Privacy Policy

Last modified:  September 30, 2024

Panasonic Connect Co., Ltd., (hereinafter, “we”, “us” or “our”) is committed to ensuring that your “Personal Data” (as explained below) is used fairly, lawfully, and securely and that your privacy is protected at all times. We place high importance on compliance with the applicable privacy and data protection laws and regulations, including, but not limited to the European Union (EU) Regulation 2016/679 General Data Protection Regulation (“GDPR”).

This Privacy Policy is intended to tell you how we “process” (as explained below) information about you ("Personal Data" as explained below) that you provide to us or that we collect through your use of TOUGHBOOK Support Web Site (collectively our “Services”). It also applies if explicit reference is made to it via link or in a similar manner.
This Privacy Policy explains what Personal Data we collect, store, use, disclose and transfer (hereinafter “process”), how we do it, for which purpose and what our legal bases are. It also provides you with information on your rights under the GDPR and how you can contact us if want to exercise your rights or have a complaint.

If you are a California resident, additional privacy notice applies to you, in accordance with the California Consumer Privacy Act. Please see CCPA Appendix below.

Please click on the links below for further information on our privacy practices:

• Information about us
• What is Personal Data?
• What Personal Data do we collect about you and how?
• How do we use your Personal Data (purpose and legal basis)?
• To whom do we disclose your Personal Data?
• What do we do to keep your Personal Data secure?
• Accessing your Personal Data and other rights you have
    What are your rights?
    Exercising your rights
    Complaints
• International Transfers
• Data Retention – How long we will retain your Personal Data?
• Third-party links and products on our Services
• Cookies
• Children's Personal Data
• Changes to this Privacy Policy or to your Personal Data
• Contact Us

1. Information about us

This Privacy Policy is issued by Mobile Solutions Business Division, Panasonic Connect Co., Ltd. (ytv Kyobashi Building, 2-2-33 Shiromi, Chuo-ku, Osaka City, Osaka 540-8553, Japan) on behalf of ourselves and the Panasonic Group of Companies. The Panasonic Group of Companies consists of Panasonic Holdings Corporation, headquartered in Kadoma, Osaka Prefecture, Japan, as well as a number of Affiliates can be found here
      https://www.panasonic.com/global/corporate/profile/group-companies.html#renketsu
In this Privacy Policy, when we refer to “Panasonic”, “we”, “us” or “our”, this means the relevant company in the Panasonic Group that is responsible for processing your Personal Data. For Personal Data gathered via this website, this is Mobile Solutions Business Division, Panasonic Connect Co., Ltd.
 

2. What is Personal Data?

For the purposes of this Privacy Policy, "Personal Data" consists of any information about an individual from which that person can, directly or indirectly, be identified. When we combine other information (i.e. information that does not, on its own, identify an individual) with Personal Data, we treat the combined information as Personal Data.
 

3. What Personal Data do we collect about you and how?

Depending upon your use of this website/our Services, see Section 4 below, and your cookie choices, see Section 11 below, we collect and process some or all of the Personal Data set out in the table below, using the methods and channels also set out in the table.

4. How do we use your Personal Data (purpose and legal basis)?

We process your Personal Data in the context of the activities and for the purposes set out in the table below and rely on one or more of the following the specified legal bases:

•  - Performance of a contract: Where we need to perform a contract which we are about to put in place or have put in place with you as a party, or (at your request) take steps before putting such a contract in place (Art. 6(1)(b) GDPR);
•  - Legal obligation: Where we need to comply with a legal obligation to which we are subject (Art. 6(1)(c) GDPR);
•  - Legitimate interests: Where we are acting in our legitimate interests, provided that they are not overridden by your fundamental rights (Art. 6(1)(f) GDPR). We assess our legitimate interests for processing your Personal Data and balance them against any potential impact on you. Where we rely on our legitimate interests you have the right to object to such processing at any time under the conditions set out in the GDPR; for more information on our legitimate interests or our balancing test please contact us by using the communication means set out in Section 14 below;
•  - Consent: Where we rely on your consent, we will ask for it separately (Art. 6(1)(a) GDPR).

Please note that we do not base any decision solely on automated processing including profiling that significantly affect you or have legal effects for you (Art. 22 GDPR).

