SOJITZ MACHINERY CORPORATION PRIVACY NOTICETABLE OF CONTENTS
1.

PERSONAL INFORMATION WE USE
1.1

Information we collect directly from you

1.2

Information we collect from other sources

1.3

Special categories of Personal Information

2.

PURPOSES AND LEGAL BASIS OF OUR USE OF YOUR PERSONAL INFORMATION

3.

YOUR RIGHTS OVER YOUR PERSONAL INFORMATION

4.

INFORMATION SHARING

5.

INFORMATION SECURITY AND STORAGE

6.

INTERNATIONAL DATA TRANSFER

7.

CONTACT US

8.

CHANGES TO THIS PRIVACY NOTICEThis privacy notice describes how SOJITZ MACHINERY CORPORATION ('Sojitz', 'we' or 'us')
collects and processes personal information about an individual in the European Economic Area(‘Personal Information’), how we use and protect your Personal Information, and your rights inrelation to your Personal Information.
This privacy notice applies to all Personal Information we collect or process about you. Personal
Information is information, or a combination of pieces of information that could reasonably allow
you to be identified.
1.

PERSONAL INFORMATION WE USE

We will collect Personal Information about you from a variety of sources. We may collect yourPersonal Information from you directly (e.g. when you contact us) or from other sources such as
public registrars, credit research agencies, recruiting agencies, employment screening agencies.
1.1

Information we collect directly from you

The categories of information that we collect directly from you are:(a)personal details (e.g. name, date of birth)(b)contact details (e.g. phone or mobile number, email address, postal address)(c)

educational details (e.g. educational history, qualifications, certifications, skills)(d)citizenship or immigration information(e)professional experience(f)

any other information you may choose to provide us in your dealings with us.

We may be required by law or as a consequence of any contractual relationship we have with you
to collect certain Personal Information from you. In such case, your failure to provide theinformation may prevent or delay the fulfilment of our obligations under the law or the contract.
11.2

Information we collect from other sources:

The categories of information that we collect about you from other sources are:

1.3

(a)

personal details (e.g. name, date of birth)(b)contact details (e.g. phone number, email address, postal address or mobilenumber)(c)background check information(d)publicly available professional profiles on websites or social media (e.g. LinkedIn)(e)information about your creditability or reputation

Special categories of Personal Information

Some of the categories of information that we collect are special categories of Personal
Information (also known as sensitive personal information). In particular, we may process
Personal Information that may reveal your racial or ethnic origin, religion or that may relate toyour health, such as your medical history and reports on medical diagnoses, injuries andtreatment.
We collect such kind of Personal Information only when you give us an explicit consent or as
permitted or required by law.
2.

PURPOSES AND LEGAL BASIS OF OUR USE OF YOUR PERSONAL INFORMATION

2.1

We use your Personal Information to:

2.2

(a)

perform and enforce any contractual obligation under a contract with us(b)provide and personalise our services(c)deal with your enquiries and requests(d)comply with legal obligations to which we are subject and cooperate withregulators and law enforcement bodies(e)contact you with marketing and offers relating to products and services offered by
us and/or other members of Sojitz Group Companies (defined in section 4)(unless you have opted out of marketing, or we are otherwise prevented by law
from doing so)(f)personalise the marketing messages we send you to make them more relevant
and interesting

We must have a legal basis to process your Personal Information. In most cases the legal
basis will be one of the following:(a)to fulfil our contractual obligations to you, for example to provide the services, toensure that invoices are paid correctly, and to ensure you are able to access ourpremises when required
23.

(b)

to fulfil our contractual obligations to you, for example your contact details andbank account details(c)to comply with our legal obligations, for example obtaining proof of your identity toenable us to meet our anti-money laundering obligations(d)to comply with our legal obligations to you, for example health and safety
obligations while you are on our premises or to a third party (e.g. the taxation
authorities)(e)to meet our legitimate interests, for example screening your background for anticorruption purpose or to understand how you use our services or products and toenable us to derive knowledge from that enable us to develop new services or
products. When we process Personal Information to meet our legitimate interests,
we put in place robust safeguards to ensure that your privacy is protected and toensure that our legitimate interests are not overridden by your interests or
fundamental rights and freedoms(f)to protect your or another person’s vital interests, for example by providing yourhealth information to a doctor in case of a medical emergency situation.

