TDK Management Services Privacy Policy

This Personal Data Protection Basic Policy is part of TDK Management Services’ Privacy Policy and describes the general rules on how TDK Management Services process personal data.

TDK Management Services processes personal data in accordance with the following principles:

2.1 Lawfulness, Fairness and Transparency

Personal data are processed on basis of the applicable legal permission and in compliance with applicable laws (lawfulness), in consideration of the interests of the affected individual (fairness) and together with reasonable provision of information including the identity of the legal person that controls and is accountable for the processing of personal data (data controller), the purpose of the processing, associated risks, and necessary safeguards (transparency).

2.2 Purpose Limitation

Personal data are processed for a specified, explicit and legitimate purpose and are no further processed in a manner that is incompatible with that purpose.

2.3 Data Minimization

Personal data are adequate, relevant and limited to what is necessary in relation to the purpose for which they are processed.

2.4 Accuracy

Personal data are kept accurate and, where necessary, up to date; every reasonable step is taken to ensure that personal data that are inaccurate in respect to the purpose for which they are processed, are erased or rectified without delay.

2.5 Storage Limitation

Personal data are kept in a form which permits identification of the affected individual for no longer than necessary for the purpose for which the personal data are processed.

2.6 Integrity and Confidentiality

Personal data are processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures. Personal data protection is taken into account when new processes are planned and implemented. Technical and organizational measures at TDK Management Services are continuously adjusted.

In course of its business operations, TDK Management Services processes data of its customers, suppliers, agents, providers, sub-contractors, consultants, advisors, journalists, users that access, browse or otherwise use the TDK Management Services Website or third party websites on which TDK Management Services has posted advertisements and other current and potential business partners (“Business Partners”). These data may also include personal data of Business Partners and in case Business Partners are corporations, of individuals (e.g. employees) affiliated with Business Partners.

3.1 Data Categories

Data processed include first, middle and last name, academic title, professional status, position, postal address, e-mail address, telephone number, login-in data, online identifiers, IP addresses and other personal data reasonably related to the business relationship with TDK Management Services. 

3.2 Data Sources

Personal data are obtained through direct and indirect online and offline sources. Direct sources include business cards, e-mails, facsimiles, letters, surveys, data collected via active entries on the TDK Management Services Website and other electronic or non-electronic communication and interaction between TDK Management Services and an individual in course of a potential or existing business relationship. Indirect sources include publicly available data collected by TDK Management Services, data of Users that access, browse or otherwise use Website or third party websites on which TDK Management Services has posted advertisements and data received from third parties including TDK Group Companies and other Business Partners in compliance with applicable laws.

3.3 Processing Purposes

Personal data are processed for TDK Management Services business operations, including Business Partner relationship management, research and development, manufacturing, enterprise resource planning, data analysis for supply, online and offline marketing and sales activities, market observance and orientation, provision of product and service information, making and answering requests and inquiries, making and accepting quotes, offers, and any communication, cooperation, and other activities reasonably related to TDK Management Services business operations.

Data analysis activities may comprise automated processing including the profiling of individuals affiliated with Business Partners. TDK Management Services may in particular combine data from the above-described direct and indirect online and offline sources and analyze or predict preferences, interests, reliability, behavior, location, movements and other activities of Business Partners and in case Business Partners are corporations, of individuals affiliated with Business Partners. TDK Management Services conducts such analysis activities to understand the needs of its Business Partners, in particular to enhance, develop, present and provide new products to them, online and offline.

Online activities include targeted advertisements on the TDK Management Services Website, third party websites and in User accounts, online newsletters by email or other electronic means, promotional campaigns and other activities reasonably related to  TDK Management Services’ business operations.

Offline activities include the delivery of marketing and other promotional material including samples by mail and other activities reasonably related to TDK Management Services business operations.

3.4 Permission 

Personal data are processed in compliance with applicable laws on basis of the applicable legal permission, in particular the initiation and performance of a contract, where the individual has given consent to the processing, where the processing is necessary for compliance with a legal obligation to which TDK Management Services is subject to and where the processing of personal data is in the legitimate interest of TDK Management Services. Legitimate interests are the development, nurturing and enhancement of existing and initiation of new business relationships and any activities reasonably related thereto to pursue TDK Management Services business operations.

3.5 Specific custom surveys  

Our online surveys are designed to explore ideas and understand potential customers’ needs. To obtain the data required for our analysis, we may contact potential customers and people working in related industries to ask if they would like to participate in our survey/interview. Before starting an interview, we ask the contacted Person for their consent (Art. 6 (1) (a) GDPR), which allows us to process their personal data such as: name, title, company, industry, email address, and other contact information along with the transcripts of the survey. If the contacted person declines to participate in the survey, we only record the person’s name to avoid contacting them again. The legal basis is Art. 6 (1) (f) GDPR. All personal information will be deleted within six months following the completion of the survey.

In course of its business operations, TDK Management Services processes data related to the recruitment of new personnel. These data may also include personal data of individuals.

