In the following, NIPPON STEEL ENGINEERING CO., LTD. ("NSE"), its Head Office located at Osaki 1-5-1, Shinagawa-ku, Tokyo, 141-8604, Japan, provides information on the processing of personal data in the context of activities of NSE in connection with its relationship with existing and potential customers, trading companies, end users, goods and service suppliers, agents, advisors, research institutions, industrial organizations and other persons with whom NSE or any of its group company maintains or is considering to create a business relationship (each a "Business Partner") pursuant to Art. 13 and 14 of the European General Data Protection Regulation ("GDPR").
NSE may process the following personal data:
NSE processes the personal data indicated above in section A for the following purposes:
When processing of personal data is necessary for the performance of a contract to which a Business Partner Contact is party or in order to take steps at the request of a Business Partner Contact prior to entering into a contract, the legal basis for such processing is Article 6 (1) (b) of the GDPR.
When personal data is explicitly provided by a Business Partners Contact, the legal basis for the processing is the consent given by the Business Partner Contact (Article 6 (1) (a) of the GDPR).
When processing of personal data is necessary to comply with a legal obligation, the legal basis for the processing is Article 6 (1) (c) of the GDPR.
Otherwise, the legal basis for processing of personal data indicated above in Section A by NSE is Article 6 (1) (f) of the GDPR. The legitimate legal interest pursued by NSE is the transmission and receipt of information in order to conduct its business activities, including expanding and/building a business relationship with Business Partners.
NSE generally does not seek to collect or otherwise process special categories of personal data of Business Partner Contacts, such as those revealing religious or philosophical beliefs, in the ordinary course of its business. Where it becomes necessary to process such special categories of personal data for any reason, NSE relies on the following legal bases depending on the circumstances: (i) explicit consent of the Business Partner Contact has been given (Article 9 (2) (a) of the GDPR), (ii) the personal data are manifestly made public by the Business Partner Contact (Article 9 (2) (e) of the GDPR), (iii) processing is necessary for the establishment, exercise or defense of legal claims (Article 9 (2) (f) of the GDPR).
For the purposes indicated under section B above, NSE may disclose personal data to the following recipients or categories of recipients:
Recipients of personal data may be located in countries and areas outside of the European Economic Area ("Third Countries"). NSE transfers personal data to external recipients in Third Countries only in case: (i) the respective recipient is located in a country or area which has received an adequacy decision from the European Commission, (ii) the respective recipient entered into Standard Data Protection Clauses/Standard Contractual Clauses pursuant to Article 46 (2) (c) of the GDPR with NSE, (iii) in case of US recipients - the recipient is certified under the EU-US Privacy Shield, (iv) the Business Partner Contact explicitly consents to the transfer of his/her personal data, or (v) another requirement under Article 49 of the GDPR is met. In case of (ii), Business Partner Contacts can receive a copy of the Standard Data Protection Clauses/Standard Contractual Clauses by contacting NSE through the contact information in section F below.
Unless indicated otherwise, NSE will retain personal data for as long as is necessary for the purpose for which they were collected or otherwise processed (including as required by applicable law or regulation or for the exercise or defense of legal claims).
I. Access, rectification, erasure, restriction, data portability
With regard to the processing of his/her personal data, a Business Partner Contact has the following rights within the limits set forth in the GDPR:
II. Right to object
A Business Partner Contact has the right to object on grounds relating to his/her particular situation, at any time to processing of his/her personal data which is based on Art. 6(1) (f) of the GDPR (see section B above), including profiling (if any) based on the same provision pursuant to Art. 21 (1) of the GDPR.
If personal data is processed for direct marketing purposes, a Business Partner Contact has the right to object at any time to processing of his/her personal data for such marketing, which includes profiling (if any) to the extent that it is related to such direct marketing pursuant to Art. 21 (2) of the GDPR.
III. Right to withdraw consent
Where the processing is based on his/her consent (Art. 6(1) (a) or Art. 9(2) (a) of the GDPR), a Business Partner Contact has the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
IV. Right to lodge a complaint
A Business Partner Contact has the right to lodge a complaint with a supervisory authority pursuant to Art. 57 (1) (f) GDPR.
If a Business Partner Contact has a question with regard to processing of his/her personal data or wants to exercise any of the above rights in section E above, he/she may contact NIPPON STEEL ENGINEERING CO., LTD. at: nsengi_EEA_rep@eng.nipponsteel.com
NSE will endeavor to address and settle any requests or complaints brought to its attention. In addition to the above, there is a possibility of approaching the competent data protection authority with requests or complaints.
As of: 28 June, 2021
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