5. To whom do we disclose your Personal Data?

We will not disclose your Personal Data to third parties for their own independent marketing or business purposes, unless you have given your explicit consent to do so. However, we may have to disclose your Personal Data to the following entities for the purposes we collected it as set out in Section 4 relying on the legal bases specified therein:

I.    Companies within the Panasonic Group We may need to transfer your Personal Data within the Panasonic Group of Companies to provide the Services you require or any other services/assistance you request. All companies within the Panasonic Group are required to follow the privacy practices set forth in this Privacy Policy, or another privacy policy that they may notify to you and to process your Personal Data in accordance with the applicable privacy and data protection laws and regulations.

II.    Service Providers We use third party service providers who provide information technology and system administration services to us and help us to administer certain activities and services on our behalf and they will operate only in accordance with our instructions as data processors.

III.    Third parties when required by Law or to Protect our Business and Services We will disclose your Personal Data to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies; to protect our customers (e.g. to prevent spam or attempts to defraud users of our Services); to operate and maintain the security of our Services (e.g. to prevent or stop an attack on our systems or networks); to protect the health and safety of our colleagues and others with whom we have contact; or to protect the rights or property of us, including enforcing any terms or agreements governing the use of our Services.

IV.    Other Parties in Connection With Corporate Transactions We may disclose your Personal Data to a third party or within the Panasonic Group of Companies as part of a reorganisation, merger, transfer, sale, joint venture, assignment or other disposition of all or any portion of our business, assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding.

6. What do we do to keep your Personal Data secure?

The security of your Personal Data is of greatest importance to us. We have put in place a range of appropriate physical and technical measures as well as robust policies and processes. The purpose thereof is to safeguard your Personal Data and to protect it against accidental or unlawful destruction or alteration, accidental loss, unauthorized disclosure or access and against other unlawful forms of processing. These measures take into account the state of the art of the technology, the costs of its implementation, the nature of the Personal Data, and the risk of the processing.

Information security, including the protection of Personal Data is organized in our global Program called Information Security Management (“ISM”). The related aim, standards and implementation measures are organized in a globally valid Policy, and further standards and guidelines. The program and all its parts follow a strong yearly Plan-Do-Check-Act (PDCA) approach to secure the confidentiality, integrity and availability of all data (including your Personal Data) for the whole information lifecycle from collection to destruction of such information.
 

7. Accessing your Personal Data and other rights you have

What are your rights?
Your rights under the GDPR include, the right to be informed, the right to access a copy of your Personal Data, the right to request the rectification or the update of any inaccurate Personal Data we hold, and the right to request erasure of your Personal Data.

You also have the right to obtain restriction of the processing of your Personal Data, the right to object to the processing of your Personal Data at any time under the conditions set out in the GDPR, and the right not to be subject to a decision based solely on automated processing.

In addition, you have the right to data portability in certain cases. This is the right to request the return of the personal data you have provided to us in a structured, commonly used and machine-readable format and to request the transmission of such personal data to a third party, without hindrance from us and subject to your own confidentiality obligations.

You also have the right to not provide consent and, where you have consented to our processing of your Personal Data, you have the right to withdraw such consent at any time without this withdrawal affecting the lawfulness of the processing prior to such withdrawal.

Exercising your rights Your rights are further specified in Art. 7 and Chapter 3 of the GDPR and other applicable data protection legislation.
 If you wish to exercise any of the above rights, then please contact us by using the communication means set out in Section 14 below.
Complaints If you are not satisfied with how we process your Personal Data, then please contact us by using the communication means below in Section 14 or alternatively file a complaint with the competent supervisory authority:
 - EEA/EU authorities: Members | European Data Protection Board (europa.eu)
 - United Kingdom (UK): Make a complaint | ICO

8. International Transfers

Where we transfer your Personal Data to recipients located outside of the European Economic Area ("EEA") we ensure that your Personal Data remains protected by transferring it only to countries that offer an adequate level of protection as recognised by the European Commission such as e.g. Japan and the United Kingdom and/or by using the Standard Contractual Clauses approved by the European Commission and where required putting supplementary measures in place to afford your Personal Data with essentially the same level of protection it has in the EEA.

In the same way, if we transfer your Personal Data outside of Serbia, Switzerland, Turkey, or the UK, we will ensure that your Personal Data remains protected in line with the requirements set out in the applicable data protection legislation.

You may request additional information in this respect and obtain a copy of the appropriate safeguards we provide for through sending a request to the contact indicated in Section 14.

9. Data Retention – How long we will retain your Personal Data?

We will only retain your Personal Data for the period necessary to fulfil the purposes for which it has been collected. This includes the purposes of fulfilling our contract with you, satisfying any legal, regulatory, accounting, reporting obligation we are subject to and the establishment and defence of legal claims.
 

10. Third-party links and products on our Services

Our websites, applications and products may contain links to third party websites, plug-ins and applications such as YouTube, LinkedIn and Facebook. These linked websites and applications are not under our control and we are not responsible for their privacy practices or the content of any linked websites and applications. If you choose to use any third party website or application, Personal Data collected by the third party’s website or application will be controlled by the privacy policy of that third party. We strongly recommend that you take the time to review the privacy policies of any third parties to which you provide Personal Data.

11. Cookies

For information on what cookies are, how we and other third parties use cookies and similar technologies, and for details of how cookies can be disabled, please see Cookie Policy of this service site.

12. Children's Personal Data

This Website is not intended for children (anyone under the age of 16 years) and we do not knowingly collect or try to collect Personal Data from or about children.

13. Changes to this Privacy Policy or to your Personal Data

It also is important that you check back often for updates to the Privacy Policy, as we may change it from time to time. The “Date last updated” Section at the top of this page states when this Privacy Policy was last updated and any changes will become effective upon our posting of the revised Privacy Policy.

We will provide additional notice to you if these changes are material by adding a statement to this website or by sending you a notification through any relevant Services or email.

We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you. It is important to us that the Personal Data we hold about you is accurate and up-to-date at all times. If any of the Personal Data we hold about you changes, please keep us informed.

14. Contact Us

If you have any questions regarding the collection, processing, or use of your Personal Data or if you wish to exercise your rights, please contact us at:
Mobile Solutions Business Division, Panasonic Connect Co., Ltd. ytv Kyobashi Building, 2-2-33 Shiromi, Chuo-ku, Osaka City, Osaka 540-8553, Japan

If you have questions about Data Protection in Europe, please contact us at:
Panasonic Europe B.V.
Zweigniederlassung Deutschland Wiesbaden Office
The Data Protection Officer
Hagenauer Strasse 43
65203 Wiesbaden
Germany
or by e-mail: Data_Protection@eu.panasonic.com

Please note that Panasonic Europe B.V. acts as Representative of the data controller (Art. 27 GDPR) if you reside in a member state of the European Economic Area.
If you have any questions about Data Protection in the United Kingdom (UK), please contact us at:
UK Legal Department
Panasonic Europe B.V.(UK branch)
Maxis 2, Western Road,
Bracknell, Berkshire,
RG12 1RT
UK
or by e-mail: UKLegal@eu.panasonic.com

Last modified: September 30, 2024

This CCPA Appendix complements Privacy Policy and tells you what your rights and our obligations are in relation to the processing of your Personal Data in accordance with the California Consumer Privacy Act (the "CCPA").

If there is any discrepancy between the terms of this CCPA Appendix and those of Privacy Policy, this CCPA Appendix will prevail.

We may change this CCPA Appendix from time to time. The "Date last updated" mention at the top of this page states when the CCPA Appendix was last updated and any changes will become effective upon our posting of the revised CCPA Appendix to the extent permitted by applicable laws.

Where required by the CCPA or other applicable law, we will request your consent to any such changes. We will provide the revised CCPA Appendix by email or by posting notice of the changes on our website or through any relevant Services.

Please click on the links below for further information on our privacy practices for residents in California:

1. What is Personal Data?
2. What Personal Data do we collect about you?
3. On which legal basis do we process Personal Data?
4. What are your rights and how can you exercise them?
5. Disclosure of Personal Data
6. Sale of Personal Data
7. Share of Personal Data
8. Children’s Personal Data
9. Contact Information

1. What is Personal Data?

For the purposes of this CCPA Appendix, "Personal Data" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. For example, Personal Data includes, but is not limited to, audio, electronic, visual, thermal, olfactory, or similar information or inferences drawn from other Personal Data to create a profile about you reflecting your preferences, characteristics, psychological trends among other things.

