PRIVACY POLICY

Kyoto Fusioneering Ltd. (“we”, “our” or “us”) and its affiliated companies listed in https://kyotofusioneering.com/en/company (the “Affiliates”) are committed to protecting your privacy in compliance with applicable data protection laws. This privacy policy (the “Policy”) explains how we may collect, use, disclose, transfer, and process any information relating to an identified or identifiable natural person (the “Personal Data”).

Our website may contain links to and from third-party websites. These third-party websites and any services that may be accessible through them have their own privacy policies. We are not responsible for these third parties’ data protection activities. We encourage you to be aware of this when you leave this website and to read the privacy policies applicable to these third-party websites.

We collect and process the following categories of your Personal Data:

1. Personal Data that we collect directly from you:
   1. contact information: name, title, email address, phone number, fax number, postal address, company name, region, country, department and job position;
   2. personal characteristic: date of birth, age, gender, place of birth, nationality, details of your qualifications and education history and information regarding your skills, experience and education;
   3. financial and payment data, including your bank account and other data necessary for processing payments, including credit/debit card numbers, security code numbers and other related billing information;
   4. location data;
   5. any other information contained in any communications that you send to us by email or through our website or any other means, including its communication content and metadata; or
   6. any Personal Data you provide to us.
   You are generally not required to provide your Personal Data to us unless such provision is required under the applicable laws and regulations. Please note, however, that we may not be able to provide you with our services in whole or in part, you may not have access to and/or be able to use some features of our website, and your customer experience may be affected if you do not provide your Personal Data. In the event the provision of your Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, we will separately notify you of such requirement, whether you are required to provide your Personal Data, and the possible consequences of failure to provide such Personal Data.
2. Personal Data automatically collected
   Personal Data collected through our website, including cookies, access logs, web beacons (also known as pixels), your communication preferences and information about how you use our websites(s), including the referral source, the services you viewed or searched for, page response times, download errors, length of visits and page interaction information (such as scrolling, clicks, and mouse-overs), website navigation paths, the Internet Protocol (IP) address, browser type and version, device type, time zone setting, geographical location, browser plug-in types and versions, operating system and platform.
3. Personal Data collected from other sources
   1. Personal Data collected from publicly available sources, including business and employment oriented social networks and websites, integrity data bases and credit agencies; and
   2. Personal Data received from the Affiliates.

We process your Personal Data for the following purposes based on the following legal basis. In addition, we may ask if you consent to a relevant use of your Personal Data in some cases. In such cases, the legal basis for us to process such Personal Data may, in addition or instead, be that you have consented.

Purposes	Legal Basis
To plan, perform and manage the contractual relationship with you or your organisation, including performing transactions and orders of products or services, processing payments, performing accounting, auditing, billing and collection activities, arranging shipments and deliveries, and providing support services.	Necessary for exercising our rights and performing our obligations under any contract; and Necessary for our legitimate interests to plan, perform and manage the relationship with you or your organisation.
To respond or manage your enquiries or requests.	Necessary for our legitimate interests to address your enquiries or requests.
To deliver newsletters, publications, seasonal greetings, marketing material and other related information, including, surveys, promotions, invitations to exhibitions or seminars or any other events that might be of your interest.	Necessary for exercising our rights and performing our obligations under any contract; and Necessary for our legitimate interests to carry out marketing and promotional activities and maintain the relationship with you or your organisation.
To administer and conduct market research, data analysis and questionnaire surveys for statistical and survey purposes, including anonymizing your Personal Data.	Necessary for our legitimate interests to measure the use of our products and services e.g. for the purposes of improving our products and services or conducting our promotional activities.
To maintain and protect the security of our products, services or websites, or prevent and detect security threats, fraud or other criminal or malicious activities.	Necessary for our legitimate interests to protect our interests or business from any security threats or criminal or malicious activities; and Necessary to comply with our legal obligations.
To ensure compliance with legal or regulatory obligations, export control and customs, screening (e.g. to prevent money-laundering, corruption or fraud), our policy or industry standards	Necessary for our legitimate interests to check your background for anticorruption purpose or prevent any fraud; and Necessary to comply with our legal obligations.
To operate and communicate for job posting, recruitment and screening, to conduct survey for the purpose of future recruitment activities.	Necessary for our legitimate interests to secure human resources and appropriate personnel evaluation.
To operate, further optimize and develop our website, and personalise our website for you.	Necessary for our legitimate interests to improve our websites and keep them in optimal condition.
To prepare for or implement any merger, sale, transfer of our assets, investment, acquisition, bankruptcy, or similar event or corporate transaction, including where necessary the management of shareholders and relevant notifications as required under applicable laws.	Necessary for our legitimate interests to protect and grow our business; and Necessary to comply with our legal obligations.
To solve disputes, enforce our rights or to establish, exercise or defend legal claims.	Necessary for exercising our rights and performing our obligations under any contract; and Necessary for our legitimate interests to protect our interests or business.

