PRIVACY POLICY

1. About this Policy

This Policy applies to the processing of your personal data by Shimadzu Corporation (the “Company,” “we,” “our,” or “us”).

2. Definitions

In this Policy:

3. How We Collect Your Personal Data

We may collect information that you provide to us, whether by means of a form on our website, by email, in a letter, or otherwise, such as your name, address, email address, telephone number, fax number, workplace information, division and department, title, position, name of your contact group or organization, technical rank, password, details of your inquiry, information on whether we can send you direct mail, etc., products or fields in which you are interested, campaign codes, consent to acquisition or use of cookies, feedback to our website, etc.

We may also receive relevant information from our distributors, agents and other third parties, such as your name, address, email address, telephone number, workplace information, division and department, name of your contact group or organization, commercial negotiation or transaction status, commercial negotiation or transaction history, details of your inquiry, information on whether we can send you direct mail, etc., history of your participation in exhibitions, seminars, etc., information on a device that you use, history of your access to our and our subsidiaries’ websites, etc.

When you visit our website, we may automatically collect the materials that you access, your download history, traffic data, location information, log, language information, dates and frequency of access, other communication information (including IP address, operating system, host domain, and type of browser), information on your computer and internet connection, and URLs of reference sources (“Communication Information”).

If you are our or our subsidiary’s employee, we may collect your name, email address, user ID, photo, address, telephone number, fax number, workplace information, division and department, schedule, attendance status, passport information, signature, etc. (“Employee Information”), as well as your login history, history of sending and receiving emails, certification log, email archive, history of use of Office 365 (email, SharePoint, Teams, Forms, etc.), if you use Office 365 (“System Information”).

4. Purposes of Processing Personal Data

We use the Personal Data that we hold about you for the purposes set forth below. We will use your Personal Data only to the extent necessary to fulfill these purposes:

5. Disclosure of Personal Data to Recipients and Joint Use of Personal Data

We may share your Personal Data with the following categories of recipients:

We may otherwise disclose your Personal Data to any third party other than those set forth above, including public agencies, if such disclosure is required to achieve the purposes for which you provided Personal Data to us or other purposes that we specify when obtaining consent or Personal Data from you, and to the extent necessary to comply with any laws and regulations applicable to us, to cooperate with relevant governmental authorities and agencies, or to establish, exercise or defend legal claims.

Under Japanese law, we may use the joint use framework under the Act on the Protection of Personal Information to share with our subsidiaries (including those subsidiaries located outside Japan) and your relevant agent, your name, address, email address, telephone number, signature, name of your contact group or organization, commercial negotiation or transaction history, details of your inquiry, information on whether we can send you direct mail, etc., history of your participation in exhibitions, seminars, etc., information on a device that you use, history of your access to our and our subsidiaries’ websites, for the purposes referred to in Section 4(a) to (l) above.

In addition, if you are a cooperating company (including a vendor, a contractor of manufacturing, a contractor of service, a receiver of our orders for services, etc.) or a person in charge therein, we may share your name, address, email address, telephone number, name of your contact group or organization, and transaction history with our subsidiaries (including those subsidiaries located outside Japan) for the purpose referred to in Section 4(j) above.

If you are our employee, we may share your Employee Information and System Information with our subsidiaries (including those subsidiaries located outside Japan) for the purposes referred to in Section 4(a), (b), (d), (e), (g), (j), (m), (n), (o), (p), (q), (r), and (s) above.

In these cases, we will be the party responsible for the management of your Personal Data. Please refer to Section 11 below for our address and the name of our representative, and other information.

6. Provision of Your Personal Data Outside Japan

Your Personal Data may be provided to third parties outside Japan, such as our subsidiaries located outside Japan, etc. The names of the countries other than Japan (excluding those countries provided by the Enforcement Rules for the Act on the Protection of Personal Information as foreign countries which have systems to protect personal information that are found to be on the same level as those of Japan in protecting personal rights and interests) where third parties to which we may provide your Personal Data are located (excluding those third parties which have established systems meeting the standards provided by the Enforcement Rules for the Act on the Protection of Personal Information), and information regarding the legislation to protect personal information in these countries are as set forth below. The third parties to which we may provide your Personal Data take all measures corresponding to the 8 Principles under the OECD Privacy Guidelines.

7. Storage Period for Personal Data

We will retain your Personal Data that we collect for the period necessary to Process such Personal Data. For example, your membership information regarding services on a members-only website will be retained until you cancel your membership, and your access log will be retained for 18 months. However, this does not apply if we are required by laws or regulations to retain your Personal Data for a longer period of time, in which case, we will retain it for the period required by laws or regulations.

