Tokyo Electron Group Privacy Policy
TOKYO ELECTRON GROUP PRIVACY POLICY
1 Compliance
In connection with collecting, using, and providing the personal information, Tokyo Electron Limited including its subsidiaries and affiliates (collectively "TEL") will comply with the "Act on the Protection of Personal Information" and its related laws and regulations, and the practices which are generally accepted as fair and appropriate for handling of the personal information, and TEL will properly handle the personal information. Furthermore, TEL will handle the Individual Number and Specific Personal Information under the "Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure" subject to the "Policy for Handling the Individual Number and Specific Personal Information" separately determined.
Since the method of handling information and the types of rights available may differ depending on your residential area, further details are written in “Tokyo Electron Group Privacy Notice” (hereinafter referred to as “Privacy Notice”).
2 Enlightenment to Employees
TEL will define the rules and regulations for handling of the personal information, and will make every effort to inform all employees (including the directors and officers, Corporate Officers, Executive Officers, the regular employees, the contract employees, the temporary employees, the part-time employees, the just-in-time employees, the dispatched employees) of such rules and regulations, and to make them observe such rules and regulations so as to properly handle the personal information.
3 Collection and Use
TEL will collect the personal information by the proper and fair procedures, and will use the personal information only for the purposes of use. The purpose of use shall be stated in the Privacy Notice, and the purpose of use shall be clearly stated each time it is used outside the scope of that purpose or when legally required.
4 Security Control
TEL will endeavor to take the necessary measures in order to prevent the illegal access to the personal information, loss, destruction, alteration and leakage of the personal information, and to ensure the security control for the personal information. TEL will continuously review and endeavor to improve handling of the personal information.
5 Providing to the Third Party, Management of Trustees
Except in the following cases, TEL will not provide the personal information to the third party. In case that TEL entrusts with handling of the personal information, TEL will take the appropriate measures to make trustees securely handle such personal information within the services entrusted:
1. Cases in which the principal has given a prior consent to the provision;
2. Cases in which the disclosure or provision of statistical data and others and in which are not identified any principal;
3. Cases in which the provision is based on laws;
4. Cases in which the provision is necessary for protection of the life, body, or property of an individual and in which it is difficult to obtain the consent of the principal;
5. Cases in which the provision is specially necessary for improving public hygiene or promoting the sound growth of children and in which it is difficult to obtain the consent of the principal; or
6. Cases in which the provision is necessary for cooperating with a state institution, a local public body, or an individual or entity entrusted by one in executing the operations prescribed by laws and in which obtaining the consent of the principal might impede the execution of the operations concerned.
6 Disclosure, Correction etc.
If the principal requests to disclose, correct or delete its personal information, TEL responds to such requests to the extent reasonable after the identification of such principal.
*If you have any questions related to the personal information, please contact Tokyo Electron Limited, Compliance Dept.
(mailto:tel-kojinjoho@tel.com）
Established: March 28, 2005
Revised: July 28, 2022
Tokyo Electron Limited
Tokyo Electron Group Privacy Policy
Tokyo Electron Group Privacy Notice
Tokyo Electron Limited and its affiliates excluding Tokyo Electron Device Limited (hereinafter collectively referred to as "TEL Group") will properly process personal information in compliance with the Act on the Protection of Personal Information and related laws and regulations, and relevant laws and regulations for protection of personal information on each country as well as generally accepted practices related to the processing of personal information when collecting, using, and providing personal information.
TEL Group will also clarify its rules and regulations concerning the processing of personal information, and strive to ensure that all officers including directors and company auditors, Corporate Officers and Executive Officers of TEL Group, persons who have entered into employment with and is rendering services to any entity in TEL Group (irrespective of employment status, such as regular employees, contract employees, advisers, fixed-term employees, employees rehired after mandatory retirement, part-time employees, and workers hired on a daily or seasonal basis), and other persons who perform work for the company such as secondees and temporary workers from another entity or agency (collectively the "Officers and Employees") properly process personal information.
In addition, the processing of Individual Numbers and Specific Personal Information under the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures shall be in accordance with the Proper Processing of Specific Personal Information Policy, etc. separately provided.
The method of handling information and the types of rights available may differ depending on your residential area. Please see Chapter II and later for further details.