4.1. Data Categories

Data processed include first, middle and last name, academic title, professional status, position, birth date, personal status, work history, current position and former positions, education, postal address, e-mail address, telephone number, login-in data, online identifiers, IP addresses and other personal data reasonably related to the recruitment of new personnel. 

4.2. Data Sources

Personal data are obtained through direct and indirect online and offline sources. Direct sources include business cards, job applications, emails, facsimiles, letters, meetings, entries on the TDK Management Services Website and other electronic or non-electronic communication and interaction between an individual and TDK Management Services in the course of a job application. Indirect sources include publicly available data, data of Users that access, browse or otherwise use the TDK Management Services Website or third party websites on which TDK Management Services has posted advertisements and data received in compliance with applicable laws from third parties including TDK Group Companies and other Business Partners in the course of a recruitment process, e.g. recruiting agencies and HR service providers.

4.3. Processing Purposes

Personal data are processed for searching and recruiting new personnel for TDK Management Services business operations including any activities reasonably related thereto. 

4.4. Permission

Personal data are processed in compliance with applicable laws on basis of the applicable legal permission, in particular where necessary for the job application and the initiation of an employment relationship with TDK Management Services, where the individual has given consent to the processing, where the processing is necessary for compliance with a legal obligation to which TDK Management Services is subject and where the processing of personal data is in the legitimate interest of TDK Management Services. Legitimate interests are the processing of the job application to find and recruit skilled personnel for TDK Management Services and other TDK Group Companies and any activities reasonably related thereto. 

For information about the processing of personal data on the TDK Management Services Website and third party websites, please refer to Policy for the Handling of Personal Data on the TDK Management Services Websites and to the TDK Management Services Cookie Policy.

Personal data will be removed from TDK Management Services systems and records and/or steps are taken to anonymize data if processing is no longer required for the original purpose unless it is necessary to keep personal data to comply with a legal obligation to which TDK Management Services is subject, e.g. statutory retention periods under applicable laws including commercial and tax laws, or where TDK Management Services has a legitimate interest in retaining information in compliance with applicable laws, e.g. for filing, enforcing or defending legal claims. TDK Management Services has installed and maintains retention policies in compliance with applicable data protection and other laws.

TDK Management Services is part of the TDK Group of Companies with joint business operations (https://www.tdk.com/corp/en/worldwide/index.htm). TDK Management Services may transfer data including personal data to other TDK Group Companies, Business Partners, courts, law enforcement agencies and other third parties, which may have access to and/or process personal data. Transfers are made on a need to know basis in compliance with applicable laws and agreements with Business Partners.

7.1 Transfer to TDK Group Companies

The purpose of data transfers to other TDK Group companies (https://www.tdk.com/corp/en/worldwide/index.htm) is the support of business operations of TDK Management Services within the TDK Group of Companies through the joint utilization of data. This may include joint business operations and the outsourcing of internal functions and the utilization of external resources, e.g. procurement and manufacturing, marketing, data analysis, Business Partner relationship management, research and development, education, administration, IT functions, HR functions, compliance with corporate organization and corporate governance rules and other activities reasonably related to TDK Management Services business operations. Categories of personal data transferred are described in 3.1 and 4.1 above.

TDK Group Companies that act as service providers are contractually bound to take appropriate technical and organizational security measures to safeguard and process personal data only as instructed by TDK Management Services. The same applies to any sub-providers of TDK Management Services service providers.

7.2 Transfer to Business Partners

Purpose of data transfers to Business Partners is to outsource internal functions and utilize external resources, e.g. IT services, HR, recruiting, marketing activities, marketing data analysis, administration of campaigns, offline and online advertisement, publishing, design, legal, tax, financial advisory services and other activities reasonably related to TDK Management Services ’business operations. 

Business Partners that act as service providers for TDK Management Services are contractually bound to take appropriate technical and organizational security measures to safeguard and process personal data only as instructed by TDK Management Services. The same applies to any sub-providers of  TDK Management Services’ service providers. 

7.3 Transfer to government authorities, courts, law enforcement agencies

Purpose of data transfer to government authorities, courts, law enforcement agencies and other public bodies is to comply with obligations to which TDK Management Services is subject to under applicable laws, e.g. transfer and disclosure obligations under social security law, civil procedure law, tax, import and export laws.

To the extent personal data are transferred to and processed in other countries than where TDK Management Services is established, TDK Management Services transfers personal data in compliance with applicable laws and has established appropriate safeguards by means of data processing and data transfer agreements that oblige the recipient in the other country to establish and adhere to an adequate level of data protection.

Qualified service providers (e.g. IT service providers, marketing agencies) are used for the operation, optimization and protection of the TDK Management Services Website. When certain tools are used, data may be transferred to recipients outside the EU, where there is not the same level of data protection as provided in the EU in accordance with the GDPR (e.g. USA). More detailed information on the service providers is provided in the TDK Management Services Cookie Policy.

