Privacy Policy

PRIVACY POLICY
CLIENTS, SUPPLIERS AND BUSINESS PARTNERS

By means of this privacy policy (hereinafter the "Policy") and in accordance with the terms of the relevant Laws for Protection of Personal Information in Possession of Individuals which are in place where the Ibiden group does business (hereinafter the "Law"), Ibiden Co., Ltd. and its group companies (hereinafter "Ibiden") disclose to current and potential (employees of or any person working for) clients, suppliers and business partners (hereinafter, individually, each will be referred to as an "Individual") this personal information protection policy.

Ibiden Co. Ltd. with address in 2-1 Kanda-cho Ogaki, 503-8604, Gifu-Pref, Japan, and its affiliated companies including branches as referenced on Ibiden's website will be responsible for the processing of the personal information it receives from any Individual.

1. Personal Information

For purposes of this Policy, any information with respect to an identified or identifiable Individual that Ibiden receives by any printed, digital, audible or visual means, remote or local means of electronic and/or optical communication or through any other technology, and which concerns to such person, will be considered personal information (hereinafter the "Personal Information"), and includes information in the following categories:

  1. General information of the Individual, such as full name, job position, business address, phone number, e-mail address;
  2. Positions, faculties or designations of the Individual within one or more companies;
  3. The powers granted in favor of the Individual to act on the name and/or on behalf of a natural person or legal entity;
  4. Information regarding the Individual which is considered "sensitive" in accordance with the Law, such as information that may reveal the ethnic or racial origin or criminal data (including data relating to criminal behavior, criminal records, proceedings regarding criminal or unlawful behavior or lists in relation to (international) sanctions).

2. Purposes

The Personal Information will be used by Ibiden for the following purposes (the "Purposes"):

  1. Establish communication between any Individual and Ibiden via phone call, e-mail or any other means of communication, regarding the rendering of the services from Ibiden to a client, supplier or business partner or vice versa, as well as to prepare service proposals and/or quotations. For this Purpose, Personal Information in the categories a) and b) above will be used;
  2. Create an internal data base with general information of current and potential clients, suppliers or business partners of Ibiden and Individuals for the purpose of maintaining a relationship with clients, suppliers or business partners. For this Purpose, Personal Information in the categories a) and b) above will be used;
  3. Manage relations and marketing, including activities such as contacting the clients, suppliers and business partners in relation to promotions, account management, customer service, recalls and the development, execution and analysis of market surveys and marketing strategies. For this Purpose, Personal Information in the categories a) and b) above will be used;
  4. Conclude and execute agreements with clients, suppliers or business partners. For this Purpose, Personal Information in the categories a), b) and c) above will be used;
  5. Perform or identify the corresponding payments that may be made between Ibiden and the clients, suppliers or business partners, as well as to issue the corresponding invoices in accordance with tax legislation in force. For this Purpose, Personal Information in the categories a) and b) above will be used;
  6. Keep a record and conduct a credit investigation of the clients, suppliers or business partners, as the case may be. For this Purpose, Personal Information in the categories a) and b) above will be used;
  7. Carry out management activities to secure the efficiency and effectiveness of Ibiden's business such as the management of Ibiden's assets, conducting audits and investigations, finance and accounting, implementing business controls, provision of central processing facilities for efficiency purposes managing mergers, acquisitions and divestitures, management reporting and analysis, archive and insurance purposes, legal or business consulting, and preventing, preparing for or engaging in dispute resolution. For this Purpose, Personal Information in the categories a), b) and c) above will be used;
  8. Manage, by itself or through the transfer of Personal Information to the procurement division or the sales offices from Ibiden or from any other subsidiary, affiliate or member of the same corporate group as Ibiden located in different countries, the orders placed on behalf of the client, supplier or business partner. For this Purpose, Personal Information in the categories a) and b) above will be used;
  9. Process photos or video images to protect Ibiden's assets (including those of its employees), for site access and security reasons, and for the authentication of the Individual's status and access rights to Ibiden's premises. For this Purpose, Personal Information in the categories a) and d) above will be used and
  10. Protect the interests of Ibiden and its employees with respect to criminal offences or administrative penalties that have been or, given the relevant circumstances are suspected to be or have been, committed against Ibiden or its employees, comply with obligations under (international) sanction laws or investigations in relation thereto. For this Purpose, Personal Information in the categories a), b) and d) above, will be used.

