HORIBA UK Limited (“HORIBA” or “we”) hereby establish the following rules with regard to theprocessing of personal data in the possession of HORIBA, based upon our internal rules and applicablelaws for respecting the privacy of Data subject (the person to whom personal data relates).
This Data Privacy Notice will help you understand how we process the personal data and how we meet
our obligations.
This Data Privacy Notice will be applicable throughout HORIBA UK Ltd.
1. Personal Data Protection Principles
We will comply with following principles for processing personal data.
1. Lawfulness, fairness and transparency
Personal data shall be processed lawfully, fairly and in a transparent manner in relation to the Data subject.
2. Purpose limitation
Except for the requirement of applicable laws, personal data can be processed only for the purpose thatwas defined before such personal data was collected. Subsequent changes to the purpose are only
possible to a limited extent and require substantiation.
3. Data minimization
Personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes forwhich they are processed.
4. Accuracy
Personal data shall be accurate and, where necessary, kept up to date; every reasonable step shall betaken to ensure that personal data that are inaccurate, having regard to the purposes for which they areprocessed, are erased or rectified without delay.
5. Storage limitation
Personal data shall be kept in a form which permits identification of Data subjects for no longer than isnecessary for the purposes for which the personal data are processed;
6. Integrity and confidentiality
Personal data shall be processed in a manner that ensures appropriate security of the personal data,
including protection against unauthorized or unlawful processing and against accidental loss, destruction
or damage, using appropriate technical or organizational measures.
2. Lawful Basis for Processing
We obtain, hold, use and disclose the personal data for our legitimate business purposes, for the1

fulfillment of legal obligations and as part of contractual arrangements. For example, the purposes ofprocessing will include:Marketing, market research, and PR activities relating to the promotions of goods and services

Manufacture, logistics and distribution management, including quality management; theoperational management for doing business globally; distributors’ details; and administrative
strategic, business, and technical advice

Sales management, including customers, market analysis, pricing, and sales service training

Accounting, including financial and purchasing management, and legal services

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R&D, quality improvement and product development, including R&D activities with customers,suppliers, agency contractors, and sub‐contractors; and technical documentation

After‐sale customers service, recalls, claims and warranty, including performance surveillance, themanagement of complaints, after‐sale service request, and repairsBusiness, department, and project management, including communications, planning of meetings,
conferences, project management activities, and business proposals

Partner, contractor, and vendor employee data, including communications, project management,
supplier relationships, audits, etc.

IT and general administration, including employees’ user accounts, building entrance, guests,visitors, video cameras, server accesses, etc.

Human resources management, including recruiting activities

Our basis for processing personal data is in all cases strictly in accordance with one or more of thefollowing:
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The explicit consent of the individual
The performance of a contract
A legal obligation upon us e.g. tax affairs
In the vital interests of an individual
In the public interest or exercise of official authority
For our legitimate business interests

We respect and will comply with all individuals' rights under existing data protection legislation.
Where personal data is held purely by virtue of the consent of the individual, that consent will be explicitly
given, recorded, verifiable and may be withdrawn at any time without penalty.
3. Your Data Protection Rights
You have certain rights regarding how your data is held, used, processed or shared by us.

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Be informed about what data we hold about you, how we use it and who we share it with.

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Access any personal data that we hold about you.

Obtain rectification where data that we hold about you is not up to date or accurate.

Obtain that we erase any data that we hold about you where we have no lawful basis for holding,using or processing that data.

Obtain that we restrict the processing of your personal data if you feel that the manner in which
we process it goes beyond our lawful basis for doing so.

Request that we give to you any personal data that we hold about you in a readable computer
format that you can use for your own purposes. This only applies where we hold your data withyour consent or as part of a contract with you.

Object to the manner in which your personal data is used, stored, processed or shared by us.
Objections are considered on their merits bearing in mind your rights and ours.

Lodge a complaint with the Information Commissioner's Office about the way that your data isprocessed.

Be made aware of any automated decision making or profiling of any personal data relating toyou.

4. Types of Personal Data Processed
In the legitimate course of our business, we may obtain, hold, use and disclose personal information
relating to or consisting of any of the following:
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Personal details such as name, sex, age, address, email address and phone number
Job Title and position including own Company or own Department
Company details such as name, address and phone number
Career background
Employment details
Data derived from IT systems such as IP addresses or location information
Information that may be required for the performance of a contract3

5. The source and origins of personal data that we hold, use or disclose
We may obtain personal information from a wide variety of sources, including the following:
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Individuals themselves
Business partners (“Business partners”) such as customers, agents, suppliers and service providers
who share a legitimate business contract with us
Prospective business partners
Current, past or prospective employers of the individual
External advisors such as auditors, accountants, lawyers and consultants
Law enforcement agencies and regulatory or licensing authorities
Legal representatives
Government, government agencies and departments
Emergency services
Education, training establishments and examining bodies
Employees of HORIBA
Survey and research organisations
Data processors working on behalf of HORIBA
Our parent organisation and its subsidiaries
CCTV systems

