Effective Date: Feburary 1, 2023
Mitas Electronics is respectful of personal data and is committed to protecting it in line with applicable data protection laws, including but not limited to the European Union (EU) General Data Protection Regulation 2016/679 (“GDPR”) and the UK Data Protection Act 2018, and the California Consumer Privacy Act, Cal. Civ. Code §§ 1798.100 et. seq., as amended and implemented (“CCPA”).
1. Personal Data Collection
You are not required to provide any personal data as a condition of using our website or our products and services. However, Mitas Electronics, here-to-forward referred to as ‘Mitas’, will process your personal data when you submit it in the following ways:
- Communications via our Website: We collect personal data when you provide it to us through communications via our website. This includes where you contact us with an inquiry or request and similar situations in which you have chosen to provide the information to us, including for customer service support.
- Products or Services you Request: Where you request a product, service, or information from us, we will collect your personal data in order to process your request and otherwise contact you following an inquiry.
When you communicate with us, including via our website, the types of information we may collect from you include:
- Personal Details: Such as your name, home address, e-mail address, telephone number (including personal mobile number) and other contact information, images/photographs, date of birth, gender, location, and details regarding military service.
- Biometric Information: Biometric identifiers, including facial recognition data, fingerprints, and handprint.
- Family and Social: Such as your family composition (including marital status or partnership, names of spouse and/or dependents and/or next of kin and relationship), nominated beneficiaries, and emergency contact details.
- Education and Training: Such as your educational and vocational training and history (including professional qualifications, grades, attendance at educational establishments and training received), student status, spoken/written/reading language proficiency, and details of other relevant skills.
- Employment and Work Record Details: Such as your status of employment, performance ratings, work time/utilization records and forecasts, training records, evaluations, holiday or annual leave arrangements, terms of labor contract, details of any disciplinary actions, health and safety data, employee benefit plan participation details, work authorization/eligibility/permit/visa requirements/status, stock option grants, grant number and type and value, employee number, company ID number, business title/unit/department/location, job position/title, functions and description, working arrangements (full/part-time), job location(s), seniority data, retirement age, contract length, hire/re-hire/termination date and codes, supervisor hierarchy, line management details, security clearance, work history and experience, business travel arrangements, details of mobility/willingness to relocate, workplace accident information, occupational health information, right to work documentation, development plans, and other recruitment information submitted as part of the application process;
- Compensation/Benefit Information: Such as your salary information, expense reimbursement, benefit information (e.g., employer health insurance program), bank account details, direct deposit/credit arrangements, pension payment and stock option information (stock grants or option exercise details), bonus, additional pay, variable compensation awards, tax data (national and local), flexible spending enrollments, grant valuation information, paid time off and credit card details (personal and business);
- Special Categories/Sensitive Information: Such as your Social Security Number, driver license number, or other government-issued identification number, citizenship/immigration information, background checks (including motor vehicle reports), and health and medical information about you and your spouse and children; and
- Information About Your Device: When you use our Website, we will automatically receive technical information, including the name of your internet service provider, the website that you used to link to our Website, the websites that you visit from our Website, the type of device you use, your operating system and software version number, IP address, the type of browser you use, user IDs, system logs, the country, and language code and time zone setting. This information can lead to your identification, but we do not use it to do so.
2. Purposes for Processing and How we Use and Share your Personal Data
We process your personal data for the following purposes:
- to process any request for a product or service you make;
- administration of an inquiry or other request you make when you contact us via our Website, including for customer service support;
- to continue to develop, test and improve our Website, including to offer new functionality and features;
- to better understand how you interact with our Website, including its functionality and features, and ensure that content is presented in the most effective manner;
- to ensure the security and integrity of our Website;
- to manage our service provider and partner relationships;
- to protect our and others’ interests, rights, and property (such as to protect our copyrighted materials); and
- to comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts, and law enforcement requests.
Recruits, Contractors, and Employees
We also collect and process your personal data if you apply to work at Mitas or at any Mitas related companies. We may use third party providers to process applications submitted through our providers’ websites. We hold such applications as necessary to evaluate potential candidates and in compliance with applicable laws.
During the application process, throughout employment, and for as long as is necessary after the termination of employment, we may process your personal data in connection with your employment or contract with us, or to further our legitimate interests related to our business operations. The main purposes for which we may use personal data of our employees, job applicants, and contractors include, but are not limited to recruitment, appraisals, performance, promotion, training, pay and remuneration, pension and insurance and other benefits, tax, other deductions from pay, health and safety, discipline, grievances and termination of your employment to:
- ensure compliance with legal and regulatory requirements and Mitas policies (such as anti-bribery, corruption, tax, and social security requirements, right to work, and litigation and other legal proceedings); and
- comply with contractual obligations for administration, reporting and management, and resource planning.
3. Sharing your Personal Data
Mitas Electronics may share your information with:
- Mitas affiliated companies, the details of which may be defined in the future and published at our website.
- a prospective seller or buyer in the event of a sale or purchase of any Mitas business or asset so that the buyer can continue to provide you with information and services;
- data processors that we engage to provide services for us. Where we provide your personal data to data processors, they are required to keep your personal data confidential and secure, and must only use your personal data as instructed by us; and
- our distributors, business partners, vendors, or service providers (e.g. insurers, legal and other professional advisers, company credit card providers, pension plan administrators), including for marketing purposes or where you have chosen to share your personal data through various features and functionality provided via our Website. We prohibit these third parties from using or disclosing your personal data except as necessary to perform services or to comply with legal requirements.
4. Storing your Personal Data
Your personal data will be stored on servers located in the United States. It may also be processed by Mitas Electronics staff or by one of our service providers operating in any of Mitas Electronics or our affiliates’ locations. This includes individuals engaged in, among other things, administration of an inquiry or request you make via our Website or the provision of support services.
5. Keeping your Personal Data Secure
Please note that the transmission of information via the internet is not completely secure. Although Mitas Electronics will do its best to protect your personal data, we cannot guarantee the security of your information transmitted via our Website or otherwise and any transmission is at your own risk.
We use the following cookies on our Website:
Essential Cookies: Some cookies serve an essential function and websites cannot work properly without them. Where such essential cookies are used, they cannot be disabled, without also disabling the related functionality of the Website.
Browser Cookies: Other cookies serve a functional purpose and improve the user experience of the Website. We use browser cookies to tell us, for example, whether you’ve visited us before, and to help us identify site features in which you may have the greatest interest. Browser cookies may enhance your online experience by saving your preferences while you are visiting a particular site so that you do not need to reset them each time you visit the website. Browser cookies cannot identify you as an individual. You can decline any Browser cookie through your browser; however, without Browser cookies you may not be able to take full advantage of all our Website features.
Web Beacons: Some types of cookies collect aggregate information which help us to improve our Websites by providing information, for example, on loading errors and the most visited webpages. Certain pages on our Website may contain web beacons (also known as Internet tags, pixel tags and clear GIFs). Mitas Electronics uses web beacons to help display content to visitors and to generate statistics regarding web traffic and trends. Web beacons cannot identify you as an individual.
Targeting Cookies: These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
- to improve our Website security;
- to identify you when you sign-in to our Website and remember your preferences;
- to analyze how you use our Website by tracking specific actions on our Website, such as visits to the various pages of our Website;
- to collect anonymous statistical information on how visitors use our Website so that we can make improvements to its usability and to improve content delivery value; and
- to allow you to share pages with social networks like Twitter, Facebook and LinkedIn.
We use Google Analytics cookies to collect information and compile reports about how visitors use our Website, and we use this information to help us improve our Website. Google Analytics mainly uses first-party cookies which are not shared across different websites that you visit. The information that the cookies collect is mostly anonymous and includes the number of visitors to the Website, where those visitors originate from and how many times they have visited the Website. Google has published information in relation to privacy and safeguarding data.
Google Analytics will collect your IP address, which is a unique code assigned to every computer and device connected to the Internet. IP addresses are usually assigned in geographic blocks and may allow website operators to identify the country, state and city in which the computer or device is based. We may collect either the full or a portion of an IP addresses to help us identify the location of our Website visitors.
