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    PRIVACY POLICY

    Last updated: December 22, 2023

    NAKANISHI INC. (hereinafter referred to as “Nakanishi”, “we,” “our” and “us”) establishes Privacy Policy (hereinafter referred to as “this policy”) for protecting personal data as below.

    1. Name, Address and Representative of Us

    Please see the following webpage for our company name, address and representative.
    https://www.en.nakanishi-inc.jp/company/profile/

    2. Management and Security Measures of Personal Data

    We maintain security systems, develop management systems, and thoroughly train employees. We will take necessary measures, including organizational and technical measures, implement safety measures, and strictly manage personal data in order to keep personal data accurate and up-to-date and to prevent unauthorized access, loss, damage, falsification, and leakage of personal data.

    3. Categories of Personal Data We Collect

    We collect the following categories of personal data related to customers, including our business partners, health care professionals, including physicians, patients, shareholders, our employees engaged in our operations under our direct or indirect instruction and supervision, and applicants for employment.

    (1) Customers

    A.Name, email address, phone number and address
    B.Company or organization and job title
    C.Business Communications including business discussions
    D.Inquiries and subsequent interactions with us
    E.Information records that our customers have purchased, used and considered purchasing our products or services
    F.Opinions, reviews, responses to surveys on our products or services
    G.Interaction with our websites, including your browsing history, Internet Protocol address (IP address), and device information
    H.Your photographs and movies taken when visiting us or our events
    I.Information necessary for you to visit us or participate in our events, such as dietary preferences, age and disability
    J.Information necessary for making arrangements when you visit from overseas, such as visas and passports

    (2) Health Care Professionals including physicians and dental hygienists other than Paragraph (1)

    A.Information described in curriculum vitae, including work history, educational background, qualification
    B.Information about license including physician’s and dental hygienist’s licenses
    C.Information about treatment using our products
    D.Information about clinical studies of our products

    (3) Patients

    A.Information about clinical studies of our products
    B.Information necessary for reporting to supervisory authorities in relevant countries and regions that adverse events related to our products have occurred, for instance, name, age, birthday, gender, body weight, ethnic origin, race, disease treatment

    (4) Shareholders

    A.Name, address
    B.Shareholder number
    C.Number of shares and voting rights
    D.Information about exercising shareholder’s rights, including voting rights.
    E.Communications with us

    (5) Applicants for employment

    A.Name, email address, phone number and address
    B.Information described in curriculum vitae, including work history, educational background, qualification
    C.Information necessary for employment, including nationality and visa
    D.Background check

    (6) Employees other than (5) above

    A.Family information and contact information
    B.Information for HR management, including attendance and personnel evaluation
    C.Information necessary for tasks on payroll, including bank account and health insurance, and on benefits
    D.Health information

    4. Purposes of Use of Personal Data

    We use personal data of our customers, health care professionals including physicians, shareholders, employees, and applicants for employment (hereinafter referred to as “you” and “your”) to the extent necessary to achieve the following purposes.

    (1)Business communications, including providing personal data with Nakanishi Group companies and our distributors
    (2)To sell, maintain, repair our products and services, and provide information
    (3)To plan, research, develop and improve our products or services, including providing personal data to notified bodies assessing whether medical devices conform to laws and regulations in relevant countries and regions
    (4)To invite you to our events and exhibitions, operate them, and respond to visitors to our facilities, including providing personal data to sponsor companies or organizations for an event
    (5)To conduct public relations and marketing activities, including providing reviews on our products to social network companies and posting them on social networks
    (6)To respond to inquiries
    (7)To manage relationships with shareholders
    (8)To have a communication with employees
    (9)For HR tasks, including attendance, salary payment, and personnel evaluation
    (10)To provide employees with education and training
    (11)To manage health and safety of employees
    (12)To select and contact applicants for employment
    (13)To manage and protect system accounts
    (14)To improve the quality of our websites, including providing browsing history to web analytics providers
    (15)To prevent unauthorized use of our websites and resolve problems
    (16)To establish, exercise or defend our legal rights
    (17)To discharge our legal obligations, including providing personal data to competent authorities

    5. Provision of Personal Data to Third Parties

    We may provide your personal data to third parties to the extent necessary to achieve the purposes described in Section 4 above or for as long as it is necessary in accordance with applicable laws. In such cases, we will take appropriate measures, including obtaining your consent, in accordance with applicable laws. The following parties are examples we may provide your personal data to, but are not limited to:

    ・Nakanishi Group companies (in the case where companies do not fall under joint users in the Act on the Protection of Personal Information of Japan)
    ・Distributors of our products
    ・Notified bodies assessing whether medical devices conform to laws and regulations in relevant countries and regions
    ・Sponsor companies or organizations for our events
    ・Service providers including web analytics providers
    ・Social network companies
    ・Competent authorities, etc.

