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1. Definition of Personal Data
Under the PDPA, PIPA and PDPO, personal data refers to any data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organization has or is likely to have access. Common examples of personal data could include names, identification numbers, contact information, medical records, photographs and video images.
MAP will collect personal data in accordance with the PDPA to the extent the personal data is collected in Singapore, the PIPA to the extent the personal data is collected in Taiwan and the PDPO to the extent the personal data is collected in Hong Kong. In this regard, MAP will ensure that it notifies any individual from whom MAP collects personal data of the purposes for which their personal data may be collected, used, disclosed and/or processed, as well as obtain that individual’s consent for the collection, use, disclosure and/or processing of that individual’s personal data for the intended purposes, unless an exception under the law permits MAP to collect, use, disclose and/or process such personal data without consent.
2. Collection of Personal Data
MAP may collect personal data to the extent necessary for MAP to conduct its business activities. MAP also collects personal data provided by customers through inquiries, requests and complaints made to the Company.
When the personal data of customers and/or trade partners is directly collected in writing, such as through a screen on an Internet web page, MAP will first notify the customers and/or the trade partners of the purposes for which the personal data is being collected, used, disclosed and/or processed; the persons to whom personal data may be transferred; the personal data’s retention period; and the rights of the persons from whom personal data is being collected such as the right to access and correct their personal data, while at the same time providing them with the contact information of the person he should contact within MAP for such purposes.
For personal data collected or from information available in the public domain, MAP will ensure that it takes reasonable steps and adopts the appropriate procedure to ensure that the collection of personal data from the aforementioned sources is performed lawfully and validly.
3. Purposes For Collection, Use, Disclosure and Processing of Personal Data
Where MAP collects personal data directly from its customers and trade partners, MAP shall only use, disclose and process the personal data for the purposes which would have been notified to such customers and/or trade partners prior to the collection of the personal data.
Where personal data is collected by MAP through methods other than the above, MAP will collect, use, disclose and process the personal data, depending on the circumstances, for any of the following purposes:
- Providing the individual with information concerning the Mizkan Group, including information on products, sales campaign and events offered or organized by the Mizkan Group1;
- Sending or offering gifts and other products and services on behalf of concerned parties (the personal data of the person designated as the delivery address will be used for the purpose of shipping and offering.);
- Contacting winners in a campaign co-sponsored with a supermarket and shipping prizes to them;
- Handling inquiries and complaints relating to Mizkan Group’s products;
- Administering questionnaires and surveys for the development and/or improvement of Mizkan Group’s products;
- Sending congratulatory or condolence messages;
- Facilitating the completion or confirmation of transactions and other business activities;
- Sending business correspondence;
- Sending you marketing information about the products and services of MAP or those of carefully selected third parties, and carrying out research and statistical analysis of marketing data, provided you have indicated that you do not object to being contacted for these purposes and/or
- Anonymizing personal data and conducting data analytics activities.
(collectively, the “Purposes”)
If MAP intends to use, disclose and/or process the personal data for a purpose that has not been set out above, or which has not been notified to the individual, MAP will contact the individual for approval in advance. MAP will not use, disclose and/or process the personal data for a new purpose without the individual’s consent unless MAP is permitted to do so under any law.
In order to conduct MAP’s business operations more smoothly, MAP may also be disclosing the personal data provided to MAP to MAP’s affiliates or related corporations, whether sited in Singapore/Taiwan/Hong Kong, or outside of Singapore/Taiwan/Hong Kong, for one or more of the above-stated Purposes. MAP’s affiliates and/or related corporations to whom MAP will share the personal data with as mentioned above are as follows:
• Mizkan Holdings Co., Ltd.;
• Mizkan J plus Holdings Co., Ltd.;
• Mizkan Co., Ltd.;
• Mizkan Partners Co., Ltd.;
• Mizkan Logitec Co., Ltd.;
• Nakano Sumise Co., Ltd.;
• Mizkan Asset Co., Ltd.;
• ZENB JAPAN Co., Ltd.;
• Nakano Forest Co., Ltd.;
• Mizkan America Holdings, Inc.;
• Mizkan America, Inc.;
• Mizkan America Partners, Inc.;
• ZENB US, Inc.;
• Mizkan Euro Holdings Limited;
• Mizkan Euro Ltd.;
• Mizkan Euro Partners Limited; and
• ZENB UK Ltd.