8. Your Rights

You have a number of legal rights in relation to the Personal Data that we hold about you. These rights may vary depending on where you are located and which data protection laws apply to the relationship between you and us, but they typically include the following:

You may exercise any of your rights by contacting us at our contact pointset forth in Section 11 below. You also may lodge a complaint with the data protection authority if you believe that any of your rights has been infringed by us.

9. Security Control Measures

We take necessary and appropriate measures to prevent any leakage, loss of, or damage to, your Personal Data to be Processed and to otherwise control the security of personal information, such as clarification of the person responsible for or the person in charge of Processing of Personal Data, regular self-inspection of the Processing status of Personal Data, establishment of a system to report leakage, etc., formulation of rules on Processing, regular training of employees regarding Processing of Personal Data, management of entries into and exits from facilities, prevention of theft or loss of equipment for Processing Personal Data, appropriate discarding of Personal Data, ensuring the security of the systems and devices used, and implementation of access controls, etc. We also exercise appropriate supervision over our contractors and employees who Process Personal Data, and if we handle personal information outside Japan, we grasp the country’s legislation to protect personal information and take appropriate security control measures.

10.Use of Cookies

Please refer to the Cookie Policy regarding the use of cookies, etc., on our website.

11.Contact Point

If you have any questions about this Policy, your rights, or any other matter relating to the protection of personal information, please contact us at the following contact point:

(a)		Address of head office: 1, Nishinokyo Kuwabara-cho, Nakagyo-ku, Kyoto-shi 604-8511
(b)		Name of representative: Yasunori Yamamoto
(c)		Responsible department: IT Strategy Unit, DX·IT Strategy Management Department, Shimadzu Corporation
(d)		Email address:
(e)		Telephone number: 075-823-1278
(f)		FAX: 075-823-2091

For Those in the EEA and the UK

This section applies to those in the European Economic Area (the “EEA”) and the UK. This section supplements our “Privacy Policy” (the “Policy”), and if there is any conflict between any provision in this section and the provisions of the Policy, the provision of this section shall prevail.

1. Legal Basis

We Process your Personal Data on the legal basis set forth below.

(a)		Contract. Where the Processing of your Personal Data is necessary to perform a contract we enter into with you or take any measures before entering into a contract according to your requests. The Processing of your Personal Data conducted by us based on the contract includes that conducted for the purpose of providing you with information, products, and services that you request from us based on a contract that we enter into with you.
(b)		Legitimate interests. Where the Processing of your Personal Data is necessary for legitimate interests pursued by us or a third party, and your interests or fundamental rights and freedoms do not override those interests. The Processing of your Personal Data conducted by us based on the legitimate interests includes that conducted for the following purposes:   to show the contents of the website in the most effective manner for you or your computer; to allow you to use the interactive functions of our services when you wish to do so; to ensure the security of the website; to provide you with technical support and to improve the relevant websites and services; to provide you with information that you request to address your inquiry; to announce a change in our services or website; if you are an existing customer, to contact you to provide you with information regarding products and services that are similar to those products and services that were previously subject to sale or negotiations for sale (including contact by email and SMS); or to disclose your Personal Data to a person that succeeds to our business due to a business transfer, merger, consolidation, change of control, transfer of material assets, restructuring, liquidation, or any other organizational restructuring. The legitimate interests which we rely on include conducting our business, increasing our sales, and ensuring our security. You may obtain further details about legitimate interests by contacting us at our contact pointset forth in Section 11 of the Policy.
(c)		Consent. Where we obtain your consent. The Processing of your Personal Data conducted by us based on your consent includes the Processing for the purpose of providing you with information regarding products or services in which you seem to be interested. If you do not wish to allow us to use your Personal Data in such manner, you are requested to refuse to give us consent when we request your consent in a form used by us to collect your Personal Data, or to withdraw your consent by sending an email containing your request to . The withdrawal of your consent will not affect the lawfulness of Processing performed based on the consent before your withdrawal.
(d)		Legal obligation. Where the Processing of your Personal Data becomes necessary in order to comply with a legal obligation to which we are subject. The Processing of your Personal Data conducted by us based on our legal obligations includes the Processing for the purpose of complying with tax law and other laws applicable to us.

2. Transfer of Personal Data Outside the EEA or the UK

Your Personal Data may be transferred to, and stored by, a third party outside the EEA or the UK. The countries in which such third party is located include not only Japan but also the countries listed in Section 6 of the Policy.

Where we transfer your Personal Data to a third party outside the EEA or the UK, we will ensure that:

You can obtain further details of the protection given to your Personal Data when it is transferred outside the EEA or the UK by contacting us, using the information about us set forth in Section 11 of the Policy.

