TDK-Lambda Singapore Pte. Ltd. (“TDK-Lambda”) is committed to the protection of personal data and privacy rights.

This TDK-Lambda Privacy Policy consists of the TDK-Lambda Personal Data Protection Basic Policy and the Policy for the Handling of Personal Data on TDK-Lambda’s website (accessed via https://www.sg.lambda.tdk.com/) (“Website”). It describes how TDK-Lambda collects, uses, discloses, transfers and/or processes personal data in the course of its business and in accordance with the applicable laws.

This Privacy Policy applies to all activities where TDK-Lambda collects, uses, discloses, transfers and/or processes personal data of individuals excluding TDK-Lambda’s personnel, which is governed by internal regulations. Personal data means data about an individual that can be identified from that data or from that data and other information to which TDK-Lambda has or is likely to have access. Processing means the carrying out of any operation or set of operations on personal data in relation to the personal data, and would include, recording, holding, organisation, adaptation or alteration, retrieval, combination, transmission, erasure or destruction. By providing TDK-Lambda with your personal data, accessing or using the Website, you consent to our collection, use, disclosure, transfer and/or processing of your personal data in accordance with this Privacy Policy. Please DO NOT provide any personal data to TDK-Lambda if you do not accept this Privacy Policy. Information provided by organisations to TDK-Lambda for business purposes is not considered personal data.

TDK-Lambda Personal Data Protection Basic Policy

Enacted: June 7, 2005
Revised: May 7, 2022

1. Scope of Application
   This TDK-Lambda Personal Data Protection Basic Policy is part of TDK-Lambda’s Privacy Policy and describes the general rules how TDK-Lambda collects, uses, discloses, transfers and/or processes an individual’s personal data. For personal data collected by TDK-Lambda through its Website and/or third party websites on which TDK-Lambda has posted advertisements, please also refer to TDK-Lambda’s Policy for the Handling of Personal Data on TDK-Lambda Websites.
2. Personal Data Processing Principles
   TDK-Lambda collects, uses, discloses, transfers and/or processes personal data in accordance with the following principles:
   • Lawfulness, Fairness and Transparency
     Personal data are collected, used, disclosed, transferred and/or 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 for the collection, use, disclosure, transfer and/or processing of the personal data, associated risks, and necessary safeguards (transparency).
   • Purpose Limitation
     Personal data are collected, used, disclosed, transferred and/or processed for purposes connected to or relevant to TDK-Lambda’s business. Such purposes would include the purposes set out at Section 4 below, at TDK-Lambda’s Policy for the Handling of Personal Data on TDK-Lambda Websites, and the following purposes:
     1. any purpose that may be informed to you when your personal data is collected;
     2. managing your relationship with TDK-Lambda;
     3. providing you with the products and/or services that you have requested for;
     4. carrying out your transactions with us and/or taking steps as may be directed by you;
     5. administration of contests, competitions, promotions, events and activities you have registered for or participate in;
     6. providing you with relevant information and updates concerning our products and/or services;
     7. processing payment or credit transactions;
     8. engaging third party service providers to perform certain aspect of services provided by us (for example, delivery services);
     9. administrative purposes, including finance, IT and HR purposes, quality assurance and staff training, and compliance with internal policies and procedures, including audit, accounting, risk management and record keeping;
     10. carrying out research and statistical analysis;
     11. responding to, handling, and processing enquiries, requests, applications (including job applications) and feedback from you;
     12. resolving any disputes, investigating any complaint, claim or dispute or any actual or suspected illegal or unlawful conduct;
     13. enforcing legal obligations owed to us, or to respond to complaints, litigation or investigations concerning us;
     14. complying with any applicable laws, governmental or regulatory requirements of any relevant jurisdiction (and any applicable rules, codes of practice or guidelines), including, without limitation, meeting the requirements to make disclosure under the requirements of any applicable law or assisting in law enforcement and investigations by relevant authorities;
     15. security and safety purposes; and/or
     16. any other reasonable purposes related to the aforesaid.

     TDK-Lambda may also collect, use, disclose and process an individual’s personal data for other purposes, without their knowledge or consent, where this is required or permitted by law.

     If you have provided us with your consent, TDK-Lambda may use your personal data for the purposes of marketing our products and services and those of our partners and business associates (e.g. informing you of our latest activities, special offers and promotions). In order for us to market products and services which are of special interest and relevance to you, we may analyse and rely on your overall interaction with us (such as but not limited to your interactions with us).

