This policy describes how NSK Europe Ltd and its European subsidiaries and affiliates (“NSK Europe” or “we”), use your personal data in the course of our business, when you use our websites, (including business applications) and the NSK Academy platform, and when we send you marketing communications. Contact details of NSK Europe companies are set out in the “Further information” section below.
In this policy personal data means any information that relates to an identifiable natural person – in this case you.
We use your personal data to sell you our products or provide you with our services (including marketing communications, where you have requested them), manage our business, recruit new staff, comply with our legal obligations, and improve and monitor the performance of our websites.
1. Who is the controller of your personal data?
For the purpose of this policy the controller is:
- NSK Europe Ltd. with its seat in the UK – with respect to the data collected on the website and the NSK Academy platform.
- The relevant NSK company – with respect to other data collected to provide you and/or your organization with its services or sending you marketing communications (the controller is also referred to in this policy as “NSK Europe”, “we”, “our”, “us”).
As a controller we make decisions about how and why we use your personal data and, because of this, we are responsible for making sure it is used in accordance with applicable data protection laws. We are required by law to give you the information in this policy.
2. What types of personal data do we collect and where do we get it from?
We collect the following categories of personal data:
- Contact information: name and surname, e-mail address, telephone number, name of the company, address of the company;
- Business related information: contact information (see above), details relating to your matter of inquiries, information about other people you share with us, information you provide us when you come into our offices, billing and payment information;
- NSK Newsletter: contact information (above);
- Information for the purpose of registering with the NSK Academy, the NSK web portal and using EDI requests: e-mail address, name and surname, institution, region, city/town, zip code, telephone number, name of the company, address of the company;
- Browsing information: IP address.
3. What do we do with your personal data, and why?
We process your personal data for a number of different purposes. We must always have a “lawful basis” (i.e. reason, prescribed by law) for processing your personal data. The table below sets out the purposes for which we process different categories of your personal data and the corresponding lawful basis for that processing. For some processing activities, we consider more than one lawful basis to be relevant – depending on the circumstances.
|Purposes of processing||Your consent||To perform a contract with you or to take steps at your request prior to entering into a contract||For our legitimate interests|
|Responding to your requests and answering your questions and communicating with you through communicating tools regarding our products and services||x
(if part of a sale of products or service contract or warranty)
(It’s important that we can respond to your enquiries)
|Business related information|
|Establishing you/your organization as a client on our systems||x|
|Providing you/your organization with our products or services, making you an offer, or to fulfill a legal contract between us and you or your company||x|
|Maintaining a business relationship with you||x|
|Taking payment from you in respect of our products or services||x|
|Sending you NSK’s newsletter||x|
|NSK Academy, web portal and EDI request|
|Registering you with the NSK Academy||x|
|Responding to your enquiries about a project, application or product||x|
|Monitoring and producing statistical information regarding the use of our websites, and analyzing and improving their functionality||x
(We need to perform this limited routine monitoring to make sure our websites work properly)
|All categories of information|
|Managing, planning and delivering our global business and marketing strategies (including client and prospective targeting)||x
(We need to use certain client personal data for our business development strategies)
|Training our staff||x
(Sometimes, it’s appropriate for us to use your personal information so that we can provide our staff with training to manage risk and improve the quality of our services)
|Continuously reviewing and improving our products and services and developing new ones||x
(We have a legitimate interest in making sure that we are continuously improve our offering)
|Resolving any complaints from or disputes with you||x||x
(We need to be able to try and resolve any complaint or dispute you might raise with us)
Please note that we reserve the right to disclose non-personal statistical information to third parties with whom we have contractual obligations. Examples of non-personal information include: domain name, browser type and version, computer operating system and platform, information searched for, pages viewed, time spent on the website and access times.
Unless otherwise provided, we reserve the right to share such information within the NSK Europe umbrella of companies, including any company that manages, and/or performs statistical reporting on the website. Any such company will be legally bound to confidentiality.
We will inform you separately in case your personal data is subject to so-called automated decision-making. In such case we will also provide you with information as to the logic used by such systems. You have the right to object to being subject to such decisions, and/or challenge any decisions made wholly on the basis of any automated decision-making system, including providing any additional evidence to assist the individual reviewing the decision.
4. How long is your personal data stored?
NSK Europe Ltd or other subsidiaries established in the UK will normally retain your personal data for 7 years from the end of any contract or event that it relates to, unless we are legally required to retain this information for longer.
Other NSK Europe companies will keep your personal data for as long as we need it to fulfil the purposes for which it was collected and in order to comply with legal and regulatory requirements as well as for the period until which all actions related to our relationship with you expire in accordance with the appropriate statute of limitations. This may mean that some information is held for longer than other information.
5. Who else will have access to your personal data?
Other NSK companies
Personal data will only be shared with other NSK companies within EU and outside EU, that will take appropriate steps to ensure that their personnel is bound by duties of confidentiality with respect to your personal data.
