Privacy Policy

Last updated: 2024-12-16

1. About this Policy

This Part A (General) (the “Policy”) applies to the collection, storage, use, updates, disclosure, transfer, deletion and other operations (“processing”) of the personal data of individuals in relation to our websites and services of the affiliates of Panasonic Energy Co., Ltd. (“Panasonic Energy”), which are listed below (“Affiliates,” “we,” “our,” or “us”):

1. Panasonic Industry Sales Asia Pacific
   Address: No.3 Bedok South Road, Singapore 469269,
   The Republic of Singapore
2. Panasonic Industrial Devices (M) Sdn. Bhd
   Address: 15th Floor, Menara IGB, Mid Valley City,
   Lingkaran Syed Putra, 59200, Kuala Lumpur, Malaysia
3. Panasonic Industrial Devices Sales (Thailand) Co., Ltd.
   Address: 252/133 Muang Thai Phatra Complex Building 2
   31st Floor, Rachadaphisek Rd., Huaykwang, Bangkok, 10320, Thailand
4. Panasonic Life Solutions India Pvt. Ltd. | Industrial Device Division
   Address: 12th Floor, Ambience Tower I Ambience Island NH-8, Gurgaon, Haryana-122002, India

※For the residents of the following countries, please read addendums of Part B(Jurisdictional Requirements) as well as Part A(General)

　　India
　　Indonesia　*For Indonesian language,please click here
　　Malaysia　*For Malay language,please click here
　　Philippines
　　Singapore
　　Thailand
　　Turkey
　　Vietnam

2. How We Collect Your Personal Data

We may collect your personal data directly from you, or automatically when you visit our websites or use our products and services. The types and examples of personal data which we may collect are as follows:

1. Business Communication Data: Electronic such as e-mails, chat messages, pdf and other document files.
2. Business Contact Data: Including your company name, job title and function, office address, work email address, work telephone numbers (landline and mobile), and work fax number.
3. Identity Data: Including your first name, last name, title, and username or similar identifier.
4. Location Data: Such as your product or device’s GPS signal or information about nearby Wi-Fi access points and cell towers that may be transmitted to us when you use certain services.
5. Marketing and Communications Data: Including your marketing and communications preferences such as e.g. language settings.
   We also track when you receive and read marketing communications from us, which information we use to improve our marketing services, provide you with more relevant information and improve the quality of our marketing materials.
6. Product/Device/Application Data: Including your hardware model, IMEI number, the MAC address of the device’s wireless network interface and the mobile phone number used by the device, mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, IP address, operating system details, and other technology on the product or device you use to access our services.
7. Profile and Usage Data: Including information collected about your use of this website/our services such as the time and duration of your use, passwords and login data, your referral website, links you click, searches you conduct, actions you take, pages you visit, your web browsing history, patterns of your usage and information from forms you fill in.
8. Transactional Data: Including information about your transactions (e.g. purchase or return of our products/devices and services) and details on such product/devices such as the name of the product/device and service, product category, model number, serial number, purchase price, proof of purchase, date and location of the transaction, invoice history.
9. Your Inquiries Data: Information in your inquiries to us.
10. Your Opinion Data: Responses and opinions to questionnaires, monitors, etc.
11. Events Participation History Data: Your participation in our events (including online events).

3. Purposes of Processing Personal Data

We process the personal data that we hold about you for the purposes set forth below. We will process your personal data only to the extent that it is necessary to fulfill the following purposes:

