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LIXIL Corporation

Address:

24F, 1 Chome-1-1, Nishishinagawa, Shinagawa City, Tokyo, 141-0033

Contact Details:

E-Mail: sato@lixil.com

Telephone: +81 3-6268-8808

Corporate and Register Details:

Legal form: Stock Corporation
Registered office: Tokyo, Japan
Register number: 0106-01-004914

Legal Representatives:

Kinya Seto, Sachio Matsumoto

Information for Consumers:

The European Commission provides a platform for online dispute resolution (OS), which you can find at http://ec.europa.eu/consumers/odr/. LIXIL Corporation is not willing or obliged to participate in dispute resolution proceedings before a consumer arbitration board.

PRIVACY POLICY

In the following, you can find further information on to the processing of your personal data when using the Website as well as your rights under the applicable data protection law, in particular the European General Data Protection Regulation (GDPR).

A.        Who is responsible for the data processing and who can you contact?

We as SATO are a brand of LIXIL Corporation, Ojima 2-1-1, Koto-ku, Tokyo 136-8535, Japan (“LIXIL”). LIXIL is the entity responsible for the processing of personal data (hereinafter only “data”) in the context of the Website.

If you have data privacy related inquiries, you can contact our data protection team under the aforementioned address or via email at: privacyjapan@lixil.com.

B.        How do we process personal data when using the Website?

We process various personal data you provide to us when using the Website for several purposes. You can find in the following further information on the specific data and the purposes we process such data for as well as the legal basis for such processing.

a)         Use of cookies

Provision of the Website to users involves use of so-called cookies. Cookies are small text files that are placed on your terminal device when visiting the Website and allow storage of certain information on the terminal device as well as access to information already stored therein (e.g. your language preference or login information). Depending on the information stored or accessed, cookies enable the user of the Website to be identified.

Some of the cookies we use on the Website are automatically deleted after the end of the browser session, i.e. after you close your browser (so-called session cookies). Other cookies remain on your terminal device and enable us to recognize your browser the next time you visit us (so-called persistent cookies).

Please note that we only use cookies if and to the extent you give us your consent, except for cookies which are strictly necessary for proper operation of the Website and the functions and services provided there; such strictly necessary cookies do not require your consent. You can withdraw your consent at any time with effect for the future by accessing the cookie settings and changing your selection there.

You can also set your browser so that you exclude the acceptance of cookies for certain cases or generally. You can delete cookies that have already been set via your browser. Please note that if you delete or do not accept certain cookies, the functionality of our Website may be limited.

For further details on the cookies we use and to activate or deactivate certain cookies please refer to our consent management tool.

b)        Server Log-files for Accessing the Website

When you visit our Website, we process the following data which are transmitted from your browser to our server in form of so-called server log-files: Name of the retrieved web page, date and time of retrieval, time difference to Greenwich Mean Time, access status, amount of data transferred, browser type and version, the operating system you are using, the referrer URL (previously visited website), your IP address and the requesting provider.

Processing of such data is technically necessary in order to provide you with access to the Website. We may also store such log-files in order to track and enforce any infringements relating to the security of the Website.

Legal basis for the processing of your data is Art. 6 para. 1 lit. f) GDPR. We have a legitimate interest to process the data in order to provide Users with proper access to the Website and to ensure sufficient security of the Website.

c)         Contacting Us

We offer you the possibility on the Website to contact us via the functions and forms provided there and to request information from us. Information can be offered in digital form, in written form or also in the context of appointments. You are free to choose from the available information.

We process the data provided by you for the purpose of processing your request as well as providing you with the requested information and contacting you for further assistance. This involves your email-address and your name as well as any other information provided by you as part of your contact request.

Legal basis for the processing of your data by us is Art. 6 para. 1 f) GDPR. We have a legitimate interest to process your data in order to properly respond to your request.

d)        Newsletter

You can register for our newsletter on the Website in order to regularly receive information about our offers, products and services.

When you register for the newsletter, we process the data you enter to complete the registration process (name, e-mail address). Furthermore, we collect via so-called “web beacons” (these are small graphics in HTML emails) information whether our newsletter was delivered, whether it has been opened and whether links have been clicked. This gives us statistical evaluations and allows us to see exactly how well our newsletter was received by you. This way we can adapt and improve our newsletter service.

In order to provide our newsletter service we use Mailchimp. This includes processing of the aforementioned data on Mailchimp’s servers located in the USA. Mailchimp is provided by The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA.

The registration for the newsletter takes place in the so-called double opt-in procedure. To prevent abuse, we will send you an e-mail after your registration, asking you to confirm your registration. In order to prove the registration process according to the legal requirements, your application will be logged. Affected are the storage of the registration and the confirmation time and your IP address.

Legal basis for the provision of the newsletter service and the involved data processing is your consent pursuant to Art. 6 para. 1 a) GDPR. You can revoke your consent at any time via the unsubscribe link included in each newsletter email. Please note that the lawfulness of the processing carried out on the basis of the consent prior to your withdrawal remains unaffected.

e)         Adobe Fonts

We use Adobe Fonts on our website. Adobe Fonts is a web font hosting service by Adobe. Responsible for providing Adobe Fonts in the European region is Adobe Systems Software Ireland Limited, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Ireland.

In order to be able to display the required fonts correctly, the fonts used on our Website are downloaded from Adobe’s servers with every visit. The servers are located in the USA and operated by Adobe, Inc. Adobe then automatically receives data about the fonts provided, the account ID, the website requesting the fonts, the server that provides the fonts, and the host name of the website where the fonts are loaded. These data are also stored on Adobe’s servers located in the USA.

Legal basis for the use of Adobe Fonts and the involved data processing is your consent pursuant to Art. 6 para. 1 a) GDPR. You can withdraw your consent at any time with effect for the future by accessing the settings of our consent management tool and changing your selection there. Please note that the lawfulness of the processing carried out on the basis of the consent prior to your withdrawal remains unaffected.

f)          Google Recaptcha

We use Google reCAPTCHA on our website. Google reCAPTCHA is an identification service by Google. Responsible for providing Google reCAPTCHA in the European region is Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland.

We use Google reCAPTCHA in order to verify whether our Website is used by a human or by an automated program. This allows us to protect our Website from abusive automated spying and from spam and to ensure the availability of our services.

For this purpose, Google reCAPTCHA analyzes the behavior of the website visitor based on various characteristics. This analysis begins automatically as soon as you enter the website. For the analysis, Google reCAPTCHA evaluates various information, including IP address, referrer URL, operating system, time spent on the website or mouse movements made by the user, data and language settings, screen resolution).

Furthermore, Google reCAPTCHA is placing cookies on user’s device. First, the Google reCAPTCHA algorithm checks if Google cookies from other Google services (YouTube. Gmail, etc.) are already placed on your browser. Then, Google reCAPTCHA places an additional cookie on your browser and captures a snapshot of your browser window. Further information about the cookies placed by Google reCAPTCHA are available in our consent tool. The data collected during the analysis is transferred to servers operated by Google LLC in the USA. The Google reCAPTCHA analyses run entirely in the background. Website visitors are not made aware that an analysis is taking place.

Legal basis for the use of Google reCAPTCHA is your consent pursuant to Art. 6 para. 1 a) GDPR. You can withdraw your consent at any time with effect for the future by accessing the settings of our consent management tool and changing your selection there. Please note that the lawfulness of the processing carried out on the basis of the consent prior to your withdrawal remains unaffected.

For more information about Google reCAPTCHA and Google’s privacy policy, please see the following links:

https://www.google.com/intl/de/policies/privacy/

https://www.google.com/recaptcha/intro/android.html

g)        Google Analytics

We use Google Analytics on our Website. Google Analytics is a web analytics service provided by Google. The responsible entity for operating Google Analytics in the European region is Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland.

Google Analytics uses cookies that enable an analysis of your use of our Website. The information collected by means of the cookies about your use of this website is generally transferred to a Google server in the USA and stored there. Such servers are operated by Google LLC.

During your website visit, your user behavior is recorded in the form of “events”. Events can be: Page views, First visit to the website, Start of session, Your “click path”, interaction with the website, Scrolls (whenever a user scrolls to the bottom of the page (90%)), clicks on external links, internal search queries, interaction with videos, file downloads, seen / clicked ads, language setting.

