NAGASE Group (“we”) appreciate your visit to our global website https://www.nagase.com (our "Website") and your interest in NAGASE Group, our services, and products. In this global personal data protection policy (this "Policy"), “NAGASE Group” means Nagase & Co., Ltd. and its global network companies indicated at the end of this Policy.

This Policy aims to give you (“you”, “Business Partners”, or “Data Subject” (including those who may become business partners, and including their officers and employees)) information on how NAGASE Group collects and processes your Personal Data (defined below) collected through our Website and/or offline activities and communications in the course of our business operations.

This Policy may be updated from time to time. We therefore ask you to check it periodically for updates.  The date this Policy was last updated is indicated at the end of this Policy.

This Policy applies to the data obtained by NAGASE Group and does not apply to data collected by any third party, including through any application or content that may link to or be accessible from or on our Website. This Policy is subject to any additional terms of disclaimers or other contractual terms you have entered into with NAGASE Group, such as client privacy statements, or notices, and any applicable laws, regulations, and guidelines on the protection of Personal Data.  We may provide you with privacy statements in addition to, or in place of, this Policy, as appropriate. Both the following individual policies or Personal Data protection notices ("Individual Policies") established by each NAGASE Group company and this Policy may be applied. Individual Policies can be found on each NAGASE Group company’s website indicated at the end of this Policy.

In this Policy, the following terms have the following meanings:

“Personal Data” means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to reference to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

“process” or “processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

We, as an administrator, handle Personal Data of Business Partners in accordance with this Policy and Individual Policies. Contact information for each NAGASE Group company is found on each NAGASE Group company’s website indicated at the end of this Policy.

We may process different kinds of Personal Data about you which we have grouped together as follows:

• Identity Data includes name, country, company, position, employer number, user account data, date of birth, and gender.

• Contact Data includes email address, telephone numbers, office location address, billing address, and delivery address.

• Financial Data includes bank account and payment card details.

• Technical Data includes internet protocol (IP) address, date and time of your access, time zone setting and location, browser type and version, your device identifiers, your internet or wireless service provider, and other technology on the devices you use to access this Website.

We do not collect the following data from or about you:

• Race, ethnic origin, political opinions, religious or ideological beliefs, or labor union membership

• Genetic information intended to identify an individual

• Social status, medical history, and criminal record

• Physical handicap, intellectual handicap, and mental disorder

• Results of physical examinations and other tests

• Health guidance, medical and dispensing information, and other health information

• Information on sexual life or sexual orientation

• Proceedings concerning protection cases of juveniles such as protective dispositions

• Having the Data Subject as a juvenile delinquent person or a person suspected to be a juvenile delinquent

We use different methods to collect Personal Data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, and Financial Data by exchanging business cards, sending emails, filling out forms, or by other means.

• Automated technologies or interactions. As you interact with our Website, we (and service providers acting on our behalf) will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this Technical Data by using cookies, web beacons, or other similar tools. Web browsers are usually set by default to accept cookies (including web beacons) but you may easily change this by modifying the settings of your browser. However, please note that should you choose to disable cookies, you may be unable to use part of the functions of this Website.
  
  If you do not agree to the use of cookies, please select "Reject all Cookies" on our cookie banner. However, essential cookies cannot be rejected. You may change your consent/rejection selection at any time on the Cookie Settings page on our Website at [https://www.nagase.com/privacy/cookie-policy/].

We will process your Personal Data when applicable law allows us to. Most commonly, we will process your Personal Data in the following circumstances, to the extent permitted by applicable law:

• Where it is necessary for our legitimate interests and your interests, and fundamental rights do not override those interests.

• Where we need to comply with a legal obligation.

• Where we need to perform the contract we are about to enter into or have entered into with you.

Where applicable data protection laws require us to obtain your consent to such processing of your Personal Data, we will ask for your consent. If you wish to withdraw your consent to process your Personal Data, please contact us as set forth in the “How to Contact Us” section.

We use your Personal Data on the lawful basis above for the following purposes:

• Notify and greet based on social customs.

• Provide you with information, products, or services.

• Enter into contracts with you and perform our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

• Fulfill customer inquiries and respond to any problems that may arise, such as difficulties in navigating our Website or accessing certain features.

• Send samples, price quotations, products, and information.

• Develop new products and services.

• Send you newsletters, features, promotional material, surveys, and other updates.

• Analyze your interests based on your browsing history or buying history on our Website.

