Introduction
Welcome to ENPLAS CORPORATION GROUP's privacy notice.
ENPLAS CORPORATION GROUP respects your privacy and is committed toprotecting your personal data. This privacy notice will inform you as to how we lookafter your personal data when we deal with you, including visiting our website, and tell
you about your privacy rights and how the law protects you.
1.

Important information and who we are
Purpose of this privacy noticeThis privacy notice aims to give you information on how ENPLAS CORPORATIONGROUP collects and processes your personal data through your use of this website,
including any data you may provide through this website.
This website is not intended for children and we do not knowingly collect data relating
to children.
It is important that you read this privacy notice together with any other privacy noticeor fair processing notice we may provide on specific occasions when we are collecting
or processing personal data about you so that you are fully aware of how and why weare using your data. This privacy notice supplements the other notices and is notintended to override them.
Controller
ENPLAS CORPORATION GROUP is made up of different legal entities, details of
which can be found here https://www.enplas.co.jp/english/company/network/. This
privacy notice is issued on behalf of ENPLAS CORPORATION GROUP so when we
mention "Enplas Corporation", "we", "us" or "our" in this privacy notice, we arereferring to the relevant Company in ENPLAS CORPORATION GROUP responsible
for processing your data. We will let you know which entity will be the controller foryour data when you purchase a product or service with us. Enplas Corporation is thecontroller and responsible for this website.
We have appointed a data privacy manager who is responsible for overseeing questions
in relation to this privacy notice. If you have any questions about this privacy notice,including any requests to exercise your legal rights (please see below), please contact
the department for data privacy administration set out below.
Contact details
Our full details are:Full name of Company: Enplas Corporation
Department for data privacy administration: Legal department
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Email address: legal-dept@enplas.com
Postal address: Shin-Marunouchi Center Bldg.9F 1-6-2 Marunouchi, Chiyoda-ku,
Tokyo 100-0005, JapanYou have the right to make a complaint at any time to the relevant supervisory authority
for data protection issues in the territory in which you are located. We would, however,appreciate the chance to deal with your concerns before you approach the relevantsupervisory authority so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 16th February 2024.
It is important that the personal data we hold about you is accurate and current. Pleasekeep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications.
Clicking on those links or enabling those connections may allow third parties to collector share data about you. We do not control these third-party websites and are notresponsible for their privacy statements. When you leave our website, we encourage you
to read the privacy notice of every website you visit.
2.

The data we collect about you
Personal data, or personal information, means any information about an individual fromwhich that person can be identified. It does not include data where the identity has been
removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which
we have grouped together follows:• Identity Data includes first name and last name• Contact Data includes email address and telephone numbers.
• Transaction Data includes details about payments to and from you and other detailsof products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser
type and version, time zone setting and location, browser plug-in types and versions,operating system and platform and other technology on the devices you use to accessthis website.
• Usage Data includes information about how you use our website, products andservices (including cookies).
2• Marketing and Communications Data includes your preferences in receiving
marketing from us and our third parties and your communication preferences.
We also 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 Data with 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 withthis privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes
details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual
orientation, political opinions, trade union membership, information about your healthand genetic and biometric data). Nor do we collect any information about criminal
convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we havewith you and you fail to provide that data when requested, we may not be able to performthe contract we have or are trying to enter into with you (for example, to provide youwith goods or services). In this case, we may have to cancel a product or service you
have with us but we will notify you if this is the case at the time.
3.

How is your personal data collected?
We use different methods to collect data from and about you including through:• Direct interactions. You may give us your Identity and Contact Data by filling informs or by corresponding with us by post, phone, email or otherwise. This includes
personal data you provide when you:• apply for our products or services;• subscribe to our service or publications;• request marketing to be sent to you;• enter a competition, promotion or survey; or• give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may
automatically collect Technical Data and cookies about your equipment, browsing
actions and patterns. We collect this personal data by using server logs and othersimilar technologies.
• Third parties or publicly available sources. We may receive personal data about
you from various third parties as set out below:• Technical Data and cookies from the following parties:3

(a) analytics providers such as Google;(b) advertising networks; and(c) search information providers.
• Contact Data from providers of technical and delivery services.
• Identity and Contact Data from data brokers or aggregators.
• Identity and Contact Data from publicly availably sources.
4.

