This Global Privacy Policy (“Global Privacy Policy”) explains how Hayashi Pure Chemical Ind., Ltd. (“we”, “us,” or “our”), may process personal data of data subjects outside of Japan, in particular, the European Economic Area and the United Kingdom (collectively, the “European Countries”).

We are committed to respecting personal data and protecting the privacy of all individuals who have a relationship with us. We will process your personal data in compliance with applicable data protection laws, including, but not limited to General Data Protection Regulation (EU) No 2016/679 (“GDPR”) for European Countries and laws in other countries similar GDPR, and any laws that replace them in the future.

This Global Privacy Policy applies to the personal data of data subjects outside of Japan that we process. As for our personal data processing in Japan, it is set forth in our general Privacy Policy （ https://www.hpc-j.co.jp/privacypolicy/ ).

This website may contain links to and from third-party websites. These third-party websites and any services that may be accessible through them have their own privacy policies. We are not responsible for these third parties’ privacy practices. We encourage you to be aware of this when you leave this website and to read the privacy policies applicable to these third-party websites.

In this Global Privacy Policy:

• (1) Your “personal data” means any information relating to an identified or identifiable natural person (“data subject”) ;
• (2) “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, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction;
• (3) “controller” means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of processing personal data;

If you have any questions about our Global Privacy Policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

We will collect and process the following personal data about you:

Source	Example	Categories of personal data
(1) Data we directly collect from you	Telephone, written, business card, verbal, our website, our online shop on e-commerce platform, inquiry form, application form, online conference etc.	Identification information (e.g., name, workplace, home/work address, email address, phone number, fax number, date of birth, gender) Curriculum vitae (e.g., personal history) Recorded video of online conference
(2) Data we collect from Third parties or in our facilities	User applicants, introducers, dealership, receptionists for packaged products, etc.	Identification information (e.g., name, workplace, home/work address, email address, phone number, fax number, date of birth, gender) from introducers or receptionists. Payment Information from payment service providers Security camera image in our facilities
(3) Data we collect from publicly accessible source	Newspapers, internet, telephone directories, publications, and other books, etc.	Identification information (e.g., name, workplace, home/work address, email address, phone number, fax number, date of birth, gender)
(4) Data we collect automatically	Automatically collect from this website	Internet activities (e.g, search history) IP address, cookie information and other online identifier

You are required to provide us with certain personal data when you sign in our website. Personal data that is mandatory is indicated in the relevant forms. We are not able to provide our website/services to you if such data is not provided.

We process your personal data for the purposes and on the legal bases described below.

Categories of personal data	Purposes of processing	Legal basis of processing
Identification information	For fulfillment of the rights and obligations under the contract and guidance of our activities (delivery / sending of contact, e-mail newsletter, DM, various notifications, etc.) To confirm the contents of the inquiry, answer, and guide the activities (contact, e-mail newsletter, DM, distribution / sending of various notifications, etc.) To inform you about our activities (contact, e-mail newsletter, DM, distribution and sending of various notifications) To be useful for marketing activities (planning and development of products and services, etc.)	Contract Legitimate interests
Curriculum vitae	For the procedure of recruitment selection of the person For our personnel and labor management, business management, health management, information management, security management	Contract Legitimate interests
Recorded video of online conference	For information on the activity, related events, and other activities (delivery / sending of contact, e-mail newsletter, DM, various notifications, etc.) To be useful for marketing activities (planning and development of products and services, etc.)	Contract Legitimate interests Consent
Payment Information	To provide you with the goods and services you purchase Proper accounting and invoicing	Contract Legal obligation Legitimate interests
Security camera image	To ensure your safety and protect your property	Legal obligation Legitimate interests
Internet activities and other online identifier	To improve your experience on our website To Analyse visitors’ interest and conducting other marketing analysis. To Provide services, advertisement distribution based on your interest. To combine with your personal data that we already have	Legitimate interests Consent

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

• (1) HPC Service Co., Ltd.
• (2) Service providers such as outside professional advisors and internet and IT-related service providers.
• (3) Any organization that organizes seminars in collaboration with us.
• (4) Any relevant party, law enforcement agency, or court, to the extent necessary for us to provide our services or comply with applicable law or regulation.

Personal data that we hold about you may be transferred to, and stored by, a third party outside the European Countries. Where we transfer your personal data to a third party outside the European Countries, we will ensure that:

The recipient destination has been subject to a finding from the European Commission that it ensures an adequate level of protection for the rights and freedoms that you possess in respect of your personal data; or
the recipient enters into standard data protection 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 by contacting us in accordance with the information indicated above in Section 3 “Contact Details”.

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

You have 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 will apply to the relationship between you and us, but would typically include:

• (1) The right to obtain information regarding the processing of your personal data and access to the personal data we hold about you.
• (2) The right to request that we rectify your personal data if it is inaccurate or incomplete.
• (3) 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.
• (4) The right to request that we restrict our processing of your personal data in certain circumstances. This may include (but is 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 defence 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).
• (5) The right to object to us about our processing of your personal data.
• (6) 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.
• (7) 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 can rely on another legal ground for doing so.

You can exercise your rights by contacting us using the information about us indicated above in Section 3 “Contact Details”. You can also lodge a complaint with the data protection regulator if you think any of your rights have been infringed by us.

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, including prohibited profiling.

Subject to the specification indicated above in Section 5, the provision of your personal data is not a statutory or contractual requirement.

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