Where necessary, Ibiden shall request the Individual consent for processing Personal Information.

3. Storage of Personal Information

Ibiden generally shall retain Personal Information which permits the identification of Individuals only for the period required to serve the applicable Purpose in accordance with the above, unless a retention period is reasonably necessary to comply with an applicable legal requirement or advisable in light of an applicable statute of limitations.

4. Obligations of Ibiden

Ibiden shall have the following obligations in relation to the Personal Information:

  1. Ibiden shall limit the processing of the Personal Information to the Purposes set forth in this Policy;
  2. Ibiden shall ensure that the processing of the Personal Information shall be adequate and relevant to the Purposes and not be excessive;
  3. Ibiden shall employ reasonable means to keep the Personal Information accurate, complete and up-to-date. Ibiden shall take reasonable steps to ensure that inaccurate, incomplete or out-dated Personal Information is corrected, completed or deleted;
  4. Ibiden shall maintain strict confidentiality of the Personal Information and abstain from transferring it to any person outside Ibiden, except for the cases authorized by Law or by the Individual;
  5. Ibiden shall maintain strict confidentiality of the Personal Information and abstain from transferring it to any person outside Ibiden, except for the cases authorized by Law or by the Individual;
  6. Ibiden shall notify third parties to whom the Personal Information of any Individual may be transferred, in the applicable cases, of the existence of this Policy and the Purposes for which the Individual agreed to the processing of his Personal Information.

5. Disclosure to Affiliates and Third Parties

Ibiden will in some cases share certain Personal Information of the Individual with the division or the sales offices from Ibiden or Ibiden's affiliates (including from members of the group located in different countries), so that such other member of the group may help Ibiden in management activities to secure the efficiency and effectiveness of Ibiden's business. Except for the established in this paragraph, Ibiden will abstain from transferring the Personal Information of the Individual to any third party without the prior written consent of the Individual.

6. Right of access, rectification, erasure and blocking

Each Individual is entitled to the rights of access (including the right to request an overview of Personal Information kept by or on behalf of Ibiden), rectification, erasure and blocking of Personal Information, as well as to the right to revoke the consent and the right to limit the use or disclosure of the Personal Information. For the exercise of any of these rights, the Individual must file an application with the Legal Division of Ibiden Co., Ltd., with the following information:

  1. Name and address or any other mean through which Ibiden can communicate its answer;
  2. Documents that prove his or her identity or, in its case, the legal representation of the person filing the application on his or her behalf;
  3. Clear and accurate description of the Personal Information over which he or she wants to exercise any of the mentioned rights, and its relevant scope, and
  4. Any other element or document that facilitates the localization of his or her Personal Information.

In case of an application for rectification of Personal Information, in addition to the requirements set forth in the previous paragraph, the person submitting the application must indicate the modifications to be made, and provide the documentation that supports his or her petition.

In case of an application for erasure of Personal Information, in addition to the aforementioned requirements, the Individual will have to exhibit along with its application, a description of the reasons for such application, where he or she must specify whether a full or a partial erasure is being requested for the processing of his or her Personal Information. Ibiden shall accept the application for erasure of Personal Information unless the Personal Information is still required for any Purpose or other legitimate interest of Ibiden.

The application, filed pursuant to the aforementioned terms, will be examined by the Legal Division of Ibiden Co., Ltd, and must be sent by e-mail to privacy@ibiden.com or in writing to Ibiden's address indicated in the second paragraph of this Policy. Ibiden will have a maximum period of four weeks, starting from the date in which the application is received, to notify the adopted decision, with the purpose of, if the application is deemed admitted, becoming effective within the fifteen days following the date in which the decision is notified.

7. Modification of Policy

The terms of this Policy can change at any time, thus Ibiden reserves the right to modify it when it is considered necessary. The modifications to this Policy will be published in Ibiden's website, therefore it is the responsibility of the Individual to be attentive of the website in order to be informed about the changes.

8. Complaints

Any complaint by the Individual due to a default from Ibiden to the Law can be filed before Ibiden Co., Ltd.'s Legal Division (privacy@ibiden.com), without prejudice to the right of the Individual to file a complaint before the relevant Data Protection Authority.