Last modified: 14 November 2023
Daikin Industries Ltd. and its Subsidiaries (hereinafter, "Daikin Group", "we", "us", “our”, etc.) produce, sells, distributes and executes marketing with regard to air-conditioning, heating, ventilation and refrigeration equipment and solution business.
Daikin Group is sincerely committed to the protection of Personal Data collected from Data Subjects (hereinafter “User”, “Customer”, “you”, “your”) offline, through e.g. paper forms, contracts, statements (hereinafter “Forms”) or online, through the Daikin Group’s websites (hereinafter "Website”) and through, for example, but not limited to, (web) applications, software and digital tools (hereinafter “Applications”) owned or managed by Daikin Group.
In accordance with applicable data protection laws of the jurisdictions where Daikin Group is subject to, including, without limitation, the European General Data Protection Regulation (EU) 679/2016 (GDPR) (hereinafter “Applicable Data Protection Laws”), in order to:
Therefore, hereby we set forth this Data Protection Policy.
The protection of your Personal Data matters to us. We aim to process your Personal Data in a lawful, appropriate and transparent manner.
This Data Protection Policy consists of:
If you reside in one of the above countries, we encourage you to read the Country Specific Addendum, which is relevant to the country of your jurisdiction as it contains important additional information about the Processing by us of Personal Data originating from or processed in those countries. In the case of conflict between the terms of this Data Protection Policy and the terms of the applicable Country Specific Addendum, such terms of the Country Specific Addendum shall prevail.
Take your time to read this Data Protection Policy and its main Key terms, that you will find hereby in capitalized form. The terms shall have the same meaning as specified under the
Applicable Data Protection Laws. If there are disparities between the definitions and terms outlined in the key terms and those stipulated in the Applicable Data Protection Laws, the definitions stated in the Applicable Data Protection Laws shall prevail.
In addition to this Data Protection Policy, there may be specific campaigns, promotions, programs, applications or websites created by Daikin Group that are governed by additional privacy terms or policies. We encourage you to read the additional terms or policies before participating in or utilizing these campaigns, promotions, programs, applications, or websites as the processing of your Personal Data in those circumstances will be governed by both this Data Protection Policy and those additional privacy terms and/or policies.
If there is a conflict between the English version of this Data Protection Policy and any other language versions, the English version shall prevail.
In this regard, if you have any questions or remarks, you can find our contact details listed depending on the country in which you are resided; please refer to the “COUNTRY SPECIFIC ADDENDUM”.
Daikin Group is subject to the Applicable Data Protection Laws, entering into force in the countries where our local entities are established. Please be noted that your Personal Data may also be processed by members of Daikin Group which are located outside countries of your jurisdiction, whether process in the capacity of data controller, joint data controllers or data processor.
We inform you that any Personal Data you submit offline through Forms or online through the Website and/or the Applications is used for the purposes described below by Daikin Group, in its capacity of Data Controller, Data User or any other term having the similar meaning as prescribed in the Applicable Data Protection Laws.
It is possible in the future that the members of Daikin Group may jointly determine, on the basis of a written agreement, purposes and means of Processing Personal Data, as Joint Data Controllers (for example, but not limited to, in any case the subsidiary is particularly involved in the Processing of Personal Data at local level for the developing of a project).
In the above cases Data Subjects whose Personal Data are to be processed by the Joint Controllers will be informed accordingly and, to the extent required by Applicable Data Protection Laws, consent will be requested and obtained from the Data Subjects.
In certain case, some of companies within Daikin Group can also act as Data Processor on behalf of other companies within Daikin Group, or for any other third parties, that are considered as Data Controller, for any online or offline Processing of Personal Data.
In all circumstances, we shall ensure that appropriate privacy measures such as having data processing agreements, are in place.
Daikin Group, to the extent necessary, Processes your Personal Data provided offline through Forms or online through the Website and/or Applications while, for example, but not limited to: visiting the Website; using Applications; filling in offline or online registration Forms; reporting non-compliance; contacting us; clicking on social media buttons; providing feedback (e.g. on Forms, products, Applications, Website, customer service); answering to surveys and other activities.
Personal Data are collected either on a facultative basis, voluntary basis or on a compulsory basis. If it is compulsory to provide the Personal Data, this will be marked accordingly. In case a Data Subject fails or denies providing the Personal Data that we have marked as compulsory, as a consequence we will not be able to carry on the process or the activity requested by you.
An example of Personal Data that is marked as compulsory is the situation in which a Data Subject wants to submit registration Forms. In this case we need some personal details in order to process the related request of registration. If you wish to register but do not provide the personal details marked as compulsory, we will not be able to accept and process the request of registration.