In compliance with applicable laws, TDK Management Services informs individuals about the personal data processing activities as described in the TDK Privacy Policy and the TDK Cookie Policy. Both online and offline, TDK Management Services refers individuals to the TDK Management Services Website for information on data protection activities.

Where required under applicable data protection and other laws, TDK Management Services processes any data only after obtaining consent. Providing consent and data is voluntary. Before obtaining consent, TDK Management Services will duly inform each individual about the respective processing activity. Without providing data, an individual may not be able to engage with TDK Management Services in respect to TDK Management Services’ business operations.

Consent can be withdrawn at any time with future effect by emailing info@managementservices.tdk.com or by sending a withdrawal notice to the contact address stated under section 12 below. A withdrawal will not affect the lawfulness of the processing prior to the withdrawal.

Where TDK Management Services processes personal data of individuals, each individual may exercise its rights under applicable laws.

Any rights can be exercised by sending an email to info@tdk-managementservices.tdk.com or using the contact details provided under section 12 below.

In addition, each individual may lodge a complaint with a competent data protection supervisory authority.

Any individual may exercise towards TDK the following rights:

• Right of access,
• Right of rectification,
• Right to erasure,
• Right to restriction of processing,
• Right to object to processing,
• Right to data portability,

Where TDK Management Services processes personal data for direct marketing purposes, each individual has the right to object at any time to the processing of its personal data for direct marketing purposes, which includes profiling to the extent related to marketing purposes.

TDK Management Services may change the Personal Data Protection Basic Policy, the Policy for the Handling of Personal Data on TDK Management Services Websites and the TDK Management Services Cookie Policy at any time and without explicit notice. The enactment date and the date of the last revision is shown in the respective document and any prior versions can be requested from TDK Management Services.

This Policy for the Handling of Personal Data on TDK Websites is part of TDK Management Services’ Privacy Policy.

It describes how TDK Management Services processes data of users that access, browse or otherwise use the TDK Management Services Website TDK Management Servicesor third party websites on which TDK Management Services has posted advertisements (“Users”). These data include also personal data that Users actively send, transmit or otherwise provide on TDK’s website and that TDK Management Services collects or otherwise obtains via cookies.

For detailed information about the use of cookies please refer to the TDK Management Services Cookie Policy.

TDK Management Services processes data for its Services (2.1 below) and Marketing (2.2. below) only after the consent of the User. Providing consent and data is voluntary. Before obtaining any consent, TDK Management Services will duly inform each individual about the respective processing activity. Without providing data, a User may still access, browse or otherwise use the TDK Management Services Website but may not able to benefit from some or all of the Services. Regarding the withdrawal of consent and other rights of Users, please refer to the Personal Data Protection Basic Policy.

TDK Management Services processes data including personal data for providing the following services in connection with its business operations (“Services”).

2.1.1 Inquiries and Requests

TDK offers the possibility to make online inquiries and requests regarding its products and services and strives to revert to the inquirer in due time.

2.1.2 Promotional Campaigns

TDK Management Services invites Users to take part in online promotional and other campaigns to bring TDK Management Services’ products and services and other information reasonably related to TDK Management Services’ business operations to the attention of current and potential customers and the wider public. TDK Management Services asks individuals to provide their comments and opinions about TDK Management Services’ products and services. TDK Management Services may also send materials and samples and other giveaways and information offline to Users participating in the campaigns.

2.1.3 Recruitment

TDK Management Services may offer information about job vacancies of any kind on its website and invite individuals to file applications via TDK Management Services’ website.

2.1.4 PC and Mobile Application Software

TDK Management Services offers software for specific services and functions alone or together with TDK Management Services’ products, services and other activities reasonably related to TDK Management Services’ business operations. TDK Management Services provides certain support services like software and firmware support. Software applications may create crash reports that help TDK Management Services and third party software developers to resolve any issues with the software.

For its marketing activities TDK Management Services processes data that Users have actively sent, transmitted or otherwise provided on the TDK Management Services Website for Services (see 2.1 above) and that TDK Management Services have collected or otherwise obtained via cookies from its and third party websites where TDK Management Services has posted advertisements. For detailed information about the use of cookies, please refer to the TDK Management Services Cookie Policy.

TDK Management Services analyses such data alone or in combination or together with other data including personal data TDK Management Services has lawfully received. Data analysis activities may comprise automated processing including profiling. TDK Management Services may, in particular combine data from the above-described direct and indirect online and offline sources and analyze or predict preferences, interests, reliability, behavior, location, movements and other activities of Users. TDK Management Services conducts such analysis to understand the needs of the Users, in particular to enhance, develop, present and provide new products to them, online and offline.

Online activities include targeted advertisements on the TDK Management Services Website, third party websites and in User accounts, online newsletters by email or other electronic means, promotional campaigns and other activities reasonably related to TDK Management Services’ business operations.

Offline activities include the delivery of marketing and other promotional material including samples by mail and other activities reasonably related to TDK Management Services’ business operations.