How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we
will use your personal data in the following circumstances:
Performance of Contract Where we need to process your data for the performance ofa contract to which you are a party or to take steps at your request before entering intosuch a contract.
In our Legitimate Interest Where it is necessary for our legitimate interests (or thoseof a third party) and your interests and fundamental rights do not override those interests.
This means the interest of our business in conducting and managing our business toenable us to give you the best service/product and the best and most secure experience.
We make sure we consider and balance any potential impact on you (both positive andnegative) and your rights before we process your personal data for our legitimate
interests. We do not use your personal data for activities where our interests areoverridden by the impact on you (unless we have your consent or are otherwise requiredor permitted to by law). You can obtain further information about how we assess ourlegitimate interests against any potential impact on you in respect of specific activities
by contacting us by e-mail to legal-dept@enplas.com.
To comply with a legal or regulatory obligation Where we need to process yourpersonal data for compliance with a legal or regulatory obligation that we are subject to.
Consent Generally we do not rely on consent as a legal basis for processing yourpersonal data other than in relation to sending third party direct marketing
communications to you via email or text message. You have the right to withdraw
consent to marketing at any time by contacting us by e-mail to legaldept@enplas.com.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use
your personal data, and which of the legal bases we rely on to do so. We have also
identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground dependingon the specific purpose for which we are using your data. Please contact us by e-mail tolegal-dept@enplas.com if you need details about the specific legal ground we are4relying on to process your personal data where more than one ground has been set out
in the table below.
Purpose/Activity

Type of data

Lawful basis for processing
including basis of legitimate
interest

To register you as a new (a) Identity
customer(b) Contact

Performance of a contract with you

To process and deliver your (a) Identity
order including:(b) Contact(a) Manage payments, fees (c) Transaction
and charges(d) Finance(b) Collect and recover(e)Marketing
andmoney owed to us
Communications(a) Performance of a contract withyou

To manage our relationship (a) Identitywith you which will include: (b) Contact(a) Notifying you about (c) Profilechanges to our terms or(d)Marketing
andprivacy policy
Communications(b) Asking you to leave areview or take a survey(a) Performance of a contract withyou

To administer and protect our (a) Identity
business and this website (b) Contact(including troubleshooting,data analysis, testing, system (c) Technicalmaintenance,
support,reporting and hosting of data)(a) Necessary for our legitimate
interests (for running our business,
provision of administration and IT
services, network security, toprevent fraud and in the context of abusiness reorganisation or group
restructuring exercise)(b) Necessary for our legitimate
interests (to recover debts due to us)(b) Necessary to comply with a legal
obligation(c) Necessary for our legitimate
interests (to keep our records
updated and to study how customers
use our products/services)(b) Necessary to comply with a legal
obligation
To use data analytics to (a) Technicalimproveourwebsite, (b) Usage
products/services,marketing,customer
relationships and experiences

Necessary for our legitimate
interests (to define types ofcustomers for our products andservices, to keep our website
updated and relevant, to develop ourbusiness and to inform ourmarketing strategy)

To make suggestions and (a) Identity
recommendations to you (b) Contact
about goods or services that

Necessary for our legitimate
interests(todevelopour
products/services and grow our5may be of interest to you(c) Technicalbusiness)(d) Usage
Marketing
We strive to provide you with choices regarding certain personal data uses, particularlyaround marketing and advertising. We have established the following personal data
control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical and Usage Data to form a view on what
we think you may want or need, or what may be of interest to you. This is how we decide
which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested informationfrom us or purchased goods or services from us and, in each case, you have not opted
out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any
company outside ENPLAS CORPORATION GROUP of companies for marketing
purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time bycontacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal
data provided to us as a result of a product/service purchase, warranty registration,
product/service experience or other transactions.
Sales
We do not sell your personal data.
CookiesPlease note that third parties (including, for example, advertising networks andproviders of external services like web traffic analysis services) may also use cookies,
over which we have no control. These cookies are likely to be analytical/performancecookies or targeting cookies.
You can set your browser to refuse all or some browser cookies, or to alert you whenwebsites set or access cookies. If you disable or refuse cookies, please note that someparts of this website may become inaccessible or not function properly.
6Change of purpose
We will only use your personal data for the purposes for which we collected it, unless
we reasonably consider that we need to use it for another reason and that reason iscompatible with the original purpose. If you wish to get an explanation as to how theprocessing for the new purpose is compatible with the original purpose, please contactus.
If we need to use your personal data for an unrelated purpose, we will notify you andwe will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent,in compliance with the above rules, where this is required or permitted by law.
5.

Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes
set out in the table in paragraph 4 above.
Internal Third Parties
Other companies in ENPLAS CORPORATION GROUP acting as joint controllers orprocessors and who are based in Japan, Singapore, Malaysia, Thailand, Vietnam, China,
Taiwan, Hong Kong, Indonesia, Philippines, United States, UK, Germany, Italy Israel
and provide IT and system administration services and undertake leadership reporting.
External Third Parties• Service providers acting as processors based in Japan or the United States who
provide IT and system administration services (note that your personal data collected
in Japan is not transferred to the United States and vice versa).
• Professional advisers including lawyers, bankers, auditors and insurers based inJapan, Singapore, Malaysia, Thailand, Vietnam, China, Taiwan, Hong Kong, Korea,
Indonesia, Philippines, United States, UK, Germany, Italy Israel who provide
consultancy, banking, legal, insurance and accounting services.
• Tax authorities, regulators and other authorities around the world who require
reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer, or merge parts of our businessor our assets. Alternatively, we may seek to acquire other businesses or merge withthem. If a change happens to our business, then the new owners may use yourpersonal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it inaccordance with the law. We do not allow our third-party service providers to use yourpersonal data for their own purposes and only permit them to process your personal data
for specified purposes and in accordance with our instructions.
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International transfers
We share your personal data within ENPLAS CORPORATION GROUP. This will
involve transferring your data outside the European Economic Area (EEA).
Many of our external third parties are based outside the European Economic Area
(EEA) so their processing of your personal data will involve a transfer of data outside
the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree ofprotection is afforded to it by ensuring at least one of the following safeguards is
implemented:• We will only transfer your personal data to countries that have been deemed toprovide an adequate level of protection for personal data by the European
Commission.
• Where we use certain service providers, we may use specific contracts approved by
the European Commission which give personal data the same protection it has inEurope.
• Where we use providers based in the United States, we may transfer data to them ifthey are part of the Privacy Shield which requires them to provide similar protection
to personal data shared between the Europe and the United States.
• Please contact us by e-mail to legal-dept@enplas.com if you want further
information on the specific mechanism used by us when transferring your personal
data out of the EEA.