We will only make transfer outside EU if:
- that country ensures an adequate level of protection for your personal data;
- the recipient or recipient country is subject to an approved certification mechanism or code of conduct with binding and enforceable commitments which amount to appropriate safeguards for your personal data – this includes for example, the EU-US Privacy Shield which enables the secure transfer of personal data to the United States;
- we have put in place appropriate safeguards to protect your personal data, such as a contract with the person or entity receiving your personal data which incorporates specific provisions as directed by the European Commission;
- the transfer is permitted by applicable laws; or
- you explicitly consent to the transfer.
NSK Europe uses third party service providers, including:
- IT support, data hosting, cloud platform providers who provide technical and support services;
- marketing service providers who send out marketing communications on our behalf;
Where applicable, your personal data will be processed by the service provider on behalf of NSK Europe. NSK Europe will ensure that any third party that processes your personal data can provide sufficient guarantees regarding the confidentiality and security of your personal data.
NSK works closely with selected social media partners (e.g. YouTube, Facebook, LinkedIn, Google). These platforms can be temporarily integrated using plug-ins. If a visitor accesses the website using such a plug-in, the browser creates a direct connection to its servers. In this case the social media partner is given the IP address and other device-related data of a visitor.
Disclosure to third parties
In certain circumstances, NSK Europe shares or is obliged to share your personal data with third parties, for the purposes described above and in accordance with applicable data protection laws. These third parties will act as controllers of your personal data in their own right, and they will be responsible for compliance with applicable data protection laws.
These third parties are:
- police, public prosecutors and law enforcement bodies;
- benefits providers;
- external advisors (such as legal advisors, accountants);
- pension trustees;
- tax officials.
6. What are your rights and how can you exercise them?
Where NSK Europe’s processing of your personal data is based solely upon your consent, you have the right to withdraw your consent at any time. If you decide to withdraw your consent NSK will stop processing your personal data for that purpose. This will not impact on the legality of any processing undertaken by us prior to the withdrawal of your consent.
Where our processing of your personal data is based on legitimate interests (see table at paragraph 3 above), you can object to this processing at any time. If you do this, we will need to show either a compelling reason why our processing should continue, which overrides your interests, rights and freedoms or that the processing is necessary for us to establish, exercise or defend a legal claim.
Where we are processing your personal data for direct marketing purposes, you have the right to object to that processing.
You have also the right to:
- request access your personal data and to be provided with certain information in relation to it, such as the purpose for which it is processed, the persons to whom it is disclosed and the period for which it will be stored;
- require us to correct any inaccuracies in your personal data without undue delay;
- require us to erase your personal data;
- require us to restrict processing of your personal data;
- request that we provide you with a copy of any personal data which you have provided to us, in a machine readable format, where we are processing it on the basis of your consent or because it is necessary for the performance of a contract between you and us (see table at paragraph 3 above) and where the processing is automated; and
- You may request to exercise any of your rights by sending an e-mail to: firstname.lastname@example.org.
You can also lodge a complaint with a competent data protection supervisory authority: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
7. Further information
In a case you would like to obtain further information about your data protection rights please contact us (or the respective data protection officer, where appointed) via the addresses below. If you have any concern about privacy issue, please contact us with a thorough description or write to: email@example.com.
|NSK Europe Ltd||Belmont Place, Belmont Road, Maidenhead, Berkshire SL6 6TB, UK|
|NSK Steering Systems Europe Ltd||South West Industrial Estate, 3 Brindley Rd, Peterlee SR8 2JD, UK|
|NSK Bearings Europe Ltd||South West Industrial Estate, 3 Brindley Rd, Peterlee SR8 2JD, UK; or|
|NSK Precision UK Ltd.||Northern Rd, Newark NG24 2JF, UK|
|NSK UK Ltd||Northern Rd, Newark NG24 2JF, UK|
|NSK Deutschland GmbH (incl. Wolfsburg, Stuttgart)||Harkortstr. 15, 40880 Ratingen, Germany|
|Neuweg Fertigung GmbH||Ehinger Str. 5, 89597 Munderkingen, Germany|
|Nsk European Distribution Centre B.V.||Brakman 54, 5047 SW Tilburg, the Netherlands|
|NSK Bearings Polska S.A.||ul. Jagiellońska 109, 25-734 Kielce, Poland|
|ISKRA Centrum Narzędzi Specjalnych sp. z o.o.||ul. Jagiellońska 109, 25-734 Kielce, Poland|
|NSK Needle Bearing Poland sp. z o.o.||ul. Jagiellońska 109, 25-734 Kielce, Poland|
|NSK Steering Systems Europe (Polska) sp. z o.o.||Mariana Jachimowicza 17, 58-306 Wałbrzych, Poland|
|NSK Polska sp. z o.o.||Karczówkowska 41, 25-001 Kielce, Poland|
|NSK France S.A.S.||2 Rue Georges Guynemer, 78280 Guyancourt, France|
|NSK Italia S.p.A.||Via Giuseppe Garibaldi, 215, 20024 Garbagnate Milanese MI, Italy|
|NSK Spain S.A.||Carrer de Tarragona, 161, 08014 Barcelona, Spain|
|NSK Europe Ltd||Belmont Place, Belmont Road, Maidenhead, Berkshire SL6 6TB, UK|
Date of issue: 05/03/2019