Last Revision Date: January 1, 2024
We are Nikon Precision Inc. (hereinafter “NPI”) with headquarters located at 1399 Shoreway Road, Belmont, CA, 94002. We are part of the Nikon Group. We are responsible for the collection and use of your personal data described in this privacy notice. References to “Nikon”, “we” and “our” throughout this notice, depending on the context, collectively refers to NPI.
We have determined our respective responsibilities for compliance with the obligations under applicable privacy legislation for processing your personal data in relation to our global processing activities by means of an arrangement between us. In summary, we have arranged that if you want to exercise your rights, such as your right to access, correct, erase, restrict, object or port personal data or to withdraw your consent, or if you have any questions about the processing of your personal data, you can contact NPI in accordance with Section 9, below. NPI and its affiliate entities, such as Nikon Americas Inc. and Nikon Corporation, will assist each other where necessary to ensure that you can exercise your rights and your questions will be properly addressed.
We have outlined our data processing operations and the purposes for which we process your personal data in “Section 2.1—Overview of NPI processing activities” below. In summary, we use various systems to deliver products and services to you. For example, NPI provides the following products and services: End Customer Administration, Vendor Management, Recruitment, and Marketing.
2.1 Overview of NPI processing activities
NPI collects personal data only to the extent that is adequate, relevant, and necessary to the stated purpose of collection, and will do so in a lawful and fair manner. Such lawful purposes include, but are not limited to:
| Processing operation | Categories of Personal Data | Purpose of Processing | Recipients |
|---|---|---|---|
| End Customer Administration | Name; Address; Country; Email; Location data; Postal Code; Phone number; & Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or customer histories | End customer administration; Contract execution; Compliance with law; Manage customer relationship and respond to inquires; Evaluate, develop, & improve products & services | Nikon Group entities; IT service & data storage providers |
| Vendor Administration | Name; Address; Country; Email; Location data, Postal Code, Phone number | Vendor Administration, Compliance with law, Contract execution, Vendor management | Nikon Group entities; IT service & data storage providers |
| Recruiting | Name; Address; Country; Email; Phone number; Resume information; Other Professional or employment-related information | Recruiting, including evaluations of qualifications for possible employment or internship possibilities & employee onboarding | Nikon Group entities, IT service & data storage providers; Recruiting agencies & service providers |
| Marketing | Name; Address; Country; Email; Phone number; Company; Business Card Info | Marketing, including providing information & advertisements about Nikon products & services | Nikon Group entities; IT service & website providers; Direct marketing service providers |
2.2 Legal basis
NPI processes your personal data to provide our products and services to you, to comply with our legal obligations, if necessary, for our legitimate business interests or interests of a third party, or on the basis of your consent.
When we process your personal data for our legitimate interests or the interests of a third party, we will take reasonable measures to prevent unwarranted harm to you. Our legitimate interests include, for example, our interest of improving our product and services by storing contact details, reducing our costs, improving our newsletters and websites by analyzing which parts of our communications are most relevant for you or of securing our services and facilities, such as the purposes mentioned in “Section 2—What personal data we collect and why.” Where we process your personal data for our legitimate interests or the interests of a third party, you have the right to object at any time on grounds relating to your particular situation (please see “Section 7—Your rights,” below).
You can withdraw your consent at any time by following the specific instructions in relation to the processing for which you provided your consent, by adjusting your setting (if available), or by reaching us through the contact details in “Section 9—Contact details,” below, for your privacy inquiries. Where we process your personal data for a purpose other than that for which it was initially collected (and we rely on a legal basis other than consent or complying with legal obligations for this new purpose), we will ascertain whether processing for this new purpose is compatible with the purpose for which the personal data were initially collected. More information on this assessment is available upon request (please see “Section 7—Your rights,” below).
Most of the personal data we process is information that you knowingly provide to us directly or through third parties. However, in some instances, we process personal data that we are able to infer about you based on other information you provide to us or from our interactions with you, or personal data about you that we receive from a group company or a third party with your knowledge (please see “Section 4—Information sharing,” below, and “Section 2—What personal data we collect and why,” above).
If you refuse to provide personal data that we require for the performance of the contract or compliance with a legal obligation, we may not be able to provide all or parts of the services you have requested from us.
We will process some of your personal data locally. However, as a global organization, many of our business activities can also be carried out (and business efficiencies achieved) by processing or consolidating information about you in specific or centralized databases and systems located at specific secured facilities worldwide. As a result, your information may be shared with other entities within the Nikon Group. However, each Nikon Group company and those other systems and databases will only collect, receive, use, share or otherwise process such personal data in accordance with applicable laws, this privacy notice, our Nikon Group Privacy Protection Statement www.nikon.co.jp/main/eng/privacy_policy.htm. Moreover, internally we maintain a strict access policy with regard to the processing of personal data. Only a limited group of authorized Nikon staff on a need to know basis will have access to your personal data.
