GDPR Privacy Policy

Alpine Electronics Marketing, Inc. (hereinafter referred to as the “Company”), is strongly aware of the social importance of personal data protection; it hereby prescribes as follows a policy related to protecting personal data; and it is conducting activities to formulate, implement, maintain, and improve the mechanism for managing personal data.

The GDPR Privacy Policy applies in relation to all processing of personal data for which the General Data Protection Regulation is applicable (hereinafter referred to as the “GDPR”).
“Personal data” refers to a person's first name, surname, address, phone number, email address or other information through which a person is identifiable.

1. Ensuring the safety of personal data

(1)

When processing personal data, the Company will comply with applicable laws, regulations, and other standards.
(2)

The Company will make board members and employees aware of the importance of protecting personal data and will formulate and reliably implement regulations for the protection of personal data in order to appropriately use and protect personal data.
(3)

In order to maintain and improve mechanisms for managing personal data, the Company will continuously conduct education and give instructions to board members and employees.
(4)

The Company will establish a person responsible for management in each department that processes personal data and will appropriately manage personal data.
(5)

The Company will implement information security measures and other safety measures and prevent unauthorized access to personal data or the loss, manipulation, destruction, or leaks of personal data.
(6)

The GDPR Privacy Policy, related regulations, and mechanisms for managing personal data will be reconsidered as necessary and continuously improved.

2. Purposes of processing personal data

The Company may process personal data for the purposes stated below.

(1)

Performing agreements or processing requests before the conclusion of agreements (Article 6.1 (b) GDPR)
In the event that you have concluded an agreement or made a request before conclusion of an agreement, the Company may process personal data in order to prepare and perform the relevant agreement.
(2)

Communication (Article 6.1 (f) GDPR)
In the event that you made an inquiry or request to the Company, personal data may be processed in order to respond to the relevant inquiry or request. Processing of the relevant personal data is necessary in order to respond to the wishes of the person submitting the inquiry or request. The Company’s legitimate interest in using the personal data to contact you, is to respond to those inquiries for the facilitation of current or future business.
(3)

Management of entry into and exit from the Company’s facilities (Article 6.1 (f) GDPR)
In the event that you entered the Company’s facilities, personal data may be processed in order to manage entry into and exit from the Company’s facilities. Processing of the relevant personal data is necessary in order to ensure the safety of the Company’s facilities and constitutes a legitimate interest for the Company,
(4)

Application for hiring (Article 6.1 (b), (c), (f) GDPR)
In the event that you submitted an application for employment to the Company, personal data may be processed in order to respond to that application. Processing of the relevant personal data is necessary for the employment process of the Company, during the employment for the administration of the employment relationship and for its dissolution, subject to retention periods under applicable laws in regard to employment relevant documents.
(5)

Marketing (Article 6.1 (a), (f) GDPR)
In the event that personal data will be processed for marketing, the Company will obtain consent in advance, where practically possible. In any event the Company has a legitimate interest in contacting existing and potential business partners for marketing.
(6)

Use of a members-only website of the Company (Article 6. (b), (f) GDPR)
The Company may process personal data for the purpose of providing members-only services to a party registered with a members-only website of the Company. The Company may also obtain and analyze information, such as histories of browsing of a members-only website of the Company, and undertake to provide information or improve quality according to the customer's interests and preferences. Processing of relevant personal data is necessary for providing members-only services tailored to the needs of parties registered with a members-only website and to facilitate current and future business. The Company therefore has a legitimate interest.
(7)

Legal Obligations (Article 6.1 (c) GDPR)
The Company may process personal data, if necessary to fulfil its legal obligations under applicable laws, for example with regard to legal retention periods.
(8)

Retention of documents for civil law claims (Article 6.1 (f) GDPR)
The Company may process personal data, if it has a legitimate interest in storing it for the establishment and enforcement of, or the defense against, legal claims.
(9)

Emergencies (Article 6.1 (d) GDPR)
The Company may process the personal data, if necessary in order to protect vital interests of the data subject.
(10)

Cookies and web beacons (Article 6.1 (a), (f) GDPR)
In the event that cookies and web beacons will be used to process personal data, the Company will obtain consent in advance. For information about use of cookies and web beacons, please refer to our Cookie Policy.

