OUR POLICY ON USING PERSONAL DATA
OF OUR CUSTOMERS FROM EUROPE

published: 6/1/2019
last updated: 6/1/2019

We, Honda Sun Co., Ltd. and Honda Motor Co., Ltd., take your privacy seriously. As we receive and respond to your inquiries, receive your orders and provide you with racing wheelchairs and their parts (hereinafter referred to as “Our Products”), or send you marketing messages, we collect and use your personal data. When we do so, we undertake to comply with applicable data protection laws including EU General Data Protection Regulation (the “GDPR”) and Japan’s Act on the Protection of Personal Information. Below is our policy on how we collet, use and protect your personal data.

We may, from time to time, amend, add to, or delete part of this policy. You can obtain the latest version on this website.

PERSON IN CHARGE

This privacy policy is issued by us, Honda Sun Co., Ltd. and Honda Motor Co., Ltd. When we collect and use your personal data, we are the data controllers in the meaning of GDPR and are responsible for protecting your rights with personal data.

PURPOSE AND LAWFUL BASIS (why and on what lawful ground we use your personal data)

(1)Provision of Our Products
For the purpose of responding to your pre-purchase inquiries, processing your orders and providing you with Our Products, we collect and use the following categories of your personal data on the lawful ground that it is necessary for the performance of our contracts or necessary in order to take steps (e.g. measurement) at your request prior to entering into contracts:
  • name, telephone number, email address of the person who places the order;
  • name and race experience of the person who use Our Products;
  • proposed measurement dates with priority; and
  • Our Products you purchased, their serial numbers, size and options, and measurement data.
  • payment data
(2) Customer support and quality control
For the purpose of customer support, product planning, product quality improvement, research and development, we collect and use the following categories of your personal data on the lawful ground that processing is necessary for the purpose of our legitimate interests, namely providing better products and services:
  • name, telephone number, email address of the person who places the order;
  • name and race experience of the person who use Our Products; and
  • transaction records including Our Products you purchased, their serial numbers, size and options, measurement data, your requests/inquiries and our responses, and repair/maintenance records.
(3) Marketing communication
For the purpose of marketing communication, i.e. sending to you information on Our Products and related services, we use the following categories of your personal data, provided that you have given us your consent to our doing so:
  • name, telephone number, email address of the person who places the order; and
  • name and race experience of the person who use Our Products

SENSITIVE PERSONAL DATA

Where we collect and use sensitive categories of your personal data as defined in Articles 9 and 10 of GDPR, we will obtain your prior and explicit consent thereto, unless we are required to do so in order to perform our statutory obligations or to protect vital interest of you or other person in emergency.

Although we collect and use your biometric data (your measurement data), we perform this processing not for the purpose of uniquely identifying you as defined in Article 9(1) of GDPR, but do so in order to provide you with racing wheelchairs that fit you. Therefore, this processing does not fall into the categories of the processing of sensitive personal data defined in the said article of GDPR.

RETENTION (how long we keep your personal data)

For the purposes (1) and (2) above, we will keep your personal data for up to 10 years from the date of your purchase, in order to ensure reasonable customer support, taking into consideration expected durable life of Our Products you purchased; For those of you who didn’t purchase Our Products, we will discard or anonymize your personal data without undue delay upon your request or at latest by the time one year after your last contact or correspondence with us.

For the purpose (3), we will keep your personal data until you withdraw your consent or we receive your objection to processing your personal data for this purpose. Thereafter we will discard or anonymize them within a reasonable period of time, so that you can no longer be identifiable.

DISCLOSURE (who we share your personal data with)

We share your personal data with our external fabricator, Yachiyo Industry Co., Ltd., in so far as may be necessary for measurement, production, delivery, customer support, quality control and research and development.

We may share your personal data with our other service providers including shipping agents, IT technology vendors, etc.

When we disclose your personal data to our service providers as described above, we protect your rights with personal data by virtue of data processing agreements in compliance with Article 28 of GDPR between our service providers and us, which impose appropriate data security and confidentiality obligations on them.

We will not disclose your personal data to anybody else without your prior consent, unless we are required to disclose them to competent public authorities by any legal obligations we are subject to.

TRANSFERS TO NON-EU COUNTRIES

We will not transfer your personal data to any third-countries without your prior consent, unless we are required to do so by any legal obligations we are subject to.

YOUR LEGAL RIGHTS

Provided that certain conditions are met, you have legal rights to request from us the following:

  • Access to your personal data and to certain supplementary information covered by this notice;
  • Correction of your personal data if inaccurate or incomplete;
  • Erasure of your personal data in certain circumstances;
  • Suspension of using your personal data in certain circumstances;
  • Stopping processing your personal data in certain circumstances; and
  • Obtaining your personal data in a structured, commonly used, and computer-readable format. If you wish to exercise your right, please contact us.

COMPLAINT

You can lodge complaints about our way of processing your personal data with data protection supervisory authorities.

INQUIRY

For further information and inquiry, contact:
General Administration Division, Honda Sun Co., Ltd.
3968 Oaza-kawasaki, Hiji-machi, Hayami-gun, Oita 879-1505
Telephone: 0977-73-1414 (Hours: Weekdays 9:00 to 12:00 and 13:00 to 17:00)
e-mail:racer@honda-sun.kir.jp

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