EEA and UK PRIVACY POLICY
1. About This Policy
This policy applies to you (a) if you interact with Sumitomo Electric Industries, Ltd. (“SEI”)
and you are based in the European Economic Area (“EEA”) or the UK or (b) if you interact
with SEI’s affiliates and related entities (listed in, but not limited to, the following link,“Group Companies”) based in the EEA or the UK or (c) if EEA or UK data protection law
otherwise applies.
This policy, which should be read together with our Global Privacy Policy, describes how wewill make use of your data when you interact with us and our websites, and when you receive
communications from us or otherwise communicate with us, when your organisation is ourbusiness partner, and when you apply to us. The list of relevant data controllers and theircontact details can be found in the “Contact Us” section. A reference to “we,” or “us” is areference to SEI and Group Companies involved in the processing of personal data.
In some cases, we may provide additional privacy policies specific to certain products,
services and areas. Those specific privacy policies shall supersede this policy to the extent
that the clauses set forth in those policies contradict the clauses set forth in this policy.
This policy also describes your data protection rights, including the right to object to some ofthe processing which we carry out. More information about your rights, and how to exercise
them, is set out in the “Your Rights” section.

2. Summary of How We Use Your Data

We use your personal data for the purposes described in this policy, such as thepromotion, sale and supply of our products and services, the management of ourrelationship with you, and recruitment.

Data is shared with our Group Companies for administrative purposes and for uses
described in this policy. We may also share your personal data with our service
providers, such as internet service providers, web analytics service providers, cloudservice providers, software venders, sales statistic analytics service providers,
recruitment or employment agencies, professional advisors, or consultants. We may
share your personal data with potential partners in the event of merger andacquisition, legal or regulatory authorities.



Due to the global nature of our business, your personal data will be disclosed toGroup Companies outside of the EEA and the UK including, in particular, to Japan asa Japanese headquartered company. The European Commission and UK government
have determined that Japan offers an adequate level of protection – you can find out
more in the adequacy decision(s) here and here. We rely on these decisions for EEAJapan and UK-Japan transfers.



Where we rely on your consent, you can withdraw this consent at any time.

13. Personal Data Obtained by Us
We collect and process personal data about you when you interact with us and our websites,
and when you receive communications from us or otherwise communicate with us, whenyour organisation is our business partner and we deal with you in that capacity, and if you
apply to us. This includes:


Identity and Contact DataName, age, date of birth, gender, occupation, address, country of residence, and otherinformation related to contact details, such as phone number, email address, and social
media accounts;



Products and Services Data
Information related to products and services your organisation has purchased;Communications Data
Details regarding your opinions, requests, inquiries, survey responses and the otherinformation you provided;Technical Data
Technical data including access data, Internet protocol (IP) address, your login data,browser type and version, time zone setting and location, browser plug-in types andversions, operating system and platform and other technology on the devices you use
to access this website;Usage Data
Information about how you use our website, products and services;

Marketing DataYour preferences in receiving marketing from us and the third parties engaged by us
and your communication preferences; and

Application-related Information
Information relating to experience, education and right to work checks if you apply towork for us.

We will not obtain or use sensitive information that reveals your data concerning health,genetic data, data concerning sexual orientation, or the like, unless provided for in laws andordinances or you consent to us doing so.

2

You may be required to provide us with certain data because the provision of personal data isrequired by statute or contract, or is a necessary to enter into a contract with us. In this case, if
you do not provide your personal data, we may not be able to provide you with our service.

4. How We Collect Your Personal Data
We may obtain the personal data described above both directly from you and through third
parties, such as contractors, business partners, and social media providers (including Facebook
and Google). More specifically, we collect and process the following personal data about you
from each of these sources:
1. Information you give us.
This includes information about you that you give us through inquiry forms on our
website, or by communicating with us, whether by email, letter or otherwise. The
information you give us is likely to include your contact information such as yourname, address, email address, phone number.
2. Information third parties give us.
This includes information about you that third parties give us through inquiry forms
on our website, or by communicating with us, whether by email, letter or otherwise. If
you apply to us, we may collect application-related information from third parties
including referees and people we interview with. If your organisation is our business
partner, we may also collect your personal information from your organisation. The
information third parties give us is likely to include your contact information such as
your name, address, email address, phone number.
3. Information we collect automatically from you.
When you visit our website, the website automatically collects certain types of data
related to you. These types of data include access logs, web beacons (also known as
pixels), cookies, etc. These types of data may remain in your computer and continue
to collect data.
We also may collect, use and share aggregated data such as statistical or demographic data
for any purpose. Aggregated data may be derived from your personal data but is notconsidered personal data in law as this data does not directly or indirectly reveal youridentity. For example, we may aggregate your usage data to calculate the percentage of users
accessing a specific website feature. However, if we combine or connect aggregated datawith your personal data so that it can directly or indirectly identify you, we treat the
combined data as personal data which will be used in accordance with this policy.

