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Global Privacy Policy for Resonac Group Companies

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Effective Date: [Jan.1.2023]
Last updated: [Jan.4.2023]


Resonac Group Companies
(“Resonac Group Companies,” “we,” or “our”) comply with the applicable personal information protection regulations of each country and process the personal information of the officers, employees, and the like of customers and other similar trading partners of, and shareholders of, Resonac Group Companies (collectively, “you,” unless specified otherwise) as follows.
“Resonac Group Companies” means Resonac Holdings Corporation, its consolidated subsidiaries, and equity-method subsidiaries of its non-consolidated subsidiaries.

In addition to this Global Privacy Policy for Resonac Group Companies (this “Global Privacy Policy”), the following country-specific exhibit may also apply to you depending on the areas in which Resonac Group Companies that process your personal information are located and the area in which you reside or are located, so please refer to the country-specific exhibit. If this Global Privacy Policy conflicts with the exhibit, then the exhibit will prevail to the extent that such conflict exists.

- Exhibit: EEA (European Economic Area) and the UK

Resonac Group Companies may have prepared their own specific exhibits. If this Global Privacy Policy conflicts with the exhibits, then the exhibits will prevail to the extent that such conflict exists.

1. Categories of personal information subject to processing
Resonac Group Companies process the following personal information and other personal information Resonac Group Companies have obtained in relation to business activities (we will obtain such personal information after separately notifying you if required by applicable laws and regulations).

(1) Personal information of officers, employees, and the like of customers and other similar trading partners
Resonac Group Companies process the following personal information of the officers, employees, and the like of customers and other similar trading partners of Resonac Group Companies (including potential trading partners and persons who access our websites).
- Name, address, name and location of company, department, type of occupation, title, telephone number, e-mail address, fax number, details of sales negotiations, details of inquiries, fields of interest, photo or video, and language settings
- Information collected from our customers’ terminals, such as the following: cookies; IP addresses; provider information; terminal information; web browser information; user activities (time of day when the website was visited, session length, frequency, transitions, traffic sources, clicks in the website, and scrolling in the website); attributes (such as age, gender, interest categories, affinity categories, and in-market segments; for more information about interest categories, affinity categories, and in-market segments, visit About Demographics and Interests - Analytics Help (google.com)); information about the referrer; and information about requests

(2) Personal information of shareholders of Resonac Group Companies
Resonac Group Companies individually process the following personal information regarding each company’s shareholders.
- Name, address, e-mail address, number of shares owned, date of share acquisition, shareholder number, dividend payment history, and account for dividends

2. Purpose of processing
Resonac Group Companies process your personal information for the following purposes and other purposes permitted by applicable laws and regulations. In addition, Resonac Group Companies may de-identify or aggregate your personal information.

(1) Personal information of officers, employees, and the like of customers and other similar trading partners
- To purchase goods or the like, to sell products and services, and to handle matters incidental to such purchasing and selling
- To conduct various registrations and procedures pertaining to international transportation
- To respond to various inquiries, requests, and claims, and to upgrade and improve existing goods, services, and business activities and to develop new goods and services (including upgrades, improvements, and development based on questionnaires, market research, analysis of customer trends and other similar necessary analysis)
- To send various announcements and offers related to Resonac Group Companies’ products and services, such as sending direct mail
- For communications regarding sales negotiations and arrangements and for greetings with the purpose of facilitating business activities
- For joint sales activities of Resonac Group Companies and the like, and making joint distribution more efficient
- For maintenance of Resonac Group Companies’ websites (including ensuring their security), and investigating faults and fixing problems with servers
- To make and defend legal claims
- For the security management of buildings and the like whose management falls under our responsibility
- To analyze your attributes acquired from your browsing history and use this to deliver targeting advertising based on such attributes
- To analyze your information that we obtain when you access our websites and use such information for the smooth operation and improvement of the services provided in our websites
- To send various announcements and offers related to Resonac Group Companies’ products and services, when consent is necessary pursuant to direct marketing regulations
- To exercise rights and perform obligations under contracts or laws

(2) Personal information of shareholders of Resonac Group Companies
- To exercise rights and perform obligations under the Companies Act and other such laws and regulations
- For management in accordance with laws and regulations
- For communicating any other matters

3. Legal basis, etc. for processing
Resonac Group Companies process your personal information in accordance with applicable personal information protection regulations. Please refer to the country-specific exhibit for details regarding our legal basis for processing in the country in question.
The provision of your personal information may be mandatory for various reasons, such as being a statutory or contractual requirement or being a necessary condition for entering into a contract. Specific details are as follows.