We can collect Personal Data on a consent basis or without the consent of the involved Data Subject, where required or permitted under the Applicable Data Protection Laws, if: 1) a legal obligation must be fulfilled; or 2) a contract in which the Data Subject is party has to be performed or will be performed; or 3) there are Legitimate Interests, public interests or Vital Interests to protect; or 4) an authority has requested us to process Personal Data.
We can further process your Personal Data only:
Please find below, under subparagraphs 2.1. and 2.2., the Personal Data we collect and the purposes for which we collect them.
You can be asked to provide us, depending on the purpose of each Processing and to the extent necessary, different kind of Personal Data including, but not limited to, name, surname, date of birth, title, role, address, telephone, mobile, email address, language, country.
You can also be asked to provide us, depending on the purpose of each Processing and to the extent necessary, some Special Categories of Personal Data (e.g. trade union membership, Personal Data concerning health). We will process Special categories of Personal Data in accordance with Applicable Data Protection Laws on the basis of : 1) explicit consent of the Data Subject; or 2) fulfillment of legal obligations and/or exercise of the rights of the Controller or of the Data Subject; or 3) Vital Interests of the Data Subject; or 4) establishment, exercise or defense of legal claims; or 5) substantial Public Interest.
We also use Personal Data you provided to third parties, for example to service providers, or Personal Data that fall within the public domain such as commonly acknowledged Personal Data, Personal Data visible on your own website or blog or posted on your publicly accessible social media profile.
We may also receive Personal Data via third parties after mergers, acquisitions and any other transforming operation.
2.1.1 Purposes of the collection of Personal Data.
Once collected, we use such Personal Data mentioned above for a variety of purposes. Please find them listed below:
Business Administration and customer management.
We have to be able to perform contracts duly and properly and to carry out all the necessary statutory and accounting processes. Accordingly, we will need some Personal Data provided by you offline through Forms or online through Website and Applications. Subject to the requirements under the Applicable Data Protection Laws, for the purpose of performing contracts, the consent of the Data Subject that is or is going to be a party to a contract may not be required.
With regard to the management of relationship with customers and the provision of consumer services, we use Personal Data (e.g. name, country, nationality, email address, client number, credit card information) in order to:
Product Distribution.
We use Personal Data for product distribution, on the basis of performing a contract/ fulfilling a legal obligation, and particularly in order to:
Direct marketing.
As leading manufacturer and supplier of heating, ventilation and air-conditioning equipment (including heat pumps and refrigeration) and of solution business, we are in the position to provide you with information that is tailored to you and your needs (for example, by using your transaction details, we are able to inform you about services, offers and suggestions related to your purchase. This is the so called “direct marketing”).
Where permitted under the Applicable Data Protection Laws, we use collected Personal Data, Personal Data that is publicly available (e.g. information available on Internet, through results of the searches, social media results) or Personal Data received from third parties (e.g. Internet Service Providers) for direct marketing purposes and to attract new customers.
We perform direct marketing also with the aim of organizing internal events, travels, presentations, and customers.
We do direct marketing through a variety of media including, without limitation, mobile’s text messaging, surveys, email, the Website, online adverts, database marketing, Applications and events.
We perform direct marketing on the basis of our Legitimate Interest of pursuing business objectives where permitted by the Applicable Data Protection Laws, or else, we will rely on your consent.
We may use your Personal Data or provide your Personal Data to third parties for use in direct marketing in response to explicit consent of the Data Subject. If you do not want to receive a highly personalised offer, you should not consent to receiving direct marketing when asked to.
We commit ourselves to ensure that direct marketing information are provided in a way that is clear and adequate and this by using the channel designated by the recipient in order to keep the inconvenience of being disturbed to a minimum.
Quality improvement of products and services.
We, based upon our Legitimate Interest to do business or the consent of Data Subjects, use Personal Data collected through Forms, surveys, inquiries, comments, feedback submitted to Daikin Group, in order to: improve its products and services; carry out further surveys; develop analytical, risk, marketing and other models and to produce statistics. We also use your transaction details to develop models and to perform analyses.
Example: We may need to process the number of people that have bought a specific Daikin Group product or have applied for a specific service.
In this regard, we commit as much as possible to aggregate Personal Data in anonymous or Pseudo Anonymous form to make sure that these Personal Data are not easily or are no longer identifiable as yours.
The practice of Processing Personal Data for statistical purposes is particularly justified by our desire to put in place strategic choices in order to better perform in the market and to provide you with better products and services.
Personal Data can also be used to assess, simplify and improve our processes, for example in order to optimize campaigns, procedures and sales, both offline or online, through the Website and/or through Applications.
Example: if you have not completed a procedure or the sales process, we may contact you to find out what went wrong and whether we can help you. In this case we limit our contact to providing technical and administrative support for that specific procedure or process.
