Each Denka Group company acquires personal information in an appropriate manner in accordance with the acts and laws on personal data/information protection and other applicable laws, regulations, and guidelines on the protection of personal information, and use personal information only within the scope of the purposes of use described below.

Each Denka Group company uses the following personal information for their own activities for the following purposes.

(1) Personal information of individual customers and related parties

(i) Items

Name, gender, place of employment, position, department to which the person belongs, e-mail address, telephone number, facsimile number, region/country where the person is located, address, date of birth, details of the inquiry, account information, history of browsing or buying activities, membership ID, password, credit card information, payment information and any other information necessary for the purpose of use set forth below.

(ii) Purpose of use

• Responding to inquiries and requests for materials, and recording of such inquiries and requests
• Provision of products, services and related information (including information on ordering, shipping, settlement of products or services, and product quality) (*)
• Planning, research and development and quality improvement of products and services, and questionnaire surveys related thereto
• Web marketing (*)
• Management of transactions, contractual relationships, etc.
• Exercise of rights and performance of obligations under contracts and laws
• Communication and provision to marketing authorization holders, manufacturers, distributors, etc.
• Advertisement and provision of information on products, services, campaigns, etc. by invitation letters, e-mail, etc.

(* Includes use by analyzing browsing history, etc.)

(2) Personal information of shareholders

(i) Items

Name, gender, e-mail address, telephone number, facsimile number, region/country where the person is located, address, date of birth, number and type of shares held, date of acquisition, account information and other information necessary for the purpose of use set forth below.

(ii) Purpose of use

• Management of shareholders under laws and regulations
• Exercise of rights and performance of obligations under laws and regulations, and handling of matters related thereto
• Handling of various inquiries and requests
• Questionnaire surveys on matters relating to the establishment of relationships with shareholders, and decisions on and implementation of various policies

(3) Personal information of corporate business partners and potential business partners

(i) Items

Name, gender, place of employment, position, department to which the person belongs, e-mail address, telephone number, facsimile number, region/country where the person is located, address, date of birth, details of the inquiry, account information and any other information necessary for the purpose of use set forth below.

(ii) Purpose of use

• Management of transactions, contractual relationships, and claims and obligations
• Business activities (meetings, consultations, studies, etc.)
• Provision of information on seminars, exhibitions, etc.
• Planning, research and development and quality improvement of products and services, and questionnaire surveys related thereto
• Provision and collection of information on the proper use of products and services, etc.
• Provision and collection of information on the quality, safety or efficacy of products and services, etc.
• Web marketing
• Provision, collection and examination of medical and academic information, etc.
• Communication and provision to marketing authorization holders, manufacturers, distributors and related parties
• Exercise of rights and performance of obligations under contracts and laws and regulations, and handling of matters related thereto

(4) Personal information of medical personnel such as physicians and pharmacists, researchers, and participants in clinical studies, etc.

(i) Items

Name, gender, place of employment, position, department to which the person belongs, e-mail address, telephone number, facsimile number, region/country where the person is located, address, date of birth, medical history, medical condition and other information necessary for the purpose of use set forth below.

(ii) Purpose of use

• Acquisition of licenses and approvals, including regulatory applications and approvals in each country
• Research, survey and provision of information in the field of pharmaceuticals and medical devices, etc. (including quality and effectiveness)
• Filing of notifications or reports to relevant authorities, such as governmental agencies and organizations

(5) Personal information of applicants for internships/employment of the Denka Group, and school officials

(i) Items

Name, gender, place of employment, position, department to which the person belongs, employment history, personal history, face photo, e-mail address, telephone number, facsimile number, region/country where the person is located, address, date of birth, result of medical examination and other information necessary for the purpose of use set forth below.

(ii) Purpose of use

• Implementation of internship
• Provision of information and communication to applicants, selection and implementation of other recruitment activities
• Communication to the person in question or his/her family member in case of emergency

(6) Personal information of Denka Group executives, employees, family members of employees and retirees

(i) Items

Name, gender, place of employment, position, department to which the person belongs, employment history, personal history, photo (including face photo), e-mail address, telephone number, facsimile number, region/country where the person is located, address, date of birth, account information, personnel evaluation information, result of medical examination, personality analysis and other information necessary for the purpose of use set forth below.

(ii) Purpose of use

• Performance of obligations prescribed in personnel and labor management, other labor-related laws and regulations, tax-related laws and regulations, and social welfare-related laws and regulations
• Operation, registration, management and use of internal systems
• Communications and distribution of internal newsletters, etc. to labor unions, health insurance societies, corporate pension funds, stockholding associations, life insurance and non-life insurance companies, Denka Group companies, etc., and communication and distribution of materials related to activities of company-affiliated associations (alumni associations), etc.
• Communication to the person in question or his/her family member in case of emergency
• Examination, effect analysis and improvement of health management and health promotion policies
• Health management of employees
• Risk assessment (including epidemiological studies), examination of policies, impact analysis and research on the working environment
• Implementation of procedures for health insurance, etc. of retirees
• Implementation of procedures for payment of retirement allowance and pension
• Implementation of internal awareness surveys and questionnaires
• Implementation of internal education (including e-learning)

(1) Formulation of basic policy

Each Denka Group company has established this policy as a basic policy on the protection of personal information.

