Privacy Policy

1. Collection of personal data

We will specify the purposes of use and collect personal data in a lawful and appropriate manner. Kuraray Group may collect personal data by your provision of personal data to us, through your accessing our websites or other means, or from business partners, suppliers, vendors, service providers, or third parties with which we transact. Personal data collected and processed by Kuraray Group includes:
- Name, address, birth date, workplace, job title, phone number, e-mail address, etc.
- Information on use of the Internet and digital services (information collected by Kuraray Group or provided by third parties other than Kuraray Group, such as website browsing history, application use, search keywords, number of views and clicks on advertisements and content, browsing time, browsing method (e.g., type of browser), use environment of each terminal used for browsing (connection environment, location, and carrier information), cookies, IP addresses, and the International Mobile Equipment Identity of each terminal)
-Other personal data necessary for performance of Kuraray Group’s business

2. Purposes of use of personal data

We will use personal data for the following purposes and to the extent deemed relevant to those purposes. Except otherwise stipulated by laws and regulations, we will not use personal data for any purpose outside of those stated below, without data subject consent.
- Planning, researching, and developing products and services; and information gathering, surveys, or analysis related to these activities
- Providing and proposing products, services, and related information
- Sending newsletters and optimizing their content
- Sending greeting letters to survey respondents and other greetings, such as season’s greetings, etc.
- Responding to inquiries, documents or other requests, complaints, etc. (including contacting data subjects to obtain additional information needed to respond)
- Improving the usability of websites (e.g., authentication at login) and distributing and optimizing advertisements and content
- Enhancing data protection and security, preventing fraud, and cooperating in the investigation of crimes (e.g., cyberattacks)
- Exercising rights and fulfilling obligations under laws and regulations or contracts

3. Provision of personal data to third parties

We will not disclose nor provide personal data to third parties without data subject consent, except where otherwise stipulated by applicable laws and regulations.

4. Shared use of personal data

We may share personal data within the Kuraray Group as follows;

1. Categories of personal data to be shared
   Personal information as described in section 1 above
2. Parties involved in shared use
   Affiliates within the Kuraray Group
3. Purposes of shared use
   Purposes of use as stated in section 2 above
4. Party responsible for management of personal data to be shared
   Name of President and Representative Director:
   https://www.kuraray.com/company/overview

5. Security control measures

We will take necessary and appropriate security control measures to prevent leakage or loss of, and damage to personal data. (including personal data that we have obtained or is about to obtain and plan to handle as personal data)We will also properly supervise our employees, and if we entrust the handling of personal data to a processor in whole or in part, we will appoint a processor who is deemed to handle personal data properly and supervise them appropriately.

A) Formulation of guidelines
- To ensure the proper handling of personal data, we will provide guidelines in this Privacy Policy with respect to compliance with relevant laws and regulations, security control measures, and requests for inquiries, including disclosure or correction of personal data.
B) Development of rules for personal data handling
- We will develop internal policies regarding personal data handling, responsible persons, and their duties, etc.
C) Organizational security control measures
- We will appoint a person responsible for handling personal data, and clearly define the responsibilities and authority of employees who handle personal data.
- We will establish a system to notify the responsible person of any violations of laws or internal policies or occurrence of personal data breaches.
D) Personnel security control measures
- We will provide regular training to our employees on matters to be noted regarding the handling of personal data.
E) Physical security control measures
- In areas where personal data is handled, we will control the entry and exit of our employees and take measures to prevent unauthorized persons from accessing personal data.
- We will take measures to prevent theft or loss of equipment, electronic media, and documents containing personal data.
F) Technical security control measures
- We will implement access control to limit the scope of persons in charge and personal information databases handled.
- We will introduce mechanisms to protect information systems that handle personal data from unauthorized external access or unauthorized software.
G) Understanding of external environments
- When handling personal data in a country other than Japan, we will obtain information on the personal information protection system in the country concerned and take necessary security control measures.

6. Requests for disclosure, correction, etc. of personal data

In accordance with applicable laws and regulations, we will respond appropriately to requests for disclosure (including disclosure of the provision records to third parties), correction, addition, removal, suspension of use or erasure, suspension of provision to third parties, or notification of purpose of use with regard to the personal data we acquire and maintain ("Requests for Disclosure, Correction, etc.") after confirming that the person making such a request is the individual concerned. Please note that a handling fee may be charged for requests for disclosure or notification of the purpose of use.

7. Contact details

If you have any questions regarding this Privacy Policy, Requests for Disclosure, Correction, etc. or any other inquiries about the handling of personal data, please contact to;
Kuraray Co., Ltd.
E-mail: PersonalDataProtection.JP@kuraray.com

8. Handling of personal data for each product and service

We may individually determine the purpose of use for each product and service, provision to third parties, contact information, etc. In such cases, the relevant individual provisions that differ from this Privacy Policy will prevail.

9. Changes in the Privacy Policy

We may change this Privacy Policy to reflect any amendments to laws and regulations or as otherwise necessary. Any changes to this Privacy Policy will be published on this website.

As of 10/4/2024

In addition to the main body of the Privacy Policy, this Section shall apply to the handling of personal data of residents of the EEA where the General Data Protection Regulations (GDPR) is applicable. In the event of conflict or inconsistency between them, this Section shall prevail.

1. Purpose of use and Legal basis under GDPR for processing the personal data which Kuraray Group processes;

1. Customers, suppliers, or vendors: Business communications, providing information on services and products offered by the Kuraray Group.
   Legal basis: Consent of the data subject (GDPR Art.6(1) a) or Legitimate interest (GDPR Art.6(1) f)
2. Response to inquiries and requests from the data subject.
   Legal basis: Consent of the data subject (GDPR Art.6(1) a) or Legitimate interest (GDPR Art.6(1) f)

2. When Kuraray Group transfers personal data to its group companies or processers, the personal data may be transferred to the countries outside the EEA. The Kuraray Group will transfer personal data only to the extent;

-the transfer to a country may take place where the EU Commission has decided that the country ensures an adequate level of protection of personal data (GDPR Art. 45),
-the transfer to a third party with whom the Kuraray Group executed the standard data protection clauses approved by the EU Commission (GDPR Art. 46.2), or
-the transfer takes place on one of the conditions listed in GDPR Art. 49.1.

3. The Kuraray Group will store personal data for the appropriate period determined based on the criteria of the respective statutory retention period. After expiration of the period, the corresponding data no longer necessary will be deleted in accordance with the respective retention policy.

4. A resident of the EEA has the following rights in connection with his/her own personal data handled by the Kuraray Group;

access (disclosure),
rectification,
erasure,
restriction of processing,
data portability,
object to processing, and
withdrawal of data processing consent.

Here is the Request Form.

5. Lodging a complaint with a competent authority

1. A resident of the EEA has right to lodge a complaint on the processing of their personal data with a competent supervisory authority. The following URL provides information of the authority:
2. http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

6. Contact information of the Data Protection Officer of the Kuraray Group in EEA:

1. Kuraray Europe GmbH
2. Philipp-Reis-Strasse 4
3. 65795 Hattersheim / Germany
4. Attn: Data Protection Officer
5. Email: dataprotection.eu@kuraray.com
6. Tel: +49-69-305-85358