Daicel Group Policy on the Protection of Personal Information (Privacy Policy)

Daicel Corporation and its affiliates (hereinafter referred to as the "Group") will properly process personal information in compliance with the Act on the Protection of Personal Information (hereinafter referred to as "APPI") and other laws and regulations relating to the protection of personal information as well as guidelines, generally accepted practices related to the processing of personal information, etc. when acquiring, using, and providing personal information. In addition, the Group will clarify its rules and regulations concerning the processing of personal information, and strive to ensure that all employees such as officers, full-time employees, contract employees, temporary employees, and part-time employees (hereinafter referred to as the "Employees") properly handle personal information.

"Personal information" means information that can identify you as a specific individual, such as your address, name, telephone number including information that falls under "personal data" as defined in Article 4 of the EU General Data Protection Regulation (hereinafter referred to as "GDPR"). However, personal numbers and specific personal information shall be specified under separate regulations.

Chapter1. Processing of Personal Information in the Group

1 Purpose of Use and Legal basis

The Group uses personal information on the following legal bases 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 with suppliers and supplying goods or services
  • Managing suppliers
  • Business contact
  • Confirming visitors and health condition
  • Soliciting services, advertising and other marketing
  • Sending direct mail, e-mail newsletters, and other greetings
  • Implementing questionnaires, surveys, etc.
  • Event implementation
  • Planning and development of products, and consideration of measures to improve customer satisfaction
  • Patent management services
  • Responding to inquiries, etc.
<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 Executives or Employees of Trustees, etc. >
(Name, Address, Phone number, E-mail Address, Company Name, Company Address, Department, Position, Passport number, etc.)
  • Administrating outsourced trustees
  • Business contact
  • Confirming visitors and health condition
<Personal Information of Applicants for Employment>
(Name, Address, Phone number, E-mail Address, Passport number, Drivers' license number, Social security number, etc.)
  • Considering employment and sending recruitment-related documents
  • Confirming visitors and health condition
  • Responding to inquiries, etc.
<Personal Information of Visitors, Residents Neighboring Daicel Facilities or Officials >
(Name, Address, Phone number, E-mail Address, Company Name, Company Address, Department, Position, etc.)
  • Making evacuation directives and other necessary contact at the time of any emergency situation, such as natural disaster or other similar situation
  • Responding to inquiries, etc.
  • Confirming visitors and health condition
  • Implementing questionnaires, surveys, etc.
  • Soliciting services, advertising and other marketing
<Personal Information of Executives or Employees of The Group>
(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 whistle-blowing, 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 The Group>
(Name, Information concerning allergies, etc.)
  • Organizing Events for Executives and Employees and their families.

2 Provision to Third Parties

The Group will not provide personal information to any third party except under any of the below conditions. Provided, however, that the provision of such information does not constitute disclosure or provision to a third party if it is provided as a result of joint use or consignment.

  1. 1With your consent;
  2. 2In accordance with laws and regulations;
  3. 3When 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. 4In 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. 5In 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. 6Provision upon succession of business due to merger, company split, transfer of business or for other reasons.

3 Handling of entrustment

Our Group may entrust part of its business activities and provide personal information to outsourcees to the extent necessary to achieve the purpose of use. In this case, the Company shall properly manage and supervise the outsourcees, including the conclusion of contracts for the processing of personal information with these outsourcees.
Acquirer of personal information as outsourcees are, for example, consultants, employment agents, crowd service providers, and IT vendors.

4 Provisions regarding the sharing of personal information

The Group will share personal information, as follows:
Sharing of personal information of Executives or Employees of Existing or Prospective Business Partners

  1. 1Items of Personal Data to be shared
    Name, Address, Phone Number, E-mail Address, Gender, Company Name, Company Address, Department and Position, etc.
  2. 2List 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
  3. 3Purpose of Sharing
    Purpose of use described in 1 above.
  4. 4Company responsible for the sharing of Personal Data
    Daicel Corporation
    Address:3-1 Ofukacho Kita-ku, Osaka-shi, Osaka 530-0011, Japan
    Responsible Person:Kotaro Sugimoto

5 Transfer outside of Japan

The Group may provide personal information to Group companies outside Japan. In this case, such Group 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

The Group shall take the following appropriate measures for the security control of personal information including preventing leakage, loss, and destruction of its handled personal information

  1. 1Development of basic rules for security control of personal information
    • Formulation of this policy to ensure proper handling of personal information and to inform you of the contact for processing of queries or complaints.
  2. 2Development of rules for handling personal information
    • Development of handling rules at each stage of acquisition, use, provision, deletion/disposal, etc.
  3. 3Institutional security control measures
    • Appointment of person responsible for management of personal information, etc.
    • Development of security control actions in rules of employment, etc.
    • Development and implementation of a regular system for inspection and audit of the handling status of personal information.
    • Development of a system for responding to information leakage or other incidents
  4. 4Human security control measures
    • Thorough dissemination of security control actions to employees and their education and training
    • Provision about obligation of confidentiality described on rules of employment, etc.
  5. 5Physical security control measures
    • Management of personal information handling area, etc.
    • Preventing theft, loss, etc., of a device and electronic medium, or the like for handling personal information.
    • Preventing leakage or other accidents etc. in carrying electronic medium, or the like; and
    • Deletion of data and disposal of electronic medium, or the like.
  6. 6Technological security control measures
    • Setting of management categories of personal information and access control
    • Development of measures to prevent the leakage, non-authorized access or other accidents.
  7. 7Understanding the external environment
    • Understanding the system of the companies where the provision destinations are located and take appropriate measures for security control.

8 Customer requests

You may have the following rights concerning personal information retained by the Group Company based on the applicable legislation.

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

For inquiries or complaints about the Group's handling of personal information, contact:

Personal Information Protection Office Daicel Corporation
E-mail Address: personal_information@jp.daicel.com

10 Appeals to the data protection authority

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

11 Contact information for data administrators and data protection officers

Daicel Corporation
Address:3-1 Ofukacho Kita-ku, Osaka-shi, Osaka 530-0011, Japan
Responsible Person:Kotaro Sugimoto
Contact:personal_information@jp.daicel.com

12 Changes to this Privacy Policy

The Group may amend or update this Privacy Policy as necessity demands. In the event of significant changes, the Group will notify you with the content and the effective date of the change.

Chapter2. 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 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 4 (Provisions regarding the sharing of personal information) of Chapter 1, the categories of third parties to which the Group disclosed personal information in the past 12 months and the personal information disclosed are as follows.

Categories of third parties with whom such personal information is disclosed: 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

Categories of third parties with whom such Personal Information is disclosed: Daicel's 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

The Group does not sell personal information to third parties.

4 Use of sensitive personal information

The Group may use the following sensitive personal information.

Executives or employees of Trustees

  • Passport number

Executives or employees of Existing or Prospective Business Partners

  • Passport number

Applicants for Employment

  • Passport number
  • Social security number
  • Drivers' license number
  • State identification card number

Executives or Employees of the Group

  • Passport number
  • Social security number
  • Drivers' license number
  • State identification card number
  • Personal information collected and analyzed concerning a health

The Group 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

The Group 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

You have the right to limit the use or disclosure of your personal information in addition to the rights described in Chapter 1 "8 Customer requests". The Group will respond to requests (the right for disclosure, deletion of personal information) for personal information of individuals residing in California, U.S.A., retained by the Group, for the following periods and to the extent reasonable, in accordance with relevant laws and regulations. In addition, we will confirm the identity of the customer in advance when responding to a request.
The disclosure request is for the content of personal information the Group collect (including the category of the personal information), source of personal information, the business or commercial purpose for which the personal information is collected, sold or shared, categories of third parties with whom such personal information is disclosed, and the specific items of personal information the business has collected about the consumer.

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 the Group for exercising your rights. You may also appoint an agent to exercise your rights.
If you want to exercise your rights, we have the following inquiry form and contact point.

Inquiry Form and Contact Point:
here or at 21515 Hawthorne Blvd, #600, Torrance, CA 90503 (Attention: Legal / Privacy)

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.

Date of last update: April 28th, 2023

Chapter3. Processing of Personal Information of Individuals Residing in China

The Group will comply with the China Personal Information Protection Law and related laws and regulations, handle the personal information of customers residing in China in an appropriate manner, and strive to protect the privacy of our customers.
In addition to Chapter 1, the provisions of Chapter 3 apply to the processing of personal information of individuals residing in China, in accordance with the China Personal Information Protection Law. In the event the contents stipulated in Chapter 1 conflict with those stipulated in Chapter 3, the provisions of Chapter 3 shall prevail.

1 How we protect your Personal Information

  1. 1We have employed security protection measures according to industry standards to protect your personal information, prevent unauthorized access to, disclosure, use, modification, damage or loss of data.
  2. 2We will take all reasonable and practical measures to ensure that unnecessary personal information are not collected. We will only retain your personal information for the period necessary to perform the purposes stated in this Policy, unless extended retention is required or allowed by laws.
  3. 3The network environment is not 100% secure. We will do our utmost to ensure or guarantee the security of any information you send to us. If your legal rights and benefits are adversely affected due to the unauthorized access to, disclosure, tampering or damage of your personal information resulting from the damage of our physical, technical or management protection facilities, we will assume legal liability, accordingly.
  4. 4In the event of a personal information security incident, the Group will, 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 the Group has already implemented or plans to implement, proposals to the customer regarding self-prevention and risk mitigation, and the Group's improvement measures for the customer. This information will be notified by e-mail, fax, telephone, push notification, etc. If it is difficult to notify the subject of personal information individually, the information will be announced in an appropriate and effective manner.

At the same time, we will also take the initiative to report the handling of personal information security incidents in accordance with regulatory requirements.

2 Your rights

  1. 1Right to access, rectify, and delete your personal information
  2. 2Right to inspect and acquire a copy of your personal information
  3. 3Right to limit or refuse the handling of your personal information by others

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 Medical 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.
Kyodo Sakusan Co., Ltd.
Kyoei Shokusan Co., Ltd.
PI-CRYSTAL Inc.
P Holdings, Inc.
PTM Holdings, Inc.
PolyplaService Co., Ltd.
Polyplastics Co., Ltd.
Polyplastics-Evonik Corporation
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.
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.
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 doubt, comment or suggestion regarding this policy, please contact us using the following contact information.

Daicel (China) Investment Co., Ltd.
Tel: +86-21-5878-0737
Fax: +86-21-5878-0649
E-mail: dcic_info@dcic.daicel.com

Date of last update: Oct. 13th, 2023

Personal Information Protection Office

Daicel Corporation. Tokyo Head Office
JR Shinagawa East Bldg.
Konan 2-18-1, Minato-ku, Tokyo, Japan
personal_information@jp.daicel.com

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