   • Data Minimization
     Personal data are adequate, relevant and limited to what is necessary in relation to the purpose for which they are collected, used, disclosed, transferred and/or processed.
   • 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 collected, used, disclosed, transferred and/or processed for.
   • Protection
     Personal data are collected, used, disclosed, transferred and/or 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 TDK-Lambda are continuously adjusted.
3. Business Partner Data
   In course of its business operations, TDK-Lambda processes data of its customers, suppliers, agents, providers, sub-contractors, consultants, advisors, journalists, users that access, browse or otherwise use TDK-Lambda’s website or third party websites on which TDK-Lambda 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 TDK-Lambda.
   • 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, data collected via active entries on TDK-Lambda’s website and other electronic or non-electronic communication and interaction between TDK-Lambda and an individual in course of a potential or existing business relationship. Indirect sources include publicly available data collected by TDK-Lambda, data of users that access, browse or otherwise use TDK-Lambda’s website or third party websites on which TDK-Lambda has posted advertisements and data received from third parties including TDK Group Companies and other Business Partners in compliance with applicable laws.
   • 3.3 Processing Purposes
     Personal data are processed for TDK-Lambda’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 TDK-Lambda’s business operations.
     Data analysis activities may comprise automated processing including the profiling of individuals affiliated with Business Partners. TDK-Lambda may in particular combine data from the above-described direct and indirect online and offline sources and analyze or predict preferences, interests, reliability, behavior, location, movements and other activities of Business Partners and in case Business Partners are corporations, of individuals affiliated with Business Partners. TDK-Lambda conducts such analysis activities to understand the needs of its Business Partners, in particular to enhance, develop, present and provide new products to them, online and offline.
     Online activities include targeted advertisements on TDK-Lambda’s website and in user accounts, online newsletters by e-mail or other electronic means, promotional campaigns and other activities reasonably related to TDK-Lambda’s business operations.
     Offline activities include the delivery of marketing and other promotional material including samples by mail and other activities reasonably related to TDK-Lambda’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 TDK-Lambda is subject to and where the processing of personal data is in the legitimate interest of TDK-Lambda. Legitimate interests are the development, nurturing and enhancement of existing and initiation of new business relationships and any activities related thereto to pursue TDK-Lambda’s business operations.
4. Recruitment Data
   In course of its business operations, TDK-Lambda collects, uses, discloses, transfers and/or processes data related to the recruitment of new personnel. These data may also include personal data of individuals.
   • 4.1 Data Categories
     Data collected, used, disclosed, transferred and/or 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, entries on TDK-Lambda’s website and other electronic or non-electronic communication and interaction between an individual and TDK-Lambda in course of a job application. Indirect sources include publicly available data, data of users that access, browse or otherwise use TDK-Lambda’s website or third party websites on which TDK-Lambda has posted advertisements and data received in compliance with applicable laws from third parties including TDK Group Companies and other Business Partners in course of a recruitment process, e.g. recruiting agencies and HR service providers.
   • 4.3 Purposes
     Personal data are collected, used, disclosed, transferred and/or processed for searching and recruiting new personnel for TDK-Lambda’s business operations including any activities reasonably related thereto.
   • 4.4 Permission
     Personal data are collected, used, disclosed, transferred and/or 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 TDK-Lambda, where the individual has given consent to the processing, where the processing is necessary for compliance with a legal obligation to which TDK-Lambda is subject and where the processing of personal data is in the legitimate interest of TDK-Lambda.
     Legitimate interests are the processing of the job application to find and recruit skilled personnel for TDK-Lambda and TDK Group Companies and any activities related thereto.
5. Website Data