• Mizkan China Co., Ltd.
The personal data that will be shared with the parties above will include the name, address, telephone number, gender, birthday, email address and other personal data of the individual.
4. Control and Protection of Personal Data
MAP will store and hold personal data under appropriate and strict controls to prevent the unauthorized disclosure of the personal data. MAP will take appropriate and reasonable level of safety measures to ensure that personal data in MAP’s possession or under MAP’s control is adequately protected against any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration.
MAP will also put in place measures such that any personal data in MAP’s possession or under MAP’s control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
MAP may outsource the processing and handling of personal data to a subcontractor. In such cases, MAP will take appropriate measures, such as entering into the necessary contracts, to ensure that the subcontractor processes and handles the personal data under appropriate and strict controls and puts in place a similarly reasonable level of safety measures to ensure that the personal data in its possession and/or under its control is adequately protected.
5. Provision of Personal Data to Third Parties
MAP will not disclose or provide personal data from customers and/or trade partners to third parties except where:
- The customers and/or trade partners have agreed to the disclosure and provision of personal data to such third parties;
- The handling of personal data is outsourced to a subcontractor for one of the abovementioned Purposes, or for any other purpose that the customer and/or trade partners have been informed of and provided their consented to.
- The personal data has been anonymized and is no longer capable of identifying any individuals either by itself or in conjunction with any information to which the third parties has or is likely to have access to;
- MAP is under a legal, statutory or regulatory obligation to disclose or provide such personal data to such third parties.
6. Accuracy of Personal Data
MAP will take reasonable efforts to ensure that personal data collected by it is accurate and complete, if such personal data is likely to be used by MAP to make a decision that affects the individual to whom it relates, or disclosed to another organization. However, this means that the individual to whom the personal data relates is required to notify and update MAP of any changes in his/her personal data. MAP will not be responsible for relying on inaccurate or incomplete personal data which is a result of the failure of the individual to whom the personal data relates to notify and update MAP of any changes in his/her personal data.
8. Cross-Border Transfer of Personal Data
In the event that MAP transfers personal data out of Singapore, Taiwan or Hong Kong where the individual is living, MAP will comply with the PDPA, PIPA and/or PDPO (as applicable) in doing so. In this regard, this includes MAP obtaining the consent of the individual to whom the personal data relates unless an exception under the PDPA, PIPA and/or PDPO (as applicable) applies, and taking appropriate steps to ascertain that the foreign recipient organization of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to the protection under the PDPA, PIPA and/or PDPO (as applicable).
9. Complaints and Other Personal Data Related Requests
Individuals who wish to submit a complaint, query or request to access, correct, update or withdraw the consent to the continued use, disclosure and/or processing of his/her personal data may do so by contacting MAP at the following. If the individual is in Taiwan, he/she also has the right to request a copy of, supplement, demand the cessation of the collection of, and erase his/her personal data, which may also be exercised by contacting MAP:
- Chief Officer for Personal Data Protection: Director
- Mizkan Asia Pacific Pte.Ltd.
Location: No.2 Pioneer Sector Lane Singapore 628321
Tel:+65 6861 6063
- Mizkan Asia Pacific Pte.Ltd. Taiwan Branch
Location: 10th Fl., 80 Sung Chiang Road, Taipei, Taiwan, R.O.C
Tel: +886 2 2511 5975
- Mizkan Asia Pacific Pte.Ltd. Hong Kong Branch
Location: Unit No.801-802, 8th Floor, Tower One, Ever Gain Plaza, No.88
Container Port Road, Kwai Chung, New Territories, Hong Kong.
Tel: +852 3579 5519