The aim of this privacy policy (the “Policy”) is to inform customers of and visitors to the website (the “Website”) of SUMITOMO CHEMICAL COMPANY, LIMITED and its group companies (the “Company” or “we” or “us”) on the collection, use, disclosure, transfer, and other processing of their individually identifiable information (“Personal Data”).

Under applicable European data privacy laws including, but not limited to the General Data Protection Regulation 2016/679 (“GDPR”), laws implementing the GDPR in Member States of the European Union, the GDPR as transposed into United Kingdom national law by operation of section 3 of the European Union (Withdrawal) Act 2018 and as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 ("UK GDPR"), the Data Protection Act 2018 (DPA 2018) (together the “Data Privacy Laws”), the Company is the data controller. You can contact us at kojinjoho-houmu@ya.sumitomo-chem.co.jp.

1. Personal Data

Through the course of accessing the Website or engaging with the Company and/or the Company’s products, we collect and process certain Personal Data about you as follows:

• Contact information: Name, Company Name, Job Title, company address, region, country, department name, telephone number, fax number, email address.
• Participation in exhibitions.
• Business (area of) interests.
• Matters pertaining to business transactions: contractual details.
• Auto-generated information: Online identifications such as IP address, cookies, date and time of visit.

You are generally not required to provide your Personal Data to us unless there is an obligation for such provision by local regulations or where we have to collect Personal Data for compliance with a legal obligation to which we are subject. However, if you do not provide your personal data, we might not be able to carry out certain processes (e.g., if bank account information is not provided, we will not be able to process any payment). Note, however, that when you use our Website, we do not identify you individually, but we may collect and process information you provide to us when you use some of our services which could directly or indirectly identify you individually.

2. Sources of Personal Data

We obtain Personal Data from the sources listed below:

• directly from you: your name, address, telephone number, fax number, e-mail address, etc.. For example, Personal Data may be collected when you fill out a 'Contact’ form, sign up for our mailing lists, register for events we host or sponsor, or otherwise provide us Personal Data through the Website and our products and/or services. Generally, the information we collect includes the Contact information as listed in section 1 ‘Personal Data’.
• Auto-collected information: we use cookies, log files, pixel tags, local storage objects and other tracking technologies to automatically collect information including personal information when users access or use our Website, [mobile applications and other online services], such as an IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider, referring/exit URLs, operating system, language, clickstream data, and other information about the links clicked, features used, size of files uploaded, streamed or deleted, and similar device and usage information.

3. Purposes and legal basis for processing Personal Data

The type of Personal Data we process differs depending on how you engage with us. The table below provides this information including how we will use the Personal Data and the context for which we use your Personal Data:

Types of Personal Data	Purposes	Legal Basis
Your first name, surname, email address, region, country, department name, telephone number, fax number, payment information (including bank account information and transaction data) and communications/complaints.	To process and administer accounts and payments in relation to the services and products you request/use and resolve any complaints you may have. This includes processing to administer our relationship with you, process any orders that you have submitted and send statements, invoices and payment reminders to you, and collect payments from you. Also, to make payments to our sub-contractors and/or consultants in relation to the services and products you request/use.	(a) the processing is necessary to our performance of a contract with you; and (b) it is our legitimate interest to review and respond to any correspondence or queries you send to us, and to send service information regarding our products and/or services that you have bought or requested.
Identification information and details of your qualifications and education history, CV, application letters, references, candidate assessment (including interview notes and interview video); information relating to right to work and information about your skills, experience and education.	To respond to request for vacancies and for recruiting and hiring purposes and to improve our recruitment process and activities.	(a) the processing is necessary for us to administer our contract with you- or take steps to consider entering into an employment contract with you; (b) necessary for our legitimate interests to maintain a world class reputation as a leading employer; and (c) necessary to comply with employment and social security law obligations (for example, carrying out right to work checks).
Your first name, surname, email address, address, business address.	To send you marketing material, newsletters and other related information, including, surveys, and promotions and to send solicited information (e.g. quotes in response to an enquiry).	(a) our legitimate interest to send you communications related to similar products or services to which you have previously purchased or entered into negotiations to purchase, where permitted by the Data Privacy Laws; or (b) your consent or where information is solicited. Please see section 8 of this Policy for more information.
CCTV images and audio.	To capture footage to help prevent and detect crime and for security purposes.	Our legitimate interest to ensure the security of our premises and for purposes of detecting and preventing crime.
Names, email addresses, addresses, business addresses.	To conduct market research, data analysis and questionnaire surveys for statistical and survey purposes and for internal business administration.	(a) our legitimate interest to measure the use of our products and/or services and interaction to inform and improve service/product direction and development and to enable provision of accurate and reliable reporting; and/ or (b) the processing is necessary to our performance of a contract with you.
Information about your visits to our Website, your geo-location and IP address, the browser software you use, the top-level domain-name used (for example .ie, .com, .org, .net), the pages visited on the website, i.e., URL’s visited, the previous website address from which the visitor reached us, including any search terms used, clickstream data which shows the traffic of visitors around the website (for example, pages accessed), and the date and time you access the website.	To provide or improve the products, services, and related our information, to help us to keep the website available and improve your experience when you visit it. This includes: (a) for verification and administration, and for statistical analysis to improve, test and monitor the effectiveness of the website; (b) to monitor metrics such as total number of visitors and traffic data (including demographic patterns); and (c) to ensure content on the website is presented in the most effective manner for you and to enhance your use of the website.	(a) our legitimate interest to provide and maintain our website through utilising cookies that are strictly necessary; (b) your consent for cookies that are not strictly necessary, such as cookies relating to performance, functionality and target/advertising. Important: Website users should read section 4 of this Policy on our use of Cookies.
All Personal Data set out above.	In connection with any merger, sale, transfer of our assets, investment, acquisition, bankruptcy, or similar event or corporate transaction, including where necessary the management of shareholders and relevant notifications as required under applicable law.	Necessary for our legitimate interests to ensure we can protect and grow our business.
All Personal Data set out above.	To perform financial accounting functions including tax reporting to comply with applicable laws and accounting standards that the Company adheres to.	Necessary to comply with relevant legal obligations (for example, relating to tax reporting).
All Personal Data set out above.	To protect the rights of the Company and Data Subjects	(a) necessary to comply with relevant legal obligations (for example, applicable data protection/privacy laws). (b) necessary for our legitimate interests to act in, and protect, the interests of our business.

In limited circumstances we may process any of the Personal Data we hold to the extent necessary to defend, establish and exercise legal claims or to comply with legal or regulatory obligations.
Where we need to collect personal data due to a legal or regulatory obligation, or for performance of a contract, and you do not provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our products/services). We will notify you of this at the time.

4. Cookies

Using Cookies

Cookies are small texts that are sent to your web browser from our Website or from a company that provides IT service infrastructure for our Website. The cookie file is stored in your web browser, allowing you to use our website efficiently.
Our website not only utilises cookies that are essential to the operation of our website ("essential" cookies), but also cookies for the purpose of collecting, marketing and analyzing analytical data to improve the functions of the website. Please see our Cookie Banner for more details.

About Declining Cookies

We respect the privacy of customers visiting our Website and have introduced a Cookie Banner. From the cookie banner displayed on our website (accessible via the hover button displayed on the lower left of our Website), you can choose to accept or deny cookies other than those essential to the operation of our Website. Should you refuse to receive cookies, you may still use our website, however some services may be unavailable.

Information on Cookies

For visits to our website by customers based in countries outside of Japan, all non-essential cookies are opt-in. For further detail of our cookies, including their name, purpose and duration, please see our Cookie Banner as described in this Section.

5. Disclosure of your Personal Data

Depending on your dealings with us, we may disclose some or all of the Personal Data we collect from and obtain about you to the following:

Other entities within our group.

We will share your Personal Data internally even between the group companies described in section 1 and our investors to the extent required for internal administrative purposes, management purposes or other business-related purposes as described in this Policy.

Service Providers and Processors.

We engage third party vendors, from time to time, including:

• IT & website service providers
• Professional advisors such as tax or legal advisors (for example, as necessary for the establishment, exercise or defence of legal claims or to protect the rights or safety of the website or the Sumitomo Chemical group)
• Consultants, insurance companies / claim managers and accountants
• Agents, suppliers or sub-contractors and other associated organisations where they are engaged by us to help deliver a service that we have instructed them on.

Third parties in case of a legal requirement.

We also disclose your Personal Data if disclosure is required by law or in the context of an investigation, regulatory requirement, judicial proceeding, court order or legal process (including to law enforcement or competent authorities like the police / tax authorities, such as HMRC in the UK).

Third parties in case of a corporate transaction.

In addition, information about our customers, including Personal Data, may be disclosed as part of any merger, sale, transfer of our assets, investment, acquisition, bankruptcy, or similar event, including while engaging with our actual or potential investors.

We may provide anonymous information to analytics and search engine providers to help us improve and optimise our services. We will only share this information in a form that does not directly identify you. Some of those recipients may be based outside the European Economic Area and/or the United Kingdom. Whenever we make transfers of your Personal Data, we implement appropriate safeguards in accordance with applicable data protection laws, e.g., the Standard Contractual Clauses, the UK Addendum, transfer impact assessments and/or make transfers to countries that have an adequacy decision by the European Commission and/or the UK Information Commissioner's Office. If you would like to find out more about any such transfers, please contact us.

6. Retention of your Personal Data

We will not retain your Personal Data longer than it is necessary to carry out the purposes listed in this Policy or than is required by law. We will generally store Personal Data for up to one year, but if you do business with us or our group companies beyond this website, your personal data will be retained in accordance with the data retention policies separately provided by the group companies. In this case, your personal data will be retained only for the period necessary to accomplish that purpose, in accordance with the legal basis to justify such retention. After the retention period expires, we delete or anonymize the data. In some circumstances, these storage periods may however be exceeded where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or to establish, exercise, or defend legal claims. In specific circumstances we may also retain your Personal Data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.

7. Your rights and how to exercise them

You have several rights in relation to your Personal Data set out in this section. In certain circumstances these rights might not be absolute, as they depend on our reason for processing your personal data. You are not required to pay any charge for exercising your rights, although we may charge a reasonable fee if your request is unfounded, repetitive or excessive. We have one month to respond to you (unless you have made a number of requests or your request is complex, in which case we may take up to an extra two months to respond).

Please note that, where we ask you for proof of identification, the one-month time limit does not begin until we have received this. If we require any clarification and/or further information on the scope of the request, the one-month deadline is paused until we receive that information.

Right to information

You have the right to request confirmation if your Personal Data is processed. When we process your Personal Data, you have a right to information about this Personal Data and for a copy of this information. For more information on your right to information, see Art. 15 of the GDPR and the UK GDPR.

Right to rectification

You have the right to request the rectification of incorrect Personal Data concerning you without delay. Taking into account the purposes of processing, you have the right to request the completion of incomplete Personal Data. For more information on your right to rectification, see Art. 16 of the GDPR and the UK GDPR.
We strive to ensure the accuracy of your Personal Data. We therefore ask you to notify us immediately of any changes to your data (such as changes in address), so that we can ensure that your Personal Data is up-to-date.

Right to erasure

If the legal requirements are met, you may request us to erase your Personal Data immediately. This shall be the case, in particular, where:

• your Personal Data will no longer be required for the purposes for which it was collected or otherwise processed;
• the processing of your Personal Data is based on your consent, you revoke this consent and we cannot base the processing on another legal basis;
• you have objected to the processing of your Personal Data on grounds relating to your particular situation and there are no overriding grounds for the processing of your Personal Data;
• if your Personal Data have been passed on to third parties and we are obligated to erase your Personal Data, we will inform these third parties about the erasure, insofar as this is required by law.

We would like to point out that your right to erasure is subject to restrictions. For example, we may not erase any Personal Data that we have to keep further due to legal requirements. Data that we need in order to assert, exercise or defend legal claims are also excluded from your right to erasure. For more information on your right to erasure, see Art. 17 of the GDPR and the UK GDPR.

Right to restriction

If the legal requirements are met, you may request a restriction on the processing of your Personal Data. This is particularly the case where:

• the accuracy of your Personal Data is contested by you, or the processing of your data will be limited for a period that allows us to verify the accuracy of your Personal Data;
• the processing of your Personal Data is not lawfully carried out and you require a restriction on the use of your Personal Data instead of the erasure of your Personal Data;
• we no longer need your Personal Data for the purposes of processing, but you need these data for the establishment, exercise or defence of legal claims;
• you have objected to the processing of your Personal Data on grounds relating to your particular situation, as long as it is not clear whether our legitimate grounds for processing outweigh your grounds.

For more information on your right to restriction of processing, see Art. 18 of the GDPR and the UK GDPR.

Right to data portability

You have the right to receive the Personal Data you have provided us and which we process for the fulfilment of the contract, on the basis of your consent or by automated procedures, in a structured, customary and machine-readable format. You also have the right to ask us to transmit this data directly to a third party, if this is technically feasible. For more information on your right to data portability, see Art. 20 of the GDPR and the UK GDPR.

Right to complain

If you consider that the processing of your Personal Data violates applicable data protection laws, you may lodge a complaint with your local supervisory authority for data protection issues, which for example in the UK is the Information Commissioner’s Office (ICO) at: https://ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach your local supervisory authority, so please contact us in the first instance using the contact details at the start of this Policy.

Withdrawal of consent

If you have given your consent to the processing of your Personal Data, you can revoke it at any time with effect for the future. The lawfulness of the processing of your data before this remains unaffected.

Right to object

8. Marketing

We take steps to limit direct marketing to a reasonable and proportionate level and to send you communications which we believe may be of interest or relevance to you, based on the information we have about you. You may change your marketing preferences at any time by contacting us. In particular, for email marketing communications, you can always opt-out by clicking the "unsubscribe" link at the bottom of marketing emails.

If you wish your data to be fully deleted from our systems we will do so at your request but, if your email address is at any point added back in to our newsletter database, by you or on your behalf, there will be no automated process in place to prevent a newsletter being emailed to you again. Please note that where we have another lawful basis for processing, we will continue to process personal data for other purposes – for example, we may process information based on contract necessity. You may also receive indirect marketing from us by way of online advertisements or general marketing communications.

9. Contact us

Please contact us (kojinjoho-houmu@ya.sumitomo-chem.co.jp) if you wish to exercise your rights above or if you have any requests related to your personal data.