For the purposes of this CCPA Appendix, "Sensitive Personal Data" means (1) personal information that reveals: (A) your social security, driver’s license, state identification card, or passport number; (B) your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (C) your precise geolocation;(D) your racial or ethnic origin, religious or philosophical beliefs, or union membership; (E) the contents of your mail, email, and text messages unless we are the intended recipient of the communication; and (F) your genetic data; and (2)(A) the processing of biometric information for the purpose of uniquely identifying you; (B) personal information collected and analysed concerning your health; and (C) personal information collected and analysed concerning your sex life or sexual orientation.

2. What Personal Data do we collect about you?

The table below describes the categories of your Personal Data that we may collect, and has collected during the 12-month period prior to the effective date of this CCPA Appendix. We will retain your Personal Data for the period necessary to fulfil the purposes for which it has been collected. This includes the purposes of fulfilling our contract with you, satisfying any legal, regulatory, accounting, reporting obligation we are subject to and the establishment and defense of legal claims.

Business or Commercial Purposes.
We may collect or use, or have collected your Personal Data during the 12-month period prior to the effective date of this CCPA Appendix for the following business or commercial purposes. We do not use or disclose your Sensitive Personal Data for purposes other than those specified in CCPA. We do not collect or process your Sensitive Personal Data for the purpose of inferring characteristics about you.
  - Provision of functions necessary for our services
  - Our website usage analysis
Categories of Sources.
The following is a list of the categories of sources from which your Personal Data was collected during the 12-month period prior to the effective date of this CCPA Appendix:
  - Obtained directly from the customer
  - Collected from Internet service providers

3. On which legal basis do we process Personal Data?

We process Personal Data of residents in California in compliance with the CCPA. If we are to use your Personal Data for purposes other than the purposes we notified on or before collecting your Personal Data, we will notify the new purposes to you and obtain your express consent.

4. What are your rights and how can you exercise them?

A. What are your rights?

(1)Your rights under the CCPA include, the right to know about your Personal Data that we collect, use, the right to delete your Personal Data, the right to correct your Personal Data.

(2)We will not unreasonably discriminate against you for exercising the rights such as the right to know about Personal Data information under the CCPA by using methods including but not limited to the following:

• I.    Denying to provide goods or services to you
• II.    Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties
• III.    Providing a different level or quality of goods or services to you
• IV.    Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services

B. Exercising your rights (right to know, right to delete, and right to correct)

If you wish to exercise the right to know, the right to delete, or the right to correct under the rights of A(1) above, please contact us by using the following means in addition to the communication means described in Privacy Policy. Upon receiving your request to exercise such rights, we will require you to submit your name and e-mail address in order to verify your identity.

I.    By telephone (Toll-free telephone number)
       +1-855-772-2891
II.    By online request form
       https://na.panasonic.com/us/ccpa-privacy-request

We will confirm receipt of your requests to exercise your rights within 10 business days in the same manner in which the request was received and provide information about how we will process the request and the limit of our response. We will respond to requests to know and requests to delete and requests to correct within 45 days, and if we exceed the period, we will notify you and respond within 90 days from the day that we receive the requests. If we cannot verify your requests within the 45-day time period, we may not process your requests.

We will record your requests and store them for 24 months.

If you use an authorized agent to submit a request to know or a request to delete, the authorized agent is required to submit to us a written permission proving the authorized agent is permitted to do so and the authorized agent’s own identity verification document(s).
 

5. Disclosure of Personal Data

We have not and will not disclose your Personal Data to any third party for a business purpose.

6. Sale of Personal Data

We have not and will not sell your Personal Data to any third party.
For the purposes of this CCPA Appendix, "sell" means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, your Personal Data by us to a third party for monetary or other valuable consideration.

7. Share of Personal Data

We have not and will not share your Personal Data with any third party.
For the purposes of this CCPA Appendix, “share” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, your Personal Data by us to a third party for cross-context behavioural advertising, whether or not for monetary or other valuable consideration.

8. Children’s Personal Data

We do not sell or share Personal Data of anyone under the age of 16.

9. Contact Information

You may contact us with questions or concerns about this CCPA Appendix and your choices and rights under CCPA at:
Company name: Mobile Solutions Business Division, Panasonic Connect Co., Ltd.
Company address: ytv Kyobashi Building, 2-2-33 Shiromi, Chuo-ku, Osaka City, Osaka 540-8553, Japan