Also the following data are recorded: Your approximate location (region), your IP address (in shortened form), technical information about your browser and the end devices you use (e.g. language setting, screen resolution), your internet service provider, the referrer URL (via which website/advertising medium you came to this website).

Google Analytics has IP address anonymization enabled by default. Due to IP anonymization, your IP address will be shortened by Google within member states of the EU or in other states party to the Agreement on the EEA. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. According to Google, the IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

Google will process the aforementioned information to evaluate your use of the website and to compile reports on website activity on our behalf. The reports provided to us by Google Analytics serve to analyse the performance of the Website.

The data collected and linked to the cookies placed by Google Analytics are automatically deleted after 2 months. The deletion of data whose retention period has been reached occurs automatically once a month.

The legal basis for this data processing is your consent pursuant to Art.6 para.1 lit. a) GDPR. You can withdraw your consent at any time with effect for the future by accessing the settings of our consent management tool and changing your selection there. Please note that the lawfulness of the processing carried out on the basis of the consent prior to your withdrawal remains unaffected.

In addition, you can prevent the collection of data generated by the cookie and related to your use of the Website (including your IP address) to Google and the processing of this data by Google, by downloading and installing the browser add-on to disable Google Analytics available here.

For more information on Google Analytics’ terms of use and Google’s privacy policy, please see the following links:

https://marketingplatform.google.com/about/analytics/terms/us/

https://policies.google.com/?hl=en.

h)        Facebook Pixel

We use the Facebook Pixel on our Website for marketing and targeting purposes, in particular to target interested users via the social media platform Facebook. The Facebook Pixel is a service by Meta. The responsible entity for operating Facebook Pixel in the European region is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland (formerly: Facebook Ireland Limited).

The Facebook Pixel is a snippet of JavaScript-code integrated in our Website which allows tracking of users’ actions on our Website via cookies. In this context, users‘ interactions on our Website as well as interactions with the advertisements placed by us on other websites (e.g. whether a user clicks on an advertisement and subsequently registers on our Website) are collected and stored on Meta’s servers. These servers are located in the USA and operated by Meta Platforms, Inc. Furthermore, the information collected also include the IP address and other data of the device used (e.g. device ID, operating system). The collection of the respective information and interactions usually takes place by storing cookies on the end device of the users and evaluating tags embedded on our Website.

Based on the information and interactions collected, we can improve the targeting of our advertisements and optimise the offers and functions provided on our Website. It is also possible for us to draw users’ attention to our offers and products again, e.g. by placing individual advertisements based on the interests of the respective users on other websites of the respective third-party providers and the advertising networks operated by them.

In addition, Meta is able to match the collected information with your Facebook account data. This means that if you are a Facebook user and are logged in your Facebook account, the visit to our website is automatically assigned to your Facebook user account. Meta uses the collected data for analysis purposes and its own advertisements. Users can adjust their settings and objections to the use of data for advertising purposes in the Facebook profile settings (https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen).

Legal basis for the processing of personal data is your consent pursuant to Art. 6 para. 1 a) GDPR. You can withdraw your consent at any time with effect for the future by accessing the consent management tool and changing your selection there. Please note that the lawfulness of the processing carried out on the basis of the consent prior to your withdrawal remains unaffected.

i)          YouTube

We have incorporated YouTube videos on our Website. This way we can present you interesting videos directly on our Website. YouTube is a video portal by YouTube, LLC, 901 Cherry Ave, San Bruno, CA 94066, USA. As part of the Google Group, the responsible entity for processing of personal data relating to the use of YouTube in the European region is Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland.

When you want to watch any YouTube video embedded on our Website, you must at first activate such video. In case of activation, your browser automatically connects to the YouTube’s servers located in the USA and various data are transferred by using cookies (depending on the settings). This includes your IP address and the URL of our Website as well as session duration, bounce rate, approximate location, technical information such as browser type, screen resolution or your internet provider.

The YouTube videos embedded on our Website have the “Privacy Enhanced Mode” activated. This means that the view of a video shown in the Privacy Enhanced Mode of the embedded player will not be used to personalize the YouTube browsing experience, either within your Privacy Enhanced Mode embedded player or in the viewer’s subsequent YouTube viewing experience. If ads are served on a video shown in the Privacy Enhanced Mode of the embedded player, those ads will likewise be non-personalized. In addition, the view of a video shown in the Privacy Enhanced Mode of the embedded player will not be used to personalize advertising shown to the viewer outside of our Website.

