Privacy Policy

This Privacy Policy was updated on April 1, 2022.

1. General Privacy Policy

1-1. Compliance with Laws and Regulations

The Tsubaki Group, consisting of Tsubakimoto Chain Co. and its domestic subsidiaries and affiliates (collectively “Group”), recognizes the importance of protecting your personal information (“Personal Information”) and personal data (“Personal Data”) both as defined in the Act on the Protection of Personal Information of Japan (“APPI”). The Group complies with the APPI and other applicable laws and regulations relating to your Personal Information and Personal Data (including the Supplementary Rules under the Act on the Protection of Personal Information for the Handling of Personal Data Transferred from the EU based on an Adequacy Decision). The Group adopts practices generally accepted as fair and appropriate for the processing of your Personal Information/Personal Data.

1-2. Employee Education

The Group establishes clear rules regarding the processing of your Personal Information/Personal Data and makes every effort to ensure that all employees of the Group (including executives, part‐time workers and contingent workers) properly process your Personal Information.

1-3. Collection and Process

The Group obtains your Personal Information and Personal Data in an appropriate manner and processes it only for the purposes as set forth in Article 1-4.

1-4. Purposes of Processing

The Group processes your Personal Information/Personal Data it obtains only for the following purposes. The Group may change the purposes of processing your Personal Information/Personal Data in accordance with the applicable laws and regulations. In the event of the changes, the Group will provide you with notice of the changes either by email, on this website or by any other appropriate means.

1. Manufacture of products (including software), production, sales, installation, repair and inspection, after-sales service, maintenance, construction, product development, as well as other services provided by the Group (including outsourcing to carry out any of the above);
2. Announcements of products and services (including direct mails and email magazine distributions), PR activities, exhibitions, seminars, events and campaign information;
3. Questionnaire surveys, data collection and analyses;
4. Responding to inquiries and sending information (including documents);
5. Procedures for the exercise of shareholders’ rights;
6. Procedures for the recruitment of employees (including internships); and
7. Matters pertaining to the implementation of any of (i) through (vi) above.

1-5. Actions for Ensuring Safe Management

The Group takes necessary steps to prevent unauthorized access, loss, destruction, alteration and leakage of your Personal Data, and endeavors to ensure the safe management of your Personal Data as set forth below. The Group strives to continuously review its processing of your Personal Information.

(i) Establishment of basic policy:

In order to ensure proper treatment of your Personal Data, this Privacy Policy has been established to serve as the basic policy providing for compliance with the APPI and other applicable laws and regulations relating to your Personal Information, contact information for inquiry regarding protection of your Personal Information and similar issues.

(ii) Formulation of rules on treatment of your Personal Data:

The rules on handling of your Personal Data have been established in order to ensure proper protection of your Personal Data to be handled in the course of business.

(iii) Organizational safety management:

Framework for safe management has been established, including appointment of personnel in charge of handling of your Personal Data, designation of employees to handle your Personal Data, clarification of the scope of your Personal Data to be handled by these employees, and the system to report violation or indication of violation of any applicable law or regulation or any provision of rules on handling thereof to the person or department responsible for the protection of your Personal Information.

(iv) Personnel safety management:

Provisions for confidentiality of your Personal Information are contained in the Work Rules.

(v) Physical safety management:

Actions have been taken for prevention of theft, loss and similar incidents for devices, electronic media, documents and similar items used for handling of your Personal Data.

(vi) Technological safety management:

The information system for handling your Personal Information has been protected from unauthorized external access and unauthorized software.

