with adequate services and products and we otherwise have a legitimate interest; (b) if required in order to perform an agreement with you or carry out procedures before execution; or (c) if we have obtained your express prior consent. In that case, we will give notification of the purpose of that collection and processing to you through notification when obtaining consent, agreement, or other appropriate means.
   You are entitled to withdraw your consent to the collection and processing of the personal data at any time, but this withdrawal will not affect the lawfulness of processing based on the consent before withdrawal thereof.
   We don’t conduct any solely data-based, automated decision-making that produces any legal or similar material effect on you.
   We will notify you separately, if the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as the possible consequences of failure to provide such data.
   
   
2. Sources of Personal Data
   We obtain your personal data directly from you or indirectly through third parties such as those stated below.
   In the case of that we obtain your personal data indirectly for fulfillment a contract which was concluded with us, through the company which had employed you as a personnel;
   The company.
   
   
3. Retention Period for Personal Data
   We will retain your personal data for as long as necessary to fulfill the aforementioned purpose for obtaining and processing your personal data. Specific retention periods are decided based on the following considerations: the purpose for obtaining and processing the personal data; the nature of the personal data; and the necessity of retaining the personal data for legal or business reasons.
   
   
4. Sharing and Disclosure of Personal Data
   At the present, we don’t share or disclose your personal data to any third parties. It may be necessary for us – by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence – to disclose personal data.
   
   
5. Data Transfers
   At the present, your personal data will not be transferred to the third countries outside the EEA. For clarity, your personal data will be transferred to Japan in accordance with GDPR (Article 45).
   
   
6. Your Rights
   You have the following rights regarding personal data obtained and processed by us.
   ・Obtaining information regarding processing of data: You have the right to obtain from us all requisite information regarding our data processing activities that concern you (Article 13 and 14 of the GDPR).
   ・Access to personal data: You have the right to obtain from us confirmation as to whether personal data concerning you are being processed, and, if so, then access to the personal data and certain related information (Article 15 of the GDPR).
   ・Rectification or erasure of personal data: You have the right to have us rectify inaccurate personal data concerning you without undue delay and the right to have us complete any incomplete personal data (Article 16 of the GDPR). Also, if certain conditions are satisfied, you will have the right to have us delete personal data concerning you without undue delay (Article 17 of the GDPR).
   ・Restriction on processing of personal data: If certain conditions satisfied, you will have the right to have us restrict processing of personal data concerning you (Article 18 of the GDPR).
   ・Objection to processing of personal data: If certain conditions are satisfied, you will have the right to object to processing of personal data concerning you (Article 21 of the GDPR).
   ・Data portability of personal data: If certain conditions are satisfied, you will have the right to receive personal data concerning you in a structured, commonly used, and machine-readable format and the right to transfer those data to another controller without hindrance from us (Article 20 of the GDPR).
   ・Not to be subject to automated decision-making: If certain conditions satisfied, you will have the right not to be subject to solely data-based, automated decision-making (including profiling) that produces any legal or similar material effect on you (Article 22 of the GDPR).
   If you intend to exercise any of the aforementioned rights, please inquire using the contact detail at the end of this privacy policy.
   You can lodge a complaint in relation to our processing of your personal data with the Data Protection Supervisory Authority of the Member State of your habitual residence, please of work or place of the alleged infringement.
   
   
7. Amendment to this Privacy Policy
   We amend this Privacy Policy from time to time. We will contact you through this website and by e-mail if necessary, where we make any substantive or material amendments.
   
   
8. Contact Details
   For question or inquiries regarding this privacy policy, please contact the data controller set out below.

Data controller
INTELLIGENT WAVE INC.
1-21-2, Shinkawa, Chuo-ku, Tokyo 104-0033 Japan
info_privacy@iwi.co.jp