Personal Information Protection Policy

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Polyplastics-Evonik Corporation (hereinafter referred to as “this company”) recognizes that it is its social responsibility as a company to appropriately protect the personal information it possesses, and shall handle personal information in an appropriate manner in compliance with the “Act on the Protection of Personal Information”, other applicable laws and regulations concerning the protection of personal information and privacy as well as generally accepted practices, guidelines, etc. concerning the processing of personal information when acquiring, using and providing personal information.
In addition, this company shall strive to clarify its rules and regulations concerning the handling of personal information and ensure that all employees and others are familiar with these rules and regulations so that they can properly handle personal information.
Personal information refers to information that can identify you as a specific individual, such as your address, name, and phone number (including information that falls under “personal data” as defined in Article 4 of the General Data Protection Regulation (hereinafter referred to as “GDPR”).

Chapter 1: Processing of Personal Information in this company

1. Purpose of use and legal basis

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

<Personal Information of Executives or Employees of Existing or Prospective Business Partners>

(Name, Address, Phone Number, E-mail Address, Company Name, Company Address, Department, Position, Passport number, etc.)

  • Conducting business transactions with and providing products and services to business partners
  • Managing business partners
  • Contact for business purposes
  • Confirming visitors and their health condition
  • Soliciting services, advertising and other marketing
  • Sending of direct mails, e-mail magazines, and other greetings
  • Implementing questionnaires, surveys, etc.
  • Holding events
  • Sending printed materials
  • Planning and developing products, or considering measures to improve customer satisfaction
  • Patent management services
  • Responding to inquiries and sending of responses

<Personal Information of Shareholders>

(Name, Number of shares held, Address, Phone number, E-mail Address, etc.)

  • IR releases and information distribution
  • Shareholder convenience and status, to manage shareholders, to implement various measures to facilitate relations with shareholders, and to hold general meetings of shareholders
  • Responding to inquiries, etc.

<Personal Information of Trustees, etc.>

(Name, Address, Phone Number, E-mail Address, Company Name, Company Address, Department, Position, Passport number, etc.)

  • Administrating outsourced trustees
  • Contact for business purposes
  • Confirming visitors and their health condition

<Personal Information of Applicants for Employment>

(Name, Address, Phone Number, Passport number, Driver's License Number, Social Security Number, etc.)

  • Considering employment and sending recruitment-related documents
  • Confirming visitors and their health condition
  • Responding to inquiries and sending of responses

<Personal Information of Residents Living Near Our Facilities, Visitors to Our Facilities or Officials>

(Name, Address, Phone Number, E-mail Address, Company Name, Company Address, Department, Position, etc.)

  • Making evacuation directive and other necessary contact at the time of any emergency situation, such as natural disaster and other similar situation
  • Responding to inquiries and sending of responses
  • Confirming visitors and their health condition
  • Implementing questionnaires, surveys, etc.
  • Soliciting services, advertising and other marketing

<Personal Information of Executives or Employees of This Company>

(Name, Address, Phone number, E-mail Address, Employee ID number, Gender, Birthdate, Emergency contact, Company Name, Company Address, Department, Position, Passport number, Drivers' license number, Social security number, Health-related information, etc.)

  • Labor management, including business communications, attendance, payroll, expense reimbursement, staffing, personnel evaluations, benefits, health, and safety, etc.
  • Sharing of information necessary for the execution of business within the company or among Group companies, etc.
  • Receipt and performance of various procedures stipulated in internal rules and regulations, etc.
  • Contacting Group companies, etc., in case of emergency, etc.
  • Handling of whistleblowing, audits, lawsuits and other court proceedings, investigations of problems, and other duties as required by relevant laws and regulations, etc.

<Personal Information of Families of Executives or Employees of This Company>

(Name, Information concerning allergies, etc.)

  • Organizing Events for Executives and Employees and their families.

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
  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

Chapter 2: Processing of personal information of individuals residing in the State of California, U.S.A

In addition to Chapter 1, the provisions of Chapter 2 apply to the processing of personal information of individuals residing in the State of California, U.S.A., in accordance with the California Consumer Privacy Act of 2018 (California Consumer Privacy Act). In the event the contents stipulated in Chapter 1 conflict with those stipulated in Chapter 2, the provisions of Chapter 2 shall prevail.

1. Acquired personal information in the past 12 months

Personal information acquired by the Group in the past 12 months is as below. All of this personal information is obtained from the data subject.

  • Personal information on our business partners
    • Personal information obtained
      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 and demographic information, such as your gender, age, zip code, interests, and recent and upcoming purchases.
    • Source of personal information
      Business partner him/herself, Agents of business partners
  • Personal information to be acquired through applications for employment
    • Personal information obtained
      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 and demographic information, such as your gender, age, zip code, interests, and recent and upcoming purchases.
    • Source of personal information
      applicant him/herself, Recruiters

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

Chapter 3: Processing of personal information of individuals residing in China

This company shall comply with the Personal Information Protection Law of the People’s Republic of China and related laws and regulations, handle the personal information of customers residing in China in an appropriate manner, and strive to protect their privacy.
In addition to the provisions set forth in Chapter 1, the provisions set forth in Chapter 3 shall apply to the processing of personal information of individuals residing in China, in accordance with the Personal Information Protection Law of the People’s Republic of China. If there is any conflict between the provisions set forth in Chapter 1 and those set forth in Chapter 3, the provisions set forth in Chapter 3 shall prevail.

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.

Japanese Group companies (Alphabetical Order)

  • Daicel Aboshi Sangyo Co., Ltd.
  • Daicel Arai Chemical Ltd.
  • Daicel Beyond Ltd.
  • Daicel Logistics Service Co., Ltd.
  • Daicel Miraizu Ltd.
  • Daicel Ohtake Sangyo Co., Ltd.
  • Daicel Pack Systems Ltd.
  • Daicel Pyrotechnics Ltd.
  • Daicel Safety Systems Inc.
  • Daicel Value Coating Ltd.
  • Daicen Membrane-Systems Ltd.
  • Dainichi Chemical Co., Ltd.
  • DM Novafoam Ltd.
  • DSL. Japan page
  • EVONIK JAPAN CO., LTD.
  • Kyodo Sakusan Co., Ltd.
  • Kyoei Shokusan Co., Ltd.
  • NIPPON AEROSIL CO., LTD.
  • PI-CRYSTAL Inc.
  • P Holdings, Inc.
  • PTM Holdings, Inc.
  • PolyplaService Co., Ltd.
  • Polyplastics Co., Ltd.
  • San Apro Ltd.

Global Group companies (Alphabetical Order)

  • Chiral Technologies Europe S.A.S.
  • Chiral Technologies, Inc.
  • Daicel America Holdings, Inc.
  • Daicel Arbor Biosciences (Biodiscovery LLC)
  • Daicel (Asia) Pte.Ltd.
  • Daicel ChemTech, Inc.
  • Daicel Chiral Technologies (China) Co., Ltd.
  • Daicel Chiral Technologies (India) Pvt. Ltd.
  • Daicel (China) Investment Co., Ltd.
  • Daicel (Europa) GmbH
  • Daicel Micro Optics Co. Ltd.
  • Daicel Miraizu (Hong Kong) Ltd.
  • Daicel Miraizu (Thailand) Co.,Ltd.
  • Daicel Nanning Food Ingredients Co., Ltd.
  • Daicel Safety Systems Americas, Inc.
  • Daicel Safety Systems Europe Sp.z o.o.
  • Daicel Safety Systems India Pvt. Ltd
  • Daicel Safety Systems (Jiangsu) Co., Ltd.
  • Daicel Safety Technologies (Jiangsu) Co., Ltd.
  • Daicel Safety Systems (Thailand) Co., Ltd.
  • Daicel Trading (Shanghai) Ltd.
  • DP Engineering Plastics (Nantong) Co., Ltd.
  • EvonikIndustriesAG
  • Evonik (Philippines) Inc.
  • Evonik (SEA) Pte Ltd
  • Evonik (Thailand) Ltd.
  • Evonik Corporation
  • Evonik Fibres GmbH
  • Evonik Korea Ltd.
  • Evonik Malaysia Sdn Bhd
  • Evonik Membrane Extraction Technology Ltd.
  • Evonik Specialty Chemicals (Shanghai) Co., Ltd.
  • Evonik Taiwan Ltd.
  • Evonik Vietnam LLC
  • EvonikOperationsGmbH
  • Jida-Evonik High Performance Polymers (Changchun) Co., Ltd.
  • LCP Leuna Carboxylation Plant GmbH
  • Polyplastics Asia Pacific Sdn. Bhd.
  • Polyplastics Asia Pacific Singapore Pte. Ltd.
  • Polyplastics China Ltd.
  • Polyplastics Europe GmbH
  • Polyplastics Korea Ltd.
  • Polyplastics Marketing (India) Private Ltd.
  • Polyplastics Marketing Mexico, S.A. de C.V.
  • Polyplastics Marketing (T) Ltd.
  • Polyplastics (Nantong) Ltd.
  • Polyplastics (Shanghai) Ltd.
  • Polyplastics Taiwan Co., Ltd.
  • Polyplastics Trading (Shanghai) Ltd.
  • Polyplastics USA, Inc.
  • PTM Engineering Plastics (Nantong) Co., Ltd.
  • PT. Evonik Indonesia
  • Roehm America LLC
  • Roehm Chemical (Shanghai) Co., Ltd.
  • Röhm GmbH
  • Shanghai Daicel Polymers, Ltd.
  • Topas Advanced Polymers GmbH

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

Last updated: Jun 12th, 2023