Chapter I Processing of Personal Information in TEL Group
1 Company name, address, name of representative
Tokyo Electron Limited
Akasaka Biz Tower, 5-3-1 Akasaka, Minato-ku, Tokyo 107-6325
Representative Director, President & CEO Toshiki Kawai
2 Purpose of Use
TEL Group may use personal information in the area where TEL Group is located for the following purposes.
<Personal Information of Business Partners or Potential Business Partners>
・Conducting business with TEL Group and supplying goods or services
・Business partners management
・Business contact
・Confirmation of visitors and their health conditions to prevent the spread of infectious diseases
・Soliciting services, advertising and other marketing
・Sending direct mails, email magazines, and other greetings
・Conducting questionnaires, surveys, etc.
・Event implementations
・Planning and development of products, and consideration of measures to improve customer satisfaction
・Patent management services
・Responding to inquiries, etc.
・Corporate governance, risk management, compliance management and related internal research
・Business travel arrangements
<Personal Information of Shareholders>
・Investor Relations releases and information distribution
・Convenience provision to shareholders’ status, shareholder’s management, implementation of various measures to facilitate relations with shareholders, and implementation of shareholder’s meeting
・Responding to inquiries, etc.
<Personal Information of Outsourcing Companies and Joint Developers, etc. >
・Management of outsourcing companies
・Business contact
・Confirmation of visitors and their health conditions to prevent the spread of infectious diseases
・Confirmation of damage status caused by accidents while commuting or in the conduct of business
・Recording and posting of presentation information at academic conferences, etc.
<Personal Information of Applicants/Candidates for Employment>
・Sending recruitment-related documents
・Confirmation of visitors and their health conditions to prevent the spread of infectious diseases
・In case an applicant/candidate is referred, informing the referrer of the application status and result
・Contacting the applicant/candidate for similar positions, unless the applicant/candidate does not wish to do so after the initial application has been rejected
・Assessment for applicant/candidate’s skills, qualifications and suitability for the role
・Conducting specific assessments: screening process, psychometric tests (such as a situational judgement test, ability or personality test), interviews (face to face, telephone or video), behavioral assessments (such as a role play, group exercises or presentations), technical assessments
・Pre-employment screening (PES): This may include background and reference checks, where applicable
・Communication with applicants/candidates about hiring process
・Keeping records related to hiring process
・Responding to inquiries
・Diagnosis of technical problems
・Management, improvement, planning and reporting of the internal hiring process
・Compliance with legal and other requirements
<Other Personal Information>
・Analyzing and visualizing the specialized fields of engineers and the relationships between engineers by use of the information collected and obtained from published patents and papers (paper titles, engineer names, etc.), and using such analysis results for development plans and sales activities
・Production and promotion of introductory images or videos of TEL Group
・Posting on TEL Group’s websites and in pamphlets, and publishing on YouTube, Twitter, Facebook, Instagram, LinkedIn, Naver blog, WeChat and other SNS etc.
・Management of litigation information, etc.
3 Provision to Third Parties
TEL Group will not provide personal information to any third party except under any of the below conditions. However, it will not apply to the disclosure or provision to a third party in case of shared use or for entrustment.
(1) Is with your consent
(2) Is in accordance with laws and regulations
(3) Is necessary for the protection of life, body, or property of a person and it is difficult to obtain the consent of the individual
(4) Is particularly necessary for the improvement of public health or the promotion of the sound upbringing of children and it is difficult to obtain the consent of the individual
(5) Is necessary to cooperate with national or local authorities to conduct official affairs and in which obtaining the consent of the individual may affect the execution of such affairs
(6) Is to a third party that is an academic research institution, etc., and it is necessary for such third party to handle the personal information for academic research purposes (including cases where part of the purpose of handling the personal information is for academic research purposes, and excluding cases where such handling is likely to unreasonably infringe the rights and interests of individuals.)
(7) Is provided upon succession of business due to merger, company split, transfer of business or for other reasons
4 Handling of Entrustment
TEL Group may entrust part of its business activities and provide personal information to outsourcing companies to the extent necessary to achieve the purpose of use. In this case, we shall properly manage and supervise the outsourcing companies, including the conclusion of contracts for the processing of personal information with these outsourcing companies.
