Privacy Policy

Global Data Privacy Notice (Job Application)

Updated on July 14, 2025

California Notice at Collection/US State Law Privacy Rights: See the US law privacy section below for important information about your rights under applicable US privacy laws.

1. Introduction

When you access to and use this website, including creating your personal profile, any personal data ( “Personal Data”) is being collected by, and will be processed by, Astemo, Ltd. (2-1-1 Otemachi, Chiyoda-ku 100-0004 Japan) and its group companies (collectively, “Astemo”). When you submit a job application through its website to Astemo, the submitted job application will be processed by the applicable company among Astemo. This website is operated by Astemo with engaging a third-party data processing partner, Workday, Inc. (6110 Stoneridge Mall Road, Pleasanton, CA 94588) (“Workday”).

By creating a personal profile or submitting a job application through this website you agree that your Personal Data may be accessed and/or processed by Astemo in accordance with the terms of this Global Data Privacy Notice. If you are a resident of the European Economic Area (“EEA”), United Kingdom (“UK”), Turkey, Brazil or the U.S., please note that the provisions of Section 4 of this Global Data Privacy Notice apply specifically to you and may contain additional or different rights, protections and procedures from those as set forth elsewhere in this Global Data Privacy Notice.

For the purpose of EU Regulation 2016/679 (i.e. the “General Data Protection Regulation”; “GDPR”), the retained version of the GDPR in the UK (“UK GDPR”) and the Data Protection Act (“DPA 2018”) and Brazil’s regulation (i.e. “Lei Geral de Proteção de Dados”; “LGPD”), Astemo operates as the Data Controller of your Personal Data.

If you do not agree to any of the terms set forth in this Global Data Privacy Notice, please do not use this website to create a personal profile or to submit a job application to Astemo.

2. Personal Data Astemo Collects

As part of the job application process, Astemo may collect the following categories of Personal Data from you without limitation:

• your contact information, such as your telephone number, postal address and email address
• your name, date and place of birth, age, gender, nationality, language proficiency, export control status
• information about your education, such as your academic history, academic and vocational qualifications, skills and competencies
• subject to any restrictions or limitations imposed by applicable law, information about your current role and compensation, such as your job position, job grade, employment status, salary and benefits, bonus and commission entitlements
• your CV/resume documents supporting your job application, including reference letters and transcripts
• information about your employment history
• information about your job application history with Astemo
• any other information you voluntarily provide

Use of this website as described in this notice will not oblige you to provide sensitive Personal Data (such as data relating to race or ethnic origin, political opinions, religious beliefs, trade union membership, criminal record, physical or mental health, or sexual orientation) unless such data is required by the laws of the country in which the job for which you are applying is located. However, such sensitive Personal Data may be collected if you voluntarily provide it in response to any diversity questionnaire provided to you by Astemo. If you do voluntarily provide sensitive Personal Data, that data will be used only to help ensure diversity in the workplace or to comply with applicable legal requirements, and by furnishing such data you are consenting its use for such purposes and in accordance with this Global Data Privacy Notice.

The Personal Data and other information that you submit to Astemo as part of a job application must be complete and accurate. Providing false or misleading Personal Data or other information during any stage of the application process may result in the termination of the job application process or subsequent termination of employment.

3. How Astemo Uses Your Personal Data

Astemo may use your Personal Data to:

• process your job application
• evaluate your qualifications for the desired position
• contact you at any time during the job application process
• if you request to receive Astemo job alerts when you create a user account on this website, inform you about and consider you for future job opportunities that Astemo believes may be of interest to you
• support any offer of employment by Astemo
• form the basis for your employee record in the event you are hired
• contact you for further information where appropriate
• comply with applicable legal requirements and Astemo's employment and compliance policies

4. Notice of Special Provisions Applicable to Residents of the EEA, the UK, Turkey, Brazil or the U.S.

Notwithstanding any other contrary or different provisions that may be contained elsewhere in this Global Data Privacy Notice, if you are a resident of the EU, the UK, Turkey, Brazil or the U.S., the specific provisions of this Section 4 apply to you.

