Privacy Policy for the United States

Effective Date: January 1, 2025

This Privacy Policy (this "Policy") describes how MAX collects, uses, and shares personal information regarding data subjects located in the United States in the course of operating our businesses.
In this Policy, any reference to MAX or “we” / “us” / “our”, means a reference to MAX CO., LTD.
Please note that this Policy only applies to MAX's processing of personal information regarding data subjects located in the United States.

Important information and who we are
MAX collects and processes your personal information in accordance with this Policy.
MAX is the data controller and is responsible for your personal information.
Our registered office is at MAX CO., LTD. Attn.: 6-6. Nihonbashi Hakozaki-cho, Chuo-ku, Tokyo, Japan. You can find our contact details in the "Contact Us" section below.
You have the right to make a complaint at any time to the relevant and competent data protection supervisory authority in your jurisdiction. We would, however, appreciate the chance to deal with your concerns before you approach such an authority, so please contact us in the first instance.
This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The data we collect about you
We collect and use the following personal information:
a. Customer data, including name; gender; contact details (home address, work email address, personal phone number); company name and address; department; title; signature specimens; contact preferences; date of birth; citizenship; and other information necessary for customer management;
b. Employee data, including name (including legal and preferred names); date of birth / age; gender; contact details (home address, home telephone number, personal mobile telephone number, and personal email address); passport details; background check results (including criminal record checks); interview feedback; position within the organization and working arrangement; business network / firm committees membership; employment history; travel and expenses information; and other information necessary for employment management;
c. Data on providers and/or users of competing and related products, including the name of an individual or company who is a provider and/or user of competing and related products; names, specifications, sales destinations, prices, number of units sold, rights and licenses of competing and related products; and other information necessary for the conduct of our business and the exercise of our rights; and
d. Technical data, including internet protocol (IP) address; your login data; browser type and version; time zone setting and location; browser plug-in types and versions; operating system and platform; and other technology on the devices you use to access this website.
We do not collect any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

How is your personal information collected?
We collect your personal information in the following ways:
a. Information that you provide to us: This includes information about you that you give us by filling in forms or by communicating with us, whether face-to-face, by phone, e-mail, or otherwise;
b. Information we collect or generate about you: This includes data from and about you through automated technologies or interactions. As you interact with our website, we will automatically collect technical data about your equipment, browsing actions, and patterns. We collect this personal information by using cookies and other similar technologies. Please see our cookie policy above for further details; and
c. Information we obtain from other sources: This includes data provided to us by our subsidiaries, third-party service providers, agencies, or other publicly available sources where applicable.

Purposes for which we will use your personal information
We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To provide our products and/or services to the relevant clients	Customer data	Necessary for the performance of a contract or to take steps at the request of the data subject prior to entering into a contract
To engage in marketing and business development activities in relation to the provision of our products and/or services.	Customer data	Necessary for our legitimate interests (to develop and grow our business)
To enable entering into a contract with an employee, and perform obligations and exercise rights under an employment contract	Employee data	Necessary for the performance of a contract or to take steps at the request of the data subject prior to entering into a contract
To manage the proper operation of the businesses, maintain consistent practices and procedures, maintain compliance with internal policies and procedures, and prevent, detect and manage criminal activities or threats, in relation to employment management	Employee data	Necessary for our legitimate interests (to carry out employment management)
To determine how to respond to others' products and/or services that are similar to or related to ours by collecting, analyzing, and considering data on their products and/or services	Data on providers and/or users of competing and related products	Necessary for our legitimate interests (to operate our businesses and exercise our rights)
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Technical data	Necessary for our legitimate interests (to study how our website is used and to develop and grow our business)
To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences	Technical data	Necessary for our legitimate interests (to develop our business and to inform our marketing strategy)

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis which allows us to perform such use.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How we share your personal information
We share your personal information with the following recipients:
a. Any of our affiliates and subsidiaries;
b. Our service providers, including IT infrastructure service providers, customer relationship management service providers, and website hosting and security service providers; and

International transfers
Whenever your personal information is transferred outside of the United States, we ensure a similar degree of protection is afforded to it by ensuring that we will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information, or via another appropriate safeguard (e.g. standard contractual clauses) should an adequacy decision not be in force in respect of a particular personal information transfer.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the United States.

Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors, and other third parties who have a business need to know the same. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put procedures in place to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention
We will only retain your personal information for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, as well as the applicable legal, regulatory, tax, accounting, or other requirements.

Your legal rights
Under certain circumstances, you have the following rights under data protection laws in relation to your personal information:

• Right to object to the processing: you have the right to object to the processing of your personal information in certain situations;

• Right to information: you have the right to be informed whether and to what extent we process your data;

• Right of access: subject to certain exceptions, you have the right to obtain a confirmation as to whether or not we process your personal information, and if we do, request access to your data;

• Right of rectification: if the personal information that we process is incomplete or incorrect, you have the right to request their completion or correction at any time;

• Right to deletion: subject to certain exceptions, if you consider that we should stop processing some or all of your personal information, you have the right to request its deletion. However, there may well be reasons why an immediate deletion may not be possible (such as where retention is required to meet legal or regulatory obligations);

• Right to restrict the processing: you have the right to request that we restrict the processing of your personal information;

• Right to data portability: where the processing takes place on the basis of your consent or contract, and is carried out by automated means, you have the right to request that we provide your personal information to you in a machine-readable format;

• Rights in relation to automated decision making and profiling: you have the right to object to decisions based exclusively on the automated processing of your personal information; and

• Right to withdraw your consent: if your personal information is processed on the basis of your consent, you have the right to withdraw your consent at any time. The withdrawal of your consent does not affect the lawfulness of processing based on consent before its withdrawal.

For California Residents
If you live in California, the California Consumer Protection Act of 2018 ("CCPA") provides you with the following rights with respect to Personal Information that we have collected about you:

✓You have the right to request that we disclose to you following information.

• The categories of personal information

• The categories of sources from which the personal information is collected

• The business or commercial purpose for collecting, selling, and sharing personal information

• The categories of third parties to whom we disclose personal information

• The specific pieces of your personal information

✓You have the right to request that we delete personal information it has collected about you.
✓You have the right to request that we correct inaccurate personal information it has collected about you.
✓You have the right to opt-out of sale or sharing of personal information collected about you.
✓You have the right not to receive discriminatory treatment by us for the exercise of privacy rights conferred by the CCPA.

To Request that we disclose to you the personal information related to you and exert any of these rights (a "Request to Know") or to request that we delete the personal information it has collected about you, email privacypolicy_corporate@mail.max-ltd.co.jp. California law requires that we verify your identity before responding to a Request to Know or a Request to Delete. To verify your identity, we will compare the information you provide on your request to the information we have in our system. We consider your identity to be verified if the information you provided to us matches the name we have in our system and at least two of the following pieces of information: email address, physical address, or telephone number.

California Consumers have the right to designate an authorized agent to make a Request to Know or a Request to Delete on their behalf. However, the process for designating an authorized agent for these purposes and the process by which we can verify your identity when a request is made on your behalf by a third person is still being developed by the California Attorney General at the time this Privacy Policy was last revised. Until the California Attorney General finalizes these procedures, we will not be able to honor a Request to Know or a Request to Delete unless it is submitted directly by a consumer.

Further, California law prohibits us from discriminating against any consumer who submits a Request to Know or a Request to Delete by, among other things, denying goods or services, charging different prices or rates for goods or services, providing a different level of quality of good or services, or suggesting that the consumer will receive a different price or rate for goods or services or a different level or quality of goods or services.

Mandatory personal information
Personal information that is mandatory to be provided is indicated in the relevant forms that you complete. In cases where the provision of personal information is mandatory, we are not able to provide our products and/or services to you if the relevant information is not provided.

Contact us
If you have any questions about this policy, please contact us: By email: privacypolicy_corporate@mail.max-ltd.co.jp Postal address: MAX CO., LTD. Attn.: 6-6. Nihonbashi Hakozaki-cho, Chuo-ku, Tokyo, Japan