5 Matters related to Shared Use of Personal Information
TEL Group will share personal information as follows:
(1) Scope of shared users
TEL Group (for TEL Group companies, please refer to here
(2) Purpose of use of shared users
Purpose of use as described in 2 above
(3) Items of personal information to be shared
Name, company name, department name, address, telephone number, email address, age, gender, work history, number of shares held by shareholders, passport number, nationality, and images/videos of facial and physical appearance
(4) Person responsible for the management of personal information
Tokyo Electron Limited
Akasaka Biz Tower, 5-3-1 Akasaka, Minato-ku, Tokyo 107-6325
Representative Director, President & CEO Toshiki Kawai
6 Retention Period for Personal Information
The period that TEL Group retains personal information differs depending on the type of information and the purpose of use. Personal Information will be deleted within a reasonable period after it is no longer necessary for the purpose for which it was collected (or for any subsequent purpose that is compatible with the original purpose). This does not affect your right to request that TEL Group delete your personal information before the end of its retention period. TEL Group may archive personal data (which means storing it in inactive files) for a certain period prior to its final deletion, as part of our ordinary business continuity procedures.
7 Transfer outside of Japan
TEL Group may provide personal information to TEL Group companies outside of Japan (please refer to here for the country in which TEL Group is located) and third parties outside of Japan under the conditions as described in each item of 3 above. In this case, TEL Group will take necessary measures for the transfer outside of Japan in accordance with the provisions of laws and regulations.
8 Matters related to Safety Management Measures
TEL Group shall take necessary measures to prevent unauthorized access to personal information, loss, destruction, tampering, and leakage of personal information, and ensure thorough the safety management of personal information. We will also continuously review and improve the processing of personal information.
The main contents of the safety management measures for personal information in TEL Group are as follows:
(1) Formulation of Privacy Policy, etc.
In order to ensure the proper handling of personal information, TEL Group has formulated the "Tokyo Electron Group Privacy Policy" and this Privacy Notice regarding "compliance with relevant laws and guidelines" and "contact point for inquiries and complaints".
(2) Establishment of discipline regarding the handling of personal information
TEL Group has established "Personal Information Protection & Management Regulations" regarding the handling method of personal information, responsible persons and their duties.
(3) Organizational safety management measures
In addition to appointing a person responsible for the handling of personal information, TEL Group has clarified the employees who handle personal information and the scope of personal information handled by such employees. TEL Group has also established a system for reporting and contacting to the person responsible when the facts or signs of violating the Act on the Protection of Personal Information and related laws and regulations or the internal regulations regarding the handling of personal information have been detected.
(4) Personal safety management measures
TEL Group provides Officers and Employees with regular training on points to note regarding the handling of personal information.
(5) Physical safety management measures
TEL Group takes measures to prevent theft or loss of equipment, electronic media, documents, etc. with personal information, and implements measures to ensure personal information is not easily identified when such equipment, electronic media, etc. are carried around, including when moving within the office.
(6) Technical safety management measures
TEL Group controls access to personal information in order to limit the scope of persons in charge and of personal information databases that are handled.
TEL Group has a mechanism for protecting information systems that handle personal data from unauthorized external access or unauthorized software.
(7) Understanding the external environment
For TEL Group's personal data, we understand the system regarding the protection of personal information in the country where we store based on the information provided by the Personal Information Protection Commission etc. and implement appropriate safety management measures.
9 Claims from Individuals
In case TEL Group receives a claim for disclosure (Including disclosure of records of third party provision), correction, deletion, addition, suspension of use, elimination, or suspension of third party provision (hereinafter referred to as "disclosure") of the retained personal data from the individual, TEL Group will respond to such claim in accordance with laws and regulations to the extent reasonable after verifying the identity of the individual (or its agent).
10 Contact for Inquiries and Complaints
For inquiries or complaints about TEL Group's processing of personal information, please contact below:
Compliance Department, Tokyo Electron Limited
E-mail: tel-kojinjoho@tel.com
11 Individual Policies and Internal Rules etc.
If there are other privacy policies and/or internal rules that are individually applied to each company in TEL Group other than this Privacy Notice, personal information shall be processed based on such privacy policies or internal rules. This Privacy Notice shall be applied to matters that are not stated in such privacy policies and/or internal rules.
Chapter II Processing of Personal Data of Individuals Located in the European Economic Area and United Kingdom
Regarding the processing of personal data of individuals located in the European Economic Area consisting of EU member states, Norway, Iceland and Liechtenstein (hereinafter collectively referred to as the "EEA"), and the UK, the provisions of Chapter II in addition to Chapter I shall apply in accordance with the EU General Data Protection Regulations ("REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC" hereinafter referred to as the "GDPR") and UK GDPR (“Data Protection Act 2018” and UK General Data Protection Regulation which sustains GDPR (hereinafter referred to as “UK GDPR”)). If the contents stipulated in Chapter I conflict with those stipulated in Chapter II, the provisions of Chapter II shall prevail.
For detailed information about the processing of personal data such as the information to be collected, purpose of use, with whom we share, and the way of privacy protection, please refer to the relevant privacy notices by clicking on the links below in addition to read through this Chapter.
| If you are: | Then the applicable privacy notice will be: |
|---|---|
| An Applicant/Candidate for Employment | ・Candidate Privacy Notice |
| Particular individuals or companies intended to promote TEE's products and services | ・Direct Marketing Policy ・TEE’s Privacy Notice |
Note: TEE stands for “Tokyo Electron Europe Limited.”
1 Transfer outside of the EEA or the UK
When TEL Group share personal data or entrust part of its business activities within the extent of the purpose of use, we may transfer personal data to shared users or outsourcing companies for processing by such third parties. Some of these third parties are located in countries outside of the EEA and the UK including Japan. In countries outside of the EEA, the same level of data protection legislation as the EEA and the UK and the rights of individuals recognized within the EEA and the UK are not necessarily guaranteed. Japan has been sufficiently certified by the European Commission and the Government of the UK as having data protection laws at the same level as the EEA and the UK.
2 Change in Purpose of Use of Personal Data
When changing the purpose of use of personal data, TEL Group will post a privacy Notice reflecting the change in purpose of use on TEL Group’s websites in advance:
(English) https://www.tel.com/privacy/
(Japanese) https://www.tel.co.jp/privacy/
3 Claims for Processing of Personal Data
TEL Group will respond to claims regarding personal data of individuals located in the EEA and the UK held by TEL Group within a reasonable period and scope in accordance with relevant laws and regulations, in addition to 9 of Chapter I (Claims from Individuals). We will verify the identity of individual in advance of responding to a claim.
(1) Claims for withdrawal of consent
After confirming the content of your claim, we will delete or suspend the use of personal data to the extent appropriate and possible. Prior to making a claim, please note that the deletion or suspension of use may result in the inability to provide services that were previously available or that meet your requirements.
(2) Claims for data portability
After confirming the content of your claim, we will deliver or receive your desired personal data to the extent appropriate and possible.
(3) Claims for opposition
After confirming the content of your claim, we will suspend the use of your personal data to the extent appropriate and possible.
(4) Method of claims
If you wish to exercise your rights, please contact below:
E-mail：Tee.dpr@europe.tel.com
4 Appeals to Supervisory Bodies
You have the right to object to the data protection authority with jurisdiction over your residence in processing of personal data related to you. The data protection authorities of each country can be found at the following URLs:
List of the data protection authorities
[https://edpb.europa.eu/about-edpb/about-edpb/members_en]
The ICO helplines
[https://ico.org.uk/global/contact-us/]
5 Contact for Data Protection Representative
Data protection representative
E-mail：Tee.dpr@europe.tel.com
Chapter III Processing of Personal Information of Individuals Residing in the United States of America
Regarding the processing of personal data of individuals residing in the United States, the provisions of Chapter III in addition to Chapter I shall apply in accordance with the state privacy requirements. If the contents stipulated in Chapter I conflict with those stipulated in Chapter III, the provisions of Chapter III shall prevail.
1 Acquired Personal Information
The personal information acquired by TEL Group in the past twelve (12) months is listed below. All of these personal information is obtained from the individual or recruitment agency. In addition, the personal information may be obtained from a third party, such as background checks by an outsourcing company.