35. Purpose of Processing Personal Data and Legal Basis
We may only use your personal data for the purposes and legal bases set out below:

Purpose/Activity
To register business contact
information

Type of data(a) Identity and Contact

To operate, develop or improve our (a) Identity and Contact
products, services and websites.
(b) Products and Services(c) Communications(d) Technical(e) Usage(f) Marketing
To process and deliver your(a) Identity and Contact
organisation’s order including:(b) Products and Services(a) Manage payments, fees and(c) Communications
charges(d) Marketing(b) Collect and recover money
owed to us
To manage our relationship with(a) Identity and Contact
you which will include:(b) Products and Services(a) Notifying you about changes to (c) Communications
our terms or privacy policy(d) Marketing(b) Asking you to leave a review ortake a survey
To enable you to partake in a prize (a) Identity and Contact
draw, competition or complete a(b) Products and Services
survey(c) Usage(d) Communications(e) Marketing
To administer and protect our(a) Identity and Contact
business and this website(b) Technical(including troubleshooting, data(d) Usage
analysis, testing, system
maintenance, support, reportingand hosting of data)

To deliver relevant website content (a) Identity and Contact
and advertisements to you and(b) Products and Services
measure or understand the(c) Communications(d) Technical4

Lawful basis for processing
Necessary for our legitimate interests(to manage our relationship with youor your organisation and keep ourrecords updated)
Necessary for our legitimate interests(to fulfil our contract with a business
partner; to operate, develop or
improve our products, services andwebsites to meet the needs of ourbusiness partners)
Necessary for our legitimate interests(to fulfil our contract with a business
partner; to develop our relationshipwith the business partner; and to
recover debts due to us)(a) Necessary to comply with a legal
obligation (such as data protection
laws, tax laws and similar obligations)(b) Necessary for our legitimate
interests (to keep our records updated
and to study how customers use our
products/services)(a) Necessary for our legitimate
interests (to study how customers use
our products/services, to develop
them and grow our business)(a) Necessary for our legitimate
interests (for running our business,
provision of administration and IT
services, network security, to prevent
fraud and in the context of a businessreorganisation or group restructuring
exercise)(b) Necessary to comply with a legal
obligation (such as data protection
and similar obligations)
Necessary for our legitimate interests(to study how customers use our
products/services, to develop them, toeffectiveness of the advertising we (e) Usage
serve to you(f) Marketinggrow our business and to inform ourmarketing strategy)

To use data analytics to improve
our website, products/services,marketing, customer relationships
and experiences(a) Technical(b) Usage

To make suggestions andrecommendations to you about
goods or services that may be ofinterest to you(a) Identity and Contact(b) Products and Services(c) Communications(d) Technical(e) Usage(f) Marketing

Necessary for our legitimate interests(to define types of customers for our
products and services, to keep our
website updated and relevant, todevelop our business and to inform
our marketing strategy)
Necessary for our legitimate interests(to develop our products/services andgrow our business)

To provide employment(a) Identity and Contact
Necessary for our legitimate interests
information to applicants and(b) Communications(to ensure we recruit possible
communication with them about(c) Application-related
candidates.)
selection procedures, either directly Informationor through their universities or
employment agencies
To consider whether or not to hire (a) Identity and Contact
Necessary for our legitimate interests
the applicants and to manage(b) Communications(to ensure we recruit possible
applicants who have been offered (c) Application-related
candidates.)
employment, and to perform other Information
procedures related to applicants for
employment
To prevent and respond to fraud,(a) Identity and Contact, (b) Necessary for our legitimate interests
violation of relevant policies and Products and Services,(to prevent fraud and protect ourrules, threats, and damage(c) Technicalbusiness interests and rights, or that of(d) Usage
individuals and the public.)