3. International transfer of personal data

The Company may, for the purposes below, transfer personal data to countries outside the European economic area (hereinafter referred to as the “EEA”), including Japan, within the scope that is necessary to accomplish the purposes of the processing described in the previous article. In the event that a transfer will be made to a country outside the EEA, appropriate protection measures will be implemented in relation to transfer of personal data including concluding standard contractual clauses based on the GDPR.

1.
Joint use
The Company may jointly use the matters below with the Company’s group companies. For more information on the Company’s group companies here:

Further, if necessary, the Company might share personal information with data processors and other companies, which offer ancillary services for administrative purposes, like shredding companies, IT providers, banks and external auditors, or which offer marketing services, like marketing companies.
1. (i)
  
  Matters of personal data that will be jointly used
  Name, information related to contact information (address, telephone number, fax number, e-mail address, etc.), information related to workplace information (company of affiliation, name of department, name of position, etc.), content of inquiry, content of request, information related to product purchase (purchase history, etc.), and content related to agreements
2. (ii)
  
  Name of the party that is liable for management of personal data that will be jointly used:
  The Company
2.

Mergers
In the event that succession of business due to a merger or another reason will be conducted, the Company may transfer personal data to related third parties.

4. Period of saving

The Company will not save personal data beyond any of the following longer periods.
(1) The periods that are necessary for the purposes of processing the personal data or (2) 35 years from the receiving date of personal data.

With regards to your right to erasure, the general Company rule is that all personal data must be deleted, if (1) the purpose for processing it has lapsed or (2) you object to the use of your personal data and

(i)

no legal requirements prohibit an early deletion, or
(ii)

no overriding legitimate grounds for further processing exist (in particular for establishment and enforcement of or defense against legal claims).

5. Rights of the data subject

The data subject will have the rights stated below. In the event that you will exercise a right stated below, please contact the office for inquiries.

(1)

It will be possible to withdraw consent related to processing of personal data at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
(2)

It will be possible to submit requests to the Company about access to or rectification or erasure of personal data, restriction of processing concerning the data subject, to object to processing, or to request data portability.
(3)

It will be possible to make complaints about the data protection supervisory authority that has jurisdiction for processing personal data.
(4)

It will be possible to ask the Company for a copy of a document that indicates the content of appropriate protection measures related to the transfer of personal data outside the EEA.
(5)

It will be possible to make a request to the Company in order not to receive an application of decisions based only on automated processing, including profiling. In the case we do profiling, we inform the data subject about the existence of automated processing, including profiling and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
(6)

The provision of personal data by you is not a statutory or contractual requirement. However, we will need your name or the name of a person authorized by your legal entity to enter into any possible contract. If you do not provide contact details of any kind, we will not be able to contact you.

6. SSL/TSL encryption

For security reasons and to protect the transmission of confidential information, such as orders or inquiries, which you send to us as site operator, this site uses SSL/TSL encryption. You can recognize an encrypted connection, if the address line of the browser changes from "http://" to "https://". If SSL/TSL encryption is activated, the data that you send to us can not be read by third parties.

7. Contact information for inquiries

For inquiries related to personal data protection, such as the GDPR Privacy Policy, please contact the Company using the contact information below.

Alpine Electronics Marketing, Inc.
Business Planning Department
E-mail: global-alpine@aoja.alpine.co.jp

8. Updating and revision of the GDPR Privacy Policy

The Company may update or revise the GDPR Privacy Policy without giving advance notification. However, subsequent substantive or material changes will be communicated appropriately. The GDPR Privacy Policy that has been updated or revised will be applied with priority over the GDPR Privacy Policy before updating or revision.

ALPINE ELECTRONICS MARKETING, INC.
June 27, 2025