Privacy Policy – Asahi Kasei Europe GmbH

Asahi Kasei Europe GmbH and its Group companies (hereinafter collectively called The Asahi Kasei Group) are committed to maintaining the privacy and security of personal information, and to ensuring that it is handled appropriately in accordance with this policy. This Privacy Policy stipulates a basic policy concerning handling of personal information of the Asahi Kasei Group. The Asahi Kasei Group handles personal information in compliance with the applicable regulations in each country or region where operations are located, in particular, the Regulation (EU) 2016/679 (General Data Protection Regulation). Because this policy may be revised, we recommend that you refer to this page again from time to time.

– We handle personal information properly and in compliance with the Personal Information Protection Law and other applicable statutes, and in conformance with generally accepted norms and standards.
– We ensure that personnel throughout the Asahi Kasei Group thoroughly understand and faithfully comply with corporate standards and regulations for the handling of personal information.
– We use personal information only for the specific purposes which have been indicated or announced at the time of its receipt.
– We employ appropriate measures in the maintenance and management of personal information to ensure against unauthorized alteration, disclosure, and loss of personal information.
– We will respond in good faith to requests from you to confirm, revise, cease using, or delete your personal information.

Specifics are described below.

1. Method of collecting personal information
In addition to collecting personal information that you provide to us, the Asahi Kasei Group automatically collects information of visitors to the Asahi Kasei Group website and may obtain information of its visitors’ preferences and browsing histories from information analysis providers.

2. Purpose of use for each type of personal information
Purposes for which personal information may be used by the Asahi Kasei Group are described below. Some Asahi Kasei Group companies include additional purposes as described in the privacy policy specific to their respective websites or sections of this website.

Personal information of customers

Types of information:
Name, e-mail address, phone number, fax number, address, age, content of inquires, attribute information, preferences, access log to our website and purchase history, cookie, member ID, passwords, credit card information, payment information

Purpose of use:
a. Response to inquiries, consultation, complaints, or requests, and confirmation and records thereof
b. Provision, accumulation, investigation, study of, and response to information related to products, services, and advertising campaigns via invitations, e-mails, etc.1, 2
c. Distribution of targeted advertising using Google, Adobe, etc.1, 2, 3, 4
d. Analysis of attribute information, behavior history, etc. for ascertaining customers’ preferences2
e. Sending products, invoices, and gifts won in campaigns.
f. Safe provision of products and services to customers of the Asahi Kasei Group; detection of users who violate our terms of use issuing notices to such users; and investigation, detection, prevention, and countermeasure of illegal acts abusing our services, etc. such as fraud, unauthorized accesses, etc.

1 We provide our services, deliver advertisements, etc. by analyzing information such as browsing and purchasing histories, etc. obtained from our customers.
2 We may associate information such as customers’ preferences, browsing histories, etc. obtained from the third parties other than the Asahi Kasei Group with the information we have already obtained, and use it within the scope described above having obtained customers’ agreement in advance.
3 We use cookies (text files containing small amounts of information which will be downloaded to your device upon your visit to a website) to improve customer convenience. For more information about the cookies, please see the Cookie Policy of each website.
4 Each company of the Asahi Kasei Group applies the analysis tools specified in the “Cookie Policy” of each website to obtain how customers use their websites. Based on the cookies we issue, the analysis companies collect, record, and analyze browsing histories of our customers, which we obtain from them to ascertain the status of visits by customers. Customer information collected, recorded, and analyzed does not contain any identifiable personal information. Furthermore, this information is controlled in accordance with the privacy policies of the analysis companies.

Personal information of suppliers (in the case of legal entities, personal information of officers)

Types of information:
Name, job position, department, e-mail address, phone number, fax number, address, date of birth, bank account information

Purpose of use:
a. Transactions, EHS activities, IR activities, inquiries on financial transactions and pension fund management, correspondence (including sending reports and materials), meetings, consultations, investigations, contracts, receiving and placing orders, shipping, billing, depositing, payment, and debts and credits management
b. Management of entrance and egress of persons and vehicles at Asahi Kasei Group facilities.
c. Liaison with communities where Asahi Kasei Group facilities are located.
d. Notification and reporting to governmental agencies, municipal offices, and public bodies.

Personal information of shareholders (in the case of legal entities, personal information of officers)

Types of information:
Name, e-mail address, phone number, fax number, address, date of birth, the class and the number of shares held and the date of their acquisition, bank account information

Purpose of use:
a. Exercise of rights and fulfillment of obligations in accordance with the Companies Act.
Conferring various benefits as the issuing company with respect to the position of shareholder.
b. Within the relationship between a shareholder and a company, implementing various measures for a harmonious mutual relationship from the perspective of a member of a group and the group itself.
c. Shareholder management, including preparing shareholder data based on standards proscribed by various laws and ordinances.

Personal information of job applicants

Types of information:
Name, e-mail address, phone number, fax numbers address, date of birth, job history, career record, portrait photo

Purpose of use:
a. Correspondence, providing information, and other recruitment related use

Personal information of executives, employees, family members of employees, and retired employees

Types of information:
Name, e-mail address, telephone number, fax number, address, date of birth, job history, career record, portrait photo, bank account information, job position and department, personnel evaluation

Purpose of use:
a. Work-related communication, attendance management, salary payment, reimbursement of expenses, appropriate placement of personnel, personnel evaluation, human resources development, company benefits, labor management including industrial safety and health, and performance of obligations under laws and ordinances related to labor, tax, and social welfare.
b. Acceptance, performance, and management of various procedures stipulated by internal regulations.
c. Correspondence regarding company benefits such as health insurance, pension fund, etc., and correspondence with Group companies, sending materials such as internal magazine, etc., emergency contact, distributing materials regarding social gatherings of retirees, etc.

3. Disclosure and shared use
We may share personal data with the following categories of recipients:

(1) Asahi Kasei Group companies
The Asahi Kasei Group may disclose personal data to Asahi Kasei Group companies.

(2) Employees
The Asahi Kasei Group may disclose personal data to employees of the Asahi Kasei Group who have the authority and need to access personal data.

(3) Service providers
The Asahi Kasei Group may disclose personal data to service providers such as delivery companies, IT service providers, etc.

Shared use of personal data among Asahi Kasei Group companies is as shown in the table below. Some Asahi Kasei Group companies include additional shared use as described in the privacy policy specific to their respective websites or sections of this website.

Information subject to shared use Name (in the case of a legal entity, name, position, and department of executive or employee) date of birth, address, telephone number, fax number, e-mail address, place of work, bank account information, etc.
Scope Asahi Kasei Group companies
Purpose of shared use As described in Item 2 above.

4. Security control measures
The Asahi Kasei Group implements necessary and appropriate security control measures to prevent leakage, loss, or alteration of personal data. We perform appropriate supervision of employees and contractors (including subcontractors) who handle personal data. We implement security control measures for personal data in accordance with specific internal rules, the gist of which is as follows.

Formulation of Privacy Policy:
To ensure the proper handling of personal data, this Privacy Policy is formulated with respect to compliance with relevant laws, ordinances, and guidelines, and contact for handling questions and complaints.

Preparation of rules for handling personal data:
Internal regulations are formulated with respect to method of handling, responsible party, handling party, and their duties, etc., for each step including acquisition, use, storage, provision, deletion, and disposal.

Organizational security control measures:
Regarding the handling of personal data, a person is assigned with responsibility for handling personal information, and the employees who handle personal data and the scope of personal data they handle are clarified. A system is in place to ensure that the person with overall responsibility is notified if there is a violation or potential violation of personal information protection laws and internal regulations.

Regarding the state of handling personal data, self-inspections are periodically performed and audits are performed by other departments.

Individual security control measures:
Employees are regularly trained on important points regarding the handling of personal data.
Items related to prevention of leakage of personal data are stipulated in internal regulations.
Physical security control measures:
In zones where personal data are handled, there is control of entry and egress of employees and restriction of devices carried. Measures are in place to prevent viewing of personal data by unauthorized persons.

Technical security control measures:
 Regarding access control, there are restrictions on the scope of the personal information database, etc., that may be handled.
 Measures are introduced to protect the information system handling personal data from improper access and improper software.

Understanding the external environment:
Security control measures are implemented based on an understanding of the system related to protection of personal information in foreign countries where personal data is stored.

5. Retention period
The Asahi Kasei Group retains personal information only for as long as needed. If there are legal obligations for longer periods of retention, the retention period is in accordance with the legal obligations.

6. Your rights
You have several legal rights regarding your personal information held by the Asahi Kasei Group. These rights may vary depending on the applicable data protection law according to your domicile and your relationship with the Asahi Kasei Group. Typically they include the following.

a. The right to obtain information regarding the handling of your personal information and the right to access personal information of yours which is held by the Asahi Kasei Group.
b. The right to request correction of your personal information if it is incorrect or incomplete.
c. In certain circumstances, the right to request deletion of your personal information.
d. In certain circumstances, the right to request restrictions on handling your personal information.
e. The right to object to the handling of your personal information.
f. The right to receive your personal information which is structured in a common machine-readable format and/or obtain direct transfer of same to a recipient within the scope technically feasible for the Asahi Kasei Group.
g. The right to retract your agreement regarding the treatment of your personal information.

If you believe your rights have been infringed by the Asahi Kasei Group, you may lodge a complaint with the data protection authorities.

7. Inquiries regarding exercise of rights
The Asahi Kasei Group accepts questions and complaints related to the exercise of rights regarding the handling of personal information as shown below. Some Asahi Kasei Group companies have different methods of contact as described in the privacy policy specific to their respective websites or sections of this website.

How to contact us
Please contact the Data Protection Officer of Asahi Kasei Europe GmbH via gdpr@asahi-kasei.eu.

For persons in the EEA and UK
This section applies to persons in the European Economic Area (EEA) and United Kingdom (UK).

1. Legal basis
The Asahi Kasei Group processes your personal data on the following legal basis:

(a) Contract. Where the processing of your personal data is necessary to perform a contract we enter into with you.
(b) Legitimate interests. Where the processing of your personal data is necessary for legitimate interests pursued by the Asahi Kasei Group or a third party (such as responding to an inquiry or advertising), and your interests and fundamental rights do not override those interests. Further details regarding legitimate interests may be obtained by inquiring to the contact shown above.
(c) Consent. Where the Asahi Kasei Group has received your consent to process your personal data. If you retract your consent, it does not affect the lawfulness of processing performed based on consent prior to such retraction.

2. Transfer of personal data outside the EEA or UK
Your personal data may be transferred to, and stored by, Asahi Kasei Group companies or a third party outside the EEA or the UK. If the Asahi Kasei Group transfers your personal data to Asahi Kasei Group companies or a third party outside the EEA or the UK, we ensure one of the other of the following.

(a) That the recipient destination has been found by the European Commission or has been designated by the government of the UK as ensuring an adequate level of protection for the rights and freedoms that you possess in respect of your personal data.
(b) That the recipient enters into a personal data transfer contract with the Asahi Kasei Group containing standard data protection clauses that have been approved by the European Commission and other requirements of data protection laws.

Further details of the protection given to your personal data when it is transferred outside the EEA or the UK may be obtained by inquiring to the contact shown above.