6. Disclosure of Personal Data to Recipient
Personal data will primarily be processed by employees in our website team, businessdepartments, IT and finance departments and our HR team if you apply to us.
We may disclose your personal data to the recipients described as follows.
1. Group Companies (affiliates and related entities of SEI listed in, but not limited to,the following link). We share your personal data with our Group Companies globallyfor internal administrative purposes and for uses that are consistent with this policy.
Particularly, we share your contact information such as addresses, names, yourcompany names, phone numbers, email addresses, or comments on the inquiry form
with our Group Companies. Those Group Companies will use the personal data to (i)provide products or services that you requested the company to deliver to you, (ii)
improve our products or service, (iii) promote our products or services, marketing5

events and campaigns, or conduct marketing surveys and analysis, and (iv) develop
new products or services. SEI is responsible for management of the personal data
shared with the Group Companies.
2. Service Providers. We may share your personal data with service providers, such as
internet service providers, web analytics service providers, cloud service providers,software venders, sales statistic analytics service providers, recruitment or
employment agencies, professional advisors, or consultants.
3. Others. We may share your personal data with potential partners of merger andacquisition, or legal or regulatory authorities.
Personal data may be shared with government authorities and/or law enforcement officials if
required for the purposes above, if mandated by law or if required for the legal protection of
our legitimate interests in compliance with applicable laws.
Please see the relevant personal data categories below:
RecipientGroup Companies

Service Providers

Others (potential partners ofmerger and acquisition, or
legal or regulatory
authorities)

Category(a) Identity and Contact(b) Products and Services(c) Communications(d) Technical(e) Usage(f) Marketing(g) Application-related Information(a) Identity and Contact(b) Communications(c) Technical(d) Usage(e) Marketing(a) Identity and Contact(b) Products and Services(c) Communications(d) Technical(e) Usage(f) Marketing(g) Application-related Information

7. Cross-Border Transfers
Due to the global nature of our business, your personal data will be disclosed to Group
Companies outside of the EEA and the UK including, in particular, to Japan as a Japaneseheadquartered company. The European Commission and UK government have determined thatJapan offers an adequate level of protection – you can find out more in the adequacy decision(s)here and here. We rely on these decisions for EEA-Japan and UK-Japan transfers.
We also transfer your personal data to some third parties which host or access personal data
outside of the EEA and UK. Where these locations do not provide an adequate level of dataprotection, we ensure appropriate safeguards are in place to protect the transfer of your personal6

data to these countries. Some of these countries are subject to a European Commission
adequacy decision. For other countries, we have put in place European Commission-approved
standard contractual clauses within group companies or with the relevant third party to protect
this personal data. We also rely on other permitted data transfer mechanisms such as relying
on the relevant third-party corporate rules (approved by EU data protection authorities and put
in place to protect your personal data).
A copy of the relevant mechanism can be obtained for your review on request by using thecontact details below.

8. Storage Limit for Personal Data
Unless indicated otherwise, we will retain the personal data that we collect about you for theperiod necessary to process such personal data. To determine the appropriate retention period
for personal data, we consider the amount, nature and sensitivity of the personal data, thepotential risk of harm from unauthorized use or disclosure of your personal data, the purposes
for which we process your personal data and whether we can achieve these purposes throughother means, and the applicable legal requirement.
Generally, we will keep data for a period of [6] years from the point at which it is no longer
required, unless there are relevant legal proceedings for which the data is reasonably
required. After this period, we will take steps to delete your personal data or hold it in a form
that no longer identifies you.

9. Your Rights
You have a number of legal rights in relation to the personal data that we hold about you.
These rights include:
1.
2.
3.
4.
5.

6.
7.

the right to obtain information regarding the processing of your personal data and accessto the personal data which we hold about you;the right to request that we rectify your personal data if it is inaccurate or incomplete;
the right to request that we delete your personal data;
the right to obtain the personal data you provide in a structured, machine-readable format
the right to object to the processing of your personal data in some circumstances (inparticular, where we don’t have to process the data to meet a contractual or other legal
requirement);
the right to object to us about our processing of your personal data;
the right to withdraw your consent to our processing of your personal data. (This rightonly exists where we are relying on consent to process your personal data. Withdrawal ofconsent will not affect the lawfulness of processing based on consent before its
withdrawal.)

You can exercise your rights by contacting us at the contact details set out in the “Contact us”
section. Also, please note that you may need to submit additional information to us to verify
your identity before we process your request.

7

These rights may be limited, for example if fulfilling your request would reveal personal data
about another person, or if you ask us to delete information which we are required by law or
have compelling legitimate interests to keep.
In some cases, we are able to send you direct marketing without your consent, where we rely
on our legitimate interests. You have an absolute right to opt-out of direct marketing, or
profiling we carry out for direct marketing, at any time. You can do this by following the
instructions in the communication where this is an electronic message, or by contacting ususing the details set out below.
If you have unresolved concerns, you have the right to complain to a data protection authority
in the country where you live, work, or where you believe a breach has occurred.