As a general rule, we do not share your personal data with anyone outside the Nikon Group. However, we may share your personal data with trusted third parties that perform business functions or provide services to us. All such third parties will be required to adequately safeguard your personal data, subject to agreements that correspond to the requirements of applicable laws. Your personal data may also be shared for investigations (e.g. disclosure to prevent crime or fraud, or to comply with a court order or legislation).
NPI will secure your personal data in accordance with our information technology (IT) and security policies so that personal data are protected against unauthorized use, unauthorized access and wrongful modifications, loss or destruction. Your personal data will be stored no longer than is necessary for the purpose they were obtained, including compliance with legal and fiscal obligations and for solving any disputes.
Given the global nature of our company, your personal data may be transferred to Nikon Group entities and trusted third parties in countries whose laws may not afford the same level of protection of your personal data. Where necessary, NPI will ensure that adequate safeguards are in place to comply with the requirements for the international transfer of personal data under applicable privacy laws. For more information about transfers of personal data within the European Economic Area, please see our European Union Privacy Policy https://www.nikonprecision.com/privacy-europe/.
You can contact us using the information provided in “Section 9—Contact details for your privacy inquiries,” below to exercise any of the rights you are granted under applicable data protection laws. This includes the rights to: (1) access your data, (2) rectify your data, (3) erase your data, (4) restrict the processing of your data, (5) receive a file of your personal data, and (6) object to the processing, and where we have asked for your consent, withdraw this consent. These rights will be limited in some situations. For example, we may deny your request for access when necessary to protect the rights and freedoms of other individuals or in case the processing of such data is necessary for compliance with legal obligations. As an additional example, the right to data portability does not apply in case the personal data was not provided by you or if we process the data not on the basis of your consent or for the performance of a contract.
When you would like to exercise your rights, please send your request to the contact details as set forth in “Section 9—Contact details for your privacy inquiries,” below. Please note that we may need you to provide additional information to confirm your identity. You also have the right to lodge a complaint with the local applicable authority. You can also contact us if you have any questions, remarks or complaints in relation to this privacy notice.
7.1 Right to access
You may ask us whether or not we process any of your personal data and, if so, receive access to that data in the form of a copy. When complying with an access request, we will also provide you with additional information, such as the purposes of the processing, the categories of personal data concerned as well as any other information necessary for you to exercise the essence of this right.
7.2 Right to rectification
You have the right to have your data rectified in case of inaccuracy or incompleteness. Upon request, we will correct inaccurate personal data about you and, taking into account the purposes of the processing, complete incomplete personal data, which may include the provision of a supplementary statement.
7.3 Right to erasure
You also have the right to have your personal data erased, which means the deletion of your data by us and, where possible, by any other controller to whom your data has previously been made public by us. However, the right to erasure of your personal data only applies in certain limited circumstances cases, as prescribed by applicable law. For example, the right to erasure includes situations where your personal data are no longer necessary in relation to the initial purposes for which they were processed as well as situations where they were processed unlawfully. Due to the way we maintain certain services, it may take some time before backup copies are erased.
7.4 Right to restriction of processing
You have the right to obtain the restriction of the processing of your personal data, which means that we suspend the processing of your data for a certain period of time. Circumstances which may give rise to this right include situations where the accuracy of your personal data was contested but some time is needed for us to verify their (in)accuracy. This right does not prevent us from continue storing your personal data. We will inform you before the restriction is lifted.
7.5 Right to receive your file (data portability)
Your right to data portability entails that you may request us to provide you with your personal data in a structured, commonly-used and machine-readable format and to have such data transmitted directly to another controller, where technically feasible. Where technically feasible, we will transmit your personal data directly to another controller upon your request.
7.6 Right to object
You also have the right to object to the processing of your personal data, which means you may request us to no longer process your personal data. This only applies in case the ‘legitimate interests’ ground (including profiling) constitutes the legal basis for processing (please see “Section 2— What personal data we collect and what we do with your data,” above).
At any time and free of charge you can object to direct marketing purposes in case your personal data are processed for such purposes, which includes profiling purposes to the extent it is related to such direct marketing. In case you exercise this right, we will no longer process your personal data for such purposes.
We will update this privacy notice from time to time with notice of any substantive changes. This version of our Privacy Policy replaces any previous versions.
For privacy-related questions, concerns, or requests, please use one of the following contact options:
Email: NPI-Privacy@nikon.com
Toll Free: 1-800-44-NIKON (1-800-446-4566)
Mailing: Nikon Precision Inc.
ATTN: Privacy Team
1399 Shoreway Road
Belmont, California 94002, U.S.A.