Privacy Notice for Business Partners
(Hoshino Europe B.V.)
Last Updated: March 1, 2019
This privacy notice provides information about the personal data that Hoshino Europe B.V. (“HEU”) (“we” “us” “our”) processes about its business partners (including our dealers, distributors, contractors and subcontractors, artists, suppliers, professional advisers (including law firms, accounting firms, and tax services firms)) (“you” or “your”). We are required under data protection legislation to notify you of the information contained in this privacy notice.
What Personal Data Are We Processing?
We may collect, store, and use the following categories of personal data about you:
· Basic information about you (such as name, address, telephone number, email address, etc.)
· Information related to your function (such as affiliated department, title, etc.)
· Information necessary to perform the contracts with you and to perform legal obligations (such as bank account information, sales and inventory record, etc.)
How Is Your Personal Data Collected?
We usually receive personal data about you directly from you. We collect your personal data from you most often through the following sources. We may receive additional personal data in the course of business related activities throughout the period you work with us.
· Emails you sent us;
· Documents and other materials or information you hand or submit to us (including your business card, electronic file, online form, etc.);
· Contract with the business partner (i.e. you or your employer) and other documents related thereto.
On What Basis Are We Processing Your Personal Data?
We will collect, store, and use your personal data only when the law allows us to do. Most commonly, we will process your personal data on the following bases.
· Contractual necessity to perform a contract. This is where we need to perform the contract we have entered into with you.
· Compliance with legal obligation. This is where we need to comply with a legal obligation.
· Legitimate interests. This is where processing your data is necessary for a legitimate interest pursued by us or a third party, and your interests and fundamental rights do not override those interests.
· Consent. We may process your personal data on the basis of your consent that you provide to us.
Why Are We Processing Your Personal Data?
We may process the listed categories of personal data for the following purposes.
· Communicating with our business partners about their products and services, or about our products and services;
· Planning, performing and managing the business relationship with our business partners, such as placing or receiving orders, making payments, delivery of products or services, receiving invoices, billing and collection, etc.;
· Administering and performing surveys, marketing activities, market analysis, etc.;
· Promoting and advertising our products;
· Making decisions about continuing the business relationship with our business partners;
· Making arrangements for the termination of the contract with our business partners;
· Checking our business partners are in compliance with any legal obligations (including legal obligations arising from data protection legislation);
· Gathering evidence for the establishment, exercise or defense of legal claims;
· To prevent fraud;
· To prevent any criminal conduct or any conduct that may result in criminal offence or convictions;
· To prevent unlawful use of our place of business and our office equipment (including our information and communication systems).
Who Do We Share Your Personal Data With?
We may disclose some of your personal data to the following categories of recipients. Most of these recipients are located in the EEA. We will ensure an adequate level of protection of your personal data when they are disclosed to a recipient located outside the EEA.
· Hoshino Gakki Co., Ltd. (HEU’s parent company) and other Hoshino Gakki related entities;
· Dealers and distributors of musical instruments;
· Logistics companies;
· Telecommunication service providers (including internet service providers and cloud service providers);
· Software vendors;
· Musical instrument rental service providers;
· Consulting services companies;
· Marketing companies.
Further to the above-listed recipients, we may share your personal data with other third parties throughout the period you work with us. In particular, we may disclose your personal data when lawfully requested by a governmental body. In such case, we will require the third parties to respect the security of your personal data and treat it in accordance with the law.
Where Do We Transfer Your Personal Data To?
We may transfer and store your personal data on our server which is located in Japan and managed by Hoshino Gakki Co., Ltd. We use data transfer agreements drafted based on Standard Contractual Clauses adopted by a European Commission decision as a valid and appropriate safeguard to protect your personal data. The data transfer agreements will be duly signed and executed between HEU and Hoshino Gakki Co., Ltd.
Personal data that are shared with our cloud based data storage, data sharing and data transfer services may be transferred and stored on their computers and servers outside the EEA. We understand that the providers of these services have taken necessary measures to ensure an adequate level of protection of your personal data when they are transferred to a country outside the EEA.
How Long Do We Keep Your Personal Data?
We will retain your personal data only for as long as necessary to fulfill the purposes for which we collected it. We may keep the listed categories of personal data for up to 7 years after the termination of business relationship with the business partner (i.e. you or your employer), unless storage or retention for a longer period is required by the laws of the European Union or of Member States of the European Union.
What Are Your Rights?
You have the right to request us to give you access, to rectify or to erase your personal data. You also have the right to require the restriction of the processing of your personal data, or to object to such processing. Also, you have the right to obtain a copy of the personal data relating to you that we process. All these rights are subject to applicable legal conditions. If you are unhappy with the way we process your requests or your personal data, you may always lodge a complaint with the competent authority.
It is important that the personal data we hold about you is accurate and current. Please cooperate with us to update your personal data in case of any change.
Right to Withdraw Consent
In the limited circumstances where you have provided your consent to the processing of your personal data, you have the right to withdraw your consent for that processing at any time. To withdraw your consent, please use the contact information indicated below in the section entitled “For Further Clarification”.
Changes to This Privacy Notice
We may change or modify this privacy notice from time to time. We will provide you with a new version of this privacy notice when we make any substantial updates.
For Further Clarification
If you have any additional questions, you can use the following contact information.
· E-mail: firstname.lastname@example.org
· Telephone Number: +31 (0)297 567788
· Address: Constructieweg 7, 3641 SB Mijdrecht, The Netherlands