This Privacy Notice explains what personal data may be processed by Iwatani Corporation of America or its affiliates (‘ICA’ or ‘we’) about you, why we are processing your personal data and for which purposes, how long we store your personal data, how to access and update your personal data, as well as the options you have regarding your personal data and where to go for further information.
What does this Privacy Notice cover?
This Privacy Notice provides information regarding the following personal data in relation to:
Applicants: Individuals who apply to work for, or who attend a recruitment event or undertake an assessment with ICA. This includes prospective employees, interns and contractors (‘Applicants’);
ICA Staff: individuals who are or were employees, interns or individual contractors as well as dependents of ICA employees (‘ICA Staff’);
Customers: Individuals who are retail energy customers or visitors to an ICA website (‘Customers’);
Business Customers: Individuals who work for, or on behalf of, or who are shareholders of our business customers (‘Business Customers’);
Suppliers: suppliers or vendors (‘Suppliers’);
Business Partners: business partners, including within non ICA-operated joint ventures, as well as investors and shareholders (‘Business Partners’).
Special Notice - if you are under 13 years old. Processing children’s personal data
Except in those cases where ICA organizes educational events specifically designed for children, we do not intentionally collect personal data of individuals under 13 years old. If you are under 13 years old please do not send us your personal data for example, your name, address and email address. If you wish to contact ICA in a way which requires you to submit your personal data (such as for education or innovation events) please get your parent or guardian to do so on your behalf.
Who is responsible for any personal data collected?
Depending upon your location, ICA or its affiliate will be responsible for processing your personal data, either solely or jointly with its affiliates.
What personal data do we collect?
We may collect the following personal data covered by this Privacy Notice:
Applicants - Personal contact information, date of birth, whether you have the legal right to work in the country in which you have applied, your application for employment, your qualifications and experience, results of interviews and assessments.
ICA Staff - Personal home contact information, date of birth, marital status, payroll and bank account information, wage and benefit information including beneficiary information, emergency contacts, work performance information, information required to ensure you have the right to work in the country you are engaged in, as well as any other information necessary for managing the employment relationship, for engaging contractors and for providing benefits to certain dependents of ICA employees (such as those dependents who accompany an ICA employee while on an expatriate assignment).
Customers – Information you provide us such as name, email address, phone number, vehicle type, where you purchase ICA products. Your purchase history includes data regarding (i) specific products you buy, (ii) the total amount of your purchase per transaction, (iii) the time and place of the purchase you make and (iv) the payment method you use; Information gathered through social media pages - When you communicate with us through an ICA Social Media Page (for example, when you comment on, share or react to a post , upload media, send a personal message or subscribe to an ICA Social Media Page), we may receive personal data about you such as your user name, profile picture, hometown, email address and gender. We will use any personal data received from social media in accordance with this Privacy Notice.
Business Customers, Suppliers, Business Partners - Private contact information such as name, postal or e-mail address, and phone number - only if necessary; or Business contact and other information such as job title, department, name of organization and your dealings with ICA on behalf of yourself or the relevant Business Customer, Supplier, Business Partner.
How does ICA process the data we collect?
We process personal data covered by this Privacy Notice for the following purposes:
Customers: Providing our products and deliver our services to you, managing relationships and marketing, customer service and development of our products and services, performance of and analysis of market surveys and marketing strategies, or for a secondary purpose where it is closely related, such as: storing, deleting or anonymizing your personal data, audits, investigations, dispute resolution or insurance purposes, litigation or defense of claims, statistical, historical or scientific research; or legal and/or regulatory compliance.
Applicants, ICA Staff, Business Customers, Suppliers, Business Partners: Organizational Analysis and Development - including budgetary, financial and organizational planning, administration and reporting, compensation, performance management, asset management, mergers, demergers, acquisitions and divestitures, implementation of controls, management reporting, analysis, internal audits and investigations; Health, safety and security - including protection of an individual’s life or health, occupational health and safety, protection of ICA’s staff and assets, and authentication of individual status and access rights; Legal and/or regulatory compliance - including compliance with legal or regulatory requirements; For a secondary purpose where it is closely related, such as: storing, deleting or anonymizing personal data; fraud prevention, audits, investigations, dispute resolution or insurance purposes, litigation and defense of claims; or statistical, historical or scientific research.
Why do we process your personal data?
The personal data covered by this Privacy Notice is processed:
where it is necessary to comply with legal or regulatory obligations relevant to ICA;
in order to take steps at the request of an individual prior to entering into a contract;
for legitimate business interests, except where such interests are overridden by the interests or fundamental rights and freedoms of the individual/s; or
(only if legally required) with the explicit consent of the individual.
In those cases where processing is based on consent, and subject to applicable local law which provides otherwise, you have the right to withdraw your consent at any time. This will not affect the validity of the processing prior to the withdrawal of consent.
Sensitive personal data
We may also process some special categories of personal data (’sensitive personal data’) such as data relating to an individual’s health, their racial or ethnic origin, religious or philosophical beliefs, sexual orientation, political opinions and trade union membership. We will only process such personal data where it is necessary for the purposes of complying with employment and other applicable laws, for the establishment, exercise or defense of claims or where necessary for the purposes of providing occupational medical advice and support, to protect the vital interests of an individual (such as in an emergency), where necessary for reasons of public health or where the individual has provided their explicit consent.
Security of your personal data
We have implemented technology and policies with the objective of protecting your privacy from unauthorized access and improper use. In particular, we may use encryption for some of our services, we apply authentication and verification process for access to ICA services and we regularly test, assess and evaluate the effectiveness of our security measures.
