In the course of doing business, the Asahi Kasei Group receives personal information (the term “personal information” is used herein as defined in Article 2, Paragraph 1, of the Act on the Protection of Personal Information (Act No. 57 of 2003)) such as names, postal addresses, phone numbers, and e-mail addresses from consumers, clients, suppliers, shareholders, and others, in addition to the personal information of our executives and employees which we hold. We are committed to maintaining the privacy and security of this personal information, and to ensuring that it is handled appropriately in accordance with this policy.

Because this policy may be revised, we recommend that you refer to this page again from time to time.

• （1）We handle personal information properly and in compliance with the Personal Information Protection Law and other applicable statutes, and in conformance with generally accepted norms and standards.
• （2）We ensure that personnel throughout the Asahi Kasei Group thoroughly understand and faithfully comply with corporate standards and regulations for the handling of personal information.
• （3）We use personal information only for the specific purposes which have been indicated or announced at the time of its receipt.
• （4）We employ appropriate measures in the maintenance and management of personal information to ensure against unauthorized alteration, disclosure, and loss of personal information.
• （5）We will respond in good faith to requests from you to confirm, revise, cease using, or delete your personal information.

Specifics are described below.

• 1. Purpose of use
• 2. Shared use
• 3. Disclosure to third parties
• 4. Personal information inquiries
• 5. This website
• 6. Privacy Statement for GDPR

Purpose of use

Purposes for which personal information may be used by Asahi Kasei Group companies are described below. Some Asahi Kasei Group companies include additional purposes as described in the privacy policy specific to their respective websites or sections of this website.

• （1）Response to inquiries or requests.
• （2）Provision, accumulation, investigation, and study of, and response to, information related to products and services.
• （3）Notification of trade shows or other events related to products and services.
• （4）Presentation of gifts or rewards won in drawings or competitions.
• （5）Inquiry, communication (including distribution of reports), consultation, discussion, study, contracting, placement and receipt of orders, shipment, invoicing, receipt of payment, remittance of payment, and management of credits and debts in relation to commercial transactions, Responsible Care, investor relations, financial transactions, and pension-fund management.
• （6）Investigation and study of, and response to, circumstances of use of products and services and needs related thereto.
• （7）Management of entrance and egress of persons and vehicles entering Asahi Kasei Group facilities.
• （8）Liaison with communities where Asahi Kasei Group facilities are located.
• （9）Notification and reporting to governmental agencies, municipal offices, and public bodies.

Shared use

Asahi Kasei Corporation may share personal data with Asahi Kasei Group companies as shown below. Some Asahi Kasei Group companies include additional shared use as described in the privacy policy specific to their respective websites or sections of this website.

Information subject to shared use	Purpose of shared use	Responsible party
Names and contact information held by General Affairs	Appropriate response to inquiries and requests	Senior General Manager of General Affairs
Names and contact information held by Corporate Procurement & Logistics	Execution of duties related to procurement	Senior General Manager of Corporate Procurement & Logistics
Names and contact information held by Corporate Accounting & Control and Corporate Finance	Management of credits and debts, handling payments	Senior General Manager of Corporate Accounting & Control and Senior General Manager of Corporate Finance

Disclosure to third parties

In cases where it becomes necessary to disclose personal information to subcontractors in the course of outsourcing, Asahi Kasei Group companies conclude agreements with the subcontracted firms requiring that such personal information is handled in accordance with Asahi Kasei Group standards. The handling of personal information by subcontracted firms is monitored and supervised to ensure compliance.

The only other cases where personal information is disclosed to third parties are described below.

• （1）If we have your prior approval to do so.
• （2）If the possibility of such disclosure was clearly indicated at the time personal information was received.
• （3）If appropriate response to an inquiry or request necessitates disclosure to an Asahi Kasei Group company.
• （4）If information in a form which precludes personal identification is disclosed for statistical analysis.
• （5）If merger, business separation, or business transfer necessitates disclosure for the succession of operations.
• （6）If required by law or regulation.
• （7）If necessitated for the protection of a person’s life, health, or assets, and we are unable to obtain your prior approval.
• （8）If required in the course of cooperation with governmental authorities and obtaining your prior approval would impede the authorities in the execution of their duties.

Personal information inquiries

• （1）Confirmation
  For your examination and confirmation, you may request that we disclose to you the retained personal data of yours which we hold or that we notify you of the purposes for which we may use it. Upon verifying that the person making such a request is the person for whom disclosure is being requested or a duly authorized proxy thereof, we will respond in a reasonable time and to a reasonable extent.
• （2）Correction, revision
  You may request that we correct or revise the retained personal data of yours which we hold. Upon verifying that the identity of the person making such a request is the person for whom correction or revision is being requested or a duly authorized proxy thereof, we will respond in a reasonable time and to a reasonable extent if the data we hold is inaccurate.
• （3）Cessation of use, deletion
  You may request that we cease using, delete, or cease disclosing to third parties the retained personal data of yours which we hold. Upon verifying that the identity of the person making such a request is the person for whom cessation of use or deletion is being requested, or a duly authorized proxy thereof, we will respond in a reasonable time and to a reasonable extent.
  Please note that the cessation of use, deletion, or cessation of disclosure to third parties of part or all of your personal information may prevent us from providing you with certain services. Please also note that relevant regulations provide that we may decline to fulfill such a request in certain cases.

• （4）How to contact us
  Requests for confirmation, correction, revision, cessation of use, or deletion of retained personal data may be made through the inquiry form, by fax to +81-(0)3-6699-3161, or by post to Corporate Affairs, Hibiya Mitsui Tower, 1-1-2 Yurakucho, Chiyoda-ku, Tokyo 100-0006 Japan.
  If your personal information was provided to us through Asahi Kasei Group company websites or sections of this website which have a separate privacy policy, please refer to the contact information shown in that privacy policy.
• （5）Handling fee
  Costs which we incur to fulfill a request for confirmation, correction, revision, cessation of use, or deletion of retained personal data may be charged to you or your duly authorized proxy as a handling fee.

This website

• （1）Security precautions
  Reasonable and appropriate security measures are employed in the maintenance and management of personal information in order to ensure against risks such as unauthorized access, loss, damage, alteration, and disclosure. To ensure that personal information is managed appropriately, personnel responsible for managing personal information are designated at each business unit which receives personal information, and all relevant personnel are thoroughly familiarized with the company-wide information security regulations.
• （2）Cookies
  This website uses cookies (a standard form of data stored on the user’s computer) for the purpose of improving our services. Please refer to our Cookie Policy regarding our purpose of using cookies and how we handle them.
• （3）Applicability of privacy policy
  This privacy policy applies to Asahi Kasei Group companies. However, some Asahi Kasei Group companies have separate privacy policies which apply specifically to those companies.
  We are not responsible for the privacy practices of other websites to which links may be included in this website. Please refer to the privacy policies of those websites separately.

The following Privacy Statement applies to the personal data we possess with respect to customers, business partners, employees, and other individuals in the European Economic Area (the “EEA”).

PRIVACY STATEMENT

The protection of your personal data is of great importance to Asahi Kasei Corporation (“Asahi Kasei”) and its affiliates (together, the “Asahi Kasei Group”). The sections below of this privacy statement (“Privacy Statement”) are intended to inform you about how the Asahi Kasei Group entities collect and process your personal data that you submit or disclose to us. We also act as data controller when we process your personal data received or obtained through third-parties. We process this personal data in accordance with the applicable EU and Member State regulations on data protection in particular, the General Data Protection Regulation No 2016/679 (the “GDPR”). If you do not wish your personal data to be used by us as set out in this Privacy Statement, please do not provide us with your personal data. Please note that in such a case, we may not be able to provide you with our services, you may not have access to and/or be able to use some features of the website, and your customer experience may be impacted.

