Panasonic Industry Privacy Notice

　

Last updated [1 April, 2022]

Panasonic Industry is committed to ensuring that your "Personal Data" (as explained below) is used fairly, lawfully, and securely and that your privacy is protected at all times. We place high importance on compliance with the applicable privacy and data protection laws and regulations, including, but not limited to the European Union (EU) Regulation 2016/679 General Data Protection Regulation ("GDPR"). If you are a California resident, additional privacy notice applies to you, in accordance with the California Consumer Privacy Act. Please see CCPA Appendix.This Privacy Notice is intended to tell you how we "process" (as explained below) information about you ("Personal Data" as explained below) that you provide to us or that we collect through your use of this website/our websites, password secured platforms, products, devices or applications, your contacts with our customer service, or your subscription to marketing communications (collectively our "Services"), or when you engage with us on social media or otherwise interact with us. It also applies if explicit reference is made to it via link or in a similar manner. Wherever we process your Personal Data and a different privacy notice is required (e.g. for other specific websites or portals), Panasonic Industry will provide a specific privacy notice. This Privacy Notice supplements other privacy notices and is not intended to override them. This Privacy Notice explains what Personal Data we collect, store, use, disclose and transfer (hereinafter "process"), how we do it, for which purpose and what our legal bases are. It also provides you with information on your rights under the GDPR and how you can contact us if want to exercise your rights or have a complaint.

Please click on the links below for further information on our privacy practices:

  1. Information about us

    This Privacy Notice is issued by
    Panasonic Industry Co., Ltd.
    1006, Oaza Kadoma, Kadoma-shi, Osaka 571-8506, Japan
    on behalf of ourselves and the Panasonic Industry Group of Companies. The Panasonic Industry Group of Companies consists of Panasonic Industry Co., Ltd., headquartered in Kadoma, Osaka Prefecture, Japan, as well as a number of Affiliates can be found here
    https://www.panasonic.com/global/industry/outline/map.html

    In this Privacy Notice, when we refer to "Panasonic Industry", "we", "us" or "our", this means the relevant company/companies (in the case of joint controllers) in the Panasonic Industry Group that is/are responsible for processing your Personal Data. For Personal Data gathered via this website, this is Panasonic Industry Co., Ltd.. Where several Panasonic Industry companies are jointly responsible for the processing of your Personal Data, you can exercise your rights against the company issuing this Privacy Notice.

  1. What is Personal Data?

    For the purposes of this Privacy Notice, "Personal Data" consists of any information about an individual from which that person can, directly or indirectly, be identified. When we combine other information (i.e. information that does not, on its own, identify an individual) with Personal Data, we treat the combined information as Personal Data.

  1. What Personal Data do we collect about you and how?

    Depending upon your use of this website/our Services, see Section 4 below, and your cookie choices, see Section 11 below, Panasonic Industry collects and processes some or all of the Personal Data set out in the table below, using the methods and channels also set out in the table.

Types of collected Personal Data

How we collect the Personal Data

“Background Data”: Including proof of identity documentation such as national identification papers or similar, corporate affiliations, government connections, litigation and regulatory proceedings, adverse media and screening against public lists of persons subject to EU or national sanctions, credit registers. This might include sensitive Personal Data under the GDPR.

From you directly, if you choose to share this information with us.
From credit agencies, integrity databases or otherwise as publicly available.

“Business Communication Data”: Electronic such as e-mails, chat messages, pdf and other document files.

From you directly, if you choose to share this information with us.

“Business Contact Data”: Including your job title and function, office address, work email address, work telephone numbers (landline and mobile), and work fax number.

From you directly, if you choose to share this information with us.

“Financial, Payment and Order Data”: Including your company’s bank account and other data necessary for processing orders, payments, deliveries and fraud/crime prevention, including credit/debit cards numbers, and other related billing information.

From you directly, if you choose to share this information with us.

“Identification Data”: Including proof of identity documentation such as national identification papers or similar.

From you directly, if you choose to share this information with us.

“Identity Data”: Including your first name, last name, title, and username or similar identifier.

From you directly, if you choose to share this information with us.

“Location Data”: Such as your product or device’s GPS signal or information about nearby WiFi access points and cell towers that may be transmitted to us when you use certain Services.

Automated, through our use of technologies set on your product, device or our application. 

“Marketing and Communications Data”: Including your marketing and communications preferences such as e.g. language settings. We also track when you receive and read marketing communications from us, which information we use to improve our marketing services, provide you with more relevant information and improve the quality of our marketing materials.

Automated, through our use of cookies and similar technologies set on your product, device or our application, if you consented to our usage on beforehand; please visit our Cookie Policy for more information.