Legal Claims and Disputes.
To the extent permitted by applicable laws, we can use Personal Data as evidence and for ascertaining, exercising and safeguarding our rights or of those it represents (e.g. in disputes) before any jurisdiction of any country (for example, among others, our right to defend ourselves from acts of unfair competition or our right to solicit the fulfilment of an unpaid invoice).
Fraud or Crime prevention.
We can also use Personal Data to prevent, detect and investigate crimes and cyber risks for Legitimate Interest or when a public authority requests to do so.
Corporate Business and Housekeeping.
We transmit and/or jointly use the Personal Data collected within Daikin Group and/or its Business Partners only when needed and in view of elaborating periodic reports on the outcome and business-related aspects, business plans and corporate strategies. The Processing is based on our Legitimate Interest of doing business.
We process Personal Data of Data Subject that were lawfully collected by another company of the Daikin Group unless there is no legal impediment (e.g. a duty of confidentiality or a provision in the data protection legislation).
We are committed to put in place all the appropriate measures for the protection of Personal Data with regard to intra group communications, in line with the Applicable Data Protection Laws.
When you are visiting the Website and/or Applications owned or managed by companies of the Daikin Group, we collect some of your Personal Data for the following purposes:
Easing the use of the Website and/or Applications.
By collecting some Personal Data (e.g., IP address, log-in data) on the basis of consent of the Data Subject or Legitimate Interest we are able to adapt the Website and/or the Applications more according to your needs.
Through the use of Cookies, we will automatically collect some Personal Data such as, but not limited to, device-specific information (e.g. IP address, browser type), log on information (e.g. search queries), geo-localization information (e.g. through Wi-fi access point) in order to facilitate the use of the Website and/or Applications and to increase your comfort while using them.
Example: in order to support and simplify your identification process, we store your username and password through a Cookie, you do not have to enter your identification credentials or any personal details every visit.
We use different types of Cookies: necessary, functional, social plug-in tracking, third-party advertising, first-party analytics. Please, read more about Cookies, what they are, what types we use and why we are using these in our “Cookie policy”.
Monitoring of Data Subjects’ interests and preferences.
Daikin Group, within its Website and/or Applications, on the basis of consent of the Data Subject or Legitimate Interest can monitor in a systematic and regular way Personal Data through Automated Decision-Making technologies/Profiling and Cookies. This in order to evaluate certain personal aspects relating to a natural person, in particular to analyse and predict aspects concerning the natural person’s performance at work, economic situation, personal preferences, interests, reliability, behaviour, location or moments (geo-localization).
For the above purposes, we may need services, counselling and/or assistance from third parties, including, but not limited to, maintenance of Applications and bug fixing, purchase of Applications, data hosting, counselling on compliance with laws and regulations, development of Applications, supply services, Internet providers’ services, production of statistics and others.
In this regard, to the extent necessary, we can transmit or disclose Personal Data we collected to any natural person or legal entity, to subcontractors and Business partners that are third parties which provide the services mentioned above with respect to Daikin Group.
Every time we need to transmit or disclose some Personal Data we collected to third parties, except in case of Legitimate Interest of the third party, we will make sure to have in place a proper privacy measure such as having a data processing agreement with this third party under the provisions of the Applicable Data Protection Laws, asking the third party to comply with the principles and the provisions of the same regulation and to align on appropriate security standards.
Within the scope of the above described purposes we transmit and jointly use the Personal Data collected, belonging to Data Subjects, with Daikin Group’s companies and/or Business Partners established in any countries. These countries include [Thailand, Singapore]
We inform you that we have arranged appropriate standard contractual clauses and appropriate safeguards regarding any transfer of Personal Data occurring among Daikin Group. In any case of transfer of Personal Data outside of your jurisdiction, Daikin Group commits itself to:
We do not keep your Personal Data forever. We use your Personal Data to the extent necessary and only with the aim of pursuing the purposes described above. Once the aim no longer exists, we commit to delete the Personal Data, unless archiving them is required by law, at international or national level.
The starting point for storing your Personal Data is the statutory retention period (which is often ten years and lasts until the expiry of a contract or the end of a business relationship). The period can be longer where needed for the exercise of our rights, or as otherwise required or permitted by applicable laws.
If no retention period is stipulated by law, the retention period can be shorter in accordance to, but not limited to, one of the following criteria: contract length and legal obligations; business and organizational needs; long-term business relationship; pursuit of direct marketing; statistics.
Some insights only get clearer once they are viewed over a longer time span. For this reason, for some types of Personal Data a more extended time horizon may be necessary (e.g. for those needed in order to design marketing and risk models).
As has been stated, we commit as much as possible to work with aggregated, anonymized or Pseudo-Anonymized Personal Data and in all cases, it will cease the connections to individuals as quickly as possible.
