Privacy Policy

1. Acquisition of personal information

We will specify the purposes of use of personal information and acquire personal information in lawful and appropriate manner. Personal information that we will acquire and treat includes,
- Name, address, birth date, workplace, job title, phone number, e-mail address, etc.
- Access data to our websites that could identify specific individuals
- Other personal information necessary for the Kuraray Group operations

2. Purposes of use of personal information

We will use personal information for the following purposes and to the extent deemed relevant to those purposes. Except otherwise approved by law or regulation, we will not use personal information for any purpose outside of those stated below, without consent of the individual.
- Provision and proposal of the Kuraray Group products, services, and related information
- Planning, research, and development of the Kuraray Group products and services; and information gathering, survey or analysis related to these activities
- Improving the usability of our website (authentication at login, etc.)
- Sending letters of greeting to survey respondents, and other greetings such as season’s greetings, etc.
- Responding to inquiries, documents or other requests, complaints, etc.
- Recruitment activities and related procedures
- Management of stock administration and shareholders under the Companies Act
- Appropriate labor management (including various procedures) of the employees of the Kuraray Group
- Exercise of rights and fulfillment of obligations under laws and regulations or contracts
- Appropriate and smooth execution of other Kuraray Group operations

3. Provision of personal data to third parties

We will not disclose nor provide personal data to third parties without the consent of the individual, except otherwise approved by law or regulation.

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, loss, or damage of personal data. We will also properly supervise our employees and, if we entrust the handling of personal data to a processor as a whole or in part, we will appoint and supervise the processor who is deemed to treat personal data properly.

1. 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.
2. Development of rules for handling personal data
   - We will develop internal policies regarding handling personal data, responsible persons, and their duties, etc.
3. 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 violation of laws or internal policies, or occurrence of personal data breach.
4. Personnel security control measures
   - We will provide regular training to our employees on matters to be noted regarding the handling of personal data.
5. 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.
6. Technical security control measures
   - We will implement access control to limit the scope of person 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.
7. Understanding of external environments
   - When handling personal data in a foreign country, we will obtain the information of the personal information protection system in the country concerned and take necessary security control measures.

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

In accordance with laws and regulations, we will respond appropriately to the requests for disclosure (including disclosure of the provision records to third parties), correction, addition, removal, suspension of use or deletion, suspension of provision to third parties, or notification of purpose of use with regard to the personal information we acquire ("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. For further details, please contact us at the following address.

7. Contact information

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

8. Handling of personal information 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 1/23/2023

In addition to the main body of the Privacy Policy, this Section shall apply to the handling of personal information 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 the 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 the Kuraray Group transfers personal data to its group companies or processers, the personal data may be transferred to the counties outside the EEA. The Kuraray Group will transfer personal data only to the extent;

1. 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 information (GDPR Art. 45),
2. 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
3. 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;

1. access (disclosure),
2. rectification,
3. erasure,
4. restriction of processing,
5. data portability,
6. object to processing, and
7. 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