(1) Residents of the EEA, the UK, Turkey and Brazil

Astemo’s written data processing arrangements with Workday ensure the protection of your Personal Data that is transferred to those parties, including the EU Standard Contractual Clauses for transfers of Personal Data out of the EEA.

Astemo will only collect and use your Personal Data where it has a legal basis for doing so. In almost all cases the legal basis will be:

• that you have expressly consented to the processing of your Personal Data for the purposes set out in this Global Data Privacy Notice; or
• that it is appropriate in order to take steps prior to entering into a contract with you; or
• that it is necessary for the purposes of the legitimate interests of Astemo.

When relying on the legitimate interests basis for processing your Personal Data, Astemo will balance the legitimate interest pursued by Astemo with your interests and fundamental rights and freedoms in relation to the protection of your Personal Data to ensure it is the most appropriate legal basis for processing your Personal Data.

You will also have a number of data protection rights including:

• Right of access
  You have the right to confirm with Astemo whether your Personal Data is processed, and if it is, to request access to that Personal Data including the categories of Personal Data processed, the purpose of the processing and the recipients or categories of recipients of that Personal Data.
• Right to rectification
  You have the right to rectify inaccurate or incomplete Personal Data concerning you. In addition, the Workday system offers a self-service function that allows you to access and review your Personal Data. Astemo encourages you to review this Personal Data regularly to ensure that it is complete and up-to-date.
• Right to erasure (right to be forgotten)
  You have the right to ask Astemo to erase Personal Data concerning you, although please note that this is not an absolute right. There are circumstances where you may not be able to exercise this right, and there are also circumstances where Astemo can refuse to comply with your request, for example, where Astemo needs to process your Personal Data to defend legal claims.
• Right to restriction of processing
  In limited circumstances, you have the right to request that Astemo restrict processing of your Personal Data.
• Right to data portability
  You have the right to receive Personal Data concerning you, which you have provided to Astemo, in a structured, commonly used and machine-readable format and you may have the right to transmit that data to another entity.
• Right to object and rights relating to automated decision-making
  Under certain circumstances you have the right to object, on grounds relating to your particular situation, at any time to the processing of your Personal Data, including profiling, by Astemo, and Astemo can be required to no longer process your Personal Data. This may include, depending on your jurisdiction, requesting human intervention in relation to an automated decision so that you can express your view and to contest the decision.

Retention of Your Personal Data:

For residents of the EEA, the UK, Turkey and Brazil, it is Astemo’s policy not to process your Personal Data for longer than is necessary for the purpose for which it has been collected. Accordingly, for residents of the EEA, the UK, Turkey and Brazil, Astemo will observe the following data retention periods:

• where you have applied for a specific role and have not indicated that you would like Astemo to retain your Personal Data on file for future job opportunities, Astemo will delete your Personal Data within 6 months after the vacancy for the role closes; and
• where you have indicated that you would like Astemo to retain your Personal Data for future job opportunities Astemo will delete your Personal Data after 12 months.

To exercise any of these EEA, UK, Turkey or Brazil-specific data protection rights, please send a written request:

• For residents of the EEA: by email to Astemo Europe GmbH , at data-protection(at)astemo.com;
• For residents of the UK: by email to Astemo’s UK representative, data-protection(at) astemo.com;
• For residents of Turkey: by email to Astemo’s Turkey representative, at data-protection(at)astemo.com;
• For residents of Brazil: by e-mail to Astemo’s Brazilian data protection officer (Jonas Rosenfeldt data-protection(at)astemo.com

The EEA, the UK, Turkey and Brazil residents also have the right to lodge a complaint with the competent supervisory authority as well as seek legal redress.
The data protection supervisory authorities and their contact addresses are listed under 12.

(2) Residents of Brazil

In addition to the provisions set forth on Section 4(1), you will also have the following rights under the LGPD:

• Right to confirm the existence of processing
  You have the right to confirm the existence of data processing by requesting such information to Astemo, who will provide a simplified statement or, within 15 business days, a complete statement confirming the origin of the Personal Data and the extent of the processing activity.
• Right to anonymization, blocking or deletion
  You have the right to request anonymization, blocking, or deletion of unnecessary or unlawfully processed Personal data.
• Right to know public and private entities with whom Personal Data has been shared
  You have the right to request information regarding public and private entities with your Personal Data was shared.
• Right to withdraw consent
  You have the right to withdraw your consent for the processing of your Personal Data through a written and express request to Astemo.

