Privacy Policy

About Acrathon

Enacted: July 21, 2020

Revised: July 1, 2021

Acrathon Precision Technologies (“APT”) is committed to respecting and protecting your personal data and privacy rights. We've structured our Web sites so that, in general, you can visit APT on the Web without identifying yourself or revealing any personal information. This Privacy Statement reflects the policies of https://www.acrathon.tdk.com.cn. We are committed to protecting the privacy of our customers and we use the information that we collect in order to facilitate a more personalized web browsing experience. Once you choose to provide us personally identifiable information (any information by which you can be identified), it will be used in accordance with law to support your customer relationship with APT.

Acrathon Precision Technologies (“APT”) is committed to the protection of personal data and privacy rights.

This APT Privacy Policy consists of the APT Personal Data Protection Basic Policy. It describes how APT processes personal data in compliance with applicable data protection and other laws and globally accepted data protection principles.

This Privacy Policy applies to all activities where APT processes personal data of individuals excluding APT’s personnel, which is governed by internal regulations. Data are personal, if the information contained therein relates to an identified individual or an individual that can be identified, directly or indirectly, by reference to an identifier or a combination of identifiers. Processing means any operation or set of operations on personal data whether or not by automated means and regardless whether electronically, physically in paper or any other form.

This Privacy Policy supplements the applicable data protection and other laws without replacing them. In case of a conflict or where an applicable law has stricter or additional requirements the law will take precedence over this Privacy Policy.

By accessing, browsing, or using APT’s website, you agree to the Terms of Use of the APT Website, this APT Privacy Policy and the APT Cookie Policy that supplements this Privacy Policy in respect of the use of Cookies on the APT Website.

APT Personal Data Protection Basic Policy

1. Scope of Application

This APT Personal Data Protection Basic Policy is part of APT’s Privacy Policy and describes the general rules how Acrathon Precision Technologies (“APT”) processes personal data

2. Personal Data Processing Principles

APT processes personal data in accordance with the following principles:

2.1 Lawfulness, Fairness and Transparency

Personal data are processed on basis of the applicable legal permission and in compliance with applicable laws (lawfulness), in consideration of the interests of the affected individual (fairness) and together with reasonable provision of information including the identity of the legal person that controls and is accountable for the processing of personal data (data controller), the purpose of the processing, associated risks, and necessary safeguards (transparency).

2.2 Purpose Limitation

Personal data are processed for a specified, explicit and legitimate purpose and are no further processed in a manner that is incompatible with that purpose.

2.3 Data Minimization

Personal data are adequate, relevant and limited to what is necessary in relation to the purpose for which they are processed.

2.4 Accuracy

Personal data are kept accurate and, where necessary, up to date; every reasonable step is taken to ensure that personal data that are inaccurate in respect to the purpose for which they are processed, are erased or rectified without delay.

Storage Limitation

Personal data are kept in a form which permits identification of the affected individual for no longer than necessary for the purpose for which the personal data are processed.

2.5 Integrity and Confidentiality

Personal data are processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures. Personal data protection is taken into account when new processes are planned and implemented. Technical and organizational measures at APT are continuously adjusted.

3. Business Partner Data

In course of its business operations, APT processes data of its customers, suppliers, agents, providers, sub-contractors, consultants, advisors, journalists, users that access, browse or otherwise use APT’s website or third party websites on which APT has posted advertisements and other current and potential business partners (“Business Partners”). These data may also include personal data of Business Partners and in case Business Partners are corporations, of individuals affiliated with Business Partners.

3.1 Data Categories

Data processed include first, middle and last name, academic title, professional status, position, postal address, e-mail address, telephone number, login-in data, online identifiers, IP addresses and other personal data reasonably related to the business relationship with APT.

3.2 Data Sources

Personal data are obtained through direct and indirect online and offline sources. Direct sources include business cards, e-mails, facsimiles, letters, surveys, and other electronic or non-electronic communication and interaction between APT and an individual in course of a potential or existing business relationship. Indirect sources include publicly available data collected by APT, data of users that access, browse or otherwise use APT’s website or third party websites on which APT has posted advertisements and data received from third parties including APT and other Business Partners in compliance with applicable laws.

3.3 Processing Purposes

Personal data are processed for APT’s business operations, including Business Partner relationship management, research and development, manufacturing, enterprise resource planning, data analysis for supply, online and offline marketing and sales activities, market observance and orientation, provision of product and service information, making and answering requests and inquiries, making and accepting quotes, offers, and any communication, cooperation, and other activities reasonably related to APT’s business operations.

3.4 Permission

Personal data are processed in compliance with applicable laws on basis of the applicable legal permission, in particular the initiation and performance of a contract, where the individual has given consent to the processing, where the processing is necessary for compliance with a legal obligation to which APT is subject to and where the processing of personal data is in the legitimate interest of APT. Legitimate interests are the development, nurturing and enhancement of existing and initiation of new business relationships and any activities related thereto to pursue APT’s business operations.

4. Recruitment Data

In course of its business operations, APT processes data related to the recruitment of new personnel. These data may also include personal data of individuals.

4.1 Data Categories

Data processed include first, middle and last name, academic title, professional status, position, birth date, personal status, work history, current position and former positions, education, postal address, e-mail address, telephone number, login-in data, online identifiers, IP addresses and other personal data reasonably related to the recruitment of new personnel.

4.2 Data Sources

Personal data are obtained through direct and indirect online and offline sources. Direct sources include business cards, job applications, e-mails, facsimiles, letters, meetings, and other electronic or non-electronic communication and interaction between an individual and APT in course of a job application. Indirect sources include publicly available data, data of users that access, browse or otherwise use APT’s website or third party websites on which APT has posted advertisements and data received in compliance with applicable laws from third parties including APT Subsidiaries/affiliates and other Business Partners in course of a recruitment process, e.g. recruiting agencies and HR service providers.

4.3 Processing Purposes

Personal data are processed for searching and recruiting new personnel for APT’s business operations including any activities reasonably related thereto.

4.4 Permission

Personal data are processed in compliance with applicable laws on basis of the applicable legal permission, in particular where necessary for the job application and the initiation of an employment relationship with APT, where the individual has given consent to the processing, where the processing is necessary for compliance with a legal obligation to which APT is subject and where the processing of personal data is in the legitimate interest of APT. Legitimate interests are the processing of the job application to find and recruit skilled personnel for APT and APT subsidiaries/affiliates and any activities related thereto.

5. Cookie Policy

We and our third-party service providers DO NOT use cookies on our websites. We may collect cookies in the future and this Privacy Policy will be updated if we choose to collect cookies.

Below is how we classify cookies:

Strictly Necessary Cookies: cookies that are necessary to the operation and functionality of our websites, such as technologies that give you access to our services, or to identify security-related issues.

Functional Cookies: cookies that perform functions such as remembering login information, language preference, locations, and IP addresses.

Performance Cookies: cookies that allow us to measure the performance and use of our websites.

Marketing Cookies: cookies that we or our third-party service providers may use to tailor advertisements to you based on your browsing history. Please note that we do not have control over the marketing cookies placed on our websites by our third party service providers, such as when that third party service provider tracks your online activities from our websites to unaffiliated third party websites, and delivers you targeted advertising. In those instances, the use of cookies is covered by that third party’s terms of use, privacy policy or cookie policy, and not by this Privacy Policy.

There are several ways for you to decline the use of certain types of functional, performance and marketing cookies, including modifying your internet browser’s settings. Please note that if you disable these types of cookies, your browser may not display content correctly, or you may be unable to use certain functionalities of our websites.