1. Manage this website and our services: To securely provide and administer this website and our services, this includes continuously improving its functioning, including monitoring performance of data centers and networks, maintaining the security of our infrastructure and services, testing, reporting and troubleshooting.
2. Creating an Account or Profile: When you create an account or profile on a Panasonic Industry website or application, and register products or services there.
3. Publish your comments on message boards and forums: Some Panasonic Industry websites and applications have message boards, forums, bulletin boards, chat functionality, blogs, and similar features(“Community Postings”) through which you can post information, messages and other materials.
4. Provide our services: To provide our services or any specific feature that you request, including to enable us to fulfil our obligations under any contract with you (such as, any product or device warranty), providing customer support services and dealing with any other support query you may have (such as, complaint handling), and providing for staff training and informing.
5. Update: To communicate with you, including communicating with you about your account, profiles or transactions with us, giving you important information about your products, devices, application or other services and sending you policies about any material changes to our terms and conditions or polices, e.g. this Policy.
6. Promotions, (online) games, prize draws, sweepstakes, cash back, competitions and similar activities: To properly conduct and administer any of the above, including sharing your Personal Data with sponsors.
7. Send marketing communications: Provide customized advertisements, sponsored content, make recommendations based on your past activities on our services and sending you promotional communications such as newsletters and sharing your personal data with a partner should you contact us with a sales inquiry.
8. Service improvement and surveys: To develop and improve new and existing Panasonic products and services, recommendations, advertisements and other communications and learning more about your preferences including asking you for your opinions on our products and services and carrying out surveys.
   This also includes creating anonymous, aggregated statistics about the use of our services.
9. Product recall: In the highly unlikely circumstance that Panasonic Industry needs to recall any product, including for safety purposes, we need to contact you with instructions on how to return your product.
10. Compliance and legal action: Ensure administration, operation and compliance with all applicable laws and regulations and internal Panasonic industry policies and processed, as well as enforcement of legal rights and defence in the event of a legal dispute.
11. Machine Learning: To automize business processes including invoicing and accounting, response to business communication.

4. Purposes of Processing Personal Data

We may disclose your personal data to the following categories of recipients, including those outside the country where you are located:

1. Affiliates: We may share your personal data with Panasonic Industry and the Affiliates indicated above in Section 1 (About this Policy).
2. Employees: We may disclose your personal data to our employees who have the authority and necessity to access the personal data.
3. Service providers: We may disclose your personal data to service providers, such as IT service providers, marketing service providers.

We may otherwise disclose your personal data to any third party other than those set forth above, including public agencies, if such disclosure is required to achieve the purposes for which you provided personal data to us or other purposes that we specify when obtaining consent or personal data from you, to the extent necessary to comply with any laws and regulations applicable to us, to cooperate with relevant governmental authorities and agencies, or to establish, exercise or defend legal claims.
We require all of the recipients of your personal data to treat it as confidential and only process it in accordance with the strict requirements of applicable data protection laws, regulations, and other applicable legal safeguards as specified in the Addendum for each jurisdiction in Part B (Jurisdictional Requirements).

5. International Transfer of Personal Data

Your personal data collected by us may be stored and processed on the servers in Japan and/or the US operated by Panasonic Industry or the Affiliates (or its server vendor(s)). We will ensure that your personal data remains protected in line with the requirements set out in applicable data protection laws, regulations, and other applicable legal safeguards as specified in the Addendum for each jurisdiction in Part B (Jurisdictional Requirements).

You may request additional information in this respect and obtain a copy of the appropriate safeguards we provide for through sending a request to the contact indicated below in Section 9 (Contact Us).

6. Data Retention

We will only retain your personal data for the period necessary to fulfil the purposes for which it has been collected. This includes the purposes of fulfilling our contract with you, satisfying any legal, regulatory, accounting, reporting obligation we are subject to and the establishment and defense of legal claims.

7. Your Rights

You have a number of legal rights in relation to the personal data that we hold about you. These rights may vary depending on where you are located and which data protection laws apply to the relationship between you and us, but typically will include:

1. right to obtain information regarding processing of your personal data and to access the personal data that we hold about you;
2. right to request that we rectify your personal data if it is inaccurate or incomplete;
3. right to request that we erase your personal data in certain circumstances;
4. right to request that we restrict our processing of your personal data in certain circumstances;
5. right to object to our processing of your personal data;
6. right to receive your personal data in a structured, commonly used, and machine-readable format and/or to request that we directly transmit such personal data to a recipient where this is technically feasible; and
7. right to withdraw your consent to our processing of your personal data at any time.