   For information about the processing of personal data on TDK-Lambda’s website and third party websites, please refer to Policy for the Handling of Personal Data on TDK-Lambda Websites.
6. Retention Periods
   Personal data will be removed from TDK-Lambda’s systems, and records and/or steps are taken to anonymize personal data which is no longer required for the original purpose, unless it is necessary to keep the personal data to comply with a legal obligation to which TDK-Lambda is subject, e.g. statutory retention periods under applicable laws including commercial and tax laws or where TDK-Lambda has a legitimate interest to retain information in compliance with applicable laws, e.g. for filing, enforcing or defending legal claims. TDK-Lambda has installed and maintains retention policies in compliance with applicable data protection and other laws.
7. Transfer of Personal Data
   TDK-Lambda is part of the TDK Group of Companies with joint business operations (https://www.tdk.com/corp/en/worldwide/index.htm). TDK-Lambda 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 TDK-Lambda 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 TDK-Lambda’s business operations. The types of personal data transferred are described in sections 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 TDK-Lambda. The same applies to any sub-providers of TDK-Lambda’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 TDK-Lambda’s business operations.
     Business Partners that act as service providers for TDK-Lambda are contractually bound to take appropriate technical and organizational security measures to safeguard and process personal data only as instructed by TDK-Lambda. 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 TDK-Lambda 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 countries other than Singapore, you fully understand and unambiguously consent that TDK-Lambda may transfers personal data to any location outside of Singapore for the purposes set out above and in compliance with applicable laws. TDK-Lambda is committed to safeguarding your personal data when it is transferred across jurisdictions. TDK-Lambda has established appropriate safeguards by means of data processing and data transfer agreements, and binding corporate rules 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, TDK-Lambda informs individuals about its personal data processing activities as described in the TDK-Lambda Privacy Policy. TDK-Lambda provides amongst others on and offline references to the TDK-Lambda Privacy Policy on TDK-Lambda’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, TDK-Lambda will only collect, use, disclose, transfer and/or process any individual’s personal data only after obtaining consent from the individual. Providing consent and data is voluntary. Before obtaining consent, TDK-Lambda will duly inform each individual about the purposes for which the personal data will be collected, used, disclosed, transferred and/or processed for
    A consent can be withdrawn at any time with future effect by e-mail to sec-privacy@tdk.comor by sending a withdrawal notice to the contact stated under section 12 below. A withdrawal will not affect the lawfulness of the processing prior to the withdrawal. However, if you withdraw your consent to any or all use of your personal data or do not consent to the collection, use, disclosure, transfer and/or processing of your personal data by TDK-Lambda, TDK-Lambda may not be able to provide or continue providing you with the products and/or services which you have requested.
11. Rights of Individuals
    Where TDK-Lambda collects, uses, discloses, transfers and/or processes personal data of individuals, each individual may exercise its following rights under applicable laws:
    • a. Access: An individual has the right to request for access to their personal data held by TDK-Lambda.
    • b. Correction: The individual must ensure that all personal data provided to TDK-Lambda is true, accurate and complete. The individual is responsible for informing TDK-Lambda of any changes to your personal data, and the individual has the right to request for the correction of their personal data which is inaccurate.
    • c. Right to Data Portability: Each individual may request the transfer of certain of their personal data to another party under certain conditions.
    • d. Erasure: Each individual may request for the deletion or removal of the personal data that TDK-Lambda hold about the individual in certain circumstances.
    • e. Restriction: Each individual may withdraw consent for TDK-Lambda’s use of their personal data (see section 10 above), or ask TDK-Lambda to suspend the processing of certain of their personal data about them, for example if the individual wants TDK-Lambda to establish its accuracy.
    • f. Objection: Each individual has the right to object to the processing of their personal data by TDK-Lambda.

