Non-EU Group Companies

Privacy Policy (applied to the group companies in non-EU and Holland)

1. Privacy Statement of Sumida Group

The protection of your personal data is of great importance to SUMIDA CORPORATION and its group companies (“Sumida Group”).

Sumida Group processes the personal data to whom those regulations apply (“you” throughout this Privacy Policy) in accordance with the applicable EU and EU Member States’ regulations on data protection, in particular the General Data Protection Regulation 2016/679 (the “GDPR”). 

This Privacy Policy explains how the group companies established in non-EEA and Holland (“we”), as the data controller, obtain and process the personal data of customers, suppliers, banks and other business partners, investors and analysts, professional advisors such as lawyers, officers (e.g. executive officers, directors), employees (full-time, part-time, contract, temporary, fixed-term and all other employees), and retired officers and employees of Sumida Group  (hereinafter “Officers and Employees, etc.”), individuals who apply or applied for Sumida Group to become officers or employees of Sumida Group (hereinafter “Employment/Director Candidates, etc.”), and users of this website (hereinafter “Users”).

2. Legal Bases for Processing and Categories of Personal Data Subject to Processing

We obtain your personal data appropriately based on the legal bases provided for in the GDPR (Articles 6 and 7) and process the data within the scope necessary to achieve the purposes as described below.  Further, we process your personal data of sensitive nature, including your religious beliefs and health status, in accordance with special criteria provided for in the GDPR (Articles 9 and 10).

(1) When processing is required for the pursuit of legitimate interests

We obtain and process the following categories of your personal data within the scope necessary to achieve following purposes because it is necessary to do so in order to pursue our legitimate interests. For details regarding the balancing test for legitimate interests, please inquire using the contact details at the end of this Privacy Policy.

Purposes Categories of Personal Data
For the purpose of offering products of Sumida Group, communicating to sell products, and/or handling inquiries or requests from you. Contact details of customers (e.g. name, phone number, e-mail address)
For the purpose of communicating to purchase materials, goods, etc., and/or handling inquiries or requests from you. Contact details of suppliers (e.g. name, phone number, e-mail address)
For the purpose of handling administrative matters to manage Sumida Group and/or communicating with banks. Contact details of banks and other business partners (e.g. name, e-mail address)
For the purpose of providing IR information. Contact details of investors and analysts (e.g. name, phone number, e-mail address)
For the purpose of receiving professional advice (e.g. legal advice). Contact details of professional advisors such as lawyers (e.g. name, phone number, e-mail address)

For the purpose of managing Officers and Employees, etc. such as performance evaluation, providing compensation and welfares, providing administrative supports (e.g. arrangement for business trips), and/or business communication in Sumida Group.

For the purpose of establishing and enforcing of, or defending against civil law claims, and reporting and/or making decision on such claims in Sumida Group.

Contact details of Officers and Employees, etc. (e.g. name, phone number, e-mail address)

Employment details (e.g. employment history, performance appraisals) of Officers and Employees, etc.

Identifier of Officers and Employees, etc. issued by a public authority (e.g. passport number)

Financial details (e.g. compensation, insurance details and bank account) of Officers and Employees, etc.

Family information (e.g. household structure) of Officers and Employees, etc.

For the purpose of evaluation of hiring and/or communicating with Employment/Director Candidates, etc. Contact details (e.g. name, phone number, e-mail address) and career history (e.g. academic background, employment history) of Employment/Director Candidates, etc.
For the purpose of ensuring operation of this website

Users’ session information, etc., obtained through cookies or other tracking technologies when Users visit this website.

For details, please refer to Cookie Policy.

 

(2) When your express consent is obtained in advance

If we have obtained your express consent in advance, we will obtain and process the following category of your personal data within the scope necessary to achieve the following purposes.

Purposes Categories of Personal Data
For the purpose of handling inquiries or requests we received through this website. Contact details of customers, suppliers, investors and analysts, employment/director candidates (e.g. name, phone number, e-mail address)
For the purpose of enhancing personalized function of this website.

Users’ language preference, etc., obtained through cookies or other tracking technologies when Users visit this website.

For details, please refer to Cookie Policy.

 

You have the right to withdraw your consent at any time by the method separately designated by us at the timing of seeking your consent. However, your withdrawal of consent will not affect the legality of processing conducted based on your consent before the withdrawal.

We will notify you separately, of whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and of the possible consequences of failure to provide such data to us.

3. Sources of Personal Data

We obtain your personal data directly from you or indirectly through Sumida Group.

4. Retention Period for Personal Data

We will retain your personal data for as long as necessary to fulfill the aforementioned purposes for obtaining and processing your personal data.  Specific retention periods are decided based on the following considerations: the purpose for obtaining and processing the personal data; the nature of the personal data; and the necessity of retaining the personal data for legal or business reasons.

5. Transfer of Personal Data

We share your personal data with and/or disclose your personal data to the following third parties in accordance with the GDPR for the purposes stated in this Privacy Policy.

  • Companies in Sumida Group (For details, please access here)
  • Travel agents, banks, embassies or consulates, external auditors, contractors

As a result of the aforementioned sharing and disclosure, in some cases your personal data will be transferred to the following third countries outside the EEA:

Japan, Hong Kong, China, Taiwan, Korea, Vietnam, Singapore, Thailand, India, USA, Mexico

In such a case, we will implement appropriate safeguards including executing with the transferee the standard data protection clauses (Article 46(2)(c) and (5) of the GDPR) approved by the European Commission. If you wish to receive a copy of documentation related to these safeguards, please inquire using the contact details at the end of this Privacy Policy.

6. Your Rights

You have the following rights regarding personal data obtained and processed by us.

  • Obtaining information regarding processing of data

You have the right to obtain from us all the requisite information regarding our data processing activities that concern you (Articles 13 and 14 of the GDPR).

  • Access to personal data

You have the right to obtain from us confirmation as to whether personal data concerning you are being processed, and, if so, then access to the personal data and certain related information (Article 15 of the GDPR).

  • Rectification or erasure of personal data

You have the right to have us rectify inaccurate personal data concerning you without undue delay and the right to have us complete any incomplete personal data (Article 16 of the GDPR). Also, if certain conditions are satisfied, you will have the right to have us delete personal data concerning you without undue delay (Article 17 of the GDPR).

  • Restriction on processing of personal data

If certain conditions are satisfied, you will have the right to have us restrict processing of personal data concerning you (Article 18 of the GDPR).

  • Objection to processing of personal data

If certain conditions are satisfied, you will have the right to object to processing of personal data concerning you (Article 21 of the GDPR).

  • Data portability of personal data

If certain conditions are satisfied, you will have the right to receive personal data concerning you in a structured, commonly used, and machine-readable format and the right to transfer those data to another controller without hindrance from us (Article 20 of the GDPR).

  • Not to be subject to automated decision-making

If certain conditions are satisfied, you will have the right not to be subject to a decision based solely on automated processing (including profiling) that produces any legal or similar material effect on you (Article 22 of the GDPR).

If you intend to exercise any of the aforementioned rights, please inquire using the contact details at the end of this Privacy Policy.

You can lodge a complaint in relation to our processing of your personal data with the Data Protection Supervisory Authority of the Member State of your habitual residence, place of work or place of the alleged infringement.

7. Amendment to this Privacy Policy

We may amend this Privacy Policy from time to time.  If we make any substantive or material amendments, we will contact you through this website.

8. Contact Details

For questions or inquiries regarding this Privacy Policy, please contact below.

GDPR Contact
dataprotection@jp.sumida.com

Last Update: 2020.05.22

Contact Form concerning European General Data Protection Regulations (the GDPR)

To exercise your rights in accordance with the GDPR you can contact us.

If you send the data entered in the contact form by clicking on the following button, you agree that we may use your details to answer your enquiry or contact you.

A transfer to third parties does not take place in principle, unless data protection regulations justify a transfer or we are legally obliged to do so.

You can revoke your consent at any time with effect for the future.

In the event of revocation, your data will be deleted immediately.

Your data will otherwise be deleted once we have processed your request or the purpose of storage has ceased to apply.

You can inform yourself at any time about the data stored about your person. Further information on data protection can also be found in the privacy policy of this website.

I have understood the declaration and expressly agree to the use of my data.