You may exercise any of your rights by contacting us, using the information about us indicated below in Section 9 (Contact Us).
You also can lodge a complaint with the data protection authority in the relevant jurisdiction if you believe that any of your rights has been infringed by us and for any other reason specified in Part B (Jurisdictional Requirements).

8. Security Control Measures

The security of your personal data is of greatest importance to us.
We have put in place a range of appropriate physical and technical measures as well as robust policies and processes.
The purpose thereof is to safeguard your personal data and to protect it against accidental or unlawful destruction or alteration, accidental loss, unauthorized disclosure or access and against other unlawful forms of processing.
These measures take into account the state of the art of the technology, the costs of its implementation, the nature of the personal data, and the risk of the processing.

Information security, including the protection of personal data is organized in a global Panasonic Program called Information Security Management (ISM).
The related aim, standards and implementation measures are organized in a globally valid Policy, and further standards and guidelines.
The program and all its parts follow a strong yearly Plan-Do-Check-Act (PDCA) approach to secure the confidentiality, integrity and availability of all data (including your personal data) for the whole information lifecycle from collection to destruction of such information.

9. Contact Us

If you have any questions about this Policy, your rights, or any other matter relating to the protection of personal data, please contact us at the following email address:

Email address: [privacy@sg.panasonic.com]

The content of this Policy may be changed to protect your personal data or to comply with any amendment to laws, regulations, or other rules.
You will be notified of any such changes on our websites, by email, or by other means.

India
Indonesia
Malaysia
Philippines
Singapore
Thailand
Turkey
Vietnam

This addendum to the Policy (“India Addendum”) applies to those in India. This India addendum shall be applicable in addition to the Policy set forth above.
We comply with the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 to protect your personal data and sensitive personal data or information.
The entities collecting and retaining the data is specified in Section 1 (About this Policy) of the Policy.

1.Sensitive Personal Data or Information (“SPDI”)

For the purpose of this India addendum, SPDI consists of the following items of personal data which we may collect from you:

1. password; and
2. financial information such as bank account or credit card or debit card or other payment instrument details.

2.Transfers of SPDI

You hereby consent to the transfers and disclosures of your SPDI to Panasonic Industry, the Affiliates, our service providers, and third parties.
While transferring and disclosing your SPDI, we ensure that the recipient of your data ensures the same level of data protection and information security practices as adopted by us.

This addendum to the Policy (“Indonesia Addendum”) applies to the extent the personal data protection laws in Indonesia apply to the processing of your personal data or so long that such activity is considered as “processing” under the Indonesian law, particularly the Law No. 11 of 2008 on Electronic Information and Transaction and Law No. 27 of 2022 on Personal Data Protection, their amendments, implementing and related regulations, official guidelines and interpretation thereof, as applicable to the processing of personal data in Indonesia that are currently in effect or that may be enacted, issued, or enforced in the future (“PDP Regulations”). Any personal data processed by us in accordance with the Policy and this Indonesia Addendum shall be subject to the PDP Regulations.

This Indonesia Addendum supplements the “Policy” and prevails over any conflicting provisions in the Policy.
Unless otherwise defined or the context otherwise requires, capitalized terms used in this Indonesia Addendum shall have the meanings as set forth in the Policy.

1. Legal Justifications and Period for the Processing of Personal Data

Personal data processing conducted by us in relation to your personal data is based on your explicit valid consent for the purposes as indicated in Section 3 (Purposes of Processing Personal Data) of the Policy and other valid legal grounds in compliance with the prevailing regulations, including the PDP Regulations.
Your personal data will be processed only for as long as necessary for accomplishment of the purposes under Section 3 (Purposes of Processing Personal Data) of the Policy, or as allowed by the PDP Regulations.

In any event, we have implemented various measures to ensure that any of personal data relating to you remains safe and secure, and we will only process your personal data based on the valid legal grounds and other requirements under the PDP Regulations.

2. Overseas Transfer of Personal Data

Where we disclose your personal data to a third party outside Indonesia, we will ensure that we comply with the overseas transfer requirements under the PDP Regulations.

