Privacy Notice on Processing of Personal data Processed within the EEA

1. General information

We, Kobelco Group (Kobe Steel Ltd. and its each of group companies), process your personal data in compliance with the applicable personal data protection regulations. In this Privacy Notice, you are informed about the categories of your personal data we process and about how and for what purpose your personal data is processed. You are also informed about what rights you have with regard to your personal data to be processed by us.

2. Categories of personal data and purposes and legal bases of processing

We collect your personal data, such as the following personal data, from you or via Kobelco Group or our business partners:

  • Your first name and surname
  • Your address
  • Your telephone number (landline and / or mobile)
  • Your personal e-mail address, and fax number if necessary
  • Your employer, your company, etc.

We process your personal data for the following purposes based on legitimate interest, that enables us to operate our business and perform contracts with our business partners and contractors:

  • to identify you as our existing or potential customer
  • to be able to correspond with you and otherwise get in touch with you
  • to successfully process your request and instruction
  • to issue invoices

We process your personal data for the following purpose based on legitimate interest, that enables us to enhance our service quality and efficiency in our business operation:

  • to use generative AI tools to enhance our productivity in documentation and communication.

We process your personal data for the following purposes based on legitimate interest, that enables us to protect our legal rights:

  • to claim establish, exercise, or defend against any existing or potential legal claims, including tracking and enforcing payment claims.

We process your personal data for the following purpose based on legal obligations:

  • to cooperate with relevant governmental authorities and agencies, including competent data protection authorities and those that are engaged in administrative or criminal investigations.

3. Retention period

We retain your personal data that we collect for the period necessary to operate our business and perform our contracts and business relationships with our business partners. However, we retain your personal data for the following purposes for a longer period:

  1. 1to comply with record retention requirements under applicable laws and regulations; and
  2. 2to establish, exercise, or defend against any existing or potential legal claims.

We delete your personal data when it is no longer required for such purposes.

4. Disclosure of personal data to third parties

We may share your personal data with the following recipients:
Kobelco Group: we may share your personal data with Kobelco Group to operate our business and perform our contracts and business relationships with our business partners and contractors.

Business partners: we may share your personal data with our business partners to fulfill the contracts and business relationships with the business partners.

Our contractors: we may share your personal data with IT vendors (such as, generative AI service venders and cloud vendors including Microsoft, Salesforce, and Sansan) and Kobelco Systems Corporation to store and share your personal data for our business operation.

Your personal data may be transferred to a third party outside the EEA (such as, Japan, China, Singapore, Vietnam, Malaysia, Thailand, India, United Arab Emirates, Saudi Arabia, Qatar, United States). Where we transfer your personal data to a third party outside the EEA, we ensure that:

  1. 1the recipient destination has been subject to a finding from the European Commission as ensuring an adequate level of protection for the rights and freedoms that you possess in respect of your personal data; or
  2. 2the recipient enters into standard data protection clauses with us, which have been approved by the European Commission.

You may obtain more details of the protection given to your personal data when it is transferred outside the EEA by contacting us, using the information indicated in Section 6 of this Privacy Notice.

5. Your rights as the subject of the personal data

You have legal rights concerning the processing of your personal data as follows:

  1. 1right to obtain information regarding the processing of your personal data and to access your personal data;
  2. 2right to request that we rectify your personal data if it is inaccurate or incomplete;
  3. 3right to request that we erase your personal data in certain circumstances;
  4. 4right to request that we restrict the processing of your personal data in certain circumstances;
  5. 5right to receive your personal data in a structured, commonly used, and machine-readable format and to request that we directly transmit such personal data to a recipient where this is technically feasible;
  6. 6where the processing is based on consent, the right to withdraw your consent to the processing of your personal data (please note, however, that we may still be entitled to process your personal data if we can rely on other legal grounds for doing so; furthermore, the withdrawal of your consent shall not affect the lawfulness of processing performed based on the consent before your withdrawal); and
  7. 7right to object to the processing of your personal data, in the case of processing personal data based on legitimate interest.

You may exercise any of your rights by contacting us, using the information specified in Section 6 of this Privacy Notice. You may also lodge a complaint with the competent data protection authority if you believe that we have infringed any of your rights.

6. Contact details

If you have any questions about this Private Notice, your rights, or any other matters relating to the protection of personal data, please contact us by using the following information:

Controller (possibly):
Name: Kobelco Group
E-mail:
EU representative:
Name: KOBELCO EUROPE GmbH
Address: Luitpoldstrasse 3, 80335 Munich, Germany

If you have any questions or complaints regarding the use of your personal data by KOBELCO EUROPE GmbH, you may also contact its Data Protection Officer at:

Name: Richard Masamitsu Scheiffele
Address: Burggrafenstr. 5, 40545 Düsseldorf
Tel: +49 211 66969515 / +49 1622673883
E-mail: