1. Handling of Personal data

1. 1.1 Mitsubishi Electric Corporation (hereinafter, "we"/"us"/"our") is committed to safeguarding the privacy of our customers and users (hereinafter, "you"/"your"). This privacy policy for the handling of personal data (hereinafter, "this notice") is intended to inform you of the ways in which we collect, use, and share any personal data that you choose to provide to us.
2. 1.2 If you are an existing customer of ours, further details about how we use your personal data are set out in your customer contract with us. When we collect your personal data, further notices highlighting certain intended uses of your personal data, together with the ability to opt in or out of such uses, may also be provided.
3. 1.3 The following will be explained to you on a case-by-case basis when we obtain personal data from you:
   1. (a) Whether the provision of personal data is a statutory requirement, a contractual requirement, or a requirement necessary to enter into a contract
   2. (b) Whether you are obliged to provide the personal data
   3. (c) Possible consequences of failure to provide the personal data
   4. (d) Whether automated decision-making is used
4. 1.4 Our websites may contain links to other third-party websites. If you follow a link to any of those third-party websites, please note that they have their own privacy policies. We (MELCO) do not accept any responsibility or liability for third-party policies, nor are we responsible for how they process or use your personal data. Please check these policies before you submit any personal data to such third-party websites.
5. 1.5 This notice is intended to explain our privacy practices and covers the following areas:
   1. (a) Information we collect about you
   2. (b) How we use your personal data
   3. (c) How we protect your personal data
   4. (d) Your rights and how to contact us
   5. (e) Changes to our privacy policy for the handling of personal data

2. Information we collect about you

1. 2.1 We may collect and process all or some of the following personal data about you:
   1. (a) Information you provide to us
      During interactions with us, we may ask you to provide personal data.
      1. (i) When you purchase, send for repair, or return one of our products, we may ask you to provide information (such as your name, address, contact details, phone number, email address, and payment information).
      2. (ii) If you contact us via a contact form on one of our websites, we may record information (such as your name, address, business contact details, telephone number, email addresses), and other information. We may also keep a record of your inquiry and our correspondence.
      3. (iii) We may ask you to complete surveys that we use for research purposes. In such circumstances, we may collect information, including: your name, address, business contact details, telephone number, email address, date of birth, contact details, and interests.
      4. (iv) When you create an account to use our online services, we may ask you to provide information, including: your name, address, business contact details, telephone number, email address, date of birth, contact details, interests, and newsletter preferences.
   2. (b) Information provided by other sources
      We may collect your personal data from publicly available sources and third parties.
   3. (c) Website and communication usage
      We may collect details of your visits to our websites and information gathered through cookies (and other tracking technologies including, but not limited to), your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and resources that you access.

3. How we use your personal data

1. 3.1 We shall set out the purposes for which we use any personal data that we collect and, in compliance with legal obligations, identify the legal grounds on which we process such information.
2. 3.2 We shall comply with Japan's Act on the Protection of Personal Information, and its rules and guidelines issued by the Personal Information Protection Commission in Japan. We shall also comply with international personal data protection laws, such as ‘The European General Data Protection Regulation (GDPR)’. Our processing of personal data is based on specific legal grounds (as outlined in the GDPR), and other applicable laws and regulations (a full description of each of these bases can be found, here). Please note that in addition to the disclosures identified below, we may disclose personal data to service providers, contractors, agents, advisors (e.g. legal, financial, business or other) and affiliates of our company that perform activities on our behalf, for purposes explained in this notice.
   1. (a) Effective communication and business purposes
      We may use your personal data to conduct our business, and to ensure effective communication for business purposes. This includes (but is not limited to) responding to your queries, and communicating with you to fulfill our obligations (arising from any agreements between you and us).
      Use justification:
      contract performance, legitimate interest (to enable us to perform our obligations and provide our services to you)
   2. (b) Providing you with marketing materials
      We may use your personal data to provide you with updates and offers, if you have chosen to receive these. We may also use your information for marketing our own (and our business partners') products and services to you by post, email, SMS, and/or phone or fax. When required by law, we will obtain your consent at the time of data collection to carry out any marketing activities. In addition, we will provide an option to unsubscribe or opt out of further communication (on any electronic marketing communication) sent to you. Alternatively, you may opt out at any time by contacting us, as set out in the "Contact us" form below.
      Use justification:
      consent, legitimate interest (to keep you updated with news in relation to our products and services)
   3. (c) Research and development purposes
      We may analyze your personal data to better understand your needs about our services and marketing activities, and to develop products and services;
      Use justification:
      legitimate interest (to allow us to improve our services)
   4. (d) Monitoring certain activities
      We may use your personal data to monitor queries and transactions in order to ensure service quality and compliance with procedures, and to combat fraud.
      Use justification:
      legal obligations, legal claims, legitimate interest (to ensure the quality and legality of our services)
   5. (e) Informing you of changes
      We may use your personal data to notify you about changes to our services and products.
      Use justification:
      legitimate interest (to notify you about changes to our service)
   6. (f) Ensuring website content is relevant
      We may use your personal data to ensure that content from our websites is presented in the most effective manner for you (and for your device), which may include passing your data to business partners, suppliers and/or service providers.
      Use justification:
      legitimate interest (to allow us to provide you with the content and services on the websites)
   7. (g) Reorganizing or making changes to our business
      In the event that we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a reorganization, we may need to transfer some or all of your personal data to the relevant third party (or its advisors) as part of any due diligence processes, for the purpose of analyzing a proposed sale or reorganization. We may also need to transfer your personal data to the relevant reorganized entity or third party after the sale or reorganization, in order for them to use it for the same purposes set out in this notice.
      Use justification:
      legitimate interest (to allow us to change our business)
   8. (h) In connection with legal or regulatory obligations
      We may process your personal data to comply with regulatory requirements, or to engage in dialogue with regulators. This could involve disclosing your information to third parties, court services, regulators, or law enforcement agencies in connecting with inquiries, proceedings, or global investigations (or wherever it is legally required). If permitted, we will direct a request to you (or will notify you before responding), unless this would interfere with crime prevention or detection.
      Use justification:
      legal obligations, legal claims, legitimate interest (to cooperate with law enforcement and regulatory authorities)

4. How we protect your personal data

Security over the internet

1. 4.1 No data transmission over the Internet or a website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic, and procedural safeguards to protect your personal data in accordance with data protection legislative requirements.
2. 4.2 All information you provide is stored on our servers, or on other secure servers set up by trusted and verified third-party service providers that meet our company's management standards. This information is accessed and used in accordance with our security policies and standards. If we have provided you with, or you have chosen, a password to access certain areas of our websites, it is your responsibility to keep this password confidential. You must also comply with any other security procedures we inform you about. Please do not share your passwords with anyone.

Export overseas

1. 4.3 Your personal data may be accessed by staff or suppliers, transferred to, and/or stored in locations outside your country, where data protection laws may be less stringent than those in your own country. In all cases, we will protect your personal data as described in this notice.
2. 4.4 If you would like to see a copy of the specific safeguards applied to the transfer of your personal data overseas, please reach out to us using the "Contact us" form below.

Storage limits

1. 4.5 Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purposes. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or, to comply with regulatory requirements regarding the retention of such data. When personal data is no longer needed, we either irreversibly anonymize the data (and may further retain and use the anonymized information) or securely destroy the data.

5. Your rights and how to contact us

Marketing

1. 5.1 To tailor the online marketing on our websites to suit your needs or interests, we use technologies that automatically track information, including browsing history on our websites, links clicked in our emails, or mobile applications that you use.
2. 5.2 You have the right to ask us to not process your personal data for marketing purposes (including the above). We will periodically notify you if we plan on using your information for specific marketing activities – Or, if we plan on disclosing your personal data to certain third parties, for marketing purposes. You can opt out of this data processing by not selecting certain boxes on the forms that we use to collect your personal data. You can also exercise the right at any time by contacting us, as set out in the "Contact us" form below.

Updating information

1. 5.3 We will make reasonable efforts to ensure that your personal data is accurate. As this requires your assistance, please contact us by clicking the "Contact us" form below to notify us of any changes to the personal data that you have provided to us.

Your rights

1. 5.4 If you have any questions that relate to our use of your personal data, please first contact us by clicking on the ‘Contact us’ form, identified below. Under certain circumstances, you may have the right to demand that we:
   1. (a) provide you with further details on our use of your information;
   2. (b) provide you with a copy of the information that you have provided to us;
   3. (c) update any inaccuracies in the personal data that we hold (please see paragraph 5.3);
   4. (d) delete any personal data that we no longer have any legal grounds to use;
   5. (e) where processing is based on consent, to withdraw your consent so that we stop the processing in question (see paragraph 5.2 for marketing);
   6. (f) object to any processing justified by legitimate interest, unless our reasons for said processing outweigh any prejudice to your data protection rights; and
   7. (g) restrict how we use your information, whilst a complaint is being investigated.
2. 5.5 Your exercise of these rights is subject to certain exemptions to safeguard public interest (e.g. prevention or detection of crime) and our interests (e.g. maintenance of legal privilege). If you exercise any of these rights, we will verify your entitlement to do so, and will respond within a month in most cases.
3. 5.6 If you are not satisfied with our use of your personal data, or our response when you exercise any of these rights, you have the right to complain to the data protection authority in the country that you reside in.

Contacting us

1. 5.7 Depending on your location, the "data controller" responsible for processing your personal data under this Privacy Policy may vary. If you have any inquiries regarding the detailed information of the data controllers in each country, please contact us as set out in the "Contact us" form below.
2. 5.8 In some countries or regions, data protection laws may require the appointment of a Data Protection Officer (DPO). Where necessary, we shall appoint a DPO in accordance with applicable regulations. If you have any inquiries regarding our Data Protection Officers (DPOs), please contact us as set out in the "Contact us" form below.
3. 5.9 If you have any questions in relation to this notice, please contact us as set out in the "Contact us" form below.

6. Changes to our privacy policy for the handling of personal data

1. 6.1 We may update our personal data handling practices, and this notice may be revised periodically. Should any changes occur, we will update the revision date, below. If the changes are significant, we will clearly highlight this on our websites.
2. 6.2 This notice was last updated on 01.04.2024.

Annex

Under the data protection laws of various countries, the use of personal data must be justified by specific legal grounds. We are required to outline these grounds for each use of personal data in this notice. The justification for each use of your information is provided alongside its description in the "How we use your personal data" section of this notice.

These are the principal legal grounds that justify our use of your information:

Consent:

Where you have consented to our use of your information (you would have been presented with a consent form in relation to any such use, and may withdraw your consent by contacting us as set out in the "Contact us" form below).

Contract performance:

Where your information is necessary to enter into or fulfil a contract between you and us.

Legal obligation:

where we need to use your information to comply with our legal obligations.

Legitimate interest:

Where we use your information to fulfil a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.

Legal claims:

Where your information is necessary for a defence, lawsuit or claim against you, us or a third party.