SUMITOMO RIKO

 

Sumitomo Riko

GDPR Privacy Policy

Our Privacy Statement

This Privacy Policy only applies to the processing of Personal Data (as defined below) which we collect from data subjects in the European Economic Area (“EEA”) in accordance with the Regulation (EU) 2016/679 (General Data Protection Regulation, the “GDPR”). This Privacy Policy explains the types of information that we may collect and hold, how that information is used and with whom the data is shared. It also sets out how you can contact us if you have any queries or concerns about this information. Some of our services also have their own privacy policy which provide details of the use of your information by that service.

We encourage you to read this Privacy Policy carefully. If you do not wish your personal data to be used by us as set out in this Privacy Policy, please do not provide us with your personal data. Please note that in such a case, we may not be able to provide you with our services, you may not have access to and/or be able to use some features of the Website, and your customer experience may be impacted.

Article 1 Definition

The terms used in this Privacy Policy shall be defined as follows:

Article 2 Scope of Privacy Policy

This Privacy Policy applies to the Processing of Personal Data, to which the Applicable Privacy Laws and Regulations are applicable. Sumitomo Riko is the designated Controller for this Processing.

Article 3 Personal Data to be Collected

1. Sumitomo Riko may collect the following Personal Data from its customers, counterparties of business transactions, job applicants, its employees, and its affiliates' employees and users of the Website:

2. Sumitomo Riko does not collect any sensitive Persona Data, such as health data, except as set forth in the Applicable Privacy Laws and Regulations.

Article 4 Legal Ground of Data Processing

Sumitomo Riko may Process your Personal Data for the purposes detailed below, which are required so that Sumitomo Riko can pursue our legitimate interests and provide you with adequate products and services:

(1) Where you have given consent.

(2) Where necessary for Sumitomo Riko's legitimate interests, as listed below, and where our interests are not overridden by your data protection rights.

(3) Where necessary to comply with a legal obligation.

(4) Where necessary to protect Sumitomo Riko's legitimate interests and legal rights, and where our interests and not overridden by your data protection rights.

(5) Protecting our legitimate business interests and legal rights. This includes, but is not limited to, use in connection with compliance, regulatory, auditing, legal claims (including disclosure of such information in connection with legal process or litigation) and other ethics and compliance reporting requirements.

Article 5 Purposes of Processing the Personal Data

1. Sumitomo Riko may Process the Personal Data for the purposes detailed below:

2. Sumitomo Riko may also Process the Personal Data for the following purposes:

3. Sumitomo Riko Processes the Personal Data in accordance with the Applicable Privacy Laws and Regulations, as specified in this Privacy Policy.

4. If Sumitomo Riko intends to further Process the Personal Data for purposes other than the Processing purpose at the time of collection of the Personal Data, it shall provide information about such other purposes and all relevant additional information before such further Processing.

Article 6 Transmission of Personal Data to Third Parties

Sumitomo Riko may transfer Personal Data to entities, including Sumitomo Riko group companies, in countries or jurisdictions outside the EEA, such as Japan. Please note that such countries or jurisdictions may not have the same data protection laws as the EEA and may not afford many of the rights conferred upon data subjects in the EEA. When Sumitomo Riko transfers your Personal Data outside the EEA, it will ensure that your Personal Data is protected and transferred in a manner consistent with legal requirements applicable to such Personal Data. You may obtain more details regarding the protection given to your Personal Data by contacting Sumitomo Riko when your Personal Data is transferred outside the EEA.

Article 7 Security

1. Sumitomo Riko implements appropriate organizational and/or technical security measures to protect the Personal Data and to prevent misuse, loss or alteration thereof. Furthermore, Sumitomo Riko limits access to the Personal Data to its employees, agents, contractors and other third parties who need access to such Personal Data. Those aforementioned persons are bound by an obligation to maintain confidentiality, either in accordance with their employment agreements or (data processing) agreements.

2. In the event that Sumitomo Riko entrusts the handling of your Personal Information, it will obligate such entrusted person to take appropriate security control according to contract and it will exercise necessary and appropriate supervision over such entrusted person.

Article 8 Retention Periods

1. Sumitomo Riko does not store the Personal Data beyond the extent that is necessary for the purpose for which such Personal Data is collected.

2. Data subject of the Personal Data may request Sumitomo Riko to delete their Personal Data at any time. Furthermore, when the Personal Data is no longer necessary or required for the purposes of collecting or Processing, Sumitomo Riko deletes such Personal Data.

Article 9 Cookies

1. Sumitomo Riko uses cookies to ensure that the Website functions properly.

2. Cookies are information stored by the browser on the computers of User of Website. Sumitomo Riko uses different types of cookies for different purposes.

3. Sumitomo Riko only uses third parties’ cookies for the purpose of improving the quality and effectiveness of the Website. For example, Sumitomo Riko uses the Adobe Analytics, which is set up in a privacy-conscious manner. The Adobe Analytics Processes IP addresses for Sumitomo Riko.

4. Cookies are enabled as a default setting on most browsers. The User of Website can set the browser to disable cookies or indicate when a cookie is being sent. However, if cookies are disabled, it is possible that some functions or services of Sumitomo Riko or other websites may not function properly.

Article 10 Data breaches

In case of breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed, we have the mechanisms and policies in place in order to identify it and assess it promptly. Depending on the outcome of our assessment, Sumitomo Riko will make the requisite notifications to the supervisory authorities and communications to the affected data subjects, which might include you.

Article 11 Rights of Data Subject

1. As long as the Processing of the Personal Data is based on consent, the data subject of the Personal Data has the right to withdraw consent in respect of their Personal Data at any time.

2. The data subject of the Personal Data has the right to request access to their Personal Data. This allows the data subject to receive a copy of their Personal Data retained by Sumitomo Riko.

3. The data subject of the Personal Data has the right to request correction of their Personal Data retained by Sumitomo Riko. This allows the data subject of the Personal Data to have any incomplete or inaccurate data concerning themselves, which are retained by Sumitomo Riko, corrected.

4. The data subject of the Personal Data has the right to request deletion of their Personal Data. This allows Sumitomo Riko to delete the Personal Data that Sumitomo Riko has been Processing without legitimate reasons.

5. The data subject of the Personal Data has the right to raise objections to the Processing of their Personal Data which Sumitomo Riko conducts for its legitimate interests. If Sumitomo Riko has been Processing the Personal Data for the purposes of direct marketing, Sumitomo Riko shall accept the objections from the data subject of the Personal Data at all times. If Sumitomo Riko has been Processing the Personal Data for other purposes, Sumitomo Riko shall cease the Processing of the Personal Data, unless it has compelling legitimate reasons (i) which override the interests or rights and freedom of the data subject of the Personal Data, or (ii) which are related to the commencement or implementation of legal action or for the proof of claims purposes.

6. The data subject of the Personal Data has the right to request restriction on the Processing of their Personal Data.

7. The data subject of the Personal Data has the right to request a transmission of their Personal Data to themselves or to a third party. Sumitomo Riko shall provide a data subject of the Personal Data or a third party designated by such user with the Personal Data of the said data subject in a structured, commonly used, machine-readable format. Please be advised that this right only applies to automatically Processed information for which the data subject of the Personal Data initially provided consent or which Sumitomo Riko used to perform an Agreement with a data subject of the Personal Data.

8. The exercise of the aforementioned rights is free of charge. Sumitomo Riko will provide information about the follow-up to the request from the data subject of the Personal Data immediately and in any case within one (1) month of receipt of such request. This period may be extended by another two (2) months, depending on the complexity of the request and the number of requests. Sumitomo Riko will notify a data subject of the Personal Data of such an extension within one (1) month of receipt of the request.

9. If a request from a data subject of the Personal Data is clearly ungrounded or excessive, in particular if the same request is made repeatedly, Sumitomo Riko will either charge such data subject of the Personal Data a reasonable fee or refuse to respond to the request from such user.

10. In addition to the aforementioned rights, a data subject of the Personal Data has the right to file a complaint to a supervisory authority (in particular, a supervisory authority in the EU Member State where the data subject of the Personal Data habitually resides, or at the place of work or where an alleged infringement of the GDPR occurred) at any time. However, Sumitomo Riko would appreciate an opportunity to deal with concerns of the data subject of the Personal Data, before they contact the supervisory authority. Your initial contact to resolve the issue would be highly appreciated.

Article 12 Contact

For any inquiries or complains, or if you wish to exercise any of the rights specified in Article 9 of this Privacy Policy, please contact Sumitomo Riko at the contact address provided below:

JP Tower Nagoya, 1-1-1 Meieki, Nakamura-ku, Nagoya-shi, 450-6316
General Affairs Department, Sumitomo Riko Company Limited
TEL: 052-571-0235 (Business hours: 9:00-17:00 on weekdays)

Article 13 External links

The Website may contain information of third parties (for example, hyperlinks or banners). Sumitomo Riko does not control such third parties’ information and is not responsible for compliance with the Applicable Privacy Laws and Regulations on behalf of these third parties. We ask the User of Website to carefully read the privacy policies of the third party websites they are visiting.

Article 14 Miscellaneous

1. Sumitomo Riko reserves the right to revise this Privacy Policy on a regular basis. It is the responsibility of the data subject of the Personal Data to regularly review the applicable provisions. This Privacy Policy was last revised in [October] 2018.

2. If a provision of this Privacy Policy is in conflict with the laws or regulations, it shall be replaced by a provision of the same purport that reflect the original intention of the provision, to the extent legally permissible. In this case, the remaining provisions shall remain applicable and unchanged.

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Sumitomo Riko

Global
Headquarters

JP Tower Nagoya 1-1-1, Meieki, Nakamura-ku, Nagoya-shi,
Aichi 450-6316, Japan
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Komaki Head
Office

1, Higashi 3-chome, Komaki-shi, Aichi 485-8550, Japan
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