PRIVACY POLICY

1. Collection‚ Use and Disclosure of Your Personal Data:

1.1 Collection.

MTT Instruments, Inc. (hereinafter referred to as “the Company”) collects Personal Data from you as you interact with our website. Additionally, the Company collects Personal Data from you during our commercial relationship. The Personal Data collected includes‚ but is not limited to‚ the following:

First and last names
Business contact information
Job title

Information provided by you to the Company relating to other people will be processed by the Company in accordance with this Policy. You are responsible for the accuracy of such information and for ensuring that those people are aware of the nature of the information you have provided and the way in which it will be processed by the Company.

1.2 Use.

The Company uses this information to personalize your experience by providing content on the Website‚ including targeted advertising‚ that we believe may be of most interest to you; fraud prevention purposes; and to send you information and other product information that we think may be of interest to you.

We may use navigational information to help us evaluate how our visitors use and navigate our Website. For example, we collect navigational information to determine things like the number and frequency of visitors to each web page of our Website; the difficulties that visitors may have with our Website; the time it takes a visitor to connect to the Website or download pages; and the length of their visits to our Website. We analyze this information to better understand and improve a visitor’s experience on our Website‚ and for other internal business purposes. We use information collected through cookies and similar technology for many of these same purposes.

In addition, cookies and similar technology are used for things like personalizing your experience on our Website‚ analyzing trends‚ determining return visitors‚ serving tailored advertisements on other sites‚ and measuring the effectiveness of our advertising.

We use third-party service providers to help us provide certain features on our Website and analyze our visitors’ preferences. These partners may use cookies and similar technologies described above to collect and analyze information about the use of our websites and mobile applications. This service may also collect information regarding the use of other websites‚ apps and online resources.

1.3 Disclosures.

Due to business requirements or contractual or statutory obligations‚ the Company may need to disclose your Personal Data to Authorized Third Parties (defined below) for the purposes described above. The Company generally will not disclose your Personal Data to any other third parties unless the disclosure is required by law.

“Authorized Third Parties” include third-party service providers under written contract with the Company or with the Parent Corporation (defined below) on the Company’s behalf.

2. International Transfers of Personal Data:

The Company will transfer your Personal Data to Authorized Third Parties‚ located in Japan‚ for the purposes described above. The Authorized Third Parties in Japan include third-party advertising companies‚ used to tailor online advertising to be directed to you on other websites. These third-party advertising companies place‚ use‚ or rely on technology‚ such as cookies and pixel tags‚ to obtain information about your interactions with our Website as well as with other websites. This information helps us select advertising to serve to you and where to serve it based on your experience on our Website and other sites that you visit.

3. Security Measures for‚ and Retention of‚ Personal Data:

The Company has implemented reasonable and appropriate administrative, physical, and technical safeguards for your Personal Data. For example, your Personal Data will be stored on a secure server when in electronic form and in physically secure areas when in paper form. Technical and physical controls restrict access to your Personal Data to employees of the Company with a need to know. The Company will retain your Personal Data throughout the commercial relationship and as long thereafter as is permitted by applicable law. For additional information about the Company’s retention of your Personal Data‚ please contact the Company.

4. No Automated Decision Making:

The Company does not make any decisions concerning our commercial relationship only by automated means.

5. Your Rights with Respect to Your Personal Data:

You have the right to access your Personal Data and to request that the Company update‚ correct or delete (the “right to be forgotten”) your Personal Data as provided by applicable law. You also have the right to restrict‚ and to object to‚ the Company’s processing of your Personal Data and to data portability as provided by applicable law. Subject to certain limitations‚ the right to data portability allows you to obtain from the Company‚ or to ask the Company to send to a third party‚ a copy of your Personal Data in electronic form that you provided to the Company in connection with our commercial relationship or with your consent. Your right to access your Personal Data includes your right to receive a copy of all‚ or a portion‚ of your Personal Data in the Company’s possession as long as the Company providing your Personal Data would not adversely affect the rights and freedoms of others.

Right to Object:

You have the right to object to the processing of your Personal Data based solely on the Company’s legitimate interests. If you do object in these circumstances‚ the processing of your Personal Data will be stopped unless there is an overriding‚ compelling reason to continue the processing or the processing is necessary to establish‚ pursue or defend legal claims.

You can exercise these rights by submitting an email to the Company. The Company will respond to such requests in accordance with applicable data protection law. If you believe that your Personal Data has been processed in violation of applicable data protection law, you have the right to lodge a complaint with the data protection authority where you live, where you work‚ or where you believe the violation occurred.

If the Company requests your consent to process your Personal Data and you do consent‚ you may use the contact information above to withdraw your consent. Any withdrawal shall not affect the lawfulness of processing based on consent before its withdrawal‚ and the Company will continue to retain the information that you provided us before you withdrew your consent for as long as allowed or required by applicable law.

October 11, 2019