Because data transmission over the Internet cannot be guaranteed to be 100% secure, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity, and privacy of any and all information and data exchanged between you and ICA through the ICA website cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.
Who will we share your personal data with?
The personal data covered by this Privacy Notice are exclusively processed for the purposes referred to above and will only be shared on a strict need to know basis with:
Other affiliates within the ICA group of companies;
Authorized third party agents, service providers, external auditors and/or subcontractors of ICA;
A competent public authority, government, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which the relevant ICA company/companies is subject to or as permitted by applicable local law;
Any successor to all or substantially all of ICA’s business or assets; or
Others when you have provided consent to do so.
Interacting with ICA through social media
If you choose to interact with ICA through social media on an ICA administered social media page (‘ICA Social Media Page’) such as Facebook, Instagram, Twitter or LinkedIn, your personal data (such as your name, your profile picture and the fact that you are interested in ICA) will be visible to all visitors of your personal webpage depending on your privacy settings on the relevant social media platform, and will also be visible to ICA. You can delete any information that you share on these sites at any time through your relevant social media platform’s account. ICA does not track your activity across the different social media sites that you use. If you send a message to ICA via any messenger service on a social media platform, these messages are held for no longer than one month after receipt. Please contact ICA if you wish to make a request that you are unable to action yourself and which relates to an ICA Social Media Page.
Additionally and to the extent ICA is jointly responsible with a social media platform of a ICA Social Media Page, ICA will have access through the social media platform to aggregated data providing statistics and insights that help to understand the types of actions you take on ICA Social Media Pages. For more information on how your personal data are processed on those social media platforms, including any targeted advertising that you may receive, please refer to your privacy settings accessible through your relevant social media platform’s account.
Transfers of your personal data to other countries
Where your personal data have been transferred to affiliates within the ICA group and/or to authorized third parties located outside of your country we take organizational, contractual and legal measures to ensure that your personal data are exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented in order to safeguard your personal data.
What are the consequences of not providing your personal data?
Personal data gathered by ICA for these purposes either directly or indirectly are required in order to:
Affect your chances of being selected for any potential employment, engagement or internship;
Fulfill legal requirements and/or which is required for entering into a contract with a counter-party and continuing to contract with that counter-party; or
Maintain contact with Customers, Business Customers, Suppliers and Business Partners.
How long do we hold your personal data for?
With some exceptions to comply with local legal requirements, all Applicant and ICA Staff personal data, is managed in line with the ICA group standards for Information and Records Management and securely deleted once no longer required for a legitimate business purpose or for a legal/regulatory purpose. Customer data will be deleted and rendered anonymous every 5 years; without undue delay upon your request; or 10 years from the date of the related financial transaction. Personal data that are required for the purposes of conclusion and execution of agreements, or data gathered as part of bids with Business Customers, Suppliers and Business Partners or for considering bids or tenders, will be held during the duration of the contractual relationship and up to 10 years after.
In all cases information may be held for (a) a longer period of time where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or (b) a shorter period where the individual objects to the processing of their personal data and there is no longer a legitimate business purpose to retain it.
Your rights in relation to your personal data
We aim to keep our information as accurate as possible. You can request:
access to your personal data;
correction or deletion of the personal data (but only where they are no longer required for a legitimate business purpose);
that you no longer receive marketing communications on behalf of the relevant Application, Business Customer, Supplier or Business Partner;
that the processing of your personal data is restricted; and/or
that you receive personal data that you have provided to ICA, in a structured, digital form to be transmitted to another party, if this is technically feasible.
To make any of these requests, please contact firstname.lastname@example.org.
California Consumer Privacy Act (CCPA)
This clause applies only to the handling of personal information of users residing in California, in addition to the aforementioned guidelines.
The California Consumer Privacy Act (CCPA) may provide you with additional rights regarding the use of your personal information. These rights include:
The right to access the personal information we process about you;
The right to know what personal information is collected about you and if any information is sold or disclosed, and if so, to whom;
The right to request the deletion of your personal information, if applicable;
The right to opt-out from the sale of your personal information, if applicable;
The right to not be discriminated against for exercising any of the rights above.
You can contact us at email@example.com and exercise any applicable rights. When you contact us and exercise such rights, you may be required to submit proof of your identity and/or address, to confirm your identity and verify that you are a California resident. When ICA receives a request based on the rights specified above, we shall respond to such requests without undue delay. You may also designate an authorized agent to make a request on your behalf, subject to proof of identity and authorization.
Who can you contact if you have a query, concern or complaint about your personal data?
If you have any questions or complaints regarding the processing of your personal data please contact ICA via email at: firstname.lastname@example.org
You may also contact the ICA Group Compliance Officer via mail correspondence: 2200 Post Oak Blvd. Suite 1150, Houston, TX 77056.
Cookies and Similar Technologies
Third Party Sites
The ICA website may permit you to link to other websites on the Internet, and other websites may contain links to the ICA website. These other websites are not under ICA’s control. The privacy and security practices of websites linked to or from the ICA website are not covered by this Privacy Notice, and ICA is not responsible for the privacy or security practices or the content of such websites.
Changes to this Privacy Notice
ICA reserves the right, in its sole discretion, to modify or replace any of this Privacy Notice at any time and without notice. It is your responsibility to periodically check this Privacy Notice for changes. Information collected is subject to the Privacy Notice in effect at the time of use. Your use of ICA’s website following the posting of any changes to the Privacy Notice constitutes your acceptance of and agreement to be bound by those changes. This Privacy Notice was last updated July 2020.