    6. Children’s Privacy

    When we collect personal data about children, we will take appropriate measures such as obtaining the consent of the child or the child’s guardian in accordance with applicable laws.

    7. Sensitive Personal Data

    When we collect your personal data that is classified as sensitive personal data under applicable laws, we will obtain your consent or take appropriate measures in accordance with applicable laws.

    8. Outsourcing the Processing of Personal Data

    We may outsource all or part of the processing of personal data to third party contractors to the extent necessary for the purposes described in Section 4 above. In this case, we will use only third party contractors that ensure appropriate security standards, conclude outsourcing contracts, monitor their processing of personal data, and perform necessary and appropriate supervision to ensure the security of personal data.

    9. Joint Use

    We may jointly use your personal data as below.

    Categories of Jointly Used
    Personal Data    		 Categories described in Section 3 above
    Scope of Joint Users Nakanishi Group companies
    Purpose for Joint Use Purposes described in Section 4 above
    Entity Responsible for Joint Use NAKANISHI INC. Please visit our website（https://www.en.nakanishi-inc.jp/company/profile/）for the representative and address of NAKANISHI INC.

    10. Your Rights

    You have certain rights with respect to your personal data under applicable laws. These rights include revocation of consent, access, correction, restriction of processing, deletion, prohibition of disclosure to third parties and objection to processing. If you make such a request, we will take steps to review the request and respond within a time as required by applicable laws. If you wish to exercise any of these rights, or if you have any questions about your rights, please contact us as described in Section 12 below.

    11. Compliance and review of laws, regulations and other norms.

    We comply with applicable laws, regulations and other norms regarding the personal data, and review this policy if necessary. If there is any update, we post it on our website (https://www.en.nakanishi-inc.jp/privacy/)

    12. Point of Contact

    Please contact below for the processing of personal data.

    NAKANISHI INC.
    700 Shimohinata, Kanuma, Tochigi 322-8666, Japan
    TEL：0289-64-3380　 FAX：0289-62-5636
    Mail: info@nsk-nakanishi.co.jp

    13. Additional Information for Residents in European Economic Area and United Kingdom

    For residents in the European Economic Area (EEA) and the United Kingdom (UK), we provide additional information in this Section 13 in accordance with the General Data Protection Regulation (“GDPR”). If there is any inconsistency or discrepancy between sections described above and this Section 13 of this policy, this Section 13 prevails for residents in the EEA and the UK to the extent of such inconsistency or discrepancy.

    (1) Controller

    We are the controller for the processing of personal data in the meaning of the GDPR.

    (2) Means to Collect Personal Data

    We collect your personal data by means including the following.

    Point of Collection Sources
    When you have business communications including business discussions with us ・You
    ・Nakanishi Group Companies
    ・Distributors of our products
    When you purchase, consider purchasing our products, request their maintenance and repair ・You
    ・Nakanishi Group Companies
    ・Distributors of our products
    When you inquire us ・You
    ・Nakanishi Group Companies
    ・Distributors of our products
    When you participate in our events and register for visiting us ・You
    ・Nakanishi Group Companies
    ・Distributors of our products
    When you provide review on our products and services, and answer to surveys ・You
    ・Nakanishi Group Companies
    ・Distributors of our products
    When you use our website ・You
    When you participate in clinical studies of our products ・You
    ・Nakanishi Group Companies
    When you acquire our shares or are recorded in the shareholder register ・Shareholders
    When you apply for employment ・Applicants for employment
    When you start working for us ・Employees
    ・Nakanishi Group Companies

    (3) Lawful Grounds

    We process your personal data for the purposes described in Section 4 above on the following lawful grounds.

