Personal Information Protection Policy

1. Purpose of use and legal basis

This company shall use personal information on the following legal basis for the following purposes.

2. Provision to Third Parties

This company will not provide personal information to third parties, except in any of the following cases. Provided, however, that the provision of such information shall not constitute disclosure or provision to a third party if it is provided as a result of joint use or entrustment.

1. With your consent;
2. In accordance with laws and regulations;
3. When it is necessary for the protection of life, body, or property of a person and it is difficult to obtain the consent of the data subject;
4. In cases in which it is particularly necessary for the improvement of public health or the promotion of the sound upbringing of children and in which it is difficult to obtain the consent of the data subject.
5. In cases in which cooperation is necessary for the State or local public entities, etc., to conduct public affairs and in which obtaining consent of the data subject may hinder the execution of such affairs; or
6. Provision upon succession of business due to merger, company split, transfer of business or for other reasons.

3. Handling of entrustment

This company may entrust part of its business operations and provide personal information to outsourcees to the extent necessary to achieve the purpose of its use. In such cases, it shall manage and supervise these outsourcees in an appropriate manner, including executing agreements with them regarding the processing of personal information.
The types of acquirers of personal data, which are outsources, are, for example, consultants, recruitment agents, cloud service providers, and IT vendors.

4. Provisions regarding the sharing of personal information

This company will share personal information as follows:

1. Items of personal data to be shared
   Name, Address, Phone Number, E-mail Address, Company Name, Company Address, Department and Position
2. List of the companies that share Personal Data
   • The Group companies including Daicel Corporation and oversea Group companies
     Please refer to the link below for details regarding the Group companies.
     Japanese Group companies: https://www.daicel.com/en/profile/network/group.html
     Global Group companies: https://www.daicel.com/en/profile/network/foreign.html
   • Group companies of Evonik Japan Co., LTD.
     Please refer to the following for information on group companies.
     https://corporate.evonik.jp/ja/company/japan
   • Evonik Industries AG (Germany)
   • Evonik Operations GmbH (Germany)
   • Other overseas affiliates
     https://www.pp-evonik.com/privacy/relation.html
3. Purposes of Sharing
   Purpose of use described in 1 above
4. Company responsible for the sharing of Personal Data
   Address: Shinjuku Monolith 13F, 2-3-1, Nishi-Shinjuku, Shinjuku-ku,
   Tokyo 163-0913, Japan
   Polyplastics-Evonik Corporation.

5. Transfer outside of Japan

This company may provide personal information to group companies located outside of Japan. In such cases, this company takes necessary measures in accordance with the provisions of laws and regulations of the relevant country.
Some of the Group companies are located in countries which are not recognized under the APPI or the GDPR as providing adequate protection and in such case the company concludes a data transfer agreement with such Group company for sufficient data protection.

6. Retention period of personal information

We will only retain your personal information as long as is necessary for business purposes. We may also retain your personal data if reasonably necessary to comply with legal, and/or regulatory requirements.

7. Matters concerning safety management measures

This company takes measures to prevent leakage, loss, or destruction of personal information and to otherwise manage it appropriately as follows.

1. Development of the basic policy for security control of personal information
   • This basic policy has been developed to ensure the proper handling of personal information and to inform you of a contact point for questions and complaints.
2. Development of rules for handling of personal information
   • Development of personal information protection rules for each stage of acquisition, use, storage, provision, deletion/disposal, etc.
3. Institutional security control measures
   • Appointment of person responsible for the handling of personal information (Personal Information Protection Manager)
   • Development of security control actions in rules of employment, etc.
   • Development and implementation of a system for periodic inspections and audits of the status of handling personal data
   • Development of a system for responding to information leakage or other incidents
4. Human security control measures
   • Thorough dissemination of security control actions to employees and their education and training
   • Provisions regarding confidentiality obligations set forth in our rules of employment
5. Physical security control measures
   • Management of areas where personal information is handled
   • Prevention of theft, loss, etc. of a device, electronic medium and the like used to handle personal information
   • Prevention of situations such as leakage of personal information occurring when carrying electronic medium and the like; and
   • Deletion of personal data and disposal of a device, electronic medium, and the like
6. Technological security control measures
   • Setting of management categories of personal data and access control
   • Development of measures to prevent the leakage, unauthorized access, and other incidents
7. Understanding external environment
   • Implementation of safety control measures after understanding the systems related to the protection of personal information at the recipient of personal information.

8. Customer requests

You may have the following rights under applicable laws and regulations with respect to your personal information held by this company.

1. To withdraw consent
2. To request for disclosure, correction, addition, and deletion
3. To request for suspension of use and stopping providing to a third party
4. To request for data portability
5. To request suspension of use for targeted advertising or marketing purposes

If you wish to make any of the above requests regarding the personal data held by the Group Company, please contact us using the contact information listed in 8 below. After confirming the identity of the person making the request, we will respond to the request to a reasonable extent and in accordance with applicable laws and regulations.

9. Request for inquiry and complaint

For inquiries or complaints regarding this company’s handling of personal information, please contact us using the following contact information.

Contact to
Controlling & Business Support, Polyplastics-Evonik Corporation
Shinjuku Monolith 13F, 2-3-1, Nishi-shinjuku, Shinjuku-ku,
Tokyo 163-0913, Japan
E-mail: info-jp@polyplastics-evonik.com

10. Appeals to the data protection authority

You have the right to object to the data protection authority having jurisdiction over your residence in processing personal information relating to you. Data protection authorities in the EU countries can be found through following URL.
(https://edpb.europa.eu/about-edpb/about-edpb/members_en)

11. Contact information for data administrators and data protection officers

Controlling & Business Support, Polyplastics-Evonik Corporation
Shinjuku Monolith 13F, 2-3-1, Nishi-shinjuku, Shinjuku-ku, Tokyo 163-0913, Japan
E-mail: info-jp@polyplastics-evonik.com

2. Disclosure to third parties

In addition to the cases set forth in Article 4, Chapter 1 (Provisions regarding the sharing of personal information), the categories of third parties to which this company disclosed personal information in the past 12 months, and the personal information disclosed are as follows.

• Category of third parties: Group companies
  • Personal information disclosed
    personally identifiable information, which is information that identifies you personally, such as your first and last name, e-mail address, phone number, address, and full payment account number.
  • The purposes
    Managing suppliers, consideration for employment and sending recruitment-related documents
• Category of third partis: Polyplastics-Evonik’ agents, vendors, consultants and other service providers
  • Personal information disclosed
    personally identifiable information, which is information that identifies you personally, such as your first and last name, e-mail address, phone number, address, and full payment account number.
  • The purposes
    Receipt of Services

3. Sales to third parties

This company does not sell any personal information to third parties.

4. Use of sensitive personal information

This company may use the following sensitive personal information.

• Executives or employees of Trustees
  • Passport number
• Passport number
  • Passport number
• Applicants for Employment
  • Passport number
  • Social security number
  • Drivers' license number
  • State identification card number
• Executives or Employees of this company
  • Passport number
  • Social security number
  • Drivers' license number
  • State identification card number
  • Personal information collected and analyzed concerning a health

This company use sensitive personal information only to perform the services or provide the goods such as business trip arrangements reasonably expected by reasonable consumers who request those goods or services.

5. Personal information of consumers under 16 years of age

This company does not disclose of sell personal information of consumers under 16 years of age to third parties.

6. Requests for the processing of personal information

This company shall respond to requests (the right for requesting disclosure and the right for deletion of personal information) regarding personal information of individuals residing in California, U.S.A., held by this company within a reasonable period and extent, in accordance with the relevant laws and regulations, as follows.
pon receiving such a request, we will confirm the identity of the customer in advance when responding to a request.

In principle, the contents of the service shall not be changed for the person who made the inquiry. You have the right not to be discriminated against by this company for exercising your rights. In addition, you may also designate an agent to exercise your rights. If you wish to exercise your rights, please contact us using the following contact information.

Contact information
Controlling & Business Support, Polyplastics-evonik Corporation
Shinjuku Monolith 13F, 2-3-1, Nishi-shinjuku, Shinjuku-ku, Tokyo 163-0913 Japan
E-mail: info-jp@polyplastics-evonik.com

Disclosure or deletion may result in the inability to provide services that were previously available or that satisfy your requirements. The customer consents to such possibility prior to making a request.
Last updated: April 28th, 2023

1. How we protect your personal information

1. This company has employed security protection measures according to industry
   standards, in order to protect your personal information and to prevent unauthorized access to, disclosure, use, modification, damage or loss of data.
2. This company shall take all reasonable and practicable measures to ensure that unnecessary personal information is not acquired. This company shall retain your personal information only for the period that is necessary to fulfill the purposes set forth in this policy; however, this shall not apply to cases where an extension of the retention period is required or permitted by law.
3. Our network environment is not 100% secure. This company shall make its upmost efforts to ensure or guarantee the security of any information you send to us. If your legal rights and benefits are adversely affected due to unauthorized access to, disclosure or tampering or damage of your personal information resulting from the damage of our physical, technical or management protection facilities, this company shall assume legal liabilities accordingly.
4. In the event of a personal information security incident, this company shall, in accordance with laws and regulations and without delay, notify the customer of the basic situation and possible impact of the personal information security incident, the response measures that this company has already implemented or plans to implement, proposals to the customer regarding self-prevention and risk mitigation, and this company’s improvement measures for the customer.
   This information hall be notified by means such as e-mail, fax, telephone, push notification. If it is difficult to notify the subject of personal information individually, the information shall be announced in an appropriate and effective manner.

At the same time, we shall also take the initiative in reporting our handling of personal information security incidents in accordance with regulatory requirements.

2. Your rights

You shall have the following rights with respect to your personal information held by this company.

• Right to access, rectify, and delete your personal information
• Right to inspect and acquire a copy of your personal information
• Right to limit or refuse the handling of your personal information by those other than the Company

3. How your Personal information is transmitted worldwide

In principle, personal information acquired in China will be stored in China.
We share your personal information with the following Group Companies, with your consent. In addition, your personal information might be transmitted to or accessed from a jurisdiction outside of the country/region after we take other necessary measures for the information security.

4. How this Policy will be updated

Our policy might be changed.
We will not reduce any of your rights under this policy without your explicit consent. We will publish any change to the policy on this page.
For major changes, we will provide a more conspicuous notice (including, for certain services, notices via email that explain the details of the changes to the policy).
We will also archive the old versions of this policy for your reference.

5. Contact

If you have any questions or comments regarding this policy, please contact us using the following contact information.

Contact information
Controlling & Business Support, Polyplastics-evonik Corporation
Shinjuku Monolith 13F, 2-3-1, Nishi-shinjuku, Shinjuku-ku, Tokyo 163-0913 Japan
E-mail: info-jp@polyplastics-evonik.com