Personal Data Protection Policy

Last updated: April 21, 2023

Scope of This Privacy Policy

This Privacy Policy applies to the data obtained by NAGASE.
This Privacy Policy does not apply to data collected by any third party, including through any application or content that may link to or be accessible from or on our Website.

This Privacy Policy is subject to any additional terms of disclaimers or other contractual terms you have entered into with NAGASE such as client privacy statements or notices, and any applicable laws, regulations, and guidelines on the protection of Personal Data. Please be aware that for certain services, NAGASE may provide you with privacy statements in addition to, or in place of, this Privacy Policy, as appropriate.

Definitions

In this Privacy Policy, the following terms have the following meanings:

“Personal Data” means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to reference to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Process” or “Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

Data We Collect About You

We may Process different kinds of Personal Data about you which we have grouped together as follows:

• Identity Data includes name, country, company, position, employer number, user account data, date of birth and gender.
• Contact Data includes, email address, telephone numbers, office location address, billing address, delivery address.
• Financial Data includes bank account and payment card details.
• Technical Data includes internet protocol (IP) address, date and time of your access, time zone setting and location, browser type and version, your device identifies, your internet or wireless service provider and other technology on the devices you use to access this Website.

We do not collect following data from you:

• race, creed, social status, medical history, criminal record, record as a criminal victim
• physical handicap, intellectual handicap, mental disorder
• results of medical examination and other examination
• health guidance, medical treatment / dispensing information
• proceedings concerning criminal cases such as arrest and search, having the data subject as the suspect or the accused
• proceedings concerning protection cases of juveniles such as protective dispositions, having the data subject as a juvenile delinquent person or a person suspected to be a juvenile delinquent

How We Collect Your Data

We use different methods to collect Personal Data from and about you including through:

・Direct interactions. You may give us your Identity, Contact and Financial Data by exchanging business card, sending emails or filling in forms or otherwise.

・Automated technologies or interactions. As you interact with our Website, we (and service providers acting on our behalf) will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Technical Data by using Cookies, web beacons or other similar tools. Web browsers are usually set by default to accept Cookies (including web beacons) but you may easily change this by modifying the settings of your browser. However, please note that should you choose to disable Cookies, you may be unable to use part of the functions of this Website.
If you do not agree to the use of Cookies, please select "Reject all Cookies" on our Cookie banner. However, essential Cookies cannot be rejected. You may change your consent/rejection selection at any time on the Cookie Settings page below.

The purposes for which we use Cookies on our Website are as follows:
(1) to perform statistical analysis to understand how our Business Partners use our Website and to help us improve the structure and content of our Website;
(2) to analyze or compile statistics of the collected information and provide better products and services by bringing our products and services closer to the interests and needs of our Business Partners; and
(3) to analyze or compile statistics of the collected information and provide information on our products and services to our Business Partners and to conduct sales promotion activities.
The following tools are mainly used on our Website for the above purposes, and information may be provided to the tool providers.

1. Google Analytics
   Tool provider: Google Inc.
   Google Privacy Policy:http://www.google.com/intl/ja/policies/privacy/partners/
   Information collected through the tool: Information about website usage by our Business Partners (access status, traffic, routing, etc.)
2. Marketing Cloud Account Engagement
   Tool provider: salesforce.com, inc.
   Salesforce Privacy Policy:https://www.salesforce.com/jp/company/privacy/full_privacy/
   Information collected through the tool: [Information about website usage by our Business Partners (access status, traffic, routing, etc.)]
3. Marketo Engage
   Tool provider: Adobe
   Adobe Experience Cloud Privacy Policy:https://www.adobe.com/jp/privacy/experience-cloud.html
   Information collected through the tool: [Information about website usage by our Business Partners (access status, traffic, routing, etc.)]
4. Kairos3
   Tool provider: Kairos Marketing Inc.
   Kairos Marketing Privacy Policy: https://www.kairosmarketing.net/corporate/
   personal-informationInformation collected through the tool: [Information about website usage by our Business Partners (access status, traffic, routing, etc.)]
5. List Finder
   Tool provider: Innovation X Solutions
   Innovation X Solutions Privacy Policy:https://faq.list-finder.jp/faq/1079
   Information collected through the tool: [Information about website usage by our Business Partners (access status, traffic, routing, etc.)]

Lawful Basis

We will process your Personal Data when the applicable law allows us to. Most commonly, we will process your Personal Data in the following circumstances, to the extent permitted by the applicable law:

• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
• Where we need to perform the contract we are about to enter into or have entered into with you.

Where applicable data protection laws require us to obtain your consent to such Processing of your Personal Data, we will ask for your consent. If you wish to withdraw your consent to Process your Personal Data, please contact us as set forth in the “How to Contact Us” section.

Purposes for Which We Will Use Your Personal Data

We use your Personal Data on the lawful basis above for the following purposes:

• Notify and greet based on social customs.
• Provide you with information, products or services.
• Enter into contracts with you and perform our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Fulfill customer inquiries and respond to any problems that may arise, such as difficulties in navigating our Website or accessing certain features.
• Send samples, price quotations, products, and information.
• Develop new products and services.
• Send you newsletters, features, promotional material, surveys, and other updates.
• Analyze your interests based on your browsing history or buying history on our Website.
• Send you emails and/or postal messages with information about the brand and other content of NAGASE Group we think may be of interest to you.
• Develop and provide advertising tailored to your interests, including interest-based advertising.
• Personalize your experience on our Website by presenting products and information tailored to you.
• Evaluate and administer products and services of NAGASE Group.
• Gauge our customers' trends to determine what products and services are popular with our customers.
• Provide information relating to NAGASE Group’s business activities and for exchange of such information.
• Provide services relating to or connected to services other than those described above.
• Share your Personal Data among NAGASE Group for the purposes listed above or for administrative purposes inside NAGASE Group.

Disclosures of Your Personal Data

We may disclose certain categories of your Personal Data as may be necessary for the purposes stated above when the applicable law allows us:

• To NAGASE Group.
• To our service providers with the appropriate management and supervision including those providing us with cloud computing, customer relation management, marketing automation, advertising, messaging or other application, business travel arrangement, courier, receptionist, conference/event arrangement, hospitality, accommodation.
• To a party that merge or acquire part or all of our business or assets.

NAGASE (for its address and representative, please see https://www.nagase.co.jp/english/company/profile/) is responsible for the management of Personal Data shared among NAGASE Group. In order to request disclosure of your Personal Data shared among NAGASE Group, or to make inquiries or complaints regarding the use of such information, please contact us in accordance with “How to Contact Us” below.

We may also disclose your Personal Data:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To protect life, body, or property, and when it is difficult to obtain consent of the data subject.
• To enhance public hygiene or promote sound upbringing of children, and when it is difficult to obtain a consent of the data subject.

International Transfers

We may transfer your Personal Data to countries whose data protection laws are not as comprehensive as those from where you are based, because of business globalization. When we transfer Personal Data overseas, we have put in place appropriate safeguards, such as contractual commitments (using the format required under applicable data protection law, if any), in accordance with applicable legal requirements to ensure that your Personal Data is adequately protected.

How Long We Keep Your Personal Data

We will retain your Personal Data we collected for the period necessary to fulfill the purposes stated in this Privacy Policy, unless a longer retention period is required by law. After such retention period, your Personal Data will be deleted promptly and safely.

Legal Rights with Regard to Your Personal Data

We respect your privacy rights and provide you with reasonable access to your Personal Data that you have provided. Based on the applicable law to your Personal Data, and within the limits of the applicable law, you may have the right to access, rectification, erasure, restrict Processing, object to Processing, suspension of data transfer, and withdraw consent. To exercise your rights, please contact us in accordance with “How to Contact Us” below.

Data Security

We follow generally accepted industry standards to protect the information submitted to us, both during transmission at our Website and once we receive it. We maintain appropriate administrative, technical, and physical safeguards to protect your Personal Data collected by us against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of Processing of your Personal Data in our possession.
However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. NAGASE cannot ensure or warrant the security of any information you transmit to us. NAGASE also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Data has been compromised, please contact us as set forth in the “How to Contact Us” section.
We have put in place procedures to deal with any suspected Personal Data breach and will notify of a breach where we are legally required to do so.

Personal Data of Business Partners Located in the European Economic Area (EEA)

Within the limits of applicable law, our Business Partners located in the European Economic Area (“EEA”) have the right to access, rectification, erasure, restrict Processing, object to Processing, data portability, and not be subject to a decision making based solely on automated Processing, including profiling, with legal or similarly significant effects. In addition, our Business Partners located in the EEA may withdraw their consent to the processing of their personal data at any time. If you wish to exercise any of the above rights or withdraw your consent, please contact us in accordance with “How to Contact Us” below.
Our Business Partners located in the EEA also have the right to lodge a complaint with the competent data protection authority concerning the processing of their personal data.

Changes to this Privacy Policy

From time to time, in order to comply with changes in applicable law or for legitimate business purposes, we may make changes to this Privacy Policy. Any changes we make will be displayed on our Website. Please check back from time to time to ensure that you have read the most recent version of this Privacy Policy.

How to Contact Us

If you exercise your rights that are referred to in this Privacy Policy or you have any questions or concerns about this Privacy Policy or our privacy practices, please contact us from our Website titled “Inquiries” (https://www.nagase.co.jp/english/contact/).
Alternatively, you can contact us in writing at:

NAGASE ABRASIVE MATERIALS CO.,LTD.
1-1-17 Shinmachi, Nishi-ku, Osaka City, Osaka 550-8668
Tel: +81-6-6535-2527 Fax: +81-6-6535-2534