3. Your Rights

In addition to your rights in the Policy, you may contact us through the contact information as stated in Section 9 (Contact Us) of the Policy to inquire about your further rights under the PDP Regulations and to exercise your rights subject to the PDP Regulations.
We will respond to your request as soon as reasonably possible within the time specified by the PDP Regulations.

4. Retention of Personal Data

We will retain your personal data collected by us in accordance with Section 6 (Data Retention) of the Policy.
In any case, in the event that retention of your personal data is no longer necessary for legal or business purposes or when the purpose for which your personal data was collected is no longer being served by the retention of your personal data, upon the lapse of retention period as required under applicable laws and regulations, including the PDP Regulations, we will remove, destroy or anonymise your personal data.

5. Changes to the Policy

Subject to any rights you may have under the law, you agree to be bound by the prevailing terms of the Policy and this Indonesia Addendum for those who are subject to the PDP Regulations as may be modified and/or updated by us from time to time.

6. Language of the Policy

The Policy and this Indonesia Addendum are issued in both English and Indonesian languages. In the event of any inconsistencies between the English version and the Indonesian language version, the English version shall prevail.

This addendum to the Policy (“Malaysia Addendum”) applies to those in Malaysia and to the extent where Malaysian personal data protection laws apply.
This Malaysia Addendum shall be in addition to and not in diminution of, the Policy set out above.
The Policy and this Malaysia Addendum are collectively referred to as “Privacy Policy” in this Malaysia Addendum.

1. Supply of Personal Data

Please note that the provision of personal data by you is voluntary.

However, in the event you choose to withhold, withdraw or limit consent for us to process your personal data, we may not be able to process your personal data for any of the purposes as stipulated in the Privacy Policy.

2. Processing of Personal Data

We will process your personal data in accordance with the purposes specified in Section 3 (Purposes of Processing Personal Data) of the Policy or otherwise in accordance with Malaysian personal data protection laws.
Without prejudice to the above, we may process your personal data if the processing is necessary:

1. for the performance of a contract to which you are a party to;
2. for the taking of steps at your request with a view to entering into a contract;
3. for complying with any legal obligation to which the data user is the subject, other than an obligation imposed by a contract;
4. in order to protect your vital interests;
5. for the administration of justice; or
6. for the exercise of any functions conferred on any person by or under any law.

3. Transfer of Personal Data to places outside Malaysia

We may transfer your personal data to the recipients described in Section 4 (Disclosure of Personal Data to Recipients) of the Policy, which may be located outside Malaysia.
We will only transfer your personal data outside Malaysia in accordance with the Malaysian personal data protection laws and, where required, will ensure that the recipient processes personal data not in contravention of the Malaysian personal data protection laws.

4. Language of the Privacy Policy

The Privacy Policy is issued in both English and Malay languages.
In the event of any inconsistencies between the English version and the Malay version, the English version shall prevail.

This addendum to the Policy applies to the processing of personal data in the Philippines.
Any personal data collected, used or disclosed by us in accordance with the Policy shall be subject to Republic Act No. 10173 or the Data Privacy Act of 2012 (“DPA”), its implementing rules and regulations, and the issuances of the National Privacy Commission of the Philippines.

1. Legal Justifications for the Processing of Personal Data

We only process your personal data when you have provided consent to the processing of your personal data for the purposes set out under Section 3 (Purposes of Processing Personal Data) of the Policy or when we have other legal justification for doing so.
Our other legal justifications for processing your personal data for the purposes specified in Section 3 (Purposes of Processing Personal Data) of the Policy are as follows:

1. to fulfill our obligations in a contract we may have with you or to take steps at your request prior to entering into said contract;
2. to comply with a legal obligation to which we are subject; and
3. to pursue our legitimate interest unless such interests are overridden by your fundamental rights and freedoms, protected under the Philippine Constitution.

2. Cross-Border Data Sharing

We may transfer your information to the types of entities described in Section 4 (Disclosure of Personal Data to Recipients) of the Policy, which may be located in countries outside the Philippines including Japan.
We will only transfer your information overseas in accordance with the DPA and will ensure through contractual or other reasonable means that the entities described in Section 4 (Disclosure of Personal Data to Recipients) of the Policy will be obliged to provide a standard of protection comparable to the protection under the DPA.

3. Exercising your Rights

If you wish to exercise your rights under Section 7 (Your Rights) of the Policy, please note that:

1. in order for us to provide any personal data, we will need to verify your identity and may request further information about your request;
2. we may refuse access to your personal data if it would affect the privacy rights of other persons or if it breaches any confidentiality that attaches to that information;
3. we may also refuse your request where we are legally permitted to do so and give you such reasons;
4. you should be aware that we may take a reasonable time to process your application for access as we may need to retrieve information from storage and review the information in order to determine what information may be provided; and
5. we may have to charge you a reasonable administrative fee for retrieving your personal data.

If you believe that any of your rights has been infringed by us, you may lodge a complaint with the National Privacy Commission of the Philippines.

This addendum to the Policy (“Singapore Addendum”) applies to our collection, use and/or disclosure of personal data in Singapore. Any personal data collected, used or disclosed by us in accordance with the Policy shall be subject to the Personal Data Protection Act 2012 of Singapore (“PDPA”).
For the purpose of this Singapore Addendum, “personal data” means any data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which any of the Parties has or is likely to have access, and such other data which is deemed as personal data under the applicable personal data laws.

1. Legal Basis for the Collection, Use and Disclosure of Personal Data

We will not collect your personal data unless (a) it is provided to us voluntarily by you directly after (i) you have been notified of the purposes for which the personal data is collected (including amongst others those set out under Section 3 (Purposes of Processing Personal Data) of the Policy), and (ii) you have provided consent to the collection, usage and/or disclosure of your personal data for such purposes; or (b) collection, use and/or disclosure of personal data without consent is permitted or required by the PDPA or other applicable laws, including amongst others by way of deemed consent by conduct, deemed consent by contractual necessity or deemed consent by notification.
In addition to the purposes listed under Section 3 (Purposes of Processing Personal Data) of the Policy, we may implement profiling and automated decision-making in respect of your personal data.

Notwithstanding the above, you may choose to exercise any of your rights set out in Section 7 (Your Rights) of the Policy.
For the avoidance of doubt, if we refuse to grant you access to your personal data pursuant to the exercise of your rights as set out in Section 7 (Your Rights) of the Policy, we shall preserve a complete and accurate copy of the personal data for a period of 30 days after the date which we notify you of our refusal to do so.

2. Transfer Overseas

We may transfer your personal data to the types of entities described in Section 4 (Disclosure of Personal Data to Recipients) of the Policy, which may be located in Japan or other countries outside Singapore.
We will only transfer your information overseas in accordance with the PDPA and will ensure that the entities described in Section 4 (Disclosure of Personal Data to Recipients) of the Policy will be obliged to provide a standard of protection comparable to the protection under the PDPA.

3. Retention of Personal Data

We will retain your personal data collected by us in accordance with Section 6 (Data Retention) of the Policy and in any case, for only as long as:

1. the retention of your personal data continues to serve the purposes for which the personal data is collected (as set out under Section 3 (Purposes of Processing Personal Data) of the Policy); and
2. the retention of your personal data is necessary for our business or legal purposes.

In the event that retention of your personal data is no longer necessary for any business or legal purposes or when the purpose for which your personal data was collected is no longer being served by the retention of your personal data, we will remove, destroy or anonymise your personal data.

We will further undertake reasonable measures to prevent (a) the unauthorized access, collection, use, disclosure, copying, modification or disposal of your personal data and (b) the loss of any storage medium or device on which your personal data is stored.

4. Breach of Personal Data

In the event of a data breach affecting your personal data (“Breach”), we will promptly conduct an assessment of whether the Breach is notifiable to the Personal Data Protection Commission (“PDPC”)in accordance with the PDPA.
If the Breach is notifiable to the PDPC, we will also notify you of the occurrence of the Breach as soon as practicable in accordance with the PDPA.

