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").

Chapter1. Processing of Personal Information in Our Group

1 Purpose of Use and Legal basis

Our Group uses 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, 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 magazines, 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>
  • 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. >
  • Administrating outsourced trustees
  • Business contact
  • Confirming visitors and health condition
<Personal Information of Applicants for Employment>
  • 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 >
  • 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, etc.
  • Confirming visitors and health condition
  • Implementing questionnaires, surveys, etc.
  • Soliciting services, advertising and other marketing

2 Provision to Third Parties

Our 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 the 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

The 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

Our Group will share personal information as follows:

  1. 1Items of Personal Data to be shared
    Name, Address, Phone Number, E-mail Address, Company Name, Company Address, Department and Position.
  2. 2List of the companies that share Personal Data
    • Daicel Arbor Biosciences (Biodiscovery LLC)
    • Chiral Technologies Europe S.A.S.
    • Chiral Technologies, Inc.
    • Daicel America Holdings, Inc.
    • Daicel (Asia) Pte.Ltd.
    • Daicel (China) Investment Co., Ltd.
    • Daicel Nanning Food Ingredients Co., Ltd.
    • Daicel ChemTech, Inc.
    • Daicel Chiral Technologies (China) Co., Ltd.
    • Daicel (Europa) GmbH
    • Daicel Miraizu (Hong Kong) Ltd.
    • Daicel Micro Optics Co. Ltd.
    • Daicel Miraizu (Thailand) Co.,Ltd.
    • Daicel Trading (Shanghai) Ltd.
    • Shanghai Daicel Polymers, Ltd.
    • Daicel Safety Systems Americas, Inc.
    • Daicel Safety Systems Europe Sp.z o.o.
    • Daicel Safety Systems Korea, Inc.
    • Daicel Safety Systems (Jiangsu) Co., Ltd.
    • Daicel Safety Technologies (Jiangsu) Co., Ltd.
    • Daicel Safety Systems (Thailand) Co., Ltd.
    • Daicel Safety Technologies (Thailand) Co., Ltd.
    • Daicel Safety Systems India Pvt. Ltd.
    • Special Devices (Thailand) Co., Ltd.
    • Daicel Chiral Technologies (India) Pvt. Ltd.
    • Lomapharm GmbH
    • Polyplastics Co., Ltd.
    • DM Novafoam Ltd.
    • Daicel Pack Systems Ltd.
    • Daicel Value Coating Ltd.
    • Daicel Miraizu Ltd.
    • Daicel Arai Chemical Ltd.
    • Daicel Ohtake Sangyo Co., Ltd.
    • Daicel Logistics Service Co., Ltd.
    • Daicel Aboshi Sangyo Co., Ltd.
    • Daicen Membrane-Systems Ltd.
    • PI-CRYSTAL Inc.
    • Kyoei Shokusan Co., Ltd.
    • Kyodo Sakusan Co., Ltd.
    • Dainichi Chemical Co., Ltd.
    • Daicel Safety Systems Inc.
    • Daicel Pyrotechnics Ltd.
    Our group company including Daicel Corporation and oversea group companies
    Please refer to the link below for details regarding our 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

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

6 Matters concerning safety management measures

Our 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 window for processing of query 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 external environment
    • Understanding system of the companies provision destinations are located in and take appropriate measures for the security control.

7 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

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.

8 Request for inquiry and complaint

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

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

9 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 agencies of the EU countries can be found at the following URL:
(https://edpb.europa.eu/about-edpb/about-edpb/members_en)

10 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

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 (California Consumer Privacy Act of 2018). 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 our Group in the past 12 months is as below. All of this personal information is obtained from the data subject.

  1. 1Personal information on business partners
    • 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
  2. 2Personal information to be acquired through applications for employment
    • 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

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 our Group disclosed personal information in the past 12 months and the personal information disclosed are as follows.

  • Group companies
    • 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
  • Daicel's agents, vendors, consultants, and other service providers
    • 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

3 Sales to third parties

Our Group does not sell personal information to third parties.

4 Requests for the processing of personal information

Our 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 our 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. 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 our 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 meet your requirements. The customer consents to such possibility prior to making a request.

Date of last update: June 21th, 2022

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 deliver the purposes stated in this Policy, unless the 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 liabilities 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 their 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 among Daicel Corporation in Japan, with your consent. In addition to that, 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 release 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 explains 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 to 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: June 21th, 2022

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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