If you have any questions about the protection of your Personal Data or the exercise of your rights, you can contact us at any time by writing to Daikin Group, by calling us, by sending via postal mail a specific Form or by submitting the Form available online under each “contact us” section throughout the Website and/or the Applications.
Once your Personal Data are subject to Processing, and depending on the country in which you are resided, you may have several rights as Data Subject that can be exercised, as listed below.
Be as specific as possible any time you wish to exercise your rights. We can only properly answer queries couched in sufficient detail. We may need to verify your identity in as much detail as possible, in order to avoid that someone else tries to exercise your rights.
If you would like to access the Personal Data that we process about you or you want to know more about:
and any other available information about the Processing of your Personal Data, please contact the DATA PROTECTION OFFICER depending on the country in which you reside; please refer to the “COUNTRY SPECIFIC ADDENDUM”.
We will use the Personal Data you provide us through the form only for the purpose of verifying and Processing your request.
If you exercise your right to access, we will give you as complete as possible a list or a copy of your Personal Data.
It can happen that certain Personal Data held on you by Daikin Group are not (or have ceased to be) correct. It can also happen that you want to add something to the Personal Data you provided us. You can ask for your Personal Data to be rectified or completed at any time, please contact the DATA PROTECTION OFFICER depending on the country in which you reside; please refer to the “COUNTRY SPECIFIC ADDENDUM”.
If you want Daikin Group to erase your Personal Data your request will be processed, unless no impediment or incompatibility arise according to law or Legitimate Interests towards the deletion. If you want to ask for the erasure of your Personal Data, please contact the DATA PROTECTION OFFICER depending on the country in which you reside; please refer to the “COUNTRY SPECIFIC ADDENDUM”.
You can obtain the restriction to the Processing of your Personal Data at any time, please contact the DATA PROTECTION OFFICER depending on the country in which you reside; please refer to the “COUNTRY SPECIFIC ADDENDUM”.
If your Personal Data were collected through electronic means, you can ask for the portability of the Personal Data you provided us to yourself or to third parties, please contact the DATA PROTECTION OFFICER depending on the country in which you reside; please refer to the “COUNTRY SPECIFIC ADDENDUM”.
Please remember that every time you provide us with your consent to process your Personal Data, you can subsequently withdraw that consent at any time by following the suggested procedure and as easily as you gave it.
If you want to withdraw your consent, you can do it at any time; please contact the DATA PROTECTION OFFICER depending on the country in which you reside; please refer to the “COUNTRY SPECIFIC ADDENDUM”.
If you disagree with how we process certain Personal Data, you can object by contacting the DATA PROTECTION OFFICER depending on the country in which you reside; please refer to the “COUNTRY SPECIFIC ADDENDUM”. We shall process objections unless there are valid reasons not do so or reasons provided by law (for example, an objection will be declined if the Processing of Personal Data has been conducted in view of combating fraud).
If you disagree with Processing of your Personal Data based solely on Automated Decision-Making (including Profiling) which produces legal effects or affects similarly a Data Subject, you can object at any time by contacting the DATA PROTECTION OFFICER depending on the country in which you reside; please refer to the “COUNTRY SPECIFIC ADDENDUM”.
If you do not agree with the way we are Processing your Personal Data or you have other questions in this regard, you can always contact Daikin Group’s Data Protection Officer via the details set out below in section 7. We will take any privacy complaint seriously. We will aim to resolve any such complaint in a timely and efficient manner. However, if you remain dissatisfied you can make a complaint to the Data Protection Authority of your country of residence.
The contact details of Daikin Group’s Data Protection Officer, depending on the country in which you are resided; please refer to the “COUNTRY SPECIFIC ADDENDUM” section.
Through its Website or Applications Daikin Group does not process any Personal Data of natural persons below the legal age of majority in the respective countries where our companies are established, neither does it make commercial offers to or tries to contact them, unless their legal representative has consented.
Daikin Group has implemented adequate security measures in order to maintain integrity and security and prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise processed, in line with the Applicable Data Protection Laws.
Daikin Group commits before starting Processing activities using new technologies to carry out data protection impact assessments in accordance with the Applicable Data Protection Laws and by undertaking appropriate actions accordingly.
Daikin Group regularly seeks to improve their efforts in protecting Personal Data. This Data Protection Policy can be changed or updated in light of upcoming legislations, both at international and national level.
We will inform you of all substantive changes of this Data Protection Policy via offline or online means (for example, via the Website, during your first visit or with each substantial update of this Data Protection Policy).
You can always find the most recent version of our Data Protection Policy available for each Application by clicking on your country of residence in the “COUNTRY SPECIFIC ADDENDUM” section.