“Product/Device/Application Data”: Including your hardware model, IMEI 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, IP address, operating system details, and other technology on the product or device you use to access the Services.

Automated, through our use of technologies set on your product, device or our application.

“Profile and Usage Data”: Including information collected about your use of this website/our Services such as the time and duration of your use, passwords and login data, your referral website, links you click, searches you conduct, actions you take, pages you visit, your web browsing history, patterns of your usage and information from forms you fill in.

Automated, through our use of cookies and similar technologies set on your product, device or our application, if you consented to our usage on beforehand; please visit our Cookie Policy for more information.

“Transactional Data”: Including information about your transactions (e.g. purchase or return of our products/devices and Services) and details on such product/devices such as the name of the product/device and service, product category, model number, serial number, purchase price, proof of purchase, date and location of the transaction, invoice history.

From you directly, if you choose to share this information with us.

“Your Inquiries Data”: Information in your inquiries to us

From you directly, if you choose to share this information with us.

“Your Opinion Data”: Responses and opinions to questionnaires, monitors, etc.

From you directly, if you choose to share this information with us.

“Events Participation History Data”: Your participation in our events (including online events)

From you directly, if you choose to share this information with us.

Any additional Personal Data you voluntarily provide to us

From you directly

  1. How do we use your Personal Data (purpose and legal basis)?

    We process your Personal Data in the context of the activities and for the purposes set out in the table below and rely on one or more of the following the specified legal bases:

    • Performance of a contract: Where we need to perform a contract which we are about to put in place or have put in place with you as a party, or (at your request) take steps before putting such a contract in place (Art. 6(1)(b) GDPR);
    • Legal obligation: Where we need to comply with a legal obligation to which we are subject (Art. 6(1)(c) GDPR);
    • Legitimate interests: Where we are acting in our legitimate interests, provided that they are not overridden by your fundamental rights (Art. 6(1)(f) GDPR). We assess our legitimate interests for processing your Personal Data and balance them against any potential impact on you. Where we rely on our legitimate interests you have the right to object to such processing at any time under the conditions set out in the GDPR; for more information on our legitimate interests or our balancing test please contact us by using the communication means set out in Section 14 below;
    • Consent: Where we rely on your consent we will ask for it separately (6(1)(a) GDPR).

    Please note that Panasonic Industry does not base any decision solely on automated processing including profiling that significantly affects you or has legal effects for you (Art. 22 GDPR).

Activity and purpose

Types of Personal Data

Legal basis

Manage this website and our Services
To securely provide and administer this website and our Services, this includes continuously improving its functioning, including monitoring performance of data centres and networks, maintaining the security of our infrastructure and Services, testing, reporting and troubleshooting.

Business Contact Data

Legitimate interests
Legal obligation
Consent

Identity Data

Profile and Usage Data

Product/Device/Application Data

Location Data

Creating an Account or Profile
When you create an account or profile on a Panasonic Industry website or application and register products or services there.

Business Contact Data

Performance of a contract

Identity Data

Transactional Data

Publish your comments on message boards and forums
Some Panasonic Industry websites and applications have message boards, forums, bulletin boards, chat functionality, blogs, and similar features ("Community Postings") through which you can post information, messages and other materials. This includes, for instance, our Toughbook Blog.

Business Communication Data

Performance of a contract
Consent

Business Contact Data

Identity Data

Profile and Usage Data

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 (such as, any product or device warranty), providing customer support services and dealing with any other support query you may have (such as, complaint handling), and providing for staff training and informing.

Business Communication Data

Performance of a contract

Business Contact Data

Identity Data

Financial, Payment and Order Data

Transactional Data

Your Inquiries Data

Business Purposes
For business monitoring, protecting our assets, internal record keeping, information management, accounting, audit and debt collection.

Business Communication Data

Legal obligation
Legitimate interests

Business Contact Data

Identity Data

Financial, Payment and Order Data

Transactional Data

Updates
To communicate with you, including communicating with you about your account, profiles or transactions with us, giving you important information about your products, devices, application or other Services and sending you notices about any material changes to our terms and conditions or polices, e.g. this Privacy Notice.

Business Contact Data

Legitimate interests
Legal obligation

Identity Data

Transactional Data

Promotions, (online) games, prize draws, sweepstakes, cash back, competitions and similar activities
To properly conduct and administer any of the above, including sharing your Personal Data with sponsors.