10. Changes to this Privacy Policy
We may modify this policy from time to time and will post the updated policy with a “Last
Updated” effective date for the revisions. We recommend that you review this policy
periodically. We will provide you with a new privacy notice when we make any substantial
updates. We may also notify you in other ways from time to time about the processing of yourpersonal data.

11. Contact usYour information is controlled by SEI and Group Companies. The list of relevant data
controllers and their contact details can be found in a table below.
If you have questions about this privacy notice or wish to contact us for any reason in relation
to our personal data processing, please contact us at the contact details below.

8Data Controller

Contact Details

If you (a) apply to, (b) provide your services to, or purchase products and services
from, (c) visit the web site of, the following companies or their subsidiaries/branches,that company will be the data controller of your personal data.
Automotive Products
SEI Automotive Europe GmbH

Gustav-Stresemann-Ring 1, 65189
Wiesbaden, Germany
Phone: +49 (0) 611-1677-1800
Data Protection Officer:
Hans Schloemer
Email: dataprotection@sei-ae.com

SEWS-Cabind SpA

Corso Pastrengo 40, 10093 Collegno(TO), Italy
Phone: +(39)-011-4010611

Sumitomo Electric Bordnetze SE

Brandgehaege 11 38444 WolfsburgHattorf, Germany
Phone: +(49)-5308-400-400
Data Protection Officer:
Felix Barth
Email:
datenschutzbeauftragter@sebn.com

Sumitomo Electric Wiring Systems(Europe) Ltd.

Prospect House, Cemetery Road,
Silverdale Newcastle-under-Lyme
Staffordshire ST5 6PA, U.K.
Phone: +(44)-1782-664700

Industrial Material
Sumitomo Electric Hardmetal Ltd.

3 Paper Mill Drive, Redditch,
Worcestershire, B98 8QJ, U.K.
Phone +(44)-18-4434-2081

Sumitomo Electric Hartmetall GmbH

Konrad-Zuse-Str. 9, 47877 Willich,
Germany
Phone: +(49)-2154-4992-0
Data Protection Officer:
Hans Schloemer
Email: dataprotection@sei-ae.com

9Sumitomo Electric HartmetallfabrikGmbH

Industriestrasse 2, 73466 Lauchheim,
Germany
Phone: +49 (7363) 87-86
Data Protection Officer:
GS Management Systeme
Email: gerald.saur@gsmanagement.deSinterwerke Herne GmbHForellstraße 100,44629 Herne, Germany
Phone: +49 (0) 2323 201-0
Data Protection Officer:
Brands Consulting
Email: info@sinterwerke.com

Sinterwerke Grenchen AG

Neckarsulmstrasse 20,2540 Grenchen, Switzerland
Phone: +41 (0) 32 655 6868
Data Protection Officer:
Email: info@sinterwerke.com

Sumitomo Electric Sintered
Components (Germany) GmbH

Dischinger Str. 1,
02763 Mittelherwigsdorf, Germany
Phone: +(49)-3583-51840

Electronic Products
Sumitomo Electric Europe Ltd.

Unit 220, Centennial Park, Elstree,
Hertfordshire, WD6 3SL, U.K.
Phone: +(44)-208-953-8118

Sumitomo Electric SchrumpfProdukte GmbH

Oststrasse 89,22844 Norderstedt, Germany
Phone: +(49)-40-5265010
Data Protection Officer:
Hans Schloemer
Email: dataprotection@sei-ae.com

SEI Identification Solutions Ltd.

Pysons Road Industrial Estate,
Broadstairs, Kent CT10 2LQ, U.K.
Phone: +(44)-1792-487-290

10

SEI Interconnect Products (Europe)
Ltd.

Axis 10 Axis Court, Mallard Way

SEI Interconnect Products (Hungary),
Kft.

5142, Alattyán, Jászapáti út 1, Hungary

Heinrich Thulesius GmbH & Co. KG

Zum Panrepel 15,

Swansea SA7 0AJ, U.K.
Phone: +(44)-1792-487-290

Phone: +(36)-57-561-200

28307 Bremen, Germany
Phone: +49 (0) 421 / 4895-0
Finance and Legal Services
Sumitomo Electric Finance U.K. Ltd.

Octagon Point, St Paul's, 5 Cheapside,
London, EC2V 6AA
Phone: +(44)-20-7073-7800

For all other processing in the context of SEI's products and services:
Sumitomo Electric Industries, Ltd.

4-5-33, Kitahama, Chuo-ku, Osaka, Japan
Inquiry Form: please click here.

Effective date: 14 April 2023
Last updated: 12 June 2023

11