• Send you emails and/or postal messages with information about the brand and other content of NAGASE Group we think may be of interest to you.

• Develop and provide advertising tailored to your interests, including interest-based advertising.

• Personalize your experience on our Website by presenting products and information tailored to you.

• Evaluate and administer products and services of NAGASE Group.

• Gauge our customers' trends to determine what products and services are popular with our customers.

• Provide information relating to NAGASE Group’s business activities.

• Provide services relating or connected to services other than those described above.

• Share your Personal Data among NAGASE Group for the purposes listed above or for administrative purposes.

We may disclose certain categories of your Personal Data as may be necessary for the purposes stated above when applicable law allows. 

(a) To NAGASE Group or to a party that merges or acquires part or all of our business or assets, as controllers of Personal Data.

(b) With appropriate management and supervision, to our service providers as processors of Personal Data, including those providing us with cloud computing, customer relation management, marketing automation, advertising, messaging or other application, business travel arrangement, courier, receptionist, conference/event arrangement, hospitality, and accommodation.

(Japan)

Nagase & Co., Ltd. (place of business and representatives can be found on our Website at https://www.nagase.co.jp/english/company/profile/) is responsible for the management of Personal Data shared among NAGASE Group. In order to request disclosure of your Personal Data shared among NAGASE Group or to make inquiries or complaints regarding the use of such information, please contact us as set forth in the “How to Contact Us” section.

(Outside of Japan)

We take necessary measures to provide personal information to third parties in accordance with the laws and regulations of each country. For example, in the European Economic Area ("EEA"), NAGASE Group has entered into data transfer agreements with group companies with which it shares Personal Data to ensure an adequate level of protection of Personal Data.

We may also disclose your Personal Data:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

• To protect life, body, or property, and when it is difficult to obtain consent of the Data Subject.

• To enhance public hygiene or promote sound upbringing of children, and when it is difficult to obtain consent of the Data Subject.

We may transfer your Personal Data to countries whose data protection laws are not as comprehensive as those from where you are for purposes consistent with this Policy. When we transfer Personal Data overseas, we have put in place appropriate safeguards such as contractual commitments (using the format required under applicable data protection law, if any) in accordance with applicable legal requirements to ensure that your Personal Data is adequately protected.

We will retain your Personal Data we collected for the period necessary to fulfill the purposes stated in this Policy, unless a longer retention period is required by law. After such retention period, your Personal Data will be deleted promptly and safely.

We respect your privacy rights and give you reasonable access to your Personal Data that you have provided. Pursuant to applicable law, you may have the right to access, rectify, erase, restrict or object to processing, suspend data transfer, and withdraw consent in relation to your Personal Data. To exercise your rights, please contact us in accordance with “How to Contact Us” below.

We follow generally accepted industry standards to protect the information submitted to us, both during transmission on our Website and once we receive it. We maintain appropriate administrative, technical, and physical safeguards to protect your Personal Data collected by us against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of your Personal Data in our possession.  However, no method of transmission over the Internet or method of electronic storage, is 100% secure. NAGASE cannot ensure or warrant the security of any information you transmit to us. NAGASE also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Data has been compromised, please contact us as set forth in the “How to Contact Us” section.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you of a breach where we are legally required to do so.

Pursuant to applicable law, our Business Partners located in the EEA have certain rights to access, rectify, erase, restrict and object to processing, data portability, and not be subject to a decision making based solely on automated processing, including profiling, with legal or similarly significant effects. In addition, our Business Partners located in the EEA may withdraw their consent to the processing of their Personal Data at any time. 

Our Business Partners located outside of the EEA have the rights described in the Individual Policies, which are established by each NAGASE Group company. 

If you wish to exercise your rights or withdraw your consent to the processing of your Personal Data, please contact us in accordance with “How to Contact Us” below.

You have the right to object to the processing of your Personal Data to the data protection authority having jurisdiction over your place of business in accordance with applicable law.

We do not use Personal Data to make automated decisions, including profiling, except when using AI to make contact recommendations.

From time to time, in order to comply with changes in applicable law or for legitimate business purposes, we may modify this Policy. Any changes we make will be displayed on our Website. Please check back from time to time to ensure that you have read the most recent version of this Policy.

If you wish to exercise your rights that are referred to in this Policy or have any questions or concerns about this Policy or our privacy practices, please contact us from our Website. [https://www.nagase.com/contact-us].