Business Contact Data

Performance of a contract
Legitimate interests
Consent

Identity Data

Transactional Data

Events Participation History Data

Send Marketing Communications
Provide customised advertisements, sponsored content, make recommendations based on your past activities on our Services and sending you promotional communications such as newsletters and sharing your Personal Data with a Partner should you contact us with a sales inquiry.

Business Contact Data

Consent
Performance of a contract
Legitimate interests

Identity Data

Marketing and Communications Data

Product/Device/Application Data

Profile and Usage Data

Your Inquiries Data

Events Participation History Data

Service Improvement and Surveys
To develop and improve new and existing Panasonic products and Services, recommendations, advertisements and other communications and learning more about your preferences including asking you for your opinions on our products and Services and carrying out surveys. This also includes creating anonymous, aggregated statistics about the use of our Services.

Business Contact Data

Consent
Legitimate interests

Profile and Usage Data

Identity Data

Transactional Data

Your Opinion Data

Product recall
In the highly unlikely circumstance that Panasonic Industry needs to recall any product, including for safety purposes, we need to contact you with instructions on how to return your product.

Business Contact Data

Legal obligation

Identity Data

Transactional Data

Compliance and legal action
Ensure administration, operation and compliance with all applicable laws and regulations and internal Panasonic Industry policies and processed, as well as enforcement of legal rights and defence in the event of a legal dispute

Background Data

Legal obligation
Legitimate interests

Business Communication Data

Business Contact Data

Identity Data

Financial, Payment and Order Data

Transactional Data

Compliance screenings
For the prevention or detection of fraud, corruption, money laundering, the financing of terrorism and other criminal acts in the context of mergers and acquisitions and/or general risk management (e.g. related to creditworthiness, export control, fraud, money laundering or anti-bribery and corruption), including screening against public lists of persons subject to EU or national sanctions, credit registers, confirm that that there is no adverse public information connecting you to fraud or financial misconduct, including bribery, and to confirm whether you are a “politically exposed person” (i.e. whether you are or have been a public official or elected official) or associate thereof.

Background Data

Legal obligation
Legitimate interests

Business Contact Data

Identification Data

Identity Data

Transactional Data

Machine Learning
To automize business processes including invoicing and accounting, response to business communication.

Business Communication Data

Legitimate interests

Business Contact Data

Identity Data

Location Data

Marketing and Communications Data

Profile and Usage Data

Transactional Data

Your Inquiries Data

Your Opinion Data

Event Participation History Data

  1. To whom do we disclose your Personal Data?

    We will not disclose your Personal Data to third parties for their own independent marketing or business purposes, unless you have given your explicit consent to do so. However, we may have to disclose your Personal Data to the following entities for the purposes we collected it as set out in Section 4 relying on the legal bases specified therein:

    1. Panasonic Group of Companies

      We may need to transfer your Personal Data within the Panasonic Group of Companies to provide the Services you require or any other services/assistance you request. All companies within the Panasonic Group are required to follow the privacy practices set forth in this Privacy Notice, or another privacy policy that they may notify to you and to process your Personal Data in accordance with the applicable privacy and data protection laws and regulations.

    2. Service Providers

      We use third party service providers who provide information technology and system administration services to us and help us to administer certain activities and services on our behalf and they will operate only in accordance with our instructions as data processors.

    3. Channel Partners

      If you have contacted us regarding a potential sales opportunity, we may provide your Business Contact Data and Identity Data to our approved channel partners in order for to them to follow up the request for contact and further qualify your requirements.

    4. Third parties when required by Law or to Protect our Business and Services

      We will disclose your Personal Data 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); to protect the health and safety of our colleagues and others with whom we have contact; or to protect the rights or property of Panasonic, including enforcing any terms or agreements governing the use of our Services.

    5. Other Parties in Connection With Corporate Transactions

      We may disclose your Personal Data to a third party or within the Panasonic Group of Companies as part of a reorganisation, merger, transfer, sale, joint venture, assignment or other disposition of all or any portion of Panasonic's business, assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding.

    6. Third party competition providers

      We may disclose your Personal Data to third party sponsors of sweepstakes, contests, free prize draws, competitions and similar promotions. These third party providers will be identified to you prior to when you enter into any competition, sweepstake, prize draw or similar promotion.

    7. Other Parties With Your Consent or At Your Direction

      We may share Personal Data about you with third parties when you consent to or request such sharing.

  1. What do we do to keep your Personal Data secure?

    The security of your Personal Data is of greatest importance to Panasonic Industry. We have put in place a range of appropriate physical and technical measures as well as robust policies and processes. The purpose thereof is to safeguard your Personal Data 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 Data, and the risk of the processing.