6. Whose Personal Data do we Process?
We may obtain, use and disclose personal information relating to a wide variety of individuals including
the following:

Staffs including volunteers, contractors, agency staff including temporary and casual workers
Business partners
Complainants, correspondents and enquirers
Relatives and associates of the individual concerned
Advisers, consultants and other professional experts
Former and potential members of staff

We will only obtain, hold, use or disclose appropriate personal data necessary to fulfill a particular purpose.
Personal data could be held in computer format or in a paper record. It can also include other types ofelectronically held information such as CCTV images or audio recordings.
7. Retention of Personal Data
We keep personal data for as long as, but no longer than is necessary for the particular purposes for which
it is held or for any period that might be required by law. Where there is no further requirement to use,hold or store personal data and the law does not require us to do so, we shall remove it from our records
and systems. Our retention of personal data is strictly on the basis of the clear and justifiable existence ofa lawful basis for processing.
It is not possible in this notice to explicitly state how long personal data should be retained for. This willvary considerably depending on the type of data. Some data should be erased as soon as its usefulness4has expired, some must by law be kept for specified periods, and some should be kept indefinitely. The
5th of Personal Data Protection Principle will apply in all cases.
8. Who We Share Information WithWe may disclose personal data to a wide variety of recipients in any part of the world, including thosefrom who personal data is obtained. Disclosure of personal data will be made strictly on the grounds ofthe following and with suitable controls in place:
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The explicit consent of the individual
The performance of a contract
A legal obligation upon us
In the vital interests of an individual
The public interest or exercise of official authority
Our legitimate business interests

Where processing is to be carried out on behalf of HORIBA by a third party organization (known as theData Processor), we shall use only processors providing sufficient guarantees to implement appropriatetechnical and organizational measures in such a manner that processing will meet the requirements of
the applicable personal data protection regulation such as General Data Protection Regulation and ensure
the protection of the rights of the Data subject. The processor shall not engage another processor without
the prior specific written authorization of HORIBA. We may share personal information with any of thefollowing:
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Business partners
Prospective business partners
Current, past or prospective employers of the individual
External advisors such as auditors, accountants, lawyers and consultantsLaw enforcement agencies and regulatory or licensing authorities
Legal representatives
Government, government agencies and departments
Emergency services
Education, training establishments and examining bodies
Data processors working on behalf of HORIBA
Our parent organisation and its subsidiaries
Survey and research organisations

9. Overseas Transfers of Personal Data
As part of an organization with a global reach, we will share certain personal data within the HORIBAGroup overseas. Some parts of the organization that we disclose personal data to are located at somecountries which are not adequate level of data protection as in the United Kingdom. All transfers of data
overseas within HORIBA Group will be subject to a FRAMEWORK AGREEMENT IN RELATION TO DATATRANSFER WITHIN HORIBA GROUP which includes standard contractual clauses.
We may also periodically share personal data with international organizations on an ad hoc basis as partof a legitimate business reason or as part of a contractual arrangement. Such a transfer of data will be5

governed by an appropriate legal basis such as standard contractual clauses published by the Information
Commissioner’s Office.
10. Automated Decision Making and Profiling
Automated decision making and profiling occurs where a computer system generates an output relating
to an individual without any human intervention, upon which a decision is made. We may in limited
circumstances use such systems.
You have the right to challenge any decision that arises from automated decision making. In thecircumstances above however, these are not the sole factors for decision making and only contribute toa wider pool of information before a decision is made.
11. Data Security
We use appropriate standard organizational and technical measures and safeguards to protect theconfidentiality and security of your personal data, especially from unauthorized access and unlawful
Processing or disclosure, as well as accidental loss, modification or destruction. Our measurement andsafeguards will be reviewed and updated when necessary.
12. Changes to our data privacy notice
We may update or modify this Privacy Notice, at any time and without prior notice, by posting the revised
version of this Notice on our Internet Sites. If we modify this Privacy Notice or any other privacy
statements, the modifications will only apply to the personal data collected after the revised Privacy
Notice or privacy statement on the applicable our Internet sites is posted.
13. Inquiry
If you have questions or concerns regarding your privacy, please contact our Data Protection Team using
the details below.
By email: ‐ data‐protection.huk@horiba.com; or
By telephone:‐ +44 (0) 1604 542500; or
By post to:‐
The Data Protection Team,HORIBA UK Limited,
Kyoto Close,
Moulton Park Industrial Estate,
Northampton,
NN3 6FL,UK.
If you are unhappy with the support that you have been provided then you can lodge a complaint with
the Information Commissioner’s Office online at https://ico.org.uk/make‐a‐complaint/data‐protection‐complaints/data‐protection‐complaints/ or by telephone on +44 (0) 303 123 1113.
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