(vii) Understanding of external environment:

Safety management measures have been implemented with understanding of the systems for protection of your Personal Information in the following countries and regions where overseas affiliated companies are located and where your Personal Data has been stored. Please refer to the following URLs and the Report on Investigation of Systems for Protection of Personal Information in Foreign Countries prepared by the Personal Information Protection Commission for the systems for protection of Personal Information in the following countries and regions:

* Japanese only

• the United States of America
• State of Illinois in the USA
• India
• Republic of Indonesia
• Commonwealth of Australia
• Canada
• Republic of Singapore
• Kingdom of Thailand
• Republic of Korea
• Taiwan
• People’s Republic of China
• Republic of the Philippines
• Federative Republic of Brazil
• Socialist Republic of Vietnam
• Malaysia
• the United Mexican States
• Russian Federation:

1-6. Provision to Third Parties

The Group will not provide your Personal Data to any third party except in the following cases:

1. You give consent;
2. Provision of your Personal Data is made in a manner in which you cannot be identified, such as statistical data;
3. Your Personal Data is provided to outsourcing contractors that facilitate the operations of the Group. In such an event, the Group will execute an agreement with such outsourcing contractors for the processing of your Personal Information and will conduct supervision of such outsourcing contractors as deemed appropriate;
4. Your Personal Data is provided as a result of the succession of business in a merger or otherwise;
5. Provision of your Personal Data is required under laws and regulations;
6. Provision is necessary for the protection of human life, human body or property and it is difficult to obtain your consent;
7. The Group is required to cooperate with national or local public authorities in pursuing their public duties and when obtaining your consent may impede the execution of such duties;
8. Article 1-7 or 1-8 applies; and
9. Provision of your Personal Data is permitted by the applicable laws and regulations.

1-7. Sharing

The Group may share your Personal Data, if and to the extent necessary for the purposes as described in Article 1-4, in accordance with the following.

1. Items of your Personal Data to be shared:
   • · Name, address, telephone number, e-mail address, affiliation, department, position, etc.
   • · Information relating to negotiation and transaction with any member of the Group, participation in exhibitions, etc.
2. Your Personal Data will be shared by:
   • · the Group companies; and
   • · sales agents and distributors of the Group companies in charge of you or the entity you belong to.
3. Purpose of sharing:
   • · As described in Article 1-4
4. Member of the Group responsible for the management of your Personal Data:
   • · Tsubakimoto Chain Co. located at Nakanoshima 3-3-3, Kita-ku, Osaka and represented by Takatoshi Kimura, President and Representative Director

1-8. Request of Disclosure, Correction, etc.

In the event that, with regard to your Personal Data, you request the Group to: (i) notify the purposes of processing; or (ii) disclose, correct, add, suspend processing of or delete your Personal Data, the Group will respond to such request to the extent required by the applicable laws and regulations or the Group deems reasonable, after the Group confirms your identity.

1-9. Revision of Policy

From time to time, the Group may revise this Privacy Policy in the event the Group needs to comply with changes in the applicable laws and regulations or the Group deems such revision appropriate. Important changes or notices regarding the protection of your Personal Information/Personal Data will be posted on this website.

1-10. Contact

The Group receives your inquiries regarding processing of your Personal Information/Personal Data through the “Contact” page.

2-1. Group Websites

The Group processes your Personal Information and your personal data as defined in the EU General Data Protection Regulation (“GDPR”) obtained through any of the Group’s websites ( “Websites”) in accordance with the provisions of this Section 2 in addition to those of Section 1 (General Privacy Policy).

2-2. Personal Information/Personal Data Obtained through Websites

The Group obtains your Personal Information/Personal Data, both directly when you provide it and automatically while you visit the Websites as follows.

1. Personal Information/Personal Data you provide
   The Group obtains your Personal Information/ Personal Data, such as your name, email address, physical address and telephone number, through a contact form or any other form on the Websites.
2. Personal Information/Personal Data collected automatically
   While you navigate through and interact with the Websites, the Group collects certain information that is automatically recorded from the computer, smartphone, tablet or other electronic device you use to visit the Websites (collectively “Device”). The Group uses cookies, web analytics services and other technologies to analyze the traffic, such as total visitors and pages viewed on the Websites, and to make improvements and personalize your experience based on the data the Group collects. While, as part of the protocol of the Internet, web servers can identify your Device by its IP address, the Group uses the data it collects in such a manner that your IP address usually remains anonymous and that the Group will not be able to identify you. Most browsers are initially set up to accept cookies.

