Privacy Policy

Introduction

Mutoh America Corporation (hereinafter referred to as “MAC” or “we”/ “our”/ “us”) recognizes that the personal information it receives is held in a position of trust. MAC seeks to fulfill that trust by adhering to general principles regarding the privacy protection. This Privacy Policy describes how we collect, use, share and protect information in the course of operating our business.

Scope

This Privacy Policy ((hereinafter referred to as “Policy”) applies to the personal information of consumers that is collected or used by MAC. This Policy applies to all the personal information that MAC collects when consumers interact with us, such as when visiting our websites, purchasing or using our products or services, contacting customer service and when interacting with us as a business customer, supplier or business partner (collectively, the “Services”). This includes, without limitation, all online and offline collections of all types of personal information.

Collection of Personal Data 

1.     Collection of Personal Data

MAC collects personal data such as customer's name, address and contact information in order to provide products and services to customers. In the course of collecting Personal Data from you, we will clearly indicate the purpose of collection and the scope of usage of the Personal Data, and collect Personal Data only to the extent necessary.  Your submission of Personal Data to us is not a requirement of or condition to the execution of any contract between you and MAC, and you are under no obligation to provide Personal Data to us.  Your failure to provide personal data to us will not adversely affect you. 

2.     How we collect Personal Data

In the course of transactions involving our products and services, MAC may collect Personal Data through the following ways:

1)     Directly from you
Orally, in writing, by telephone, on business cards, or via the Internet

2)     From people duly authorized by you
Such authorized persons may include those authorized to apply for our products or service on behalf of you or to introduce a customer, and medical institute persons

3.     Types of Personal Data Collected by MAC

MAC may collect the following Personal Data.

1)     Basic information about you, such as:
Name, home address, email address, telephone number, facsimile number, and credit card number

2)     Additional information about you, such as:
Occupation, workplace information (workplace name, address, telephone number, department, title)

3)     Details of communications with MAC, such as:
Information contained in emails, fax transmissions, or letters; or provided to us using our website data entry form or as answers to surveys

4)     Information automatically obtained by websites of MAC
Cookies, IP address, browser type, and date and time of access

5)     Information required by instructions or directives issued by the relevant authorities or by law, regulations, ordinances, etc.

6)     Information that can be linkable to your household (If CCPA applies)

In cases that CCPA applies, personal data collected, disclosed or shared during the past 12 months for business purposes are among the categories described in (1) through (6) above.

For each of the above categories of personal data, the source of the personal data, the commercial purpose of the collection, and the scope of the provision or joint use of the personal data are as follows:

If CCPA applies and MAC uses Personal Data in categories other than those listed in this Privacy Policy, or uses Personal Data in categories listed in this Privacy Policy for purposes other than those set forth in this Privacy Policy In such cases, MAC shall first take the necessary steps to comply with this Privacy Policy and then use the Personal Data in accordance with such use after changing or updating this Privacy Policy.

Legal Bases for Using Your Personal Information 

There are different legal bases that we rely on to use Personal Information, namely:

  • Performance of a Contract - The use of Personal Information may be necessary to perform the contract that you or your organization has with us or to take steps at your request prior to entering into a contract with you or your organization. For example, where you work for us either as an employee or a service provider or apply for a job with us, your Personal Information will be necessary in connection with your contract of employment or services agreement or for the possibility of entering into a contract with us. If you are a consumer or a user of our services, we will use your Personal Information to carry out our obligations under the contract that we have with you. We similarly process patient-related Personal Information from our customers and representative information from our customers, suppliers and business partners to fulfill our contracts with those organizations.

  • Consent – We will rely on consent, which, in some cases, may be implied, to use: (i) technical information, such as cookie data, as described in this Policy; and (ii) Personal Information for certain marketing purposes. Where we would like to use Special Personal Information, like health information that we collect from you, we will only do so with your explicit consent if required by law, unless we have an obligation under employment law. You may withdraw your consent at any time by contacting us at the addresses at the end of this Policy. We may obtain certain Personal Information and Special Personal Information about you from healthcare professionals (including hospitals, medical scanning facilities or similar healthcare providers or one of their representatives) that use our products and services, in which case they are responsible for obtaining and handling any required consents or for having another legitimate basis for processing such information.

  • Legitimate interests – It is in our legitimate interests to process Personal Information in order to improve our products, services, perform administrative tasks, communicate with you, including the delivery of marketing communications with users and patients (and where consent is not required by applicable law), customize and personalize content for users, identify and authenticate you, secure our systems and information, conduct research, and develop new products. It is also in our legitimate interests to protect the legal rights, safety, and security of MAC, and our business partners; to respond to and resolve claims or complaints; to prevent fraud; and to manage risks associated with our business. For more information about the balancing test that we carry out to process your Personal Information to meet our legitimate interests, please contact us using the details below.

  • Public interest – In limited circumstances, including, in some cases, complaint handling, we may process your information, including sensitive Personal Information, for reasons of public interest in the area of public health. In particular, MAC may process your information in connection with efforts to ensure high standards of quality and safety for medical devices.

  • Legal Obligations - We may use personal information to comply with legal obligations to which we are subject. For example, we may disclose personal information to law enforcement agencies in order to comply with regulatory reporting requirements for medical devices or in accordance with legal process.  

Cross-Border Transfers

To the extent personal information is transferred out of the country where the owner of that personal information lives, such as to MAC affiliates or business partners in other countries, including in the United States, different standards may apply to how your data is used and protected in those countries. MAC has appropriate safeguards in place in accordance with applicable legal requirements to ensure that data is adequately protected irrespective of the country. This includes obtaining written assurances from any third party given access to your data so as to require them to adopt standards that ensure an equivalent level of protection for data as that adopted by MAC and standardized corporate safeguards and contractual measures (based on the European Commission's model clauses) for internal data transfers to MAC affiliates in third countries that are determined to have inadequate levels of data protection.

Disclosure of Information

MAC does not share your personal information with unaffiliated third parties for their own direct marketing purposes.

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Privacy Policy for Children

MAC will not collect personal information from anyone we know to be under the age of 16 without the prior, verifiable consent from his or her legal representative. Such legal representative has the right, upon request, to view the information provided by the child and/or to require that it be deleted. 

Retention of Information

MAC will retain your personal information for as long as reasonably necessary to comply with legal obligations or for no longer as required for legitimate business purposes. 

Security

The security and confidentiality of your personal information is important to us. To this reason, MAC has put in place physical, technical, and managerial controls to protect your personal information from unauthorized access, use, or disclosure, and MAC continually evaluates these safeguards to minimize risk as new security threats are identified. 

Rights

You may request details of personal information which we hold about you. If you believe that any personal information we are holding about you is incorrect or incomplete, please contact us as soon as possible, at the address below. We will promptly correct any personal information found to be incorrect.

You may always choose to object to the collection or use of your personal information or to have your information erased. If you would like a copy of the information held about you for your own use or to transfer to another party, or if you wish to exercise any other right, please contact us at info@mutohusa.co.jp .

Updates to Privacy Policy

This Policy may be amended at any time. If material changes are made in how personal information is collected, used, disclosed or otherwise processed, this Policy will be updated, and notices will be provided when/where appropriate. Any material changes to this Policy will be effective at the time of our posting of the notice of the update. Where required to do so by law, MAC may seek your prior consent to any material changes we make to this Privacy Policy.

Contact for Inquiries and Complaints

MAC has established a customer service desk to respond to your inquiries, comments, and complaints regarding your Personal Data collected and kept by MAC.  After conducting the required verification of your identification or the identification of your agent, we will provide a response that we determine in good faith to be reasonably necessary. Please note that depending on the inquiry, comment, or complaint, it may take some time for us to provide a response.

MAC Personal Information Center

Personal Data Controller and Data Protection Officer

Mutoh America Co., Ltd.

TEL: +1-508-907-6012

info@mutohusa.co.jp

If we do not respond to you in writing within a reasonable period of time, or if you are dissatisfied with the response you receive from us, you may file a complaint with the data protection authority in your home country.

Last Updated December/2020