3. EU/UK Representative

You may contact our EU/UK representative by postal mail addressed to the contact point below:

EU representative
Name: Shimadzu Europa GmbH
Address: Albert-Hahn Str. 6-10, 47269 Duisburg, Germany

UK representative
Name: SHIMADZU UK Limited
Address: Unit 1A, Mill Court, Featherstone Road
Wolverton Mill South, Milton Keynes MK12 5RD, U.K.

For Those in California (Addendum for California Consumer Privacy Act)

Last Update：[3/21/2024]

If you are a California resident, this Addendum for California Consumer Privacy Act (this “CCPA Addendum”) applies to you. This CCPA Addendum supplements our “Privacy Policy” (the “Policy”), and if there is any conflict between a provision of this CCPA Addendum and the provisions of the Policy, the provision of this CCPA Addendum shall prevail.

This CCPA Addendum uses certain terms that have the meanings given to them in the California Consumer Privacy Act (the “CCPA”), including:

• “Personal Information,” which 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.
• “Sell,” “selling,” “sale,” or “sold,” which means, whether orally, in writing, or by electronic or other means, selling, renting, releasing, disclosing, disseminating, making available, transferring, or communicating your Personal Information by a business to a third party for monetary or other valuable consideration.
• “Share,” “sharing,” or “shared,” which means, whether orally, in writing, or by electronic or other means, sharing, renting, releasing, disclosing, disseminating, making available, transferring or communicating your Personal Information by a business to any third party, for the purpose of cross-context behavioral advertising.

1. Our Collection, Use, and Disclosure of Your Personal Information

A. Categories, Sources, and Purposes of Your Personal Information Collected or to Be Collected

The table below describes the categories of your Personal Information that we collect or have collected during the last 12-month period.

Business or commercial purposes. The business or commercial purposes for which your Personal Information will be collected or used are as described in Section 4, “Purposes of Processing Personal Data” of the Policy.

Categories of sources. The categories of sources from which we collect your Personal Information are as follows:

• collected directly from you;
• collected from our distributors and agents; or
• collected automatically through our website from your devices.

B. Sale and Sharing of Your Personal Information

(A) Sale and Sharing of Your Personal Information

The table below describes (i) the categories of the Personal Information which we have sold/shared; and (ii) that categories of third parties to which we have sold/shared the Personal Information, during the last 12-month period.　

Please note that we do not sell/share your Personal Information to obtain any monetary compensation or while knowing you are under 16 years old.

(B) Disclosure of Your Personal Information for a Business Purpose

The table below describes: (i) the categories of your Personal Information that we have disclosed for our business purposes; and (ii) the categories of third parties to which we have disclosed such Personal Information for our business purposes, during the last 12-month period.

2. Your Rights and Requests

If you are a California resident, you have certain rights regarding your own Personal Information, as described below. We may refuse your request in the event that any of the exemptions permitted by the CCPA apply:

How to Submit a Request. To make each of these requests, please contact us using the information about us indicated in Section 11 of the Policy or the following toll-free number:

[ 1-877-225-1192 ]
*This is the telephone number for those in California only.

If we receive any opt-out preference signal from your device requesting us to cease the sale/sharing of Personal Information, we will promptly cease the sale/sharing of your Personal Information linked to such signal.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before responding to your request for disclosing, deleting and correcting your Personal Information.

Upon receiving a disclosure, deletion or correction request from you, we first will verify your identity by requiring you to submit Personal Information you have provided us already (such as your name or e-mail address), and by matching the information you submitted with what we already have. If we are unable to verify your identity because you have not submitted this information, we may refuse your request.

If you use an authorized agent to make a disclosure, deletion or correction request on your behalf, we may require the agent to provide documents proving that you have given the agent signed permission to make the request. We also may require you to (i) verify your own identity directly with us; or (ii) directly confirm with us that you provided the authorized agent with permission to submit the request.

Additional Information. If you exercise any of your rights under the CCPA, you have the right not to receive discriminatory treatment from us.

Do Not Sell or Share My Personal Information
We are selling/sharing your Personal Information as set forth in “B. Sale and Sharing of Your Personal Information” in Section 1. of the CCPA Addendum.

If you wish to cease the sale/sharing of your Personal Information, please click here.  More Information

You may also request us to cease the sale/sharing of your Personal Information via an application through the following web form:

[Inquiry Form link [SHIMADZU] Inquiry]

If we receive any opt-out preference signal from your device requesting us to cease the sale/sharing of your Personal Information, we will promptly cease the sale/sharing of your Personal Information linked to such signal.

3. Changes to this CCPA Addendum

We may change this CCPA Addendum from time to time. The date “Last Updated” at the top of this CCPA Addendum states when this CCPA Addendum was last updated. Any changes will become effective upon us posting the revised CCPA Addendum.