Purpose of Use

We will always process your personal data based on the GDPR. In addition, we will always process your sensitive personal data, for example, concerning your trade union membership, religious views, or health condition, in accordance with the GDPR.

We may collect and process your personal data for the purposes detailed below, which are required so that we can pursue our legitimate interests and provide you with adequate services and products:

• to ensure that content from our site is presented in the most effective manner for you;
• to notify you about changes to our service(s);
• to manage your customer account;
• to offer you products and services;
• to inform you about our policies and terms;
• to promote safety and security, such as by monitoring fraud and investigating suspicious or potentially illegal activity or violations of our terms or policies;
• to provide, improve, and develop our products, services, and advertising;
• to use personal data for purposes such as data analysis, research, and audits;
• to ensure business continuity.

In addition, subject to obtaining your express prior consent, we may also collect and process your personal data for the following purposes:

• to make marketing advertisements;
• to provide you with information which we feel may be of your interest;
• to allow you to participate in interactive features of our services, when you choose to do so;
• to manage your subscription to the newsletter;
• to share your personal data with third-party partners who may send you marketing communications in relation to their products and services;
• for making business analysis.

Please be aware that you are entitled to withdraw your consent at any time, and this without affecting the lawfulness of processing based on your consent before withdrawal thereof.

We will process your personal data for these specified, explicit and legitimate purposes, and will not further process the data in a way that is incompatible with these purposes. If we intend to process the personal data originally collected for one purpose in order to attain other objectives or purposes, we will ensure that you are informed of this. We will keep your personal data for as long as it is necessary for us to comply with our legal obligations, to ensure that we provide an adequate service, and to support our business activities.

Types of Personal Data

For the purposes specified under this Privacy Statement, we need to collect the categories of personal data referred to above.

We can obtain such personal data either directly from you when you decide to communicate such data to us (i.e., when you fill in forms displayed on the website) or indirectly where such personal data is provided to us by your electronic communication terminal equipment or your internet browser. We ensure that the personal data processed is adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.

Shared Use

We may transfer your personal data to Asahi Kasei Group entities and to third parties so as to share such personal data with them in accordance with the GDPR. Where we transfer your personal data to a data processor so as to share such personal data with them, we will put the appropriate legal framework in place in order to cover such transfer and processing. Furthermore, where we transfer your personal data to any entity outside the EEA so as to share such personal data with them, we will put appropriate legal frameworks in place, notably controller-to-controller (2004/915/EC) and controller-to-processor (2010/87/EU) Standard Contract Clauses approved by the European Commission, in order to cover such transfers.

Strategic Partners

Subject to your prior consent, your personal data may be transferred to, stored by, and further processed by strategic partners that work with us to provide our products and services or help us market to customers. We may currently share your personal data with the strategic partners. Your personal data will only be shared by us with these companies in order to provide or improve our products, services, and/or advertising.

Service Providers

We share your personal data with companies which provide services on our behalf, such as hosting, maintenance, support services, email services, marketing, auditing, fulfilling your orders, processing payments, data analytics, providing customer service, and conducting customer research and satisfaction surveys. We may currently share your personal data with the service providers.

Corporate Affiliates and Corporate Business Transactions

We may share your personal data with all the Asahi Kasei Group. In the event of a merger, reorganization, acquisition, joint venture, assignment, spin-off, transfer, or sale or disposition of all or any portion of our business, including in connection with any bankruptcy or similar proceedings, we may transfer any and all personal data to the relevant third party.

Legal Compliance and Security

It may be necessary for us – by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence – to disclose your personal data. We may also disclose your personal data if we determine that, due to purposes of national security, law enforcement, or other issues of public importance, the disclosure is necessary or appropriate.

We may also disclose your personal data if we determine in good faith that disclosure is reasonably necessary to protect our rights and pursue available remedies, enforce our terms and conditions, investigate fraud, or protect our operations or users.

Data Transfers

Such disclosures may involve transferring your personal data out of the European Union to the following countries: Japan, China, Korea, Thailand, Hong Kong, Taiwan, USA, and UK. Such transfer may take place for business operations, accounting, human resources management, IT and general administration, marketing, market research and PR activities, and sales and/or after-sales management. For each such transfer, we make sure that we provide an adequate level of protection to the transferred data.

Records of Data Processes

We handle records of all processing of personal data in accordance with the obligations established by the GDPR, both where we might act as a controller or as a processor. In these records, we reflect all the information necessary in order to comply with the GDPR and cooperate with the supervisory authorities as required.

Security Measures

We process your personal data in a manner that ensures their appropriate security, including protection against unauthorised or unlawful processing and accidental loss, destruction, or damage. We use appropriate technical or organisational measures to achieve this level of protection.

We will retain your personal data for as long as it is necessary to fulfill the purposes outlined in this Privacy Statement, unless a longer retention period is required or permitted by law.

Notification of Data Breaches to the Competent Supervisory Authorities

In case of breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data which have been transmitted, stored, or otherwise processed, we have the mechanisms and policies in place in order to identify it and assess it promptly. Depending on the outcome of our assessment, we will make the requisite notifications to the supervisory authorities and communications to the affected data subjects, which might include you.

Processing Likely to Result in High Risk to Your Rights and Freedoms

We have mechanisms and policies in place in order to identify data processing activities that may result in high risk to your rights and freedoms. If any such data processing activity is identified, we will assess it internally and either stop it or ensure that the processing is compliant with the GDPR or that appropriate technical and organizational safeguards are in place in order to proceed with it.

In case of doubt, we will contact the competent Data Protection Supervisory Authority in order to obtain their advice and recommendations.

Your Rights

You have the following rights regarding personal data collected and processed by us.

• Information regarding your data processing: You have the right to obtain from us all the requisite information regarding our data processing activities that concern you.
• Access to personal data: You have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to such personal data and certain related information.
• Rectification or erasure of personal data: You have the right to obtain from us the rectification of inaccurate personal data concerning you without undue delay, and to complete any incomplete personal data. You may also have the right to obtain from us the erasure of personal data concerning you without undue delay, when certain legal conditions apply.
• Restriction on processing of personal data: You may have the right to obtain from us the restriction of processing of your personal data, when certain legal conditions apply.
• Object to processing of personal data: You may have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you, when certain legal conditions apply.
• Data portability of personal data: You may have the right to receive your personal data in a structured, commonly used, and machine-readable format, and have the right to transmit such data to another controller without our hindrance, when certain conditions apply.
• Not to be subject to automated decision-making: You may have the right not to be subject to automated decision-making (including profiling) based on the processing of your personal data, insofar as this produces legal or similar effects on you, when certain conditions apply.

If you intend to exercise such rights, please refer to “Personal information inquiries” above.

If you are not satisfied with the way in which we have proceeded with any request, or if you have any complaint regarding the way in which we process your personal data, you may lodge a complaint with a Data Protection Supervisory Authority.

Children

Our products and services are not especially intended for children customers. Thus, we do not knowingly collect and process information on children under sixteen (16). If we discover that we have collected and processed personal data concerning a child under sixteen (16), or the equivalent minimum age depending on the concerned jurisdiction, we will take steps to delete the information as soon as possible. If you become aware that a child under sixteen (16) has provided us with personal data, please contact us immediately in accordance “Personal information inquiries” above.

Links to Other Sites

We may propose hypertext links from the website to third-party websites or internet sources. We do not control and cannot be held liable for third parties’ privacy practices and content. Please read carefully their privacy policies to find out how they collect and process your personal data.

Updates to the Privacy Statement

We may revise or update this Privacy Statement from time to time. Any changes to this Privacy Statement will become effective upon posting of the revised Privacy Statement via our services. If we make changes which we believe are significant, we will inform you through the website to the extent possible and seek your consent where applicable.

Revised April 1, 2020