Notice on Processing of Personal Information Collected within the EEA

1．General information

We, Kobe Steel Group, use your personal information in compliance with the applicable personal information protection regulations. Below you will be informed about which personal information we collect and store from you. You will also be informed about how and for what purpose your personal information is used and what rights you have with regard to your personal information to be used by us.

2．Collection and storage of personal information and the nature and purpose of its use

We collect your personal information, such as the following information, if necessary:

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.

The personal information is collected in certain situations like the following:

to identify you as our existing or potential customer
to be able to correspond with you and / or otherwise get in touch with you
to successfully process your request / instruction
to issue invoices
to be able to settle any liability claims by you against us
to be able to track and enforce any (payment) claims by us against you

Your personal information is processed based on your request or instruction. Processing of personal information is necessary for the appropriate processing of your request and for the mutual performance of obligations under a contract (Art. 6 par.1 (b) of GDPR). Your personal information will be stored or collected electronically.

The personal information collected by us within the scope approved by you will be stored or kept until the expiry of the statutory retention period and then deleted or destroyed; provided, however, that we will comply with other regulations if we are subject to a longer storage / retention obligation due to other legal regulations (Art.6 par. 1 (c) of GDPR), and / or you have consented to a continuation of contractual relationship with us for a long-term storage / retention of your personal information or have instructed us accordingly (Art. 6 par. 1 (a) of GDPR).

3．Disclosure of personal information to third parties

We basically do not transfer your personal information to third parties (e.g. other companies within our group or our contractors) for purposes other than those listed below. Your personal information may be transferred only to the extent necessary for the processing scheduled under the contractual relationship with us. The transferred information may only be used by the recipient scheduled for the stated purposes. Of course, a transfer to third parties is made only in your interest that can gain your understanding and upon consultation with you. The employees of Kobe Steel Group who handle your personal information are subject to a strict confidentiality obligation, the compliance of which we constantly monitor. Other persons to whom we outsource our work and who handle your personal information are obliged by us to keep confidentiality in writing, and are monitored by us to be prevented from beaching such obligation, and will be punishable if breaching the same.

In the case that it is necessary to transfer your personal information to any third party who is in any overseas country, we will explain to that effect and take necessary measures prior to such transfer.

4．Your rights as the subject of the personal information

You have the right to withdraw your consent you have once given to us at any time in accordance with Art. 7 par. 3 of GDPR. The withdrawal of your consent does not affect the lawfulness of the processing based on your prior consent.

The withdrawal of your consent only has the consequence that we are not allowed to continue processing of your personal information for the future based on such consent.

You have the right to request disclosure of the information about your personal information processed by us in accordance with Art. 15 of GDPR.

In particular, you can request disclosure of the information about:

the processing purposes
the categories of personal information that will be or have been processed
the recipients or categories of recipients to whom your information will be or has been disclosed
the planned storage duration
the right to rectify, erase or restrict processing or to object to processing
the existence of a right of appeal to a supervisory authority
the source of your personal information, if such information is not collected from you
the existence of automated decision-making, including profiling, and where relevant, meaningful information about the logic involved, and the scope and intended impact of such processing on you

You have the right to ask, without delay, for the rectification of incorrect personal information concerning you or the storage of complete information by us, if such information is incomplete, in accordance with Art. 16 of GDPR.

You have the right to demand the deletion of your personal information stored by us in accordance with Art. 17 of GDPR; provided, however, that this does not apply if the processing of your personal information is necessary:

to exercise the right of freedom of expression and information
to fulfill a legal obligation
for reasons of public interest in the field of public health
for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes
to assert, exercise or defend legal claims

You have the right to demand the restriction of the processing of your personal information in accordance with Art. 18 of GDPR.

This applies only as far as:

the accuracy of the information is disputed by you
the processing is unlawful, but you reject the deletion of the information and instead request the restriction of its use
we no longer need the information, but you need the information to assert, exercise or defend legal claims

You have the right to object to processing in accordance with Art. 21 of GDPR.

You have the right to receive your personal information, which you have provided to us, in a structured, commonly used and machine-readable format, or to request transmission of such information to another person who shall be responsible, in accordance with Art. 20 of GDPR.

You have the right to complain to a supervisory authority in accordance with Art. 77 of GDPR.

As a rule, you can contact the supervisory authority of your usual place of residence or workplace or our office.

5．Right of objection

If your personal information is processed based on legitimate interests under Art. 6 par. 1 (f) of GDPR, you have the right to object to the processing in accordance with Art. 21 of GDPR as far as there are reasons which arise from your particular situation.

If you want to exercise your right to object, please send an e-mail to individual Kobe Steel Group companies.

6．Personal information controllers

Based on GDPR, each department of individual Kobe Steel Group companies to which you provided your personal information, shall be responsible for collecting, processing and using your personal information. If you are not sure where to contact, please send an e-mail to:

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