Privacy Policy
Date Last Updated: April 3, 2023
DENSO CORPORATION (the “Company”) shall comply with Japanese Act on the
Protection of Personal Information, the law of the EU concerning the protection of Personal
Data including the GDPR and other related laws, ordinances and guidelines and
appropriately handle the Personal Data obtained from the user as follows for the protection
of the Personal Data.
If you are a California “consumer” within the meaning of the California Consumer Privacy
Act of 2018, as amended by the California Privacy Rights Act of 2020, please read
Addendum for California Consumer Privacy Act for additional information.
1. Personal Data to Be Processed
The Company shall process (meaning any operation or set of operations which is
performed upon personal data or sets of personal data, whether or not by automated
means, and such operation means acquisition, recording, organization, structuring, storage,
rectification, alteration, recovery, retrieval, consultation, use, disclosure by transmission,
dissemination or otherwise making available, alignment, combination, restriction, erasure or
destruction; hereinafter the same) the Personal Data of the user that you give us through
the service, including but not limited to the following information.
User ID, Nickname, Location information of user (including during background operation),
Use log of NaviCon and NaviBridge application (including location and time of use), and
History of access to Company’s server (including time, IP address and Cookie)
Since it is necessary for the Company to receive such information from the user to provide
the user with the service, the user who cannot provide such information may not use the
service.
2. Legal Basis for and Purpose of Processing Personal Data
We will process your personal data on the following legal bases unless such data
processing would conflict with applicable laws and regulations:
- Contract. When we need to process your personal data to perform a contract we
enter into with you.
- Legal Obligation. When we need to comply with a legal obligation.
- Legitimate Interests. When the processing of your personal data is necessary
for the fulfilment of legitimate interests pursued by us or a third party and your
interests and fundamental rights do not override those interests.
- Consent. When you have given consent for us to process your personal data.
However, even if we obtain consent from you, we may process your personal data
based on other legal grounds. The withdrawal of your consent shall not affect the
lawfulness of processing performed based on the consent before your withdrawal.
We use the personal data that we hold about you for the following purposes. We will
only use your personal data to the extent that it is necessary to do so to fulfil the
purposes described below.
- To provide merchandise or services that you request (based on contract or
legitimate interests)
- To improve our merchandise or services we provide to you (based on contract or
legitimate interests)
- To provide information and communications; to conduct questionnaires relating to
products, services, various events, campaigns, and similar matters (based on
legitimate interests)
- To conduct sales analysis, investigations, and research; to develop new services
and products (based on legitimate interests)
- To conduct web analytics (see our Cookie Policy)
- To ensure compliance with legal obligations (such as record keeping obligations),
export control and customs, compliance screening obligations (to prevent white-
collar or money laundering crimes), and our policies or industry standards (based
on legal obligation or legitimate interests)
- To solve disputes, enforce our contractual agreements and to establish, exercise
or defend legal claims (based on legal obligation or legitimate interests).
You may experience disadvantages if you refuse to provide your personal data, such
as being unable to make use of some of our services.
The Company shall keep the Personal Data of the user as long as it is necessary to provide
the user with the service but promptly erase it if it is no longer necessary.
3. Provision to Third Party
The Company shall provide the companies which the Company entrusts to develop and
operate the service to and ties up with to provide the service or new related service with the
Personal Data of the user for the purpose of accomplishing the purposes of use specified
above.
4. Ensuring of Accuracy
The Company shall endeavor to keep the Personal Data up to date and if it is inaccurate or
insufficient, rectify it.
5. Security
To prevent unauthorized access to Personal Data or divulgence of Personal Data, the
Company evaluates and determines the risk of breach of the Personal Data privacy in a
comprehensive manner after taking into account the category of Personal Data, degree of
sensitivity, influence including economic and mental damage to the user when the Personal
Data privacy is breached, and takes personnel, organizational and technical safety
management measures that are necessary and appropriate according to the risk of breach
of Personal Data privacy, set the process to inspect and correct such safety management
measures as necessary and makes ceaseless efforts to improve security.
6. Access to Personal Data, Rectification, Erasure, Restriction on Processing, Right
of Data Portability
The user may request the Company make the Personal Data concerning the user retained
by the Company available to the user, rectify or restrict the processing of such information
or take procedures for data portability within the scope which is recognized by the laws and
regulations of each county and region. Further, the user shall have the right to raise an
objection to the Company or data protection authority governing the location where the user
resides with respect to the processing of the Personal Data related to the user within the
scope which is recognized by the laws and regulations of each county and region. If the
user requires the procedures for exercising various types of rights granted to the user with
respect to the Personal Data, please contact us at the following e-mail address.
navicon@jp.denso.com
7. Amendment to Privacy Policy
The Company may amend the privacy policy at any time. If the Company amends this
privacy policy, the Company shall clarify the changes and inform it the users.
8. Company’s Policy for Children
The Company makes sure to obtain the consent of a guardian when obtaining Personal
Data from the user under 16 years of age. The Company shall request the user under 16
years of age ask his/her guardian to give consent after his/her guardian has confirmed the
details of the privacy policy without fail, but shall not request the user himself/herself give
consent, before using the service. Further, if a guardian or other person finds the user
under the age of 16 who consents to the privacy policy and uses the service without
obtaining the confirmation and consent of his/her guardian, please notify the Company at
the following contact point.
9. Inquiries
If the user has any matter for consultation or question with respect to the privacy policy or
the processing of the Personal Data by the Company, or request with respect to the access
to, rectification or erasure of the Personal Data, restriction on processing or right of data
portability, please contact the Company at the following website.
navicon@jp.denso.com
10. Administrator and Representative
The Company determines the purposes of use and method of processing of the Personal
Data of the user. The contact information of the Company is as follows.
DENSO CORPORATION
1-1, Showa-cho, Kariya, Aichi, Japan
navicon@jp.denso.com
Addendum for California Consumer Privacy Act
Last Updated: April 3, 2023
If you are a California “consumer” within the meaning of the California
Consumer Privacy Act of 2018 (“CCPA”), as amended by the California
Privacy Rights Act (“CPRA”), this Addendum for California Consumer Privacy
Act (“CCPA Addendum”) applies to you. The CCPA Addendum
supplements our privacy policy (the “Policy”) and prevails over any
conflicting provisions in the Policy. We are both a “business” and a “service
provider” under the CCPA. This CCPA Addendum applies to information we
collect in our role as a business. If you would like more information about
how your personal information is processed by such other companies,
including companies that engage us as a service provider, please contact
those companies directly.
This CCPA Addendum uses certain capitalized terms that shall have the
meanings given to them in the CCPA.
1. Our Collection, Use, and Disclosure of
Personal Information
A. Categories, Sources, and Purposes of Your Personal
Information Collected or to Be Collected
The table below describes the categories of Personal Information (as listed in
the CCPA) that we may collect, and have collected during the 12-month period
prior to the effective date of this CCPA Addendum.
Category of Personal
Information Collected
Example
A. Identifiers
User ID, IP address, Nickname
F. Internet or network
activity information
use log of NaviCon and NaviBridge application (including
location and time of use, userID,), and history of access to
Company’s server (including time, IP address, HTTP
version, URLs, and cookies)
G. Geolocation data
Location information of user(including during background
operation)
Purposes of Collection. The business or commercial purposes for which
the categories of Personal Information will be collected or used, or was
collected or used during the 12-month period prior to the effective date of this
CCPA Addendum, is as described in “2. Legal Basis for and Purpose
of Processing Personal Data” in the Policy.
Categories of Sources. The categories of sources from which Personal
Information was collected during the 12-month period prior to the effective
date of this CCPA Addendum are as described in “1. Personal Data to Be
Processed” in the Policy.
B. Sharing of Your Personal Information
(A) Sale of Your Personal Information
There is no Personal Information that we may have sold during the 12-month
period prior to the effective date of this CCPA Addendum.
Children’s Personal Information and Opt-In Right. We do not sell, and
have not sold, the Personal Information of minors under 16 years of age.
(B) Disclosure of Personal Information for a Business Purpose
The table below describes: (i) the categories of Personal Information (as listed
in the CCPA) that we may have disclosed for our operational business
purposes during the 12-month period prior to the effective date of this CCPA
Addendum; and (ii) the categories of third parties to whom we have disclosed
such Personal Information for our operational business purposes during the
12-month period prior to the effective date of this CCPA Addendum.