We will post a prominent notice on the site to notify you of any significant changes to this CCPA Addendum and indicate the date it was most recently updated.

4.Contact Point

If you have any questions or concerns regarding this CCPA Addendum or our privacy practices, please contact us using the information about us indicated in Section 11 of the Policy.

For Those in the Peoples’ Republic of China

This section applies to those in the Peoples’ Republic of China. This section supplements our “Privacy Policy” (the “Policy”), and if there is any conflict between any provision in this section and the provisions of the Policy, the provision of this section shall prevail.

We shall engage in personal information handling measures such as collection, retention, use, processing, transmission, provision, disclosure, and deletion in accordance with the Personal Information Protection Law of the Peoples’ Republic of China (hereinafter in this Section, the “Law”).

1. How We Handle Your Personal Information and Legal Requirements

We shall engage in personal information handling measures such as collection, retention, use, processing, transmission, provision, disclosure, and deletion in accordance with the Law. We shall only handle the personal information upon obtaining your consent, except for in the following events:

2. Processing of Sensitive Personal Information

In the case of handling sensitive personal information, we shall implement measures required under the Law such as notifying you of the necessity of handling sensitive personal information, and effects on individuals’ rights and interests.

Sensitive personal information means any personal information which, once leaked or used illegally, could easily cause the violation of the individuality and dignity of a natural person, or cause any physical harm or property damage to a person. We shall handle Communication Information and System Information as sensitive personal information. The necessity for handling Communication Information and System Information, and effects on individual rights and interests, are as follows:

Communication Information

Necessity for handling
It is necessary for us to handle your Communication Information to announce products and services, etc. in line with your needs.

Effects on individuals’ rights and interests
Your Communication Information is managed under appropriate security control measures, and the possibility of it having effects on individuals’ rights and interests due to leakage, etc. is limited.

System Information

Necessity for handling
It is necessary for us to handle your System Information in order to enable the use of Office 365 (email, SharePoint, Teams, Forms, etc.) by employees.

Effects on individuals’ rights and interests
Your System Information is managed under appropriate security control measures, and the possibility of incidence of effects on individuals’ rights and interests due to leakage, etc. is limited.

3. Provision of Personal Information

In the case we provide your personal information to third parties other than the outsourcees to which the handling of personal information is outsourced by us, we shall implement measures required under the Law, such as notifying you of such third parties’ names, contact methods, handling purposes, handling methods, and categories of personal information.

In the case we provide your personal information to third parties outside China, we will implement measures required under the Law, such as notifying you of such third parties’ names, contact methods, handling methods, categories of personal information and the methods and procedures in which the rights set forth under the Law will be exercised against such third parties, and we will also take any appropriate measures to protect the personal information so that the handling of your personal information by such third party satisfies the personal information protection standards as stipulated in applicable Chinese laws and regulations.

We shall provide your personal information to the following third parties outside China.

A.

Third parties’ names
SAP Japan Co.,Ltd., Amazon Web Services Japan G.K.

How to contact third parties
Please contact us using our contact details stated in Section 11 of the Policy.

Purposes of third-party handling
To announce our and our subsidiaries’ exhibitions, seminars, products, and services, etc., and to analyze your behavior.

Third-party handling methods
In the manner stated in 1. above

Categories of Personal Information
Name, email address, workplace information, inquiry details, Communication Information, etc.

Manner and procedures, etc. to exercise the rights set forth by the Law against third parties
Please contact us using our contact details stated in Section 11 of the Policy.

B.

Third party name
Shimadzu Business Systems Corporation

How to contact third parties
Please contact us using our contact details stated in Section 11 of the Policy.

Purposes of third-party handling
Log-in setting, operation and troubleshooting responses for systems used in transactions

Third-party handling methods
In the manner stated in 1. above

Categories of Personal Information
Name, email address, telephone number, workplace information, division and department

Manner and procedures, etc. to exercise the rights set forth by the Law against a third party
Please contact us using our contact details stated in Section 11 of the Policy.

C.

Third party name
OneTrust, LLC

How to contact third parties
Please contact us using our contact details stated in Section 11 of the Policy.

Purposes of third-party handling
Use of cookie consent management tool

Third-party handling methods
In the manner stated in 1. above

Categories of Personal Information
Consent to acquisition or use of cookies, IP address and language information

Manner and procedures, etc. to exercise the rights set forth by the Law against a third party
Please contact us using our contact details stated in Section 11 of the Policy.

4. Your Rights and Requests

You may exercise the rights with respect to your Personal Information as set forth in Section 8 of the Policy; provided, however, that we may refuse your request in any of the following events: