This Privacy Notice is intended to tell you how we use any information we collect about you (called Personal Data as defined below) and what your rights and our obligations are in relation to the processing of your Personal Data, in accordance with the General Data Protection Regulation (the “GDPR”).
This Privacy Notice applies to the use of our Product introduction websites (collectively, our “Services”) and will apply whether you access our Services using a computer, mobile phone, tablet, TV or other devices.
If you are a California resident, additional privacy notice applies to you, in accordance with the California Privacy Rights Act. Please see CPRA Appendix.
Please click on the links below for further information on our privacy practices:
- Who are we?
- What is Personal Data?
- What Personal Data does i-PRO collect about you?
A. Accessing our Website
B. Setting of cookies
C. Website Analysis
D. Use of contact forms
E. Subscription to our email communications - On which legal basis do we process Personal Data?
- How do we use your Personal Data?
- To whom and where do we disclose your Personal Data?
- What do we do to keep your Personal Data secure?
- What are your rights and how can you exercise them?
- Data Retention – How long will we store/keep your Personal Data
- Third-Party Links and Products on Our Services
- Cookies
- Changes to this Privacy Notice
- Contact Us / Further Information
- Representative
1. Who are we?
I. i-PRO Co., Ltd. 2-15-1 Konan, Minato-ku, Tokyo, Japan is responsible for the processing of your Personal Data acting as controller (“i-PRO”, “we”, “us” or “our”);
II. We are part of the i-PRO Company, headquartered in Tokyo Prefecture, Japan;
III. We have a number of Affiliates who can be found below.
- i-PRO Americas Inc., --- Sales Company
- i-PRO EMEA B.V. --- Sales Company
- i-PRO APAC Pte. Ltd. --- Sales Company
- i-PRO Sensing Technology (Suzhou) Limited --- Manufacturing Company
2. What is Personal Data?
For the purposes of this Privacy Notice, "Personal Data" consists of any information that relates to an identified or identifiable individual (such as you). For example, information which identifies you may consist of your name, address, telephone number, photographs, payment details, a specific i-PRO product/device identification number that you purchased, location data, an online identifier (e.g. cookies and your IP address) Information which does not identify you on its own but that we link to you also qualifies as Personal Data.
3. What Personal Data does i-PRO collect about you?
In the following we wish to provide you with information on how we handle your personal data when you use our Website.
A. Accessing our Website
Personal data | Means | Timing | Purpose of processing | Legal Basis(GDPR) |
IPAdress | Web browser | Access to our website | To protect our legitimate interests | 6-1-(f): Legitimate interests |
Date and time of access | Web browser | Access to our website | To protect our legitimate interests | 6-1-(f): Legitimate interests |
Status of access/HTTP status code | Web browser | Access to our website | To protect our legitimate interests | 6-1-(f): Legitimate interests |
Transferred volume of data | Web browser | Access to our website | To protect our legitimate interests | 6-1-(f): Legitimate interests |
Browser, language settings, version of browser software operating system and surface | Web browser | Access to our website | To protect our legitimate interests | 6-1-(f): Legitimate interests |
B. Setting of cookies
Personal data | Means | Timing | Purpose of processing | Legal Basis(GDPR) |
Essential cookies | Web browser | Access to our website | To protect our legitimate interests | 6-1-(f): Legitimate interests |
Performance cookies | Web browser | Access to our website | To improve the way our website works for you and for others visitors to our website. | 6-1-(a): Consent |
If you want to know further information, Please Refer Section 11. Cookies.
C. Website Analysis
Personal data | Means | Timing | Purpose of processing | Legal Basis(GDPR) |
Google Analytics data | Web browser | Access to our website | For access analysis | 6-1-(f): Legitimate interests |
File download data by Google Analytics | Web browser | File download | To understand the status of file downloads | 6-1-(f): Legitimate interests |
Unique Marketo Person ID | Web browser | Access to our website/Upon cookie acceptence | To protect our legitimate interests | 6-1-(a): Consent |
Referrer URL & datetime of access | Web browser | Access to our website/Upon cookie acceptence | To protect our legitimate interests | 6-1-(a): Consent |
D. Use of contact forms
Personal data | Means | Timing | Purpose of processing | Legal Basis(GDPR) |
Name and surname | Webform | Making an inquiry | To respond to inquiries | 6-1-(a): Consent |
Mail Adress | Webform | Making an inquiry | To respond to inquiries | 6-1-(a): Consent |
Company, Department | Webform | Making an inquiry | To respond to inquiries | 6-1-(a): Consent |
Country | Webform | Making an inquiry | To respond to inquiries | 6-1-(a): Consent |
Salutation/Gender | Webform | Making an inquiry | To respond to inquiries | 6-1-(a): Consent |
Areas/Subjects of Interest | Webform | Making an inquiry | To respond to inquiries | 6-1-(a): Consent |
E. Subscription to our email communications
Personal data | Means | Timing | Purpose of processing | Legal Basis(GDPR) |
Name and surname | Webform | When filling out a webform | To deliver our marketing communications | 6-1-(a): Consent |
Mail Adress | Webform | When filling out a webform | To deliver our marketing communications | 6-1-(a): Consent |
Company, Department, Job Title | Webform | When filling out a webform | To deliver our marketing communications | 6-1-(a): Consent |
Country | Webform | When filling out a webform | To deliver our marketing communications | 6-1-(a): Consent |
Salutation/Gender | Webform | When filling out a webform | To deliver our marketing communications | 6-1-(a): Consent |
Areas/Subjects of Interest | Webform | When filling out a webform | To deliver our marketing communications | 6-1-(a): Consent |
4. On which legal basis do we process Personal Data?
We are not allowed to process Personal Data if we cannot rely on a valid legal ground. Therefore, we will only process your Personal Data when:
A. Accessing our Website
We rely on our legitimate interests for processing personal data collected through our Website.(Art. 6-(1)-(f) General Data Protection Regulation) To protect our legitimate interests, we will store such information for a limited period of time in order to be able to initiate a tracking of personal data in the event of actual or attempted unauthorized access to our servers
B. Setting of cookies
I. Essential cookies
We rely on our legitimate interests for processing personal data collected through our first-party essential cookies. (Art. 6-(1)-(f) General Data Protection Regulation)
II. Performance cookies
All other non-essential cookies will only be used with your consent.(Art. 6-1-(b) General Data Protection Regulation)
C. Website Analysis
On our Website we use a web analysis service of Google.
Google will analyze your use of our Website on our behalf. To this purpose we use the cookies described in more detail in the Privacy Preference Center. The information collected by Google in connection with your use of our Website (e.g. the referring URL, our webpages visited by you, your browser type, your language settings, your operating system, your screen resolution) will be transmitted to a server of Google in the US, where it will be stored and analyzed. The respective results will then be made available to us in anonymized form. Your usage data will not be connected to your full IP address during this process. We have activated on our Website the IP anonymizing function offered by Google, which will delete the last 8 bits (type IPv4) or the last 80 bits (type IPv6) of your IP address after each data transfer to Google. Moreover, by concluding specific agreements with Google we ensure that an adequate level of data protection is maintained with respect to the processing of personal data by Google in the US.
You may withdraw your consent to the use of web analysis at any time, either by downloading and installing the provided Google Browser Plugin or by administrating your consents in the Privacy Preference Center, in which case an opt-out cookie will be placed. Both options will prevent the application of web analysis only as long as you use the browser on which you installed the plugin and do not delete the opt-out cookie.
Further information on Google Analytics is available in the Google Analytics Terms of Use, the Privacy and Data Protection Guidelines of Google Analytics and in the Google Privacy Policy.
D. Use of contact forms
We process information provided by you via the contact forms exclusively for the processing of your specific request.(Art. 6-1-(b) General Data Protection Regulation)
E. Subscription to our email communications Based on your prior consent, we will collect and use the email address you indicate for providing you with the newsletter, name and sername, company, department, job title, country, salutation/gender, areas/subjects of interest (Art. 6(1)(a) General Data Protection Regulation).
5. How do we use your Personal Data?
We may use the Personal Data we collect for the following purposes:
A. Accessing our Website
This is required to make available to you the requested information.
B. Setting of cookies
I. Essential cookies
To make our website work or to provide necessary functions relating to the services you request or to enable communications. They allow us to provide you with a seamless internet experience. We also use them for security purposes.
II. Performance cookies
To improve how our website works by, for example, ensuring that you can easily find what you are looking for and to overall enhance visitors’ experience on our website.
C. Website Analysis
To improve how our website works by, for example, ensuring that you can easily find what you are looking for and to overall enhance visitors’ experience on our website.
D. Use of contact forms
To provided by you via the contact forms exclusively for the processing of your specific request.(Art. 6-1-(b) General Data Protection Regulation)
E. Subscription to our email communications
To deliver our marketing communications to customers who have requested to receive them.
6. To whom and where do we disclose your information?
We will not disclose your Personal Data to third parties for their own independent marketing or business purposes without your consent. However, we may disclose your Personal Data to the following entities:
A. Third party recipients of the Personal Data
I. i-PRO Affiliates
We may need to transfer your Personal Data to other i-PRO Affiliates to provide the Services you require or any other services/assistance you request. All i-PRO Affiliates are required to follow the privacy practices set forth in this Privacy Notice.
II. Service Providers
We use third party service providers to help us to administer certain activities and services on our behalf, such as fulfilling your purchases and delivering products, processing credit card payments, sending postal mail and emails, sending text messages (such as SMS), providing advertisements, analyzing usage of our Services, tracking effectiveness of our marketing campaigns, allowing users to connect to their social network and providing customer support services. We share Personal Data about you with such third party service providers solely for the purpose of enabling them to perform services on our behalf and they will operate only in accordance with our instructions. Here are examples of third-party service providers we use:
a. Analytics Service Providers – analytics providers are used to assist us in understanding the usage of our products/devices and other Services, to enable us to improve our Services. The analytics providers we currently use are Google Analytics. For further information see the Cookie section of this Privacy Notice.
III. Third parties when required by Law or to Protect our Services
We will disclose your Personal Data to comply with applicable Member State or European Union law or respond to valid legal process, including from law enforcement or other government agencies.
IV. Other Parties in Connection With Corporate Transactions
We may disclose your Personal Data to a third party (or other i-PRO Affiliate) as part of a reorganisation, merger, transfer, sale, joint venture, assignment or other disposition of all or any portion of i-PRO’s business, assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding.
B. International Transfer of Personal Data
The Personal Data that we collect from you may be stored and processed in your region, or transferred to, stored at or otherwise processed outside the European Economic Area ("EEA"), including but not limited to Japan or in any other country which do not offer an adequate level of data protection as recognised by the European Commission and where i-PRO or its Affiliates, subsidiaries or service providers maintain facilities.
Where we transfer your Personal Data outside the EEA, we will ensure that suitable safeguards such as appropriate transfer agreements and mechanisms (such as the EU Model Clauses) are in place to help ensure that our third party service providers provide an adequate level of protection to your Personal Data. You may request additional information in this respect and obtain a copy of the relevant safeguards upon request through sending a request to the contact indicated in section 8 below.
7. What do we do to keep your Personal Data secure?
i-PRO have put in place appropriate physical and technical measures to safeguard the Personal Data we collect in connection with our Services.
A. General
These measures take into account:
I. the state of the art of the technology;
II. the costs of its implementation;
III. the nature of the data; and
IV. the risk of the processing.
The purpose thereof is to protect against accidental or unlawful destruction or alteration, accidental loss, unauthorized disclosure or access and against other unlawful forms of processing.
However, please note that although we take appropriate steps to protect your Personal Data, no website, product, device, online application or transmission of data, computer system or wireless connection is completely secure and therefore we cannot guarantee the security of your Personal Data.
B. Other security measures
Information security, including the protection of Personal Data is organized in a global i-PRO Program called “Information Security Management” (ISM). The related aim, standards and implementation measures are organized in globally valid policy, standards and guidelines. All central European IT systems are externally assessed and fall under the information security management rules applicable under the ISO 27001 certification. The program in all its parts follow a strong yearly PDCA (Plan-Do-Check-Act) 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 data.
8. What are your rights and how can you exercise them?
A. What are your rights?
i-PRO will collect, store and process your Personal Data in accordance with your rights under any applicable data protection laws.
Your rights under the UK and EU GDPR include, the right to access a copy of your Personal Data, the right to request the correction or the update of any inaccurate Personal Data and the right to object to the processing of your Personal Data under the conditions set out in applicable law.
You also have the right to request the erasure of your Personal Data and, where you have consented to the processing of your Personal Data, you have the right to withdraw such consent at any time (without this withdrawal affecting the lawfulness of the processing prior to such withdrawal).In addition, you also have the right to data portability in certain cases. This is the right to request the return of the Personal Data you have provided to us in a structured, commonly used and machine-readable format and to request the transmission of such Personal Data to a third party, without hindrance from us and subject to your own confidentiality obligations.
B. Exercising your rights
If you wish to exercise any of the above rights, please contact us by using any of the communication means below in the Contact Us/Further Information section of this Privacy Notice.
I. By mail:
2-15-1 Konan, Minato-ku, Tokyo, Japan
We will respond to your request without undue delay and no later than one month from receipt of any such request, unless a longer period is permitted by applicable data protection laws.
C. Complaints
If you are not satisfied with how we process your Personal Data, you may also file a complaint with the competent supervisory authority, in addition to your rights outlined above.
EEA/EU authorities: Members | European Data Protection Board (europa.eu)
United Kingdom (UK): Make a complaint | ICO
9. Data Retention – How long will we store/keep your Personal Data
We will retain your Personal Data for the period necessary to fulfil the purposes for which your Personal Data has been collected as outlined in this Privacy Statement unless a longer retention period is required by law. When your Personal Data is no longer required for the purpose it was collected or as required by applicable law, it will be deleted and/or returned to you in accordance with applicable law.
10. Third-Party Links and Products on Our Services
Our websites, applications and products may contain links to other third party websites that are not operated by i-PRO, and our websites or your products and devices may contain applications that you can download from third parties. These linked sites and applications are not under i-PRO's control and as such, we are not responsible for the privacy practices or the content of any linked websites and online applications. If you choose to use any third party websites or applications, any Personal Data collected by the third party’s website or application will be subject to any existing privacy policy of that third party. We strongly recommend that you take the time to review the privacy policies of any third parties to which you provide Personal Data.
11. Cookies
A. What are cookies?
i-PRO, as well as certain other third parties that provide content, advertising, or other functionality on our Services, may use cookies and other technologies in certain areas of our Services. Cookies are small tracking codes that can be read by a web server in the domain that put the cookie on your hard drive. We may use cookies to store your preferences and settings, help you with signing in, provide targeted ads, and analyse site operations.
Please note that you can modify your browser so that it notifies you when cookies are sent to it. If you do not want to receive cookies, you may also refuse cookies altogether by activating the relevant settings on your browser. Please note that if you choose to refuse all the cookies, some features of the Services may not be accessible to you or not work properly. Finally, you can also delete cookies that have already been sent.
B. Further information on cookies
For further information on what cookies are, how i-PRO and other third parties use them, and for details of how cookies can be disabled, please see our Cookie Policy.
12. Changes to this Privacy Notice
i-PRO may change this Privacy Notice from time to time. The “Date last updated” mention at the bottom of this page states when the notice was last updated and any changes will become effective upon our posting of the revised Privacy Notice.
We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. We will provide this notice by email or by posting notice of the changes on the i-PRO website or through any relevant Services.
13. Contact Us / Further Information
If you have any questions regarding the collection, processing, or use of your Personal Data or if you wish to correct, block, rectify, object, access, revoke your consent to any applicable aspect of this Privacy Notice or delete any of your Personal Data, please contact us using any of the methods used on this page :
Contact-us
14. Representative
If you have questions about privacy protection in Europe, please contact us at:
i-PRO EMEA B.V.
Laarderhoogtweg 25, 1101 EB, Amsterdam,
The Netherlands
or via email: data_protection.eu@i-pro.com
If you have any questions about data protection in the UK:
i-PRO EMEA B.V. - UK
1010 Cambourne Business Park
Cambridgeshire CB23 6DP
Cambridge
Or by email: uklegal@i-pro.com
UK Establishment (Branch): |
i-PRO UK, a branch of i-PRO Marketing Europe GmbH |
---|---|
Head Office (UK) |
Maxis 2, Western Road, Bracknell, Berkshire, RG12 1RT |
Head Office (Ireland) |
No 1, The Courtyard, Kilcarberry Business park, Dublin 22 |
Company Name: |
i-PRO Marketing Europe GmbH |
Legal Form/Limited Liability Status: |
German Incorporated limited liability company. |
Share Capital |
20,461,000.00 EUR (Held by i-PRO Europe B.V) |
Foundation |
1972 |
Date last updated : [January] 2023
CPRA Appendix
Date last updated: 1st , Jan, 2023
This CRPA Appendix complements i-PRO Privacy Notice and tells you what your rights and our obligations are in relation to the processing of your Personal Data in accordance with the California Privacy Rights Act (the “CPRA”).