This addendum to the Policy (“Thailand Addendum”) applies to those in Thailand and/or to the extent the personal data protection laws in Thailand apply to the processing of your personal data. In addition to other laws and regulations applicable to us, we are committed to respecting and fulfilling our duties under the Personal Data Protection Act B.E. 2562 (2019) of Thailand (“Thai PDPA”), where applicable.

1. Legal Basis for the Processing of Personal Data

We will process your personal data for the specified purposes described in Section 3 (Purposes of Processing Personal Data) of the Policy.
We will handle your personal data consistent with the consent you give us.
Moreover, Thai PDPA also sets out legal basis under Section 24 of Thai PDPA, enabling us to process your personal data without the need to obtain your consent, among others, as follows:

1. Where it is necessary 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 (Section 24 (3) of Thai PDPA).
2. Where it is necessary for legitimate interests of us or of a third party to collect, use or disclose your personal data.
   However, if we rely on the basis of legitimate interests to collect, use or disclose your personal data, we will take into account interests or fundamental rights you have as a data subject (Section 24 (5) of Thai PDPA).
3. Where it is necessary for us to comply with our legal or regulatory obligations (Section 24 (6) of Thai PDPA).

2. What if You do not Provide Personal Data?

Providing your personal data is not mandatory.
However, if you refuse to provide the requisite personal data requested by us, this refusal will affect our ability to manage our website and provide our service to you, and we may not be able to provide some or all services to you.
Specifically, in some cases, the lack of certain personal data may hinder our ability to fulfill an agreement with you (such as any product or device warranty); to provide customer services; and to support or assist you and improve customer relationship with you (such as query or complaint handling, providing you an update and any other communication with you).

3. Transfer of Personal Data from Thailand to Third Party Countries

We may transfer your personal data to the types of entities described in Section 4 (Disclosure of Personal Data to Recipients) of the Policy, which may be located in Japan or other countries outside Thailand.
In such circumstances, if to do so will trigger our cross-border obligations under Thai PDPA, we will ensure that we will do so only if it is allowed by and in accordance with Thai PDPA.

This addendum to the Policy (“Turkey Addendum”) applies to those in Turkey to inform the data subjects located in Turkey and whose personal data will be collected and processed by the entities specified in Section 1 (About this Policy) of the Policy acting as the data controller pursuant to the Law on the Protection of Personal Data numbered 6698 (“LPPD”) and to fulfill our disclosure obligations set forth under the Article 10 of LPPD.

This Turkey Addendum supplements the Policy and prevails over any conflicting provisions in the Policy.

This Policy and Turkey Addendum shall be collectively referred to as “Privacy Policy” within the Turkey Addendum herein

1. Legal Basis for the Processing of Personal Data

Your personal data we collect from you as described under Section 2 (How We Collect Your Personal Data) of the Policy, shall be processed for the purposes specified under the Section 3 (Purposes of Processing Personal Data) of the Policy relying on the legal grounds set forth below;