(1) Personal information of officers, employees, and the like of customers and other similar trading partners
- Provision of information related to cookies, IP addresses, types of web browser, and user activities that are strictly required for the use of Resonac Group Companies’ websites is mandatory. If you do not provide us with this information, you might not be permitted to use our websites.
- In any other case where you do not provide us with your personal information despite the fact that the provision of that personal information is a statutory or contractual requirement or is a necessary condition for entering into a contract, Resonac Group Companies might not be able to provide you with goods, service, or the like of Resonac Group Companies (including our websites).

(2) Personal information of shareholders of Resonac Group Companies
- The provision of your name, address, e-mail address, number of shares owned, date of share acquisition, shareholder number, dividend payment history, and account for dividends is mandatory as a contractual requirement. If you do not provide us with this information, it might not be possible to exercise rights and perform obligations under the Companies Act of Japan and other such laws and regulations.

4. Retention period for personal information
In order to decide the appropriate retention period for personal information, Resonac Group Companies consider the following: the volume, nature, and confidentiality of the personal information; the potential risk of damage caused by unauthorized use or disclosure of the personal information; the purposes for which Resonac Group Companies process the personal information, and whether Resonac Group Companies can achieve those purposes by other means; and applicable legal requirements. If your personal information collected by Resonac Group Companies becomes no longer necessary, Resonac Group Companies will delete or anonymize your personal information, or if such measures are impracticable (for example, if your personal information has been stored in back-up archives), we will retain your personal information safely until its deletion becomes practicable and ensure that any new processing will not be conducted with respect to your personal information.

5. Sources of personal information
Resonac Group Companies obtain your personal information directly from you (including in cases where personal information is obtained automatically). However, we may obtain your personal information indirectly from a third party other than you in the following cases:

(1) Personal information of officers, employees, or the like of customers and other similar trading partners
- Other companies within Resonac Group Companies
- Secondment destinations of employees of Resonac Holdings Corporation
- Website traffic analysis service providers, such as Google LLC
- Trading companies
- Internet severvice providers
- Marketing automation tools and other OS providers
- Platform operation and maintenance providers

(2) Personal information of shareholders of Resonac Group Companies
- Stock brokerage firms

6. Sharing and disclosure of personal information
Resonac Group Companies share with or disclose to a third party the personal information stated in “1. Categories of personal information subject to processing” above to fulfill the purposes stated in “2. Purpose of processing” above if (a) any of the following cases applies, (b) we have your consent to do so, or (c) it is permitted by applicable personal information protection regulations of the country in question.

Please refer to “8. Regarding joint use of personal information” below in the case of third-party provision on the grounds of joint use under the Personal Information Protection Act of Japan.

(1) Personal information of officers, employees, or the like of customers and other similar trading partners

• Sharing with and disclosure to Resonac Group Companies, etc.
- Companies within Resonac Group Companies may share personal information with or disclose personal information to other companies within Resonac Group Companies.
- Resonac Holdings Corporation may share personal information with or disclose personal information to secondment destinations of its employees. Although the destination countries include countries outside Japan, the destination countries cannot be specified because they are located in more than one country and they are not decided until the time of provision which country each personal information is provided to which destination located in which country.

• Sharing with and disclosure to processors (service providers)
- Website traffic analysis service providers, such as Google LLC
- Other contractors that provide services necessary for the business activities of Resonac Group Companies

7. Cross-border transfer of personal information
As a result of sharing and disclosure pursuant to “6. Sharing and disclosure of personal information” above, your personal information may be transferred to the following countries:
- United States
- Canada
- Mexico
- Brazil
- Germany
- United Kingdom
- Netherlands
- Italy
- Russia
- United Arab Emirates
- South Africa
- Kenya
- Japan
- Hong Kong
- Taiwan
- China
- South Korea
- Singapore
- Thailand
- Philippines
- Malaysia
- Indonesia
- Vietnam
- India
- Myanmar
- Cambodia
- Australia
- Colombia
- Chile
- Argentina
- Serbia
- Turkey
- Switzerland
- Ukraine
- Morocco
- Bahrain
- Iran
- Iraq
- Jordan
- Qatar
- Saudi Arabia

Upon transferring personal information to any of the countries listed above, Resonac Group Companies take appropriate protection measures required by the personal information protection regulations of that country. For protection measures in the country in question, please refer to the country-specific exhibit.


8. Joint use of personal information
Resonac Group Companies jointly use personal information with specified persons on the grounds of joint use under the Personal Information Protection Act of Japan as follows. However, if your consent is required under applicable personal information protection regulations other than the Personal Information Protection Act of Japan, we will obtain your consent.