    Any rights can be exercised by sending an e-mail to TLJ.sec-privacy@tdk.com or to the contact details stated under section 12 below. The individual may be required to submit certain forms or provide certain information in order for their request to be processed. Where permitted by law, TDK-Lambda may charge a fee to process such request. In addition, each individual may lodge a complaint with a competent data protection supervisory authority (i.e. Singapore’s Personal Data Protection Commission).

12. TDK-Lambda Personal Data Protection Organization
    TDK-Lambda controls and is accountable for the collection, use, disclosure, transfer and/or processing of personal data within its operations (data controller).
    TDK-Lambda maintains a personal data protection organization, which serves as point of contact for all inquiries regarding the collection, use, disclosure, transfer and/or processing of personal data by TDK-Lambda.Contact us at:
    2-5-1 Nihonbashi
    Chuo-Ku
    Tokyo 103-6128
    Japan
    Email address: TLJ.sec-privacy@tdk.com
13. Change Management
    TDK-Lambda may amend the TDK-Lambda Personal Data Protection Basic Policy, the Policy for the Handling of Personal Data on TDK-Lambda Websites at any time and without 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 TDK-Lambda.

Policy for the Handling of Personal Data on TDK-Lambda Websites

1. Scope of Application
   This Policy for the Handling of Personal Data on TDK-Lambda Websites is part of TDK-Lambda’s Privacy Policy, and the terms under the TDK-Lambda Personal Data Protection Basic Policy would similarly apply.
   It describes how TDK-Lambda collects, uses, disclosures, transfers, and/or processes data of users that access, browse or otherwise use the Website or third party websites on which TDK-Lambda has posted advertisements (“Users”). These data include also personal data that Users actively send, transmit or otherwise provide on TDK-Lambda’s website..
2. Purposes
   • 2.1 Services
     TDK-Lambda collects, uses, discloses, transfers and/or processes data including personal data for providing the following services in connection with its business operations (“Services”):
     • 2.1.1 User Accounts
       After registration, TDK-Lambda offers personalized User accounts that allow access to product information and services and other information reasonably related to TDK-Lambda’s business operations.
     • 2.1.2 Inquiries and Requests
       TDK-Lambda offers individuals the possibility to make online inquiries and requests regarding its products and services and strives to revert to the inquirer in due time.
     • 2.1.3 Newsletters
       After registration, TDK-Lambda offers online newsletters by e-mail or other electronic means. Newsletter comprise information about TDK-Lambda’s products, services, events, seminars, exhibitions, campaigns and other information reasonably related to TDK-Lambda’s business operations.
     • 2.1.4 Information Download
       After registration, TDK-Lambda offers information about products and services and other information reasonably related to TDK-Lambda’s business operations.
     • 2.1.5 Promotional Campaigns
       TDK-Lambda invites Users to take part in online promotional and other campaigns to bring TDK-Lambda’s products and services and other information reasonably related to TDK-Lambda’s business operations to the attention of current and potential customers and the wider public. TDK-Lambda asks individuals to provide their comments and opinions about TDK-Lambda’s products and services. TDK-Lambda may also send materials and samples and other giveaways and information offline to Users participating in the campaigns.
     • 2.1.6 Recruitment
       TDK-Lambda may offer information about job vacancies of any kind on its website and invite individuals to file applications via TDK-Lambda’s website.
     • 2.1.7 PC and Mobile Application Software
       TDK-Lambda offers software for specific services and functions alone or in together with TDK-Lambda’s products, services and other activities reasonably related to TDK-Lambda’s business operations. TDK-Lambda provides certain support services like software and firmware support. Software applications may create crash reports that help TDK-Lambda and third party software developers to resolve any issues with the software.
       Where required under applicable data protection and other laws, TDK-Lambda processes data only after the consent of the User. Providing consent and data is voluntary. Before obtaining any consent, TDK-Lambda will duly inform each individual about the respective processing activity. Without providing data, a User may still access, browse or otherwise use TDK-Lambda’s website but may not able to benefit from some or all of the Services.
       Regarding the withdrawal of a consent and other rights of Users, please refer to the TDK-Lambda Personal Data Protection Basic Policy.
   • 2.2 Marketing
     For its marketing activities TDK-Lambda collects, uses, discloses, transfers and/or processes data that Users have actively sent, transmitted or otherwise provided on TDK-Lambda’s website for Services (see section 2.1 of the Policy for the Handling of Personal Data on TDK-Lambda Websites ).
     TDK-Lambda analyses such data alone or in combination or together with other data including personal data TDK-Lambda has lawfully received. Data analysis activities may comprise automated processing including profiling. TDK-Lambda may in particular combine data from the above-described direct and indirect online sources and offline sources and analyze or predict preferences, interests, reliability, behavior, location, movements and other activities of Users. TDK-Lambda conducts such analysis to understand the needs of the Users, in particular to enhance, develop, present and provide new products to them, online and offline.
     Online activities include targeted advertisements on TDK-Lambda’s website and in User accounts, online newsletters by e-mail or other electronic means, promotional campaigns and other activities reasonably related to TDK-Lambda’s business operations.
     Offline activities include the delivery of marketing and other promotional material including samples by mail and other activities reasonably related to TDK-Lambda’s business operations.
     Where required under applicable data protection and other laws, TDK-Lambda collects, uses, discloses, transfers and/or processes data only after the consent of the User. Providing consent and data is voluntary. Before obtaining any consent, TDK-Lambda will duly inform each individual about the respective processing activity. Without providing data, a User may still access, browse or otherwise use TDK-Lambda’s website but may not able to benefit from some or all of the Services.
     Regarding the withdrawal of a consent and further rights of Users, in particular to object at any time to the processing of its personal data for direct marketing purposes, which includes profiling, please refer to the TDK-Lambda Personal Data Protection Basic Policy.