1. For purposes set forth under Section 3(a), based on protection of our legitimate interests of us provided that it does not harm the fundamental rights and freedoms of data subjects (Article 5/2-f of LPPD), and based on compliance with legal obligations (Article 5/2/ç of LPPD),
2. For the purposes set forth under Section 3(b), based on the performance or conclusion of the agreement to which you are party (Article 5/2-c of LPPD),
3. For the purposes set forth under Section 3(c), in accordance with your explicit consent (Article 5/1 of LPPD), based on the performance or conclusion of the agreement to which you are party (Article 5/2-c of LPPD), and where appropriate, based on that it has been made public by the data subject himself/herself (Article 5/2-d of LPPD),
4. For purposes set forth under Section 3(d), based on the performance or conclusion of the agreement to which you are party (Article 5/2-c of LPPD),
5. For purposes set forth under Section 3(e), based on the performance or conclusion of the agreement to which you are party (Article 5/2-c of LPPD), and based on compliance with legal obligations (Article 5/2/ç of LPPD),
6. For the purposes set forth under section 3(f), in accordance with your explicit consent (Article 5/1 of LPPD), based on the performance or conclusion of the agreement to which you are party (Article 5/2-c of LPPD), and based on protection of our legitimate interests of us provided that it does not harm the fundamental rights and freedoms of data subjects (Article 5/2-f of LPPD),
7. For purposes set forth under Section 3(g), in accordance with your explicit consent (Article 5/1 of LPPD), and based on protection of our legitimate interests of us provided that it does not harm the fundamental rights and freedoms of data subjects (Article 5/2-f of LPPD),,
8. For purposes set forth under Section 3(h), in accordance with your explicit consent (Article 5/1 of LPPD), and based on protection of our legitimate interests of us provided that it does not harm the fundamental rights and freedoms of data subjects (Article 5/2-f of LPPD),
9. For purposes set forth under Section 3(i), based on the compliance with legal obligations (Article 5/2/ç of LPPD),
10. For purposes set forth under Section 3(j), based on the compliance with legal obligations (Article 5/2/ç of LPPD) and on the establishment, exercise or protection of a legal right (Article 5/2-e of LPPD),
11. For purposes set forth under Section 3(k), in accordance with your explicit consent (Article 5/1 of LPPD), and based on protection of our legitimate interests of us provided that it does not harm the fundamental rights and freedoms of data subjects (Article 5/2-f of LPPD).

For processing your personal data for the purpose of sending marketing communication as described under the Section 3 (Purposes of Processing Personal Data) paragraph (g) of the Policy, we rely on your consent you provide us for marketing communication.

2. Transfer of Your Personal Data Outside Turkey

We, as the data controller, are a global organization, with legal entities, business practices, and technical systems that operate across borders.
Your personal data may be collected, transferred to, and stored outside Turkey by us, Panasonic Industry, the Affiliates and/or third-party service providers that are in other countries.
Therefore, your personal data may be transferred and processed outside Turkey and in countries that may not provide the same level of data protection as your own jurisdiction.
The recipients of personal data are specified under the Section 4 (Disclosure of Personal Data to Recipients) of the Policy.

We may transfer your personal data to third party service providers who act under our instructions in processing your data in order to enable us to offer you our services and to carry out the purposes specified under the Section 3 (Purposes of Processing Personal Data) of the Policy.
Our service providers include, but not limited to the below:

• HubSpot Inc. with its head office in 2 Canal Park Cambridge MA 02141 United States, provides the platform and hosting services for the platform which hosts our services provided to you.
  For more information, please also see their own privacy policy at https://legal.hubspot.com/

For international transfers of your personal data outside Turkey for the purposes specified under the Section 3 (Purposes of Processing Personal Data) of the Policy, and as explained hereunder, we abide by the requirements set forth under the Article 9 of the LPPD until one of the appropriate safeguards set forth are ensured and where it is required we rely on your explicit consent in accordance with the Article 9/1 of the LPPD.
When transferring your personal data outside Turkey, we ensure that your personal data will be adequately protected, including by ensuring that the recipient country is deemed to provide an adequate level of protection recognized by the Turkish DPA and, if that is not the case, ensuring that we put appropriate safeguards in place such as executing standard agreements as published and approved by the Turkish DPA with data importers.

3. Your Additional Rights and Obligations

In addition to the rights listed under the Section 7 (Your Rights) of the Policy, you have the below additional rights as per the Article 11 of the LPPD:

• To learn the purpose of processing personal data and whether your personal data are used in accordance with such purposes,
• To learn the third parties to whom your personal data are transferred to domestically or internationally,
• In case you request that we rectify or erase your personal data, to request notification of such transactions to third parties to whom your personal data is transferred to,
• To object to the occurrence of a result to the detriment to yourself by analysing the processed personal data exclusively through automated systems,
• To demand compensation for damages in case you suffer damage due to unlawful processing of your personal data.