Category of Personal
Information Disclosed
Example
Third Parties to whom Personal
Information Was Disclosed in
the Last 12 Months
A. Identifiers
User ID, IP address,
Nickname
Our employees
Service providers including
application development,
infrastructure construction,
operation monitoring, and
anomaly investigation
F. Internet or network
activity information
use log of NaviCon and
NaviBridge application
(including location and time
of use, userID, user agent),
and history of access to
Company’s server
Our employees
Service providers including
application development,
infrastructure construction,
operation monitoring, and
anomaly investigation
Category of Personal
Information Disclosed
Example
Third Parties to whom Personal
Information Was Disclosed in
the Last 12 Months
(including time, IP address,
HTTP version, URLs, and
cookies)
G. Geolocation data
Location information of
user(including during
background operation)
Our employees
Service providers including
application development,
infrastructure construction,
operation monitoring, and
anomaly investigation
2. Your Rights and Requests
If you are a California consumer, you have certain choices regarding your
Personal Information, as described below:
- Access: You have the right to request, twice in a 12-month period, that
we disclose to you the categories and specific pieces of information we
have collected, used, disclosed, and sold about you during the 12
months preceding your request:
- Deletion: You have the right to request that we delete certain Personal
Information we collected from you, subject to certain limitations under
applicable law.
- Sale: You have the right to disclosure of any Personal Information we
have shared for valuable consideration.
- Non-Discrimination: You have the right not to be discriminated against
for exercising certain rights under California law.
How to Submit a Request. To exercise the above rights , please submit
requests to:
Contact form: Please click here
E-mail: navicon@jp.denso.com OR you may also call
Toll-free telephone number: 0120-087-413
Please be as specific as possible in relation to the Personal
Information you wish to access.
Verifying Requests. We will take steps to verify your identity before
granting you access to your Personal Information or complying with your
deletion request.
Upon receiving an access or deletion request from you, we will first verify your
identity by requiring you to submit your name and e-mail address, and by
matching the information you provide with what we already have on file.
If you use an authorized agent to make an access or deletion request on your
behalf, we may require you to (1) provide the authorized agent signed
permission to do so, (2) verify your own identity directly with us (as described
above), and (3) directly confirm with us that you provided the authorized agent
permission to submit the request.
3. Changes to this CCPA Addendum
We may change this CCPA Addendum from time to time. The “Date last
updated” at the top of this page states when this CCPA Addendum was last
updated; any changes will become effective upon us posting the revised
California Addendum.
We will post a prominent notice on the site to notify you of any significant
changes to this CCPA Addendum and indicate the date it was most recently
updated.
4. Contact Us
If you have any questions or concerns regarding this CCPA Addendum or our
privacy practices, please contact us at our office address described in “10.
Administrator and Representative” in the Policy.
California Consumer Privacy Act Notice at Collection
In this notice, DENSO CORPORATION (“DENSO”) is addressing specific disclosure requirements
under the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California
Privacy Rights Act of 2020 (“CPRA”), vis-a-vis California residents who are not acting as an
employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship,
non-profit, or government agency (a “Business Representative”) where DENSO holds personal
information reflecting a written or verbal communication or a transaction between DENSO and
the Business Representative and the communications or transaction with DENSO occur solely
within the context of DENSO conducting due diligence regarding, or providing or receiving a
product or service to or from such company, partnership, sole proprietorship, non-profit, or
government agency.
1. Categories of Personal Information. DENSO collects personal information through its
mobile application. The personal information DENSO collects depends on the particular request
and the way you interact with the mobile application. The categories of personal information
include unique user IDs, Nickname, your location information (including in the background), log
data including IP address, use log of NaviCon and NaviBridge application (including location and
time of use, user agent), and history of access to DENSO’s server (including time, HTTP version,
URLs, and cookies).
2. Purposes. DENSO uses personal information to provide merchandise or services that you
request to:
* improve our merchandise or services we provide to you;
* provide information and communications;
* conduct questionnaires relating to products, services, various events, campaigns, and similar
matters;
* conduct sales analysis, investigations, and research;
* develop new services and products;
* conduct web analytics;
* ensure compliance with legal obligations (such as record keeping obligations), export control
and customs, compliance screening obligations (to prevent white-collar or money laundering
crimes), and our * policies or industry standards (based on legal obligation or legitimate
interests); and
* solve disputes, enforce our contractual agreements and to establish, exercise or defend legal
claims.
3. Recipients of Information. DENSO shares your personal information with our employees
and unaffiliated service providers for application development, infrastructure construction,
operation monitoring, and anomaly investigation.
If you have a visual disability, you may be able to use a screen reader or other text-to-speech or
text-to-Braille tool to review the contents of this notice.
DENSO’s Privacy Policy, is available here [https://navicon.com/navibridge/ja/support#6].