(g)when you gave us consent to the processing of your Personal Information for thespecific purposes (When the legal basis to process your Personal Information isbased on your consent, you may withdraw your consent at any time by contacting
us using the details at the end of this privacy notice.)

YOUR RIGHTS OVER YOUR PERSONAL INFORMATION

You have certain rights regarding your Personal Information, subject to local law. These include
the following rights to:access your Personal Information

rectify your Personal Information

erase your Personal Information

restrict our use of your Personal Information

object to our use of your Personal Information



receive your Personal Information in a usable electronic format and transmit it to a thirdparty (right to data portability)withdraw your consent where our processing is based on your consent

lodge a complaint with your local data protection authority.

We encourage you to contact us to update or correct your information if it changes or if the
Personal Information we hold about you is inaccurate.
We will contact you if we need additional information from you in order to honour your requests.
If you would like to discuss or exercise such rights, please contact us at the details below.
3

4.

INFORMATION SHARING

We may share your Personal Information with third parties under the following circumstances:
Service providers and business partners. We may share your Personal Information with
our service providers and business partners that perform marketing services and otherbusiness operations for us. For example, we may partner with other companies toprocess secure payments, fulfil orders, optimize our services, send newsletters andmarketing emails, support email and messaging services and analyse information.

Our group companies. We work closely with other businesses and companies that fallunder Sojitz Corporation (1-1, Uchisaiwaicho 2-chome, Chiyoda-ku, Tokyo 100-8691,Japan) (‘Sojitz Group Companies’). We may share your Personal Information with Sojitz
Group Companies for marketing purposes or anti-corruption compliance purposes.

Law enforcement agency, court, regulator, government authority or other third party. We
may share your Personal Information with these parties where we believe this isnecessary to comply with a legal or regulatory obligation, or otherwise to protect our rights
or the rights of any third party.

Asset purchasers. We may share your Personal Information with any third party thatpurchases, or to which we transfer, all or substantially all of our assets and business.
Should such a sale or transfer occur, we will use reasonable efforts to try to ensure thatthe entity to which we transfer your Personal Information uses it in a manner that is
consistent with this privacy notice.

Because we operate business globally, the recipients referred to above may be located outsidethe jurisdiction in which you are located (or in which we provide the services). See section 6(International Data Transfer) for more information.
5.

INFORMATION SECURITY AND STORAGE

We implement reasonable technical and organisational measures to ensure a level of security
appropriate to the risk to the Personal Information we process. These measures are aimed atensuring the on-going integrity and confidentiality of Personal Information. We evaluate thesemeasures on a regular basis to ensure the security of the processing.
We will keep your Personal Information for as long as we have a relationship with you. Once ourrelationship with you has come to an end, we will retain your Personal Information for a period oftime that that in our opinion will enable us to:Maintain business records for analysis and/or audit purposesComply with record retention requirements under the law or under applicable record
retention policies



Defend or bring any existing or potential legal claims



Deal with any complaints regarding the services, to the extent it is reasonably possible forus

We will delete your Personal Information when it is no longer required for these purposes. If thereis any information that we are unable, for technical reasons, to delete entirely from our systems,
we will put in place appropriate measures to prevent any further processing or use of the data.
46.

INTERNATIONAL DATA TRANSFERYour Personal Information may be transferred to, stored, and processed in a country that is notregarded as ensuring an adequate level of protection for personal information by the European
Commission.
We have and shall put in place appropriate safeguards (such as contractual commitments) inaccordance with applicable legal requirements to ensure that your personal information isadequately protected. For more information on the appropriate safeguards in place, pleasecontact us at the details below.
7.

CONTACT US

SOJITZ MACHINERY CORPORATION (6-1, Marunouchi 1-chome, Chiyoda-ku, Tokyo 100-0005,Japan) is the controller responsible for your Personal Information we collect and process.
If you have questions or concerns regarding the way in which your personal information has been
used, please contact web-info@sojitz-mac.com.
We are committed to working with you to obtain a fair resolution of any complaint or concern
about privacy. If, however, you believe that we have not been able to assist with your complaint
or concern, you have the right to make a complaint to the data protection authority in your country.
8.

CHANGES TO THIS PRIVACY NOTICE

We may modify or update this privacy notice from time to time.
If we change this privacy notice, we will notify you of the changes. Where changes to this privacy
notice will have a fundamental impact on the nature of the processing or otherwise have asubstantial impact on you, we will give you sufficient advance notice so that you have theopportunity to exercise your rights.

20 February 20195