You may exercise any of your rights by contacting us, using the information about us indicated in Section 9 (Contact Us).
You also have a right to lodge a complaint with the relevant supervisory authority in Turkey that is the Personal Data Protection Authority for Turkey (further information available at: www.kvkk.gov.tr)

This addendum to the Policy (“VN Addendum”) applies where the Policy and this VN Addendum are used for our processing of your personal data pursuant to the Vietnam data protection regulations, including Decree No. 13/2023/ND-CP dated 17 April 2023 of the Government of Vietnam on personal data protection, as amended from time to time.
In relation to the processing of your personal data governed by the laws of Vietnam, “we,” “our,” or “us” used herein means the entities specified in Section 1 (About this Policy) of the Policy.

This VN Addendum provides additional provisions of the Policy from the perspective of Vietnamese law and is an integral part of the Policy. Unless otherwise specified herein, this VN Addendum shall prevail over any conflicting provisions in the Policy and amendments thereto (if any). Other sections of the Policy that are not amended hereunder shall remain unchanged.

1. How We Process Your Personal Data

After being collected by us from the relevant sources as mentioned in Section 2 (How We Collect Your Personal Data) of the Policy and obtaining necessary legal basis for processing your personal data, we will start processing your personal data in accordance with the Policy and this VN Addendum.
Your personal data will be collected electronically via our website or manually from paper media and then input automatically (if entered by you on the website) into our website servers, or manually (if provided in paper media) by our designated staff of responsible department into our information technology system (e.g., computer system) and stored electronically and securely in servers in Japan and/or the US operated by Panasonic Industry or the Affiliates (or its server vendor(s) such as HubSpot located in the US), and locked storage. Your personal data will be further processed electronically in such servers.
We and the parties set forth in Section 4 (Disclosure of Personal Data to Recipients) of the Policy will access, manage, and use the personal data electronically and securely for the purposes in accordance with the Policy and this VN Addendum.
If personal data is received directly in hard documents by paper, the hard copy will be kept in locked document cabinet.
The parties set forth in Section 4 (Disclosure of Personal Data to Recipients) of the Policy may download or have us electronically send, store, and use your personal data electronically and securely in servers operated by themselves or third-party vendors for the purposes in accordance with the Policy and this VN Addendum.

2. Processing of Your Personal Data for marketing purpose

In relation to “Send marketing communications” mentioned in Item (g) of Section 3 (Purposes of Processing Personal Data) of the Policy, details of our marketing communications to be sent to you are as below:

1. Contents:
   • Regular contents: Monthly newsletters, sponsored content, advertisements for upcoming products, affiliate programs with our business partners to offer promotions to customers;
   • Irregular contents: Information about short-term promotions and special offers tailored to you.
2. Method: We may send marketing contents to you via multiple communication channels that we think appropriate and effective, including via email, phone, post, etc.
3. Formality: Our marketing contents come in form of e-advertisement, e.g., picture, poster, short video, or voice.
4. Frequency: In principle, our marketing contents will be sent to you once a month; however, occasionally it will be sent to you more frequently, depending on the contents.

3. Potential Unexpected Consequences and Damage That May Occur During The Processing of Your Personal Data

We commit to the protection of your personal data and have implemented reasonable technical and organizational measures to achieve this goal. However, you acknowledge that no data transmission over the internet is completely secure, and transmissions may be exposed to cyberattacks, resulting in leakage of or unauthorized access to the collected personal data, and that you transmit this data to us at your own risk.

4. Your Additional Rights and Obligations

In addition to the rights listed out in Section 7 (Your Rights) of the Policy, you have additional rights granted by the Vietnam data protection regulations as below:

1. right to consent or not consent to the processing of your personal data, unless otherwise provided by applicable law;
2. right to erase, rectify, review your personal data, unless otherwise provided by applicable law;
3. right to complain, denounce, or initiate lawsuits;
4. right to claim damages; and
5. right to self-defense.

In addition to the rights to your personal data, you have certain obligations including but not limited to the following obligations:

1. to respect and protect others’ personal data,
2. to provide your personal data fully and accurately once you consent to the processing of your personal data, and
3. to comply with, and to prevent and combat violations of the Vietnam data protection regulations.

Before using/employing our products