We do not conduct any automated decision-making based solely on your Personal Data, including profiling, that produces any legal effects concerning you or similarly significantly affects you.

We disclose your Personal Data to the following categories of recipients:

1. any of the Affiliates, which are listed in https://kyotofusioneering.com/en/company;
2. third party service providers, including IT and website service providers, agents, suppliers or subcontractors and other associated organisations where they are engaged by us to help deliver a service that we have instructed them on.
3. professional advisors such as legal counsels, accountants, tax advisors, financial advisors, consultants, and insurers;
4. courts, arbitrators, regulators, or any other law enforcement and government authorities; or
5. our actual or potential investors, purchasing or acquiring entity in any merger, sale, transfer of our assets, investment, acquisition, bankruptcy, or any similar event.

Some of the recipients referred to above are located in countries outside, or process Personal Data outside your country or region of residence, including Japan, the United Kingdom and the United States.
(For residents in the European Economic Area (the “EEA”) or the United Kingdom (the “UK”)) Where we transfer your Personal Data from the EEA and the UK to elsewhere outside the EEA or the UK, the level of data protection in any such country may not be equivalent to that in the EEA or the UK. However, we only transfer your Personal Data to countries where the European Commission or the UK Government, as appropriate, has decided that they have an adequate level of data protection, or we take appropriate measures to ensure that all recipients provide an adequate level of data protection, including by executing appropriate data transfer agreements based on the European Commission’s Standard Contractual Clauses, the UK Addendum to the EU Commission Standard Contractual Clauses or the UK Information Commissioner’s Office’s International Data Transfer Agreement. These are accessible upon request (see the contact details in Clause 8 below).

We will retain and process your Personal Data for as long as we require it for the purposes for which it was originally collected or as is otherwise required by applicable laws and regulations.

In order to determine the appropriate retention period for your Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the risk of potential harm from its unauthorised use or disclosure, the purposes for which we process it, whether we may achieve our purposes by other means, and the applicable legal requirements.

The retention period also depends on the statutory limitation periods. In addition, we are subject to various retention obligations, including those arising from the applicable laws and regulations.

You have a number of legal rights in regard to the Personal Data we retain. These rights may depend on where you are located and which data protection laws will apply to the relationship between you and us, but would typically include:

1. The right to access: you may request us for a copy of part or all of your Personal Data which we process for the purposes set out above;
2. The right to rectification: you may request us at any time to correct your Personal Data if it is incorrect or incomplete;
3. The right to erasure: you may request us to delete your Personal Data we process, if this does not otherwise violate our obligations under applicable laws or a natural person’s vital interests;
4. The right to restriction on processing: you may request us to limit the processing of your Personal Data;
5. The right to data portability: you may request us to deliver any Personal Data which we process about you on the basis of your consent or on a contract (as opposed to any other legal ground) and where the processing is carried out by automated means in a structured, commonly used and machine-readable format and/or request that we transmit that data to a recipient where this is technically feasible;
6. The right to withdraw consent: where the data processing is based on your consent, you may withdraw your given consent to the processing of your Personal Data without affecting the lawfulness of any processing performed pursuant to your consent given to us prior to such withdrawal; we will, upon your request, restrain from any future process of your Personal Data, unless the processing can be continued based on another legal basis (e.g., our legitimate interests, legal obligations, a natural person’s vital interests or public interest);
7. The right to lodge a complaint with a supervisory authority: You may lodge a complaint with a supervisory authority. In particular, in the member state of the European Union or the United Kingdom where you have a habitable residence or place of work or where the alleged infringement of the applicable laws and regulations; and
8. THE RIGHT TO OBJECT PROCESSING: You may object to processing of your Personal Data, if the processing is not based on our legitimate interests and there is no other lawful basis that we can rely on to continue processing your Personal Data.

You can exercise your rights by contacting in writing at the postal address or the email address listed in Clause 8.

This Policy may be updated from time to time for any reason. We will notify you of any changes to this Policy. Thus, we encourage you to regularly check this page to review our revisions of any changes we make in this Policy.

Kyoto Fusioneering Ltd. is responsible for your Personal Data as a data controller. If you have any questions or intend to uphold your rights, please contact us at:
Mail: 5th Floor Inspired.Lab, Otemachi Building, 1-6-1 Otemachi, Chiyoda-ku, Tokyo, 100-0004, Japan