(1) Personal information of business partners or potential business partners
・Name, company name, department name, address, telephone number, email address, gender and work history
・Information contained in inquiry content and in documents, etc. which were provided for inquiries
・Log information collected from devices for business use (IP address, location, user account information, sign-in log, computer operation log, security alert log, email transmission/ reception log, network log, device log, device event logs, device usage log)
(2)Personal information to be acquired through applications for employment
・Information provided by applicants/candidates; username, password, email address, etc.
・Basic profile information; name, company name, date of birth, telephone number, etc.
・Information necessary to evaluate the applicant/candidate's background; educational background, work history and experience, qualifications, etc.
・Information related to the position that the applicant/candidate applies for; current annual income, desired annual income, etc.
・Information contained in resumes, job application forms and other documents submitted for applicant/candidate selection
・All information related to selection obtained through reference check and other procedures
・All content of any form of communication between TEL Group and the applicant/candidate, including dialogue, communications, telephone inquiries, and other forms of interviews
・Usage information from websites used in the hiring process; login information, login date and time, etc.
・History of employment application and selection result
Some of the sensitive personal information will be acquired according to applicable laws and regulations. The sensitive personal information to be acquired contains listed below:
・Race or ethnicity
・Political view
・Membership in political associations or religious beliefs, factions or beliefs
・Membership in professional associations or business associations, or membership in labor unions
・Genetic or biometric information
・Sexual Orientation or sexual life
・Criminal history
・Information on health management, age and disability
To the extent that applicable laws and regulations allows TEL Group to obtain sensitive personal information, or to the extent that applicants/candidates voluntarily submit it, we will process the information in accordance with applicable laws, regulations and this Privacy Notice.
2 Disclosure to Third Parties
The categories of third parties to which TEL Group disclosed personal information in the past twelve (12) months and the personal information disclosed are as follows.
・TEL Group companies
・All personal information listed in 1 above
3 Sales to Third Parties
TEL Group does not sell personal information to third parties.
4 Claims for Processing of Personal Information
TEL Group will respond to the following claims regarding the personal information of individuals residing in California, U.S.A., held by TEL Group, within a reasonable period and scope in accordance with relevant laws and regulations, as follows:
(1) No more than twice in any 12-month period, requests for disclosure of the following information:
・Categories of Personal Information we collect
・Categories of sources from which Personal Information is collected
・Categories of Personal Information sold or disclosed to third parties
・Categories of third parties with whom such Personal Information is sold or disclosed
・Business or commercial purpose(s) for collecting or selling Personal Information
・Specific items of Personal Information we collect
(2) Request for deletion of your Personal Information, subject to the exceptions provided by law
(3) Opt-out from having your Personal Information sold to third parties, if applicable
We will verify the identity of individual in advance of responding to a claim. In principle, the contents of the service shall not be changed for the individual who made claims. You have the right not to be discriminated against by TEL Group due to exercising your rights. You may also appoint an agent to exercise your rights.
If you wish to exercise your rights, please contact below:
E-mail：telgr-privacyinquiry.us@tel.com
Prior to making a claim, please note that the suspension of use or deletion may result in the inability to provide services that were previously available or that meet your requirements.
Chapter IV Processing of Personal Information of Individuals Residing in the People’s Republic of China
Regarding the processing of personal information of individuals residing in the People’s Republic of China (hereinafter referred to as “PRC”), the provisions of Chapter IV, in addition to Chapter I, shall apply in accordance with the PRC privacy requirements. If the contents stipulated in Chapter I conflict with those stipulated in Chapter IV, the provisions of Chapter IV shall prevail.
1 The Types of Personal Information Processed
(1) Personal information of business partners or potential business partners
・Name, company name, department name, address, telephone number, email address, gender, and work history of employees/contact persons/representatives of business partners or potential business partners (hereinafter collectively referred to as "Business Partners")
・Body temperature, whereabouts and tracks (for the purpose of confirmation of visitors’ health condition to prevent the spread of infectious diseases)
・Log information collected from devices for business use (IP address, location, user account information, sign-in log, computer operation log, security alert log, email transmission/reception log, network log, device log, device event logs, device usage log)
・Other information that can be used to identify Business Partners or reflect their activities
(2) Personal information of applicants/candidates for employment
Basic profile information: name, nationality, address, telephone number, e-mail address, company name, date of birth, age, mobile phone number, marital status, etc.
・Information necessary to evaluate the applicant/candidate's background: educational background, work history and experience, qualifications, etc.
・Information related to the position that the applicant/candidate applies for: current annual income, desired annual income, etc.
・Information contained in resumes, job application forms and other documents submitted for applicant/candidate selection
・Information related to the family members of the applicant/candidate
・All information related to selection obtained through reference check and other related procedures
・Usage information from websites used in the hiring process: username, account number, password, login information, login date and time, etc.
・History of employment application and selection result
・Some of the sensitive personal information will be processed according to applicable laws and regulations, which includes:
・Personal identity information (citizen identity card, passport, social security card, resident certificate)
・Undisclosed criminal records
・Religious belief
・Personal information of applicants/candidates’ children under the age of 14
・Other information that can be used to identify applicants/candidates or reflect the activities of applicants/candidates.
TEL Group may collect, retain, use, process, transmit, provide, disclose, etc., the above personal information based on this Privacy Notice.
Please be noted that if the applicants/candidates submit the employment applications via the WeChat official account of “TOKYO ELECTRON(东电电子)”, the personal information of applicants/candidates will be processed by Tokyo Electron (Shanghai) Ltd., Tokyo Electron (Shanghai) Logistic Center Ltd. and Tokyo Electron (Kunshan) Ltd. in accordance with separate Personal Information Protection Statement rather than this Privacy Notice.
TEL Group will process the sensitive personal information for necessary purposes, and will strive to reduce the adverse impact on personal rights and interests.
TEL Group and third parties mentioned in 2 below may process the personal information through various methods, including but not limited to e-mails, systems, paper/electronic documents, etc.
2 Provision to Third Parties
TEL Group will provide some of the personal information mentioned in 1 above to TEL Group companies and/or following third parties:
| Types of entities/third parties | Purposes |
|---|---|
| TEL Group companies (please refer to[https://www.tel.com/about/locations/] | Purposes mentioned in 2 of Chapter I |
| Government organs, judicial organs, arbitration institutions, notary organs | Fulfilling legal obligations, handling government formalities, tax declaration/tax payment, handling litigation/arbitration, handling notarization procedures |
| Logistic companies, express couriers | Delivering documents, packages |
| Vendors, customers of TEL Group | Performing the contracts with business partners |
| Other third parties | Purposes mentioned in 2 of Chapter I |
3 Provision Outside PRC
Within the extent of purposes mentioned in 2 of Chapter I and 2 above, some of personal information will be provided to TEL Group companies or third parties mentioned in 2 above outside PRC. In such case, TEL Group will take appropriate measures (e.g., execution of standard contracts published by national cyberspace authority of PRC) required by applicable laws to ensure the safety of the personal information.
2 Claims from Individuals
TEL Group will respond to following claims regarding personal information of individuals residing in PRC held by TEL Group within a reasonable period and scope in accordance with applicable laws.
・Claims to access or make copies of their personal information
・Claims for personal information portability if TEL Group is required to provide the personal information subjects concerned a way for exercising their right of portability under applicable laws
・Claims for correction and addition of their personal information
・Claims for deletion of their personal information
・Claims for opposition
・Claims for withdrawal of consent
・Other claims raised in accordance with applicable laws
TEL Group will verify the identity of individuals before responding claims. If individuals wish to raise such claims, please contact below:
E-mail：telgr-privacyinquiry.chn@tel.com
Individuals are also entitled to raise claims against above third parties outside PRC. For claims against such third parties, individuals may raise such claims to TEL Group via the e-mail address above. TEL Group will forward such claims to such third parties outside PRC, but TEL Group cannot guarantee that such third parties will respond to claims.
As per relevant laws, under certain circumstances (e.g., where it is necessary for performing a statutory responsibility or statutory obligation), TEL Group may process the personal information of individuals without their consents. In such cases, even the claims for deletion, opposition or withdrawal of consent are raised, TEL Group may still process their personal information. Please also be noted that these claims may result in the inability to provide services that were previously available or that meet your requirements.
As for the claims for deletion or withdrawal of consent, if the retention period prescribed by applicable laws has not expired, or it is technically difficult to delete the personal information, TEL Group may cease the processing of the personal information, except for the storage and any necessary measure taken for security protection.
Date of last update: Sept 15, 2022