    Information security, including the protection of Personal Data is organized in a global Panasonic Program called Information Security Management ("ISM"). The related aim, standards and implementation measures are organized in a globally valid Policy, and further standards and guidelines. The program and all its parts follow a strong yearly Plan-Do-Check-Act (PDCA) approach to secure the confidentiality, integrity and availability of all data (including your Personal Data) for the whole information lifecycle from collection to destruction of such information.

  1. Accessing your Personal Data and other rights you have

    What are your rights?

    Your rights under the GDPR include, the right to be informed, the right to access a copy of your Personal Data, the right to request the rectification or the update of any inaccurate Personal Data we hold, and the right to request erasure of your Personal Data.

    You also have the right to obtain restriction of the processing of your Personal Data, the right to object to the processing of your Personal Data at any time under the conditions set out in the GDPR, and the right not to be subject to a decision based solely on automated processing.

    In addition, you 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 have the right to not 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.

    Your rights related to Marketing Communication

    Where permitted under applicable law, we process your Business Contact Data, Identity Data, Marketing and Communications Data, Product/Device/Application Data and Profile and Usage Data for marketing communication purposes to send you correspondence by post, email, telephone and/or text message (such as SMS) related to Panasonic products, devices and other Services in accordance with your marketing preferences.

    You have the right to object to the processing of your Personal Data for these purposes. If you object and request us to stop processing your Personal Data for marketing purposes, we shall stop processing your Personal Data for those purposes.

    You also may opt-out from receiving electronic communications from us. If you don’t want to receive marketing communication from Panasonic, please update your email and contact preferences in your My Panasonic Account or click "Unsubscribe" from any marketing or promotional email you receive from us.

    Exercising your rights

    If you wish to exercise any of the above rights, then please contact us by using the communication means set out in Section 14 below.

    Complaints

    If you are not satisfied with how we process your Personal Data, then please contact us by using the communication means below in Section 14 or alternatively file a complaint with the competent supervisory authority:

  1. International Transfers

    Your Personal Data may be stored and processed in the USA and may be transferred to, stored at or otherwise processed in any other country where Panasonic or its Affiliates, subsidiaries or service providers maintain facilities. We will ensure that your Personal Data remains protected in line with the requirements set out in the applicable data protection legislation.

    Where we transfer your Personal Data obtained from the European Economic Area ("EEA") to recipients located outside of EEA we ensure that your Personal Data remains protected by transferring it only to countries that offer an adequate level of protection as recognised by the European Commission such as e.g. Japan and the United Kingdom and/or by using the Standard Contractual Clauses approved by the European Commission and where required putting supplementary measures in place to afford your Personal Data with essentially the same level of protection it has in the EEA.

    In the same way, if we transfer your Personal Data outside of Serbia, Switzerland, Turkey, or the UK, we will ensure that your Personal Data remains protected in line with the requirements set out in the applicable data protection legislation.

    You may request additional information in this respect and obtain a copy of the appropriate safeguards we provide for through sending a request to the contact indicated in Section 14.

  1. Data Retention - How long we will retain your Personal Data?

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

    Please note that your account information will be deleted without prior notice under the following circumstances.

    1. Your account information is not correct. (In case the information such as name, place of work and telephone number does not exist.)

     

  1. Third-party links and products on our Services

    Our websites, applications and products may contain links to third party websites, plug-ins and applications such as YouTube, LinkedIn and Facebook. These linked websites and applications are not under Panasonic's control and we are not responsible for their privacy practices or the content of any linked websites and applications. If you choose to use any third party website or application, Personal Data 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 Data.

  1. Cookies

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

  1. Children's Personal Data

    This Website is not intended for children (anyone under the age of 16 years) and we do not knowingly collect or try to collect Personal Data from or about children.

  1. Changes to this Privacy Notice or to your Personal Data

    It also is important that you check back often for updates to the Privacy Notice, as we may change it from time to time. The "Date last updated" Section at the top of this page states when this Privacy Notice was last updated and any changes will become effective upon our posting of the revised Privacy Notice.

    We will provide additional notice to you if these changes are material by adding a statement to this website or by sending you a notification through any relevant Services or email.

    We encourage you to review the Privacy Notice whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.It is important to us that the Personal Data we hold about you is accurate and up-to-date at all times. If any of the Personal Data we hold about you changes, please keep us informed.

