1. Personal Date We Collect About You and How We Collect It

For the purposes of this privacy policy, “personal data” means any information relating to a natural person from which that natural person can, directly or indirectly, be identified.

We will process the following personal data about you:

• a.Contact information of the person in charge of our (potential) clients and business partners:
  We will obtain this data from you through the exchange of business cards, filling in questionnaire forms, etc. We will also obtain this date from third parties such as your company or other organization to which you belong or our distributors in European Countries. It may include your name, e-mail address, phone number, company name, address, department and position, and other information.
• b.Information provided through the contact form on our website:
  We will obtain your personal data when you contact us through the contact form on our website. It may include your name, e-mail address, phone number, company name, address, department and position, and other information.
• c.Information of the members registered on our membership websites:
  We will obtain your personal data when you register on our membership websites. It may include your name, e-mail address, phone number, company name, address, department and position, and other information.
• d.Information provided to us in the course of our services:
  We will obtain your personal data when you apply to our services, such as our e-mail newsletters. It may include your name, e-mail address, phone number, company name, address, department and position, and other information.
• e.Information collected through this website:
  When you visit our website, it automatically collects certain types of data related to you. These types of data include access logs, web beacons (also known as pixels), cookies, etc. and may remain in your computer and continue to collect data.
• f.Other information provided when you give us consent to the processing of your personal date for the specific purposes.
  

2. Purpose and Legal Basis of Processing Personal Data

We will use personal data only within the scope permitted by law. When we process it, we will rely on at least one of the following legal bases:

• a.Contract. This is where we need to process your personal data to perform the contract we enter into with you.
• b.Legal Obligation. This is where we need to comply with a legal obligation.
• c.Legitimate Interests. This is where the processing of your personal data is necessary for legitimate interests pursued by us or a third party, and your interests and fundamental rights do not override those interests.
• d.Consent. This is where you have given consent to us to process your personal data. However, even if we obtain consent from you, we may process your personal data based on other legal grounds. The withdrawal of your consent (please see Section 6 (g) of this privacy policy below) shall not affect the lawfulness of processing performed based on the consent before your withdrawal.

The purposes for which we process personal data and the legal basis on which we perform such processing are as follows:

3. Disclosure of Personal Data to Recipients

We may share your personal data with the following categories of recipients:

• a.Our group companies (including, but not limited to Industrial Quimica Lasem, S.A.U, our subsidiary in Spain).
• b.Our business partners such as distributors in European Countries.
• c.Service providers such as external professional advisors and IT-related service providers.

4. Transfers of Personal Data outside the European Countries

The personal data that we hold about you may be transferred to, and stored by, a third party outside the European Countries.

When we transfer your personal data to a third party outside the European Countries, we will ensure that:

• a.The recipient destination has been subject to the European Commission decisions that it ensures an adequate level of protection for the rights and freedoms that you possess in respect of your personal data; or
• b.The recipient enters into standard contractual clauses with us that have been approved by the European Commission.

You can obtain more details of the protection given to your personal data when it is transferred outside the European Countries (including a copy of the standard contractual clauses which we have entered into with recipients of your personal data) by contacting us in accordance with the information indicated in Section 8.

5. Storage Period of Personal Datan

We will retain the personal data that we collect about you as long as it is necessary for the purposes set out in this privacy policy, unless a longer period is required by applicable laws.

6. Your Rights

You have a number of legal rights in relation to the personal data we hold about you. These rights may vary depending on where you are located and which data protection laws apply to the relationship between you and us, but would typically include:

• a.The right to obtain information regarding the processing of your personal data and access to the personal data we hold about you.
• b.The right to request that we rectify your personal data if it is inaccurate or incomplete.
• c.The right to request that we erase your personal data in certain circumstances. This may include (but is not limited to) circumstances in which:
  • (i) it is no longer necessary for us to retain your personal data for the purposes for which we collected it;
  • (ii) we are only entitled to process your personal data with your consent, and you withdraw your consent; or
  • (iii) you object to our processing of your personal data for our legitimate interests, and our legitimate interests do not override your own interests, rights and freedoms.
• d.The right to request that we restrict our processing of your personal data in certain circumstances. This may include (but not limited to) circumstances in which:
  • (i) You dispute the accuracy of your personal data (but only for the period of time necessary for us to verify its accuracy);
  • (ii) we no longer need to use the personal data except for the establishment, exercise, or defense of legal claims; or
  • (iii) you object to our processing of your personal data for our legitimate interests (but only for the period of time necessary for us to assess whether our legitimate interests override your own interests, rights and freedoms).
• e.The right to object to us about our processing of your personal data.
• f.The right to receive any personal data which we process about you on the basis of your consent or on a contract (as opposed to any other legal ground), and where the processing is carried out by automated means in a structured, commonly used, and machine-readable format, and/or request that we transmit that data to a recipient where this is technically feasible. Please note that this right only applies to personal data that you have provided to us.
• g.The right to withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we may rely on another legal ground for doing so.

You are entitled to exercise your rights by contacting us using the information about us indicated in Section 8. You may also lodge a complaint with the competent supervisory authorities if you believe any of your rights have been infringed by us.

7. Miscellaneous

The processing of your personal data that we conduct does not involve any automated decision-making that produces legal effects concerning yourself or otherwise similarly affects you significantly.
Subject to the specification indicated above in Section 2, the provision of your personal data is not a statutory or contractual requirement.

8.Contact Details

You may contact us using the information below.
Name：The Nisshin OilliO Group, Ltd.
Address：1-23-1 Shinkawa, Chuo-ku, Tokyo 104-8285, Japan
E-mail Address：nog_1051100_dmy@nisshin-oillio.com

9. Changes to this Privacy Policy for Europe

We may modify this privacy policy for Europe from time to time and will post the updated privacy policy with a “Last Updated” effective date of the revisions. We recommend that you review this privacy policy periodically.

Last Updated : October 1, 2024