Legal basis for the processing of personal data is your consent pursuant to Art. 6 para. 1 a) GDPR. You can withdraw your consent at any time with effect for the future by accessing the consent management tool and changing your selection there. Please note that the lawfulness of the processing carried out on the basis of the consent prior to your withdrawal remains unaffected.

C.        Are you obliged to provide personal data?

When you use our Website, we may ask you to provide us with the data necessary for providing certain functionalities on the Website. Please note that without such personal data, we may not be able to offer you the full functionalities of the Website and our services may be limited. However, there is no legal or contractual obligation to provide us with your personal data when you visit our the Website.

D.        With whom do we share personal data?

We use external service providers to process personal data when providing the Website and its functionalities and services to you. Processing of personal data by such service provider is carried out on our behalf and in accordance with our instructions (so-called “Processors”, see Art. 4 (8) GDPR). We engage the following service providers or categories of services providers:

• Technical service provider (re. hosting of the Website and provision of support and security services for the Website), located in Germany.
• Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland and Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA Google (re. use of Google Analytics, Google reCAPTCHA and YouTube).
• Adobe Systems Software Ireland Limited, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Ireland and Adobe, Inc. located in the USA (re. use of Adobe Fonts).
• The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA (re. provision of Mailchimp for the newsletter service).
• Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland and Meta Platforms, Inc. located in the USA (re. use of Facebook Pixel)
• YouTube LLC (re. use for embedding YouTube videos).

E.        Do we transfer personal data to third countries?

We transfer personal data to service providers and recipients in countries outside the EU/EEA (so-called third countries) where such transfer is necessary for the purposes set out in this Privacy Policy.

A transfer to a third country will only take place in compliance with the applicable data protection regulations, in particular the guarantee of an adequate level of data protection. This means that your data will only be transferred insofar as a decision of the EU Commission on an adequate level of data protection exists for the respective third country (Art. 45 GDPR), appropriate guarantees are provided for the protection of your personal data (cf. Art. 46 GDPR) or a legal permission norm exists (cf. Art. 49 GDPR). Appropriate safeguards within the meaning of Art. 46 GDPR include the standard data protection clauses published by the EU Commission.

The transfer of your data involves processing of personal data in the USA by the respective service providers when using the following services: Mailchimp, Adobe Fonts, Google reCAPTCHA, Google Analytics, Facebook Pixel and YouTube. For further information on the processing please check the previous sections in this privacy policy. The transfer of your data is based on the EU standard contractual clauses in order to establish an appropriate level of data protection. You can find further information here:

F.         How long do we store personal data?

We only store personal data for as long as it is necessary for the purposes for which it is processed or if your consent has been revoked. In addition, statutory storage requirements may apply. Such statutory storage requirements can be up to 10 years, regardless of the processing purposes.

Regarding the storage of data processed via Google Analytics please see the information set forth in Sec. B.g).

G.        Which rights do you have?

You have the right of access (Art. 15 GDPR), the right to rectification (Art. 16 GDPR), the right to erasure (Art. 17 GDPR), the right to restriction of processing (Art. 18 GDPR) and the right to data portability (Art. 20 GDPR).

When personal data is processed based on your consent, you have the right to withdraw your consent according to Art. 7 (3) GDPR. Please keep in mind that your withdrawal only affects future processing based on your consent.

As far as the personal data is processed for the purpose of our legitimate interest according to Art. 6 (1) lit. f GDPR, you have the right to object according to Art. 21 GDPR. You can find further information regarding your right to object at the end of this Privacy Policy.

To exercise the aforementioned rights, you can contact us via the contact details provided in section A. To facilitate the processing of your request it is helpful, if you could indicate in your communication information on where you were in contact with us (e.g. in which country and under which circumstances). Please note that we may require you to present proof of identity to verify the eligibility of your rights execution.

If you are of the opinion that the processing of your personal data is unlawful, you have the right to lodge a complaint with the competent supervisory authority (Art. 77 GDPR). This right to complain is without any prejudice to any other administrative or judicial remedy.