TOPPAN Digital Language Customer Privacy Data Policy

1. PURPOSE OF NOTICE

1.1 TOPPAN Digital Language Ltd. and its subsidiaries, doing business as TOPPAN Digital Language, (“we”, “our”, “us”, “the Company”) is committed to protecting the privacy and security of your personal information.

1.2 This privacy notice describes how we collect and use personal information about you during and after your working relationship with us as a customer (or contractor to, or employee or representative of a customer) of the Company (“Customer Parties”), in accordance with the UK General Data Protection Regulation (UK GDPR). We may update or amend this notice at any time.

1.3 This notice does not apply to circumstances where we act as Data Processor on behalf of a customer.

2. DATA PROTECTION PRINCIPLES

2.1 The Company is a “data controller”. This means that we are responsible for how we hold and use personal information about you.

2.2 We will comply with data protection law. This says that the personal information we hold about you must be:

2.2.1 Used lawfully, fairly and in a transparent way;

2.2.2 Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;

2.2.3 Relevant to the purposes we have told you about and limited only to those purposes;

2.2.4 Accurate and kept up to date;

2.2.5 Kept only as long as necessary for the purposes we have told you about; and

2.2.6 Kept securely.

3. THE KIND OF INFORMATION WE HOLD ABOUT YOU

3.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

3.2 Certain types of personal data require extra protection, such as information about a person’s health (“special categories” data). Information about criminal convictions also requires additional protection.

3.3 We will collect, store, and use the following categories of personal information about you and the basis for processing each is identified below:

4. HOW IS YOUR PERSONAL INFORMATION COLLECTED?

4.1 We collect personal information about Customer Parties when it is supplied to us through our working relationship with you.

5. HOW WE WILL USE INFORMATION ABOUT YOU

5.1 We will only use your personal information when the law allows us to. We will generally use the personal information set out in the table in section 3 for the following purposes:

5.1.1 To perform our contract with you (meaning the company you represent);

5.1.2 To enable us to comply with a legal obligation;

5.1.3 Where it is necessary for our legitimate interests (or those of a third party) and your interests and rights do not override those interests.

5.2 We may also use your personal information in the following (probably rare) situations:

5.2.1 Where we need to protect your interests (or someone else’s interests).

5.2.2 Where it is needed in the public interest.

6. SITUATIONS IN WHICH WE WILL USE YOUR PERSONAL INFORMATION

6.1 The situations in which we will process your personal information are listed below. We have indicated in the table the purpose or purposes for which we are processing or will process your personal information.

6.2 Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

7. IF YOU FAIL TO PROVIDE PERSONAL INFORMATION

7.1 If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with the customer (such as providing a benefit)

8. CHANGE OF PURPOSE

8.1 We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis for doing so.

8.2 We may process your personal information without your knowledge or consent where this is required or permitted by law.

9. DATA SHARING

9.1 We may have to share your data with third parties, including third-party service providers where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so

9.2 We require third parties to respect the security of your data and to treat it in accordance with the law.

9.3 We may transfer your personal information outside the UK or the EU.

9.4 If we do, you can expect a similar degree of protection in respect of your personal information.

9.5 Which third-party service providers process my personal information?

“Third parties” includes third-party service providers (including contractors and designated agents). The following activities are or are likely to be carried out by third-party service providers: IT services, legal advice, auditing and administration.

9.6 How secure is my information with third-party service providers?

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

9.7 What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.

We may also need to share your personal information with a regulator or to comply otherwise with the law.

10. Transferring information outside the UK or the EU

10.1 We will transfer personal information we collect about you to our group companies and servers/hosting partners located in the UK, EU and USA. There are GDPR adequacy regulations in place in respect of the UK and EU but there are no GDPR adequacy regulations in respect of the USA. This means that the USA is not deemed by the UK and EU GDPR to provide an adequate level of protection for your personal information (except in limited circumstances) unless specific safeguards are put in place.

10.2 To ensure that your personal information does receive an adequate level of protection, we have put in place a data protection agreement which includes EU GDPR model clauses as well as provisions UK International Data Transfer Agreement provisions governing the transfer of data between our corporate entities and we are only entering service agreements for hosting or other services with Supplier Parties outside the UK and EU where EU model clauses or an IDTA forms part of the contract.

10.3 If you require further information about this you can request it from privacy@toppandigital.com.

11. DATA SECURITY

11.1 We have put in place measures to protect the security of your information. Details of these measures are available upon request from privacy@toppandigital.com.

11.2 Third parties will be required by us to only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

11.3 We have put in place appropriate security measures to protect your personal information and we limit access to your personal information on a need to know basis. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

DATA RETENTION

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal information to another party

Complain to the Information Commissioner’s office in the UK if you believe we have breached our obligations in respect of your data.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact privacy@toppandigital.com in writing.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).

Right to withdraw consent

If you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact privacy@toppandigital.com. If you inform us that consent is withdrawn, we will no longer process your information for the original purpose unless we have another legitimate basis for doing so.

CHANGES TO THIS PRIVACY NOTICE

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact privacy@toppandigital.com.