6. Retention Periods

Personal data will be removed from APT’s systems and records and/or steps are taken to anonymize data if processing is no longer required for the original purpose unless it is necessary to keep personal data to comply with a legal obligation to which APT is subject, e.g. statutory retention periods under applicable laws including commercial and tax laws or where APT has a legitimate interest to retain information in compliance with applicable laws, e.g. for filing, enforcing or defending legal claims. APT has installed and maintains retention policies in compliance with applicable data protection and other laws.

7. Transfer of Personal Data

Acrathon Precision Technologies (“APT”) is part of the TDK Group of Companies with joint business operations (https://www.tdk.com/corp/en/worldwide/index.htm). APT may transfer data including personal data to other TDK Group Companies, Business Partners, courts, law enforcement agencies, government authorities, other public bodies and other third parties, which may have access to and/or process personal data. Transfers are made on a need to know basis in compliance with applicable laws and agreements with Business Partners.

7.1 Transfer to TDK Group Companies

Purpose of data transfers to other TDK Group Companies (https://www.tdk.com/corp/en/worldwide/index.htm) is the support the business operations of APT within the TDK Group of Companies and the joint utilization of data. This may include joint business operations and the outsourcing of internal functions and the utilization of external resources, e.g. procurement and manufacturing, marketing, data analysis, Business Partner relationship management, research and development, education, administration, IT functions, HR functions, compliance with corporate organization and corporate governance rules and other activities reasonably related to APT’s business operations. Categories of personal data transferred are described in 3.1 and 4.1 above.

TDK Group Companies that act as service providers are contractually bound to take appropriate technical and organizational security measures to safeguard and process personal data only as instructed by APT. The same applies to any sub-providers of APT’s service providers.

7.2 Transfer to Business Partners

Purpose of data transfers to Business Partners is to outsource internal functions and utilize external resources, e.g. IT services, HR, recruiting, marketing activities, marketing data analysis, administration of campaigns, offline and online advertisement, publishing, design, legal, tax, financial advisory services and other activities reasonably related to APT’s business operations.

Business Partners that act as service providers for APT are contractually bound to take appropriate technical and organizational security measures to safeguard and process personal data only as instructed by APT. The same applies to any sub-providers of Business Partners’ service providers.

7.3 Transfer to government authorities, courts, law enforcement agencies

Purpose of data transfer to government authorities, courts, law enforcement agencies and other public bodies is to comply with obligations to which APT is subject to under applicable laws, e.g. -transfer and disclosure obligations under social security law, civil procedure law, tax, import and export laws.

8. Transfer of Personal Data to other Countries

To the extent personal data are transferred to and processed in other countries than where APT is established, APT transfers personal data in compliance with applicable laws and has established appropriate safeguards by means of data processing and data transfer agreements that oblige the recipient in the other country to establish and adhere to an adequate level of data protection.

9. Information Obligations

In compliance with applicable laws, APT informs individuals about its personal data processing activities as described in the APT Privacy Policy and the APT Cookie Policy. APT provides amongst others on and offline references to the APT Privacy Policy on APT’s website, electronic or non-electronic communication with individuals and electronic or non-electronic business documents to promote its data privacy activities.

10. Consent and Withdrawal of Consent

Where required under applicable data protection and other laws, APT processes any data only after consent. Providing consent and data is voluntary. Before obtaining consent, APT will duly inform each individual about the respective processing activity. Without providing data, an individual may not be able to engage with APT in respect of APT’s business operations.

A consent can be withdrawn at any time with future effect by e-mail to privacy@acrathon.com. A withdrawal will not affect the lawfulness of the processing prior to the withdrawal.

11. Rights of Individuals

Where APT processes personal data of individuals, each individual may exercise its rights under applicable laws.

Any rights can be exercised by sending an e-mail to privacy@acrathon.com.

In addition, each individual may lodge a complaint with a competent data protection supervisory authority.

12. Change Management

APT may change the APT Personal Data Protection Basic Policy and APT Cookie Policy at any time and without explicit notice. The enactment date and the date of the last revision is shown in the respective document and any prior versions can be requested from APT.