Opting out of cookies
You may refuse to accept cookies by altering the settings on your internet browser (for example Internet Explorer, Chrome and Firefox). Please note that if you choose not to permit cookies some areas of our Website may not function properly or be accessible.
In general, by consulting the help menu item in your internet browser, instructions on how to disable or delete cookies is available. Most browsers are set-up to accept these cookies automatically. In addition, you can deactivate the storing of cookies or adjust your browser to inform you before the cookie is stored on your computer. You may also use self-regulation programs available in your jurisdiction to manage the way that companies other than Google advertise to you, such as the EU-based Your Online Choices.
7. Links to Other Web Sites
Links to other websites are provided for information only and do not constitute endorsements of those other websites. Mitas and/or its affiliated companies are not responsible for the content of links or third-party websites and do not make any representation regarding their content or accuracy. Your use of third-party websites is at your own risk.
9. Your Rights Under Applicable Laws
Depending on your jurisdiction, you may have certain rights to your personal data processed by Mitas Electronics. You can find more information about these rights, and how to exercise them, by contacting us. Please note that we may request additional information to respond to or fulfill any requests regarding your rights under applicable laws or regulations.
GDPR requires Mitas Electronics to provide additional information about how Mitas processes the personal data of individuals resident within the EU. The GDPR governs the use of “personal data”, which is any information that identifies or from which an individual could be identified, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to an individual’s identity. Mitas processes personal data for a number of reasons:
- to provide goods and/or services pursuant to an agreement;
- where required by the law of the EU or its member states; and
- where Mitas has legitimate business interest in doing so.
The GDPR provides EU residents with certain rights in relation to the processing of their personal data, including the right to request access, to have personal data rectified or erased, to object to its processing or to have access to personal data restricted. Mitas Electronics respects individuals’ rights under the GDPR, and we may ask you for additional information to confirm your identity and for security purposes, before providing individuals with access to their personal data. There may also be circumstances where Mitas Electronics is permitted by law to deny access. We have implemented appropriate safeguards, to protect your personal data when it is transferred, including the execution of data transfer agreements with recipients of the information.
CCPA governs the use of “personal information”, which includes any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.
If you are a California consumer, you may have the right, subject to certain exceptions defined in CCPA, to request that companies:
- disclose certain information to you about their collection, use, and disclosure of your personal information over the past 12 months and to request access to such information; and
- delete any of your personal information that it has collected from you and retained;
- not sell your personal information.
California consumers also have the right not to receive discriminatory treatment if they exercise the rights list above.
When you make a request, we may require that you provide information and follow procedures so that we can verify the request and your jurisdiction before responding to it. The verification steps we take may differ depending on the request you make. We will match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us verify your request. California consumers will be required to submit their first and last name and email address and may also be asked to provide their telephone number or address so that we can verify the request. Please provide as much of the requested information as possible to help us verify the request. We will only use the information received in a request for the purposes of responding to the request.
The CCPA permits California consumers to use an authorized agent to make privacy rights requests. We require the authorized agent to provide us with proof of the California consumer’s written permission (for example, a power of attorney) that shows the authorized agent has the authority to submit a request for the California consumer. An authorized agent must follow the process described above to make a request. The authorized agent must also verify his/her own identity. We will confirm the agent’s authority with the California consumer about whom the request was made.
We are not required to respond to a consumer’s requests for access or disclosure of personal information more than twice in a twelve (12) month period.
We do not share personal information with other people or non-affiliated businesses for their direct marketing purposes. We are not currently selling your personal information.
Although Mitas Electronics does not sell “personal information”, Nevada residents have the right to submit a verified request directing Mitas not to sell their personal information. If you are a Nevada resident, and would like to submit such a request, please send your request through any of the methods noted below.
Exercising your rights
To exercise any of the rights described above, you can reach us by e-mail at [email protected].
Mitas Electronics does not knowingly or specifically collect personal data from individuals under the age of 13 and no one under age 13 is authorized to submit any information, including personal data to us, via our Website or otherwise. If we determine that such information has been inadvertently collected on anyone under the age of 13, we will take the necessary steps to ensure that such information is deleted from our systems.
11. Contact Us
If you have any questions or concerns as to the processing of your personal data, please contact us at [email protected].