• Joint use among Resonac Group Companies
(1) Items of personal information to be jointly used
Name, address, telephone number (including fax number), e-mail address, company (or association) name, department name, occupational type, title, inquiry history, purchase history, and other similar information
(2) Scope of joint users
Resonac Group Companies
(3) Purposes of joint use
- To purchase goods or the like, to sell products or the like, and to handle matters incidental to such purchasing and selling
- To respond to various inquiries, claims or the like from customers
- To make various announcements and offers regarding our products and services, such as sending direct mail
- To send greetings or the like for the purpose of facilitating business activities
- To exercise rights and perform obligations under contracts or laws
(4) Name of person who is responsible for the management of personal information to be jointly used
Resonac Holdings Corporation
Adress: 1-13-9 Shiba Daimon, Minato-ku, Tokyo 105-8518, Japan
Name of representative: Hidehito Takahashi

9. Safety management measures
In order to ensure the accuracy and safety of personal information, Resonac Group Companies strive to keep personal data accurate and up-to-date. We also strive to deploy both managerial and organizational systems and information and communication technology to devise effective security measures for the prevention of unauthorized access to personal information and the prevention of loss, falsification, leaking, or the like of personal information.

10. Regarding Cookies etc.
Cookies are small pieces of information that are sent to your browser when you access a website. In most cases, cookies are used to streamline use of the website. If you prefer to avoid the use of cookies, you may refuse cookies for the website in question, or change the settings in your internet browser so that cookies are rejected, deleted, or deactivated. However, please note that this may have consequences for your ease of use of the website.
The websites of Resonac Group Companies automatically generate log files that recognize and register use by each user with cookies and other cookie-like technologies. Resonac Group Companies maintain user data, such as source addresses for pages requested, IP (internet protocol) addresses and domain names, dates and times of page requests, links from other websites, and other parameters in the URLs. These log files and data are used, on an anonymous basis, for statistical purposes and for improving the services offered via the websites.
For more details of cookies on our websites, please visit our Cookie Policy.

• Regarding the use of Google Analytics

Resonac Group Companies may work with third parties that collect data about your use of our websites over long periods of time. For example, the system may use Google Analytics for analytics and marketing purposes.
With Google Analytics, user information is collected using cookies, etc. For more information about how Google Analytics collects and uses data when you use our websites, please visit www.google.com/policies/privacy/partners.
To opt out of Google Analytics, please visit tools.google.com/dlpage/gaoptout.

11. Your rights
Resonac Group Companies respect the rights you hold under the applicable personal information protection regulations of each country. For example, as far as the applicable personal information protection regulations of each country grant, you may have right to access; right to rectification; right to erasure; right to restriction of processing; right to objection to prosessing; right to withdraw your consent (It may be granted if you have given your consent regarding certain types of processing activities. However, your withdrawal of consent does not affect the lawfulness of processing conducted based on your consent before its withdrawal.); right to data portability; and right to not be subject to automated decision-making and so on. The Personal Information Protection Act of Japan grants the right to request the following in relation to retained personal data (meaning retained personal data prescribed in Article 16, paragraph 4 of the Personal Information Protection Act of Japan): notification of the purpose of use; disclosure; correction, addition, or deletion of content; suspension of use, erasure, or suspension of third-party provision; and disclosure of records of third-party provision (meaning third-party provision prescribed in Article 37, paragraph 2 of the Personal Information Protection Act of Japan). For rights granted under the personal information protection regulations of the country in question, please check the country-specific exhibit.
If you wish to exercise your rights granted under the personal information protection regulations of the country in question, please contact us using the contact details stated in “12. Contact details” below.

12. Contact details
For questions and inquiries regarding this Global Privacy Policy, please contact us using the contact details below:

Resonac Holdings Corporation, Legal Division
Address: 1-13-9, Shiba Daimon, Minato-ku, Tokyo 105-8518 Japan
TEL: +81-3-5470-1111
Reception hours: Weekdays 9:00-12:00/13:00-17:45
(excluding Saturdays, Sundays, and national holidays)

13. Amendment to the Global Privacy Policy
If Resonac Group Companies intend to amend this Global Privacy Policy (including the country-specific exhibit), we may amend all or part of, or make an addition to, this Global Privacy Policy by publishing that amendment or addition on our websites, sending an e-mail to that effect to our customers, or giving notice by any other method that Resonac Group Companies deem appropriate (subject to applicable laws and regulations, if any). In such a case, the post-amendment version of this Global Privacy Policy will be applied from the earlier of the date on which you use a product or service of Resonac Group Companies or access our websites for the first time after receiving such notice, or the date stated in such notice. If there are any necessary procedures under personal information protection regulations that are to be applied, such procedures will be taken.

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