Controllers & scope

The website is hosted by PHC Holdings Corporation, Japan, the parent company of PHC Europe B.V. For the purpose of this Notice, the controllers of the personal data processed are PHC Holdings Corporation, with registered address at 15F DAI-ICHI LIFE HIBIYA FIRST 1-13-2 Yurakucho, Chiyoda-ku, Tokyo 100-8403, Japan, jointly with PHC Europe B.V. with the registered address at Eikdonk 1, 4825 AZ Breda, Netherlands (‘we’ and ‘us’).

The aim of this Policy

The aim of this Notice is to explain which categories of personal data we collect, for what purpose and to outline how we handle such data.

The categories of personal data subject to processing

The categories of personal data depend on the source and can include the following:

• Personal data provided to us directly by you;
• Personal data provided to us by our business partners (e.g. distributors);
• Data obtained from publicly available sources (e.g. public records, online publications), including references to such information received via reputable service providers (e.g. providers of credit risk and due diligence solutions);
• Data related to your online visit, stored and retrieved in the form of cookies.

Marketing

We may contact you to tell you about products and services that we feel may be of interest to you or that are similar to those that you have already purchased or enquired about.

You may be contacted by us, by a distributor of PHC EU products, or by one of our selected partners, in each case where you have consented to receive these communications.

You may opt out of receiving our marketing communications at any time by contacting us at marketing@eu.phchd.com or by using the unsubscribe link in any of our communications.

We will continue to contact you for non-marketing related purposes where we need to issue a field corrective or safety notice, or to where we need to send certain information to you under a legal, regulatory, or ethical requirement.

Sharing your Personal Data

We do not rent or sell your personal data to anyone. We do not disclose personal data of our website visitors outside the PHC Group of companies unless for the following reasons:

If you ask us for a price quote, we may share your contact details with all of the distributors operating in your country to give you the opportunity to compare sales prices and get the best possible deal. However, you have the possibility to expand or restrict the list of the recipients of your inquiry among the distributors manually.

For product-related inquiries the geographical location of the inquirer usually determines which parties handle your inquiry. Inquiries received from the Netherlands, UK, Germany, France or Italy may be handled by our colleagues directly or be forwarded to one of our distributors, depending on the circumstances and the nature of the inquiry.

We may also disclose your personal data where required to respond to authorized requests from government authorities or where required by law, including for national security. Where we are required by law, we may also disclose your personal data where it is necessary to enforce or apply our Website Terms of Use, this Notice or other agreements, to investigate or protect the rights, property or safety of PHC EU and our group companies, our products and services and our customers, distributors or business partners or to prevent or take action regarding illegal activities or fraud, situations involving potential threats to the safety of any person or as evidence in litigation. Your personal data may be subject to foreign laws and may be accessible by foreign governments, courts, law enforcement and regulatory agencies.

Your inquiry will be registered in our CRM system.

Transfer of your personal data outside the EEA

Please note that if you are based in any of the countries belonging to the European Economic Area (‘EEA’), your personal data will be stored on servers located within the European Union (‘EU’). Transfer of your personal data to our representatives or affiliates located in third countries outside the EU will only take place where

• based on the decision of the European Commission, the third country in question ensures an adequate level of protection of personal data; or
• appropriate safeguards have been provided in accordance with applicable laws.

Retention periods

We will store your information for as long as we have to by law, and where there is no legal requirement, we will only store it for as long as necessary to fulfil the purposes for which it was collected as described in this Notice.

To determine the appropriate period for storing personal data, we take into account the personal data in question; its nature and sensitivity; the purpose of processing; the potential risk of harm in the case of a data breach; and the applicable legal requirements. If your personal data have been used for the purpose of establishing and maintaining a business relationship, such data will be stored until such relationship lasts plus a retention period stipulated by applicable commercial and tax laws. In your own interest, we will keep a permanent record of your request (including a minimum amount of your personal details) in a designated database.

Keeping your Personal Data Secure

In order to protect your privacy, we

• implement and maintain appropriate administrative, technical and physical measures to prevent unauthorized disclosure, use, modification or destruction of the personal data in our possession;
• conduct regular training seminars on key principles of the protection of personal data for the relevant members of the staff;
• regularly review the established policies and procedures, including those related to reporting of information security breaches, to ensure a swift and adequate response.

Data related to your online visit stored and retrieved in the form of cookies

Our website tracking program collects aggregate information about the number of visitors, types of browsers used, Internet Service Providers used, visit times and length, pages visit, referring pages and exit pages (commonly known as log files). This information helps us measure popularity, traffic, and effectiveness of various areas of this website and helps us to offer our visitors a better browsing experience.