7.

Data security
We have put in place appropriate security measures to prevent your personal data frombeing accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal data to those employees, agents, contractors
and other third parties who have a business need to know. They will only process yourpersonal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach andwill notify you and any applicable regulator of a breach where we are legally required
to do so.

8.

Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes wecollected it for, including for the purposes of satisfying any legal, accounting, orreporting requirements.
To determine the appropriate retention period for personal data, we consider the amount,8

nature, and sensitivity of the personal data, the potential risk of harm from unauthoriseduse or disclosure of your personal data, the purposes for which we process your personal
data and whether we can achieve those purposes through other means, and the applicablelegal requirements.
Details of retention periods for different aspects of your personal data are available inour retention policy which you can request from us by contacting us by e-mail to legaldept@enplas.com.
In some circumstances you can ask us to delete your data: see Request Erasure below
for further information.
In some circumstances we may anonymise your personal data (so that it can no longer
be associated with you) for research or statistical purposes in which case we may use
this information indefinitely without further notice to you.
9.

Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to
your personal data. You have the right to:
Request access to your personal data (commonly known as a "data subject accessrequest"). This enables you to receive a copy of the personal data we hold about you
and to check that we are lawfully processing it.
Request to know about what personal information we collected, disclosed, or sold. If
you are a California resident, you may request disclosure of the categories of data, thecategories of sources, purpose of use and so on for the personal data about you which
we collected, disclosed, or sold.
Request correction of the personal data that we hold about you. This enables you tohave any incomplete or inaccurate data we hold about you corrected, though we mayneed to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove
personal data where there is no good reason for us continuing to process it. You also
have the right to ask us to delete or remove your personal data where you havesuccessfully exercised your right to object to processing (see below), where we may
have processed your information unlawfully or where we are required to erase yourpersonal data to comply with local law. Note, however, that we may not always be able
to comply with your request of erasure for specific legal reasons which will be notified
to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest(or those of a third party) and there is something about your particular situation whichmakes you want to object to processing on this ground as you feel it impacts on yourfundamental rights and freedoms. You also have the right to object where we areprocessing your personal data for direct marketing purposes. In some cases, we may
9demonstrate that we have compelling legitimate grounds to process your information
which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us tosuspend the processing of your personal data in the following scenarios: (a) if you want
us to establish the data's accuracy; (b) where our use of the data is unlawful but you do
not want us to erase it; (c) where you need us to hold the data even if we no longer
require it as you need it to establish, exercise or defend legal claims; or (d) you have
objected to our use of your data but we need to verify whether we have overriding
legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide
to you, or a third party you have chosen, your personal data in a structured, commonly
used, machine-readable format. Note that this right only applies to automatedinformation which you initially provided consent for us to use or where we used theinformation to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process yourpersonal data. However, this will not affect the lawfulness of any processing carried out
before you withdraw your consent. If you withdraw your consent, we may not be able
to provide certain products or services to you. We will advise you if this is the case at
the time you withdraw your consent.
Right to non-discrimination. We do not discriminate you for exercising rights torequest erasure, disclosure or any other privacy rights granted under laws in connection
with your personal data. This discrimination includes but not limited to denial ofproviding goods or services, undue raises of prices of goods or services, or provision ofpoor quality goods or services.
If you wish to exercise any of the rights set out above, please contact us by e-mail tolegal-dept@enplas.com.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of theother rights). However, we may charge a reasonable fee if your request is clearly
unfounded, repetitive or excessive. Alternatively, we may refuse to comply with yourrequest in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identityand ensure your right to access your personal data (or to exercise any of your otherrights). This is a security measure to ensure that personal data is not disclosed to any
person who has no right to receive it. We may also contact you to ask you for further
information in relation to your request to speed up our response. Specific procedure forverification will be separately informed upon receiving a request from you.
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Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may takeus longer than a month if your request is particularly complex or you have made anumber of requests. In this case, we will notify you and keep you updated.

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