ASPINA Group composed of Shinano Kenshi Co., Ltd., its subsidiaries and affiliated companies (hereinafter referred to as "We, our Group, etc.") has established the following basic policy with a deep awareness that personal information is important information relating to the privacy of our customers. We will handle personal information with the utmost care and in compliance with related laws, regulations, guidelines and the like.
We will acquire personal information by lawful and fair means. If we acquire personal information from customers directly, we will notify customers of the purpose of use of customers' personal information in advance and will acquire customers' personal information only within the scope necessary to achieve that purpose.
We will use, entrust and provide personal information only within the scope necessary to achieve the purpose of use.
We will take the appropriate technical and organizational safety measures to prevent risks such as unauthorized access to personal information or the loss, alteration and leakage of personal information in order to maintain the safety and security of personal information.
We will disclose to customers the content of customers' personal information in our possession upon customers' request and correct, delete or otherwise dispose of that information as necessary.
We will make efforts to facilitate the safe management of personal information by providing the education and training to our employees necessary to further deepen their awareness of the protection of personal information.
1. Definition of Personal Information
"Personal information" refers to information about a living individual from which the specific individual can be identified by their name, date of birth, gender, telephone number, e-mail address or other description, etc. (including information that can easily be matched with other information to identify the specific individual) . The personal information acquired by our Group includes personal information relating to customers' use of the services provided by our Group and personal information acquired from third parties in addition to the personal information provided by customers to us directly.
2. Purpose of the Acquisition, Use and Provision of Personal Information
We may acquire customers' personal information for the purpose of our operations, sales, product warranty and other business activities. We will acquire, use, entrust and provide customers' personal information only within the scope necessary to achieve the following purposes of use:
To perform the operations necessary to deliver the products customers have ordered;
To provide customers with information deemed to be useful and necessary such as information about our new products;
To make various inquiries and confirmation necessary to sell customers our products;
To provide customers with information about our products such as product specifications;
To ask for customers' opinions and feedback to assist us in planning, developing or improving our Group products and otherwise enhancing our services;
To provide customer support for our products, to perform product repairs, etc. under our warranty service and to otherwise provide customers with after-sales services;
To conduct inspection of products and inform customers of product safety; or
To otherwise comply with any related laws, regulations and guidelines.
3. Joint Use of Personal Information by Group Companies
Group companies may share customers' personal information with the other companies within our Group listed below only within the scope necessary to achieve the purposes of use set forth in paragraph 2.
Shinano Kenshi Co., Ltd. (Japan)
Dongguan Shinano Motor Co., Ltd. (China)
Hefei Shinano Motor Co., Ltd. (China)
Shinano Kenshi (Hong Kong) Co., Ltd. (China/Hong Kong)
ASPINA Inc. (The USA)
ASPINA, S.A. de C.V.(Mexico)
ASPINA GmbH (Germany)
ASPINA ABV Pvt. Ltd. (India)
4. Personal Information Acquired Within the EU/EEA and Customers' Rights
We will transfer personal information externally from within the EU/EEA in accordance with the Standard Contractual Clauses (SCC) adopted by the European Commission for the protection of personal information. Customers located with the EU/EEA have the right to request access to their personal information, the correction or deletion thereof, and the placement of restrictions on the usage thereof, and may file an objection with our Group or regulatory agencies (the relevant data protection supervisory authorities.)
5. Supervision of Contractors, etc.
If we entrust or provide customers' personal information to a third party, we will conduct the supervision necessary to ensure that such third party properly manage customers' personal information.
6. Management of Personal Information and Continuous Improvement
We will appoint a chief privacy officer in order to prevent incidents such as leakage, loss and damage and endeavor to ensure the safety and security of personal information. We will also appropriately manage personal information to keep it accurate and up-to-date and will strive to continuously improve our handling of personal information.
7. About the Collection and Handling of Personal Information through Our Websites
8. Requests to Disclose, Correct or Delete Customers' Personal Information
We will respond to customers' requests to disclose the content of customers' personal information in our possession as well as correct or delete that information, etc. without delay after first verifying customers' identity and conducting the necessary investigation.
9. Retention of Personal Information
We will retain and use customers' personal information for the period necessary to achieve the purposes of use set forth in paragraph 2.
10. Inquiries about Personal Information Protection
Shinano Kenshi Co., Ltd.
1078, Kami-maruko, Ueda City, Nagano Prefecture
Please continue to direct any inquiries concerning our various products and services to the relevant contact for the corresponding product or service.
January 31, 2023