If there is any discrepancy between the terms of this CPRA Appendix and those of i-PRO Privacy Notice, this CPRA Appendix will prevail.
We may change this CPRA Appendix from time to time. The “Date last updated” mention at the top of this page states when the CPRA Appendix was last updated and any changes will become effective upon our posting of the revised CPRA Appendix to the extent permitted by applicable laws.
Where required by the CPRA or other applicable law, we will request your consent to any such changes. We will provide the revised CPRA Appendix by email or by posting notice of the changes on our website or through any relevant Services.
Please click on the links below for further information on our privacy practices for residents in California:
- What is Personal Data?
- What Personal Data did we collect about you in the preceding 12 months?
- On which legal basis do we process Personal Data?
- What are your rights and how can you exercise them?
- Disclosure of Personal Data
- Sale of Personal Data
- Share of Personal Data
- Children’s of Personal Data
- Contact Information
1. What is Personal Data?
For the purposes of this CPRA Appendix, "Personal Data" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. For example, Personal Data includes, but is not limited to, audio, electronic, visual, thermal, olfactory, or similar information or inferences drawn from other Personal Data to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends among other things.
2. What Personal Data did we collect about you in the preceding 12 months?
Categories of Personal Data collected | Categories of sources | Business or commercial purpose(s) for collecting Personal Data |
Essential and Performance Cookie | direct collection | Business |
3. On which legal basis do we process Personal Data?
We process Personal Data of residents in California in compliance with the CPRA. If we are to use your Personal Data for purposes other than the purposes we notified on or before collecting your Personal Data, we will notify the new purposes to you and obtain your express consent.
4. What are your rights and how can you exercise them?
A. What are your rights?
(1) Your rights under the CPRA include, the right to know about your Personal Data that we collect, use, disclose the right to request the deletion of your Personal Data, and the right to limit the use of your Sensitive Personal Data, and the right to request the corrections to your Personal Data.
(2) We will not unreasonably discriminate against you for exercising the rights such as the right to know about Personal Data information under the CPRA by using methods including but not limited to the following:
I. Denying to provide goods or services to you
II. Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties
III. Providing a different level or quality of goods or services to you
IV. Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services
B. Exercising your rights (right to know and right to request the deletion of your Personal Data)
If you wish to exercise the right to know or the right to request the deletion of your Personal Data, and the right to limit the use of your Sensitive Personal Data, and the right to request corrections to your Personal Data under the rights of A(1) above, please contact us by using the following means in addition to the communication means described in i-PRO Privacy Notice. Upon receiving your request to exercise such rights, we will require you to submit your [name and e-mail address] in order to verify your identity.
I. By telephone (Toll-free telephone number)
+1-855-772-2891
II. By online request form
https://i-pro.com/corp/en/contact/
We will confirm receipt of your requests to exercise your rights within 10 business days in the same manner in which the request was received and provide information about how we will process the request and the limit of our response. We will respond to requests to know and requests to delete within 45 days, and if we exceed the period, we will notify you and respond within 90 days from the day that we receive the requests. If we cannot verify your requests within the 45-day time period, we may not process your requests.
We will record your requests and store them for 24 months.
If you use an authorized agent to submit a request to know or a request to delete, the authorized agent is required to submit to us a written permission proving the authorized agent is permitted to do so and the authorized agent’s own identity verification document(s).
5. Disclosure of Personal Data
We have not and will not disclose your Personal Data to any third party for a business purpose.
6. Sale of Personal Data
We have not and will not sell your Personal Data to any third party.
For the purposes of this CPRA Appendix, “sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, your Personal Data by us to another business or a third party for monetary or other valuable consideration.
7. Share of Personal Data
We have not and will not share your Personal Data to any third party.
For the purposes of this CPRA Appendix, “share" means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, your Personal Data by us to another business or a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.
8. Children’s Personal Data
We do not sell Personal Data of anyone under the age of 16.
9. Contact Information
You may contact us with questions or concerns about this CPRA Appendix and your choices and rights under CPRA at:
Company name: i-PRO Co., Ltd.
Company address: 2-15-1 Konan, Minato-ku, Tokyo, Japan