2-3. Purposes of Processing

1. The Group processes your Personal Information/Personal Data entered on the contact form or any other form on the Websites for the purpose of: (i) responding to your requests or inquiries; (ii) providing you with services associated with the circumstances under which you provided the Personal Information/Personal Data; or (iii) developing and improving products or services of the Group.
2. The Group processes your Personal Information/Personal Data automatically collected through cookies, web analytics services and other technologies for the purpose of facilitating your use of the Websites, analyzing usage by visitors, improving user experience and delivering better services.

2-4. Transfer to Overseas Affiliates

The Group conducts business activities globally. In order to better respond to inquiries received through the Websites, the Group may transfer such inquiries, including your Personal Information/Personal Data, to affiliates of the Group outside Japan ("Overseas Affiliates"). In such an event, the Group will take necessary measures to protect your Personal Information/Personal Data in accordance with the applicable laws and regulations of the countries where the Overseas Affiliates are located and the privacy policies of the Overseas Affiliates. Concerning the privacy policies of the Overseas Affiliates, please visit their respective websites.

2-5. Children’s Personal Information/Data

The Websites are not intended for use by children, and the Group will not knowingly collect Personal Information/Personal Data from a child under the age of 16 without a parent’s or guardian’s prior consent.

2-6. Contact

Article 1-10 applies to your inquiries regarding processing of your Personal Information/Personal Data.

2-7. Personal Data of the Data Subject in the EEA

The Group processes personal data of the data subject in the EEA (the European Economic Area: the EU member states and three states, Iceland, Liechtenstein and Norway, as amended) which is obtained through the Websites (“EEA Personal Data”) in accordance with this Article 2-7 in addition to the provisions above.

(i) Legal Basis for Processing

The Group processes the EEA Personal Data on the legal basis of:

1. the consent you have given freely, specifically, informed and unambiguously. You have the right to withdraw your consent at any time without affecting the lawfulness of processing based on your consent before its withdrawal;
2. necessity for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
3. necessity for compliance with a legal obligation to which the Group is subject; and
4. necessity for the purposes of the legitimate interests pursued by the Group, including introduction of new products.

(ii) Retention Period

The Group will retain your EEA Personal Data until you request its deletion or withdraw your consent for its storage or until the purpose for its storage no longer pertains (e.g. after fulfilling your request). Provided, however, that the Group may retain beyond the above period if any applicable laws and regulations require the Group to further retain the EEA Personal Data.

(iii) Transfer outside the EEA

Your EEA Personal Data will be transferred by the Group to the member of the Group or the Overseas Affiliates outside the EEA. If such transfer is made to such companies, outside the EEA, located in the countries which have not been deemed by the European Commission to provide an adequate level of data protection, such transfer will be subject to the contractual terms approved by the European Commission that impose data protection obligations directly on such companies.

(iv) Your Rights

You have the following rights:

1. the right to obtain from the Group confirmation as to whether or not your EEA Personal Data is being processed, and, where that is the case, access to your EEA Personal Data and the information on its processing;
2. the right to correct inaccuracy of your EEA Personal Data;
3. the right to erase your EEA Personal Data;
4. the right to restrict processing of your EEA Personal Data under certain conditions;
5. the right to receive your EEA Personal Data in a structured, commonly used and machine-readable format and transmit that data under certain conditions;
6. the right to object, on grounds relating to your particular situation, to processing of your EEA Personal Data which is based on d. of Article 2-7 (i); and
7. any other rights under the GDPR.

If you would like to exercise any of the above rights, please email your request to .
Please also note that you have the right to lodge a complaint with a supervisory authority.

Established: April 1, 2005
Revised: April 1, 2022