  1. Contact Us

    If you have any questions regarding the collection, processing, or use of your Personal Data or if you wish to exercise your rights, please contact us at:
    Panasonic Industry Co., Ltd.
    1006, Oaza Kadoma, Kadoma-shi, Osaka 571-8506, Japan
    Inquiry email address : industry-gl-contact@ml.jp.panasonic.com

    If you have questions about Data Protection in Europe, please contact us at:
    Panasonic Marketing Europe GmbH
    The Data Protection Officer
    Hagenauerstrasse 43
    D-65203 Wiesbaden
    or by e-mail: Data_Protection@eu.panasonic.com

    Please note that Panasonic Marketing Europe GmbH acts as Representative of the data controller (Art. 27 GDPR) if you reside in a member state of the European Economic Area.

    If you have any questions about Data Protection in the United Kingdom (UK), please contact us at:
    UK Legal Department
    Panasonic Business Support Europe GmbH (UK branch)
    Maxis 2, Western Road,
    Bracknell, Berkshire,
    RG12 1RT
    or by e-mail: UKLegal@eu.panasonic.com

CCPA Appendix

Date last updated: April 1, 2022

This CCPA Appendix complements Panasonic Privacy Notice and tells you what your rights and our obligations are in relation to the processing of your Personal Data in accordance with the California Consumer Privacy Act (the "CCPA").

If there is any discrepancy between the terms of this CCPA Appendix and those of Panasonic Industory Privacy Notice, this CCPA Appendix will prevail.

We may change this CCPA Appendix from time to time. The "Date last updated" mention at the top of this page states when the CCPA Appendix was last updated and any changes will become effective upon our posting of the revised CCPA Appendix to the extent permitted by applicable laws.

Where required by the CCPA or other applicable law, we will request your consent to any such changes. We will provide the revised CCPA Appendix by email or by posting notice of the changes on our website or through any relevant Services.

Please click on the links below for further information on our privacy practices for residents in California:

  1. What is Personal Data?

    For the purposes of this CCPA Appendix, "Personal Data" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. For example, Personal Data includes, but is not limited to, audio, electronic, visual, thermal, olfactory, or similar information or inferences drawn from other Personal Data to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends among other things.

  1. What Personal Data do we collect about you?

    Please see Chapter 3 of Panasonic Privacy Notice.

  1. On which legal basis do we process Personal Data?

    We process Personal Data of residents in California in compliance with the CCPA. If we are to use your Personal Data for purposes other than the purposes we notified on or before collecting your Personal Data, we will notify the new purposes to you and obtain your express consent.

  1. What are your rights and how can you exercise them?

    1. What are your rights?

      (1) Your rights under the CCPA include, the right to know about your Personal Data that we collect, use, the right to request the deletion of your Personal Data.

      (2) We will not unreasonably discriminate against you for exercising the rights such as the right to know about Personal Data information under the CCPA by using methods including but not limited to the following:

      1. Denying to provide goods or services to you
      2. Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties
      3. Providing a different level or quality of goods or services to you
      4. Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services

    2. Exercising your rights (right to know and right to request the deletion of your Personal Data)

      If you wish to exercise the right to know or the right to request the deletion of your Personal Data under the rights of A(1) above, please contact us by using the following means in addition to the communication means described in Panasonic Industry Privacy Notice. Upon receiving your request to exercise such rights, we will require you to submit your [name and e-mail address] in order to verify your identity.

      1. By e-mail industry-gl-contact@ml.jp.panasonic.com

      We will confirm receipt of your requests to exercise your rights within 10 business days in the same manner in which the request was received and provide information about how we will process the request and the limit of our response. We will respond to requests to know and requests to delete within 45 days, and if we exceed the period, we will notify you and respond within 90 days from the day that we receive the requests. If we cannot verify your requests within the 45-day time period, we may not process your requests.

      We will record your requests and store them for 24 months.

      If you use an authorized agent to submit a request to know or a request to delete, the authorized agent is required to submit to us a written permission proving the authorized agent is permitted to do so and the authorized agent’s own identity verification document(s).

  1. Disclosure of Personal Data

    We have not and will not disclose your Personal Data to any third party for a business purpose.

  1. Sale of Personal Data

    We have not and will not sell your Personal Data to any third party.

    For the purposes of this CCPA Appendix, "sell" means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, your Personal Data by us to another business or a third party for monetary or other valuable consideration.

  1. Children’s Personal Data

    Our services and products are principally directed at business professionals.

    They are generally not intended for children under the age of 16. We do not sell Personal Data of anyone under the age of 16.

  1. Contact Information

    You may contact us with questions or concerns about this CCPA Appendix and your choices and rights under CCPA at:

    Company name: Panasonic Industry Co., Ltd.
    Company address: 1006, Oaza Kadoma, Kadoma-shi, Osaka 571-8506, Japan
    Company email address: industry-gl-contact@ml.jp.panasonic.com