Addendum for Individuals in EEA

Last Updated: March 12, 2021

If you are an individual in the European Economic Area (the “EEA”,

comprising the European Union member states as well as Iceland,

Liechtenstein and Norway), this addendum applies to you. This addendum

supplements our privacy policy (the “Policy”) and prevails over any conflicting

provisions in the Policy.

could be, in particular, to merchandise our services, to conduct market

research and to analyze trends, as well as to develop new services and

products (more information on the balancing test is available upon

request).

ii. Consent. In case we obtain consent from you, we may process your

personal data based on other legal grounds, but only as far as such

processing is not already covered by your consent.

2. Your rights

Please note that these rights might be limited under applicable national data

protection law.

circumstances. This may include (but is not limited to) circumstances in

which:

(i) it is no longer necessary for us to retain your personal data for the

(ii) we are only entitled to process your personal data with your consent,

(iii) you object to our processing of your personal data for our

circumstances in which:

(i) you dispute the accuracy of your personal data (but only for the period

(ii) we no longer need to use your personal data for our processing, but

(iii) you object to our processing your personal data for our

v. the right to object to us about our processing of your personal data;

basis of your consent or for the performance of a contract with you (as

opposed to any other legal ground) in a structured, commonly used and

machine-readable format and/or request that we transmit that data to a

recipient where this is technically feasible. Please note that this right only

applies to personal data which you have provided to us, and on the

condition that the processing is carried out by automated means;

been infringed by us.

The provision of personal data is necessary for the conclusion of the contract

between us and/or the performance of the services provided by us, and it is

voluntary. However, if you do not provide the personal data, the provision of

the services might be delayed or impossible.

3. Data Transfer Outside EEA countries and UK

Personal data is transferred to us in Japan. The EU Commission has made

an adequacy decision to the effect that an adequate level of data protection

exists in Japan.

to the effect that an adequate level of data protection exists in these third

countries, we will take other measures to implement appropriate guarantees

for the protection of your personal data in accordance with the GDPR.

Personal data is only transferred to external recipients in third countries if they

have concluded EU standard contractual clauses with us.

For further information on the respective guarantee, please refer to the

Further information and a copy of the implemented measures can be obtained

upon request from us (see the information about us indicated in Section 10 of

the Policy).

to achieve the purposes for which the information is collected, in accordance

with applicable data protection laws. When we no longer need to use your

personal data to comply with contractual or statutory obligations, we will

remove it from our systems and records and/or take steps to properly

anonymize it so that you can no longer be identified from it, unless we need

to keep your personal data to comply with legal or regulatory obligations to

which we are subject, e.g. statutory retention periods which can result from

commercial and tax laws and usually contain retention periods from six to ten

5. Automated Decision-Making

If you have any questions about the Policy, this addendum, your rights, or any

other issues regarding the protection of your personal data, or if you wish to

exercise any of your rights, you may contact us as follows: