TDK Privacy Policy

TDK Privacy Policy

TDK - Micronas GmbH (“TDK”) is committed to the protection of personal data and privacy rights.

This TDK Privacy Policy consists of the TDK Personal Data Protection Basic Policy and the Policy for the Handling of Personal Data on TDK Websites. It describes how TDK processes personal data in compliance with applicable data protection and other laws and globally accepted data protection principles including the German Federal Data Protection Act  and the Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation, “GDPR”).

This Privacy Policy applies to all activities where TDK processes personal data of individuals excluding TDK’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 TDK’s website, you agree to the Terms of Use of the TDK Website, this TDK Privacy Policy and the TDK Cookie Policy that supplements this Privacy Policy in respect of the use of Cookies on the TDK Website.

TDK Personal Data Protection Basic Policy

1. Scope of Application

This TDK Personal Data Protection Basic Policy is part of TDK’s Privacy Policy and describes the general rules how TDK - Micronas GmbH (“TDK”) processes personal data.

2. Personal Data Processing Principles

TDK processes personal data in accordance with the following principles:

(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) 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. 

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

(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.

(5) 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. 

(6) 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 TDK are continuously adjusted.

3. Business Partner Data

In course of its business operations, TDK processes data of its customers, suppliers, agents, providers, sub-contractors, consultants, advisors, journalists, users that access, browse or otherwise use TDK’s website or third party websites on which TDK 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. Additional information on the data process is provided in Policy for the Handling of Personal Data on TDK Websites and TDK Cookie Policy. 

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’s website and other electronic or non-electronic communication and interaction between TDK and an individual in course of a potential or existing business relationship. Indirect sources include publicly available data collected by TDK, data of users that access, browse or otherwise use TDK’s website or third party websites on which TDK 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’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’s business operations.

Data analysis activities may comprise automated processing including the profiling of individuals affiliated with Business Partners. TDK 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 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’s website and in user accounts, online newsletters by e-mail or other electronic means, promotional campaigns and other activities reasonably related to TDK’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’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 is subject to and where the processing of personal data is in the legitimate interest of TDK. Legitimate interests are the development, nurturing and enhancement of existing and initiation of new business relationships and any activities related thereto to pursue TDK’s business operations.

4. Recruitment Data

In course of its business operations, TDK processes data related to the recruitment of new personnel. These data may also include personal data of individuals. Additional information is provided in the Policy for the Handling of Personal Data on TDK Websites.

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, entries on TDK’s website and other electronic or non-electronic communication and interaction between an individual and TDK in course of a job application. Indirect sources include publicly available data, data of users that access, browse or otherwise use TDK’s website or third party websites on which TDK 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. Processing Purposes

Personal data are processed for searching and recruiting new personnel for TDK’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 TDK, where the individual has given consent to the processing, where the processing is necessary for compliance with a legal obligation to which TDK is subject and where the processing of personal data is in the legitimate interest of TDK. Legitimate interests are the processing of the job application to find and recruit skilled personnel for TDK and TDK Group Companies and any activities related thereto. 

5. Website Data and Cookies

For information about the processing of personal data on TDK’s website and third party websites, please refer to Policy for the Handling of Personal Data on TDK Websites and to the TDK Cookie Policy.

6. Retention Periods

Personal data will be removed from TDK’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 TDK is subject, e.g. statutory retention periods under applicable laws including commercial and tax laws or where TDK has a legitimate interest to retain information in compliance with applicable laws, e.g. for filing, enforcing or defending legal claims. TDK has installed and maintains retention policies in compliance with applicable data protection and other laws.

7. Transfer of Personal Data

TDK is part of the TDK Group of Companies with joint business operations (https://www.tdk.com/corp/en/worldwide/index.htm). TDK 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 within the TDK Group of Companies and the joint utilization of data as joint controller together with other TDK Group Companies. 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’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 TDK. The same applies to any sub-providers of TDK’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’s business operations. 

Business Partners that act as service providers for TDK are contractually bound to take appropriate technical and organizational security measures to safeguard and process personal data only as instructed by TDK. 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 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 TDK is established, TDK 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, TDK informs individuals about its personal data processing activities as described in the TDK Privacy Policy and the TDK Cookie Policy. TDK provides amongst others on and offline references to the TDK Privacy Policy on TDK’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 processes any data only after consent. Providing consent and data is voluntary. Before obtaining consent, TDK will duly inform each individual about the respective processing activity. Without providing data, an individual may not be able to engage with TDK in respect of TDK’s business operations.

A consent can be withdrawn at any time with future effect by e-mail to Datenschutz@Micronas.com or by sending a withdrawal notice to the contact stated under 12. below. A withdrawal will not affect the lawfulness of the processing prior to the withdrawal.

11. Rights of Individuals

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

12. TDK Personal Data Protection Organization

TDK - Micronas GmbH controls and is accountable for the processing of personal data within its operations (data controller).

TDK maintains a personal data protection organization, which serves as point of contact for all inquiries regarding the processing of personal data by TDK. 

TDK - Micronas GmbH
Hans-Bunte-Strasse 19, D-79108 Freiburg, 
Germany
Phone +49 761 517-0
Fax +49 761 517-2174
www.micronas.tdk.com
datenschutz@micronas.com

You can reach the data protection officer by post at the above address with the addition "Attn. Data protection officer” and by email at Datenschutz@Micronas.com.

13. Change Management

TDK may change the TDK Personal Data Protection Basic Policy, the Policy for the Handling of Personal Data on TDK Websites and the TDK 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 TDK.

Policy for the Handling of Personal Data on TDK Websites

1. Scope of Application

This Policy for the Handling of Personal Data on TDK Websites is part of TDK’s Privacy Policy. 

It describes how TDK-Micronas GmbH (“TDK”) processes data of users that access, browse or otherwise use TDK’s website or third party websites on which TDK has posted advertisements (“Users”), namely

  • your visit to our website and our social media presence,
  • using the contact form,
  • the use of the internal service area,
  • of job advertisements,
  • of sending the newsletter


(hereinafter collectively "website") collect the purposes for which we use this data and how we use it to optimize our services for you. These data include also personal data that Users actively send, transmit or otherwise provide on TDK’s website and that TDK collects or otherwise obtains via cookies. 

For detailed information about the use of cookies please refer to the TDK Cookie Policy.

2. Types of data processed, categories of data subjects

2.1. Type of data processed

  • Contact details (e.g., email, phone numbers)
  • Content data (e.g. text input, photographs, videos)
  • Application data and documents you have uploaded
  • Usage data (e.g. websites visited, interest in content, access times)
  • login data
  • Communication data and history
  • Geolocation
  • Selected preferences, e.g. language and cookie settings
  • Meta/ communication data (e.g., device information, IP addresses)
  • Tracking data
  • Range measurement
  • Data according to Art. 4 and the TDK Cookie Policy


2.2 Categories of Data Subjects

  • Visitors and users of the website and online offers
  • clients, prospective customers and business partners
  • Applicants
  • Newsletter subscribers and direct marketing in existing customer relationships
  • Other communication partners


3. Purposes

TDK use your personal data

  • For providing the website and the online offer, its features and content,
  • For answering contact inquiries and communicating with users,
  • in the context of applications,
  • security measures,
  • for range measurement,
  • for the purpose of direct marketing, e.g. in the form of personalized advertisements, email newsletter or postal advertising, surveys, invitations to events,
  • for the purpose of surveys and analysis of product and service satisfaction.


4. Provision of the website and log files

(1) If you only use the website for informational purposes, i.e. if you do not register or otherwise provide us with information, we only collect the personal data that your browser automatically transmits to our server. If you want to view our website, we collect the following data, which is technically necessary for us to display our website to you and to guarantee stability and security (legal basis is Art. 6 para. 1 lit. f) GDPR):

  • IP address
  • Date and time of the request
  • Time zone difference to Greenwich Mean Time (GMT)
  • Content of the request (specific page)
  • Access status / HTTP status code
  • amount of data transferred in each case
  • Website from which the request came
  • Browser
  • Operating system and its interface
  • Language and version of the browser software


(2) The IP addresses of the users are deleted or anonymized after use. For technical reasons, your full IP address will be used for max. 2 minutes and then transferred to an anonymous form. In the case of anonymization, the IP addresses are changed in such a way that the individual details about personal or factual circumstances can no longer be assigned to a specific or identifiable natural person or only with a disproportionately large amount of time, costs and manpower.

5. Contact

(1) There is a contact form on our website with which you can easily and simply contact us electronically. If a user makes use of this option, the data entered in the input mask will be transmitted to us and saved. The corresponding data, in particular personal data, address data, contact details and messages (free text field) can be seen directly on the respective input mask. At the time of sending, the following data is also stored:

  • The user's IP address
  • Date and time the form was sent


When you call up the contact form, your IP address will be saved for a week in order to be able to solve any technical problems when submitting the form.

(2) For the processing of the data, reference is made to this data protection declaration during the sending process. Alternatively, you can contact us using the email addresses provided. In this case, the user's personal data transmitted with the email will be saved. The data will only be used to process the request.

(3) The legal basis for processing the data that is transmitted when using the contact form or when sending an email is Article 6, para 1 lit. f) GDPR. If the aim of the email contact is to conclude a contract, the additional legal basis for processing is Art. 6 para. 1 lit. b) GDPR.

(4) The processing of the personal data from the input mask serves us only to process the contact. If you contact us by e-mail, there is also the necessary legitimate interest in processing the data. The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.

(5) You can contact us via the e-mail addresses provided on the website. In this case, the user's personal data transmitted with the email will be saved. The data will only be used to process the request. The legal basis for the processing of the data that is transmitted in the course of sending an email is Art. 6 Para. 1 lit. f) GDPR. If the aim of the email contact is to conclude a contract, the additional legal basis for processing is Art. 6 para. 1 lit. b) GDPR.

(6) The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. For the personal data from the input mask of the contact form and those sent by email, this is the case when the respective conversation with the user has ended. The conversation is ended when it can be inferred from the circumstances that the matter in question has been finally clarified. The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

(7) Notwithstanding paragraph 3: Contact requests from customers, which will refer to a specific business process is stored, as long as for the implementation and execution of the contract (Art. 6 para 1 lit. b) GDPR) or due to legal retention requirements (Art. 6 para. 1 lit. c) GDPR) is required. Contact requests from customers that do not relate to a specific business transaction are saved as long as the business relationship exists. Legal basis is Art. 6 para. 1 lit. f) GDPR to protect our legitimate interests and the customer, especially support and quality assurance. Customers can object to processing at any time in individual cases.

6. Newsletter subscription

(1) With your consent, you can subscribe to our e-mail newsletter (hereinafter referred to as “newsletter”), which we use to inform you about our products and events.

(2) We use the so-called double opt -in procedure to register for our newsletter subscription. This means that after you have registered, we will send you an e-mail to the e-mail address provided, in which we ask you to confirm that you wish to receive the newsletter. If you do not confirm your registration within 14 days, your information will be automatically deleted. In addition, we save the IP addresses you used for registration and confirmation and the times of registration and confirmation. The purpose of the procedure, your registration to be wise and to be able to clear up any possible misuse of your personal information if necessary.

(3) The only mandatory information for sending the newsletter is your email address. The provision of further information is voluntary and is used to address you personally. After your confirmation, we will save your e-mail address for the purpose of sending you the newsletter.

(4) The legal basis for the above-mentioned processing operations in the context of the newsletter subscription is your consent in accordance with Art. 6 para 1 lit. a) GDPR.

(5) You can revoke your consent to the sending of the newsletter at any time by unsubscribing from the newsletter. You can cancel your subscription by clicking on the link provided in every newsletter e-mail or by sending a message to the contact details given in section 1. lit. a) of this data protection declaration.

(6) The data you provided when registering for the newsletter will be deleted when you unsubscribe from the newsletter.

7. Micronas Service

(1) You must register as a user to access the internal Micronas service area. The data required for registration can be seen on the input mask. As part of the registration, you will be given the required mandatory information and additional optional information. The data entered during registration will be used for the purpose of making the offer available. The legal basis is Art. 6 para. 1 lit. b) GDPR.

(2) You can Micronas services to retrieve data sheets and product-specific information and documents and how to be notified via e-mail registration supply- relevant information or changes in the breadth, or technical circumstances. If you cancel your account, that will he deleted data with respect to the user account, subject whose retention is of commercial or fiscal reasons, according to Art. 6 para. 1 lit. c) GDPR necessary. It is your responsibility to secure your data before the end of the contract if you cancel. We are entitled to irretrievably delete all user data stored during the term of the contract.

(3) As part of the use of our registration functions and the use of the user account, we save the IP address and the time of the respective user action. The storage takes place on the basis of our legitimate interests, as well as the users in protection against misuse and other unauthorized use. This data is generally not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with Art. 6 para. 1 lit. c) GDPR. The IP addresses are anonymized or deleted after 7 days at the latest.

8. Job advertisements (job portal)

(1) We advertise vacancies on our website. We collect, process and use your personal data to process your online application. The legal basis is Art. 6 para. 1lit. b) GDPR in conjunction. Section 26 BDSG. We provide an online application form for this purpose. The information required for the application as well as optional information can be seen on the web mask. You also have the option of uploading application documents and documents. The transmission is encrypted. Your online application data will be sent directly to the HR department. Appropriate technical and organizational measures ensure that your personal data is treated confidentially within the statutory provisions.

(2) Alternatively, you can apply by email. Please note that the transmission of the data by e-mail is unencrypted and the data could possibly be read or falsified by unauthorized persons. You are welcome to send us your documents by post.

(3) If you have applied for a specific position and this should already be busy or we look for another position also or even more suitable, we would like your application e forward within our company. The legal basis for this is Article 6 para lit. f) GDPR to protect your and our legitimate interests. Please inform us if you do not agree with this procedure. After the application process has ended, but no later than after 6 months, your personal data will be automatically deleted, unless you expressly consent to storage for a longer period of time.

(4) We use an external service provider for the administration of applications. The third-party provider is rexx systems GmbH, Süderstrasse 75-79, 20097 Hamburg, Germany, Tel. +49 40 8 900 800, Fax +49 40 8 900 80 - 120.

(5) There is an order processing contract in place with the company Rexx in accordance with Art. 28 GDPR. Information on data protection policy by Rexx can be found here: https://www.rexx-systems.com/datenschutz.php

9. Automated decision making, profiling

In principle, we do not use fully automated decision-making in accordance with Article 22 GDPR to establish and implement the business relationship. Profiling by third parties may be subject to TDK Cookie Policy. 

10. Links to other websites

(1) Our website may contain links to websites that are operated by third parties and are not covered by this data protection declaration. These third-party websites have their own privacy policies and may also use cookies or other tracking technologies. The respective operator or the person named as responsible of the respective website is responsible.

(2) The links to external websites are checked by us before being linked. However, we have no influence on whether their operators comply with data protection regulations. If we become aware of violations or legal violations, we will remove the corresponding links.