(2) Development of rules

In order to securely manage personal information, each Denka Group company has established rules concerning the acquisition, use, etc. of personal information and require all employees to comply with them.

(3) Organizational security control measures

Each Denka Group company has appointed a person in charge of the management of personal information to ensure that personal information is properly managed, including access restrictions. In addition, all employees are required to report to the company to which the employees belong any violation of the handling of personal information. Furthermore, in the event of a serious incident involving personal information, such as a leak, a special committee shall be established to deal with it. Moreover, each Denka Group company conducts an internal audit to ensure appropriate management of personal information by, for example, storing access logs for ex-post monitoring as necessary.

(4) Personnel security management measures

Each Denka Group company provides internal education on the handling of personal information.

(5) Physical security control measures

Each Denka Group company requires all employees to properly manage personal information and devices and electronic media containing personal information, and in the case of disposal, to dispose of them to an unrecoverable extent.

(6) Technical security control measures

In order to appropriately manage personal information, Each Denka Group company restricts access to personal information databases, etc. In addition, reasonable and appropriate security measures have been introduced to prevent unauthorized external access to and loss, damage, destruction, alteration, leakage and unauthorized outflow of personal information. Further, electromagnetic records containing personal information are protected by passwords, etc. as necessary.

(7) Understanding of the external environment

When handling personal information in a foreign country, each Denka Group company takes security control measures based on an understanding of the system for protecting personal information in that country.

(8) Other security control systems

In order to facilitate business operations, each Denka Group company may outsource all or part of their operations to third parties and provide personal information to such third parties to the extent necessary. In this case, each Denka Group company shall appropriately supervise such third parties by, for example, entering into agreements concerning the handling of personal information with such third parties.

In order to fulfill the purposes listed in (ii) of (1) through (6) in “2. Type and purpose of use of personal information” above, the Denka Group companies may provide personal information to a third party regarding the types of personal information listed in (i), (a) upon obtaining the prior consent of the person in question, and/or (b) if permitted by applicable personal information protection laws of each country. This includes, but is not limited to, the following cases. For the provision of personal information to a third party on the grounds of shared use under Japan's Act on the Protection of Personal Information, please refer to "5. Joint use of personal information" below.

• Provision to a Denka Group company for joint use
• In case Denka shares or discloses personal information of the employees of Denka to a Denka Group company (excluding Denka) in connection with the secondment of such employees.
• Other cases required by laws and regulations.

Denka Group companies may share personal information within Denka Group on the grounds of joint use under Japan's Act on the Protection of Personal Information. However, if it is necessary to the obtain consent of the person in question under applicable personal information protection regulations other than Japan's Act of Protection of Personal Information, such consent shall be obtained.

[Items of personal information for joint use]

Name, gender, place of employment, position, department to which the person belongs, address, date of birth, personal history, result of medical examination, telephone number, e-mail address, facsimile number, history of buying activities of products and services, browsing history of HP, etc., history of activities and attribute information obtained from HP, information on medical history and symptoms of participants in clinical trials, etc.:

[Extent of persons to be jointly used]

Denka Group companies
[Please refer to the following link for information on the major companies of the Denka Group.]

https://www.denka.co.jp/corporate/group/

[Purpose of use]

Same as the purpose of use stated in "2. Purpose of use of personal information" of this policy

[Person Responsible for the management of personal information]

Denka Company Limited
Address: Nihonbashi Mitsui Tower, 2-1-1 Nihonbashi Muromachi, Chuo-ku, Tokyo
Ikuo Ishida, Representative Director, President & CEO

Denka Group companies shall retain collected personal information for the period necessary to handle such personal information. However, this shall not apply in cases where laws or regulations require the retention of personal information for a longer period of time. In this case, each Denka Group company shall retain such personal information for the period prescribed by laws and regulations.

A person has several legal rights to his/her personal information held by a Denka Group company. For example, the person has the following rights, to the extent permitted by applicable national laws and regulations on protection of personal information:

• Right to access personal information
• Right to request correction of personal information
• Right to request deletion of personal information
• Right to request restrictions on the handling of personal information
• Right to object to the handling of personal information
• Right to withdraw consent to the processing of personal information
• Data portability rights
• Rights not to be subject to automated decision making

The person may file a complaint with a Denka Group company or a supervisory body regarding the protection of personal information.
If you wish to exercise the rights related to the handling of personal information at a Denka Group company, please submit a request to the relevant department of the Denka Group company in writing or through an inquiry form on the website so that your request is accurately understood. The relevant department will provide information on procedures and costs.
If you have any questions, please contact the following.

Denka Company Limited
General Affairs Department
Address: Nihonbashi Mitsui Tower, 2-1-1 Nihonbashi Muromachi, Chuo-ku, Tokyo, 103-8338
Phone: 03-5290-5055
FAX: 03-5290-5059
Inquiry form (URL): https://www.denka.co.jp/contact/form