(3) Residents of the U.S.

Sensitive personal information

We do not use or disclose sensitive personal information as defined by the California Consumer Privacy Act (“CCPA”) in ways subject to California residents’ right to limit use or disclosure of sensitive personal information under the CCPA.

Sources of personal information

We collect personal information from you during your candidacy for a job, and during and after your employment. We may also collect your personal information from various other sources and combine it with the personal information you provide to us. For example, we may collect your personal information from:

• job board websites you may use to apply for a job with us;
• providers of services that we make available to our employees as part of our benefits program;
• prior employers, when they provide us with employment references;
• professional references that you authorize us to contact;
• providers of background check, credit check, or other screening services (where permitted by law);
• your public social media profiles or other publicly-available sources;
• employment agencies or recruiters;
• your related persons who communicate with us directly;
• Company communications and IT systems/applications that automatically collect information about, and transmitted by, users; and other Company personnel.

The information in this section generally describes our practices currently and during the preceding 12 months.

Personal information that we collect, use, and disclose

The table below describes our personal information practices by reference to the categories in the “Information we collect about employees” section above and the categories described in the CCPA (Cal. Civ. Code Section 1798.140(v)) and describe our practices currently and during the 12 months preceding the effective date of this Notice.

Retention

The criteria for deciding how long to retain personal information is generally based on whether such period is sufficient to fulfil the purposes for which we collected it as described in this Notice, including to comply with our legal records retention obligations.

Privacy rights available to California residents

If you are a California resident, you have a number of data protection rights under the CCPA. These rights include:

• Information
  You can request the following information about how we have collected and used your personal information:
  - The categories of personal information that we have collected.
  - The categories of sources from which we collected personal information.
  - The business or commercial purpose for collecting or selling personal information.
  - The categories of third parties to whom we disclose personal information.
  - The categories of personal information that we sold or disclosed for a business purpose.
  - The categories of third parties to whom the personal information was sold or disclosed for a business purpose.
• Access
  You can request a copy of the personal information that we have collected about you.
• Deletion
  You can ask us to delete certain personal information that we have collected from you.
• Correction
  You can ask us to correct inaccurate personal data that we have collected about you.
• Opt-out of sales or sharing of personal information
  California residents can opt-out of any “sale” of their personal information or “sharing” of personal information for cross-contextual behavioral advertising as such terms are defined under the CCPA. We do not sell or share personal information of contractors in the manner restricted by the CCPA and have not done so in the preceding 12 months. However, we encourage you to review our Privacy Policy for information about the sale or sharing of personal information that may occur when you interact with us offline or online in the same manner that a website visitor or other non-contractor may interact with us. We do not recruit, and have no actual knowledge of having sold or shared the personal information in the past 12 months of, contractors under age 16.
• Nondiscrimination
  You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA, including exercising such rights without retaliation.

How to exercise your California privacy rights

You may submit requests to exercise your California privacy rights to data-protection(at)astemo.com or submitting a request through +1(248) 474-2800. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. We reserve the right to confirm your California residency.

Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent with written and signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity, and provide us with confirmation that you have given the authorized agent permission to submit the request.

Your obligations

It is your responsibility to ensure that information you provide to us does not violate any third party’s rights. You should keep your personal information on file with the Company up to date and inform us of any significant changes to it.

5. Sharing of your Personal Data by Astemo

Your Personal Data will be disclosed to Astemo staff responsible for processing job applications and performing recruitment functions and with other Astemo companies or with third-party service providers for purposes relating to the administration, evaluation and management of your job application or future job opportunities as described in this Global Data Privacy Notice.

Please note that the sharing of your Personal Data between Astemo group companies may result in your Personal Data being shared with, or made available to, Astemo group companies in countries where the local laws may not afford the same level of data protection as your country of residence. However, to safeguard your Personal Data, Astemo will adopt at least the same or higher standards of data protection as is described in this Global Data Privacy Notice and as required by applicable laws.

6. Your Rights to Manage Your Personal Data and Your Relationship with Astemo

You can update or amend your Personal Data at any time by accessing your user account on this website using your username and password.

When you create a user account on this website, you can request to receive Astemo job alert email notifications when Astemo posts a new position matching your profile. You can stop receiving these notifications at any time by logging into your user account and either changing your user preferences or deleting your user account. Such changes can be made from the “Candidate Home” section of your user account.

Except as otherwise specifically stated in Section 4 with respect to the EEA, the UK, Turkey, Brazil, and the U.S. residents, you can terminate the processing of your Personal Data by Astemo at any time by accessing the “Candidate Home” section of your user account, which enables you to delete your user account.

7. Transfer of Your Personal Data to Other Countries

Personal Data may be transferred to and stored and processed in in a country (or countries) outside your country of residence in the manner outlined in this Global Data Privacy Notice. In such a case, Astemo enters into an appropriate contract to protect your Personal Data. For instance, Standard contractual clauses in accordance with (EU) 2021/914 have been concluded for data transfers from the EEA and Contracts in accordance with the LGPD and Ordinance CD/ANPD 19/2024 have been concluded for the transfer of data from Brazil.

8. How Astemo protects your Personal Data

Astemo and its data processing partner, Workday, use appropriate organizational and technical measures in order to reduce ‘high’ or ‘very high’ risk in the processing of Personal Data with the objective of reducing this to a residual level of risk that does not cause harm or damage.

Workday has its own privacy policy, which can be accessed at https://www.workday.com/en-us/privacy.html

9. Retention of your Personal Data

Except as otherwise provided in Section 4 above (in the case of EEA, the UK, Turkey, Brazil, and the U.S. residents) or except in the event you terminate the processing of your Personal Data by Astemo in the manner set forth in Section 6 above, Astemo will retain your Personal Data for a period of five (5) years after your original submission of that Personal Data or, to the extent a longer period of retention is required by applicable law, until the expiration of such longer period.

10. Updates to this Global Data Privacy Notice

Astemo reserves the right to amend this Global Data Privacy Notice at any time by posting an updated or amended version on this website. As a user of this website you accept that it is your responsibility to check regularly for such updates or amendments and that it is not the responsibility of Astemo to alert you individually to such updates or amendments. The title of the Global Data Privacy Notice indicates the date of the last update.

11. How to Contact Astemo:

Residents of the EEA, the UK, Turkey, Brazil, and the U.S. can contact Astemo about this Global Data Privacy Notice using the instructions provided in Section 4 above.

Residents of other jurisdictions can contact Astemo about this Global Data Privacy Notice by sending an email to: gyoumu.astemo_legal(at)astemo.com

12 .Contact addresses supervisory authority:

You can contact the competent supervisory authority in the event of complaints under the applicable data protection law:

For convenience of use, Astemo uses cookies*1 and web beacons (clear GIFs)*2 in the website.
A person can refuse to receive a cookie, or can change the web browser settings to have a warning message displayed when receiving a cookie. For more details, please refer to the instructions of the web browser a person is using. Moreover, a person can reject a web beacon by refusing the receipt of a cookie.
However, please note a person may not be able to use part or all of our　Company’s services provided in the website when rejecting a cookie.

*For individuals residing in countries or regions where the Applicable Laws require the explicit prior consent for the use of cookies (including but not limited to the European Union), Our company has implemented a mechanism to obtain such explicit consent in advance of any cookie usage.

Glossary

*1
Cookies:
Cookies are information exchanged between a web server that control a web site and a web browser that a person uses. Cookies may be saved as files in the hard disk of a person's PC. If a person uses a cookie, the web server can track and record information about which pages in the web site the particular computer visits, etc. However, we cannot identify the person unless he or she enters personal information on the web site.

*2
Web beacons:
Technology that functions with a cookie to check how many times a person accesses a particular page. However, we cannot identify the person, unless he or she enters personal information when receiving cookies.

For those who wish to apply for Astemo, Ltd., please see the following provisions.

Astemo株式会社の採用選考をご希望される方は、下記をご確認ください。