    Purpose of Processing Your Data Lawful Grounds
    Business Communications Legitimate interest of us and third parties including our business partners: To have smooth communications between us and our business partners.
    To sell, maintain, repair our products and services, and provide information Legitimate interest of us and third parties including our business partners: To provide our products or services in a proper manner.
    To plan, research and develop, and improve our products or services. Legitimate interest of us: To plan, research and develop, and improve our products or services.
    To conduct public relations and marketing activities. Your consent.
    To invite to our events and exhibitions, operate them, and respond to visitors to our facilities. Legitimate interest of us: To invite to our events and exhibitions, operate them, and respond to visitors to our facilities in a proper manner.
    To respond to inquiries. Legitimate interest of us and third parties including our business partners: To respond to inquiries in a proper manner.
    To manage relationships with shareholders. Legitimate interest of us: To ensure compliance with laws including Companies Act of Japan and building smooth relationships with shareholders.
    To have a communication with employees. Legitimate interest of us: To have a communication with employees.
    For HR tasks, including attendance, salary payment, and personnel evaluation Legitimate interest of us: To conduct HR tasks in a proper manner.
    To take steps prior to entering into an employment contract.
    To provide employees with education and training Legitimate interest of us: To provide employees with education and training in a proper manner.
    To manage health and safety of employees. Legitimate interest of us: To manage health and safety of employees.
    To protect vital interests of employees.
    To accept applications for employment and select and contract with applicants. To take steps prior to entering into an employment contract.
    To manage and protect system accounts. Legitimate interest of us: To manage and protect system accounts.
    To improve the quality of websites. Legitimate interest of us: To improve the quality of websites.
    To prevent unauthorized use of the websites and resolve problems. Legitimate interest of us: To maintain the functionality of websites and provide them in a proper manner.
    To establish, exercise or defend our legal rights. Legitimate interest of us: To establish, exercise or defend our legal rights.
    To discharge our legal obligations. Compliance with legal obligations

    (4) Retention Period

    We will retain your personal data for as long as it is necessary for the purposes described in Section 4 or specific periods we set as consistent with the GDPR. When the specified period has expired or we no longer need your personal data, we will delete or anonymize it without delay in accordance with the GDPR and our established procedures.

    (5) Cross-Border Transfer of Personal Data

    Our disclosure of your personal data to our contractors (processors in the meaning of the GDPR) or third parties may constitute cross-border transfer of personal data to a country or region other than the EEA member countries or the UK. In such cases, we rely on adequate decisions made by the European Commission or the UK government, use the Standard Contractual Clauses (SCCs) adopted by the European Commission, the International Data Transfer Agreement (IDTA) or the International Data Transfer Addendum to the European Commission's SCCs approved by the UK Parliament, or take other necessary measures to protect your personal data.

    (6) Your Rights

    You have the following legal rights set out in the GDPR with the processing of your personal data by us.

    ・Withdrawal of consent – You can withdraw at any time previously given consent to our processing of your personal data as described in Section 13.(3) “Lawful Grounds”.
    ・Right of access - You have the rights to make an inquiry, to review and to request for copies of your personal data we hold.
    ・Right to rectification - You have the right to request us to correct any of your personal data we hold which you believe is inaccurate. You also have the right to request us to complete your personal data we hold which you believe is incomplete.
    ・Right to erasure - You have the right to request that we erase your personal data, under certain conditions.
    ・Right to restrict processing - You have the right to request that we restrict the processing of your personal data, under certain conditions.
    ・Right to data portability - You have the right to request us to obtain your personal data in a structured, commonly used, and machine-readable format and have the right to transmit those data to another controller, under certain conditions.
    ・Right to object to processing - You have the right to object to our processing of your personal data, under certain conditions.

    f you would like to exercise any of these rights, or if you have any inquiries about your rights, please contact us in accordance with Section 12 above.

    (7) Lodging Complaint with Data Protection Authority

    You can lodge complaints about our way of processing your personal data with a data protection supervisory authority that has a jurisdiction over the region where you reside. Contact information of data protection supervisory authorities is available at the following URL.

    ・For EEA residents：https://edpb.europa.eu/about-edpb/about-edpb/members_en
    ・For UK residents：https://ico.org.uk/