Metal One UK Ltd
Privacy Statement
Metal One UK Ltd and data privacy
Metal One UK Ltd is committed to protecting and respecting your privacy.
This privacy statement sets out the basis on which we will process any personal informationthat we may collect about you as a visitor to our website or premises or a contact at one of ourcustomers, suppliers or other business partners.
The information that we collect about you
We may collect and process the following information about you:
Information that you give us: This is information about you that you give to us when
visiting our website, giving us a business card (or similar), filling in forms that we ask you
to complete or corresponding with us by telephone, post, email or otherwise. It may include,for example, your name, address, email address and telephone number; information about
your business relationship with Metal One UK Ltd; and information about yourprofessional role, background and interests.

Information that our website and other systems collect about you:o If you visit our website it will automatically connect some information about you
and your visit, including the Internet protocol (IP) address used to connect yourdevice to the Internet and some other information such as your browser type andversion and the pages on our site that you visit.
o If you exchange emails, telephone conversations or other electronic
communications with our employees and other staff members, our information
technology systems will record details of those conversations, sometimes including
their content.
o Some of our premises have closed circuit TV systems which may record you if youvisit our premises, for security and safety purposes.

Other information: We may also collect some information from other sources. Forexample:o If we have a business relationship with the organisation that you represent, yourcolleagues or other business contacts may give us information about you such as
your contact details or details of your role in the relationship.
o We sometimes collect information from third party data providers or publicly
available sources for anti-money-laundering, background checking and similar
purposes, and to protect our business and comply with our legal and regulatory
obligations.

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The uses that we make of your information
We may use your information for the following purposes:
to operate, manage, develop and promote our business and, in particular, our relationshipwith the organisation you represent (if any) and related transactions – this includes, forexample, billing / payment purposes;

to operate, administer and improve our website and premises and other aspects of the way
in which we conduct our operations;to protect our business from fraud, money-laundering, breach of confidence, theft ofproprietary materials and other financial or business crimes; and

to comply with our legal and regulatory obligations and bring and defend legal claims.

We may from time to time review information about you held in our systems – including thecontents of and other information related to your email and other communications with us –for compliance and business-protection purposes as described above. This may include reviews
for the purposes of disclosure of information relevant to litigation and/or reviews of records
relevant to internal or external regulatory or criminal investigations. To the extent permitted byapplicable law these reviews will be conducted in a reasonable and proportionate way andapproved at an appropriate level of management. They may ultimately involve disclosure ofyour information to governmental agencies and litigation counterparties as described below.
Your emails and other communications may also occasionally be accessed by persons otherthan the member of staff with whom they are exchanged for ordinary business management
purposes (for example, where necessary when a staff member is out of the office or has left
Metal One UK Ltd).
We will only process your personal information as necessary so that we can pursue the purposes
described above, and then only where we have concluded that our processing does not prejudice
you or your privacy in a way that would override our legitimate interest in pursuing those
purposes. In exceptional circumstances we may also be required by law to disclose or otherwise
process your personal information. We will tell you, when we ask you to provide information
about yourself, if provision of the requested information is necessary for compliance with alegal obligation or, on the other hand, if it is purely voluntary and there will be no implications
if you decline to provide the information. Otherwise you should assume that we need theinformation for our business or compliance purposes (as described above).
Disclosure and international transfer of your information
We may disclose personal information about you, where reasonably necessary for the various
purposes set out above:to the other members of the Metal One group of companies;

to your colleagues within the organisation that you represent;to service providers who host our website or other information technology systems orotherwise hold or process your information on our behalf, under strict conditions ofconfidentiality and security;

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to a person who takes over our business and assets, or relevant parts of them; orin exceptional circumstances:o to competent regulatory, prosecuting and other governmental agencies, or litigation
counterparties, in any country or territory; oro where we are required by law to disclose.

These disclosures may involve transferring your personal information overseas. You should beaware that this may include transfers to countries outside the European Economic Area / UK,which do not have similarly strict data privacy laws. In those cases, where we transfer personal
data to other members of the Metal One group or our service providers, we will ensure that ourarrangements with them are governed by data transfer agreements, designed to ensure that yourpersonal information is protected, on terms approved for this purpose by the European
Commission. Please Contact us (see below) if you would like to know whether any suchagreements are in place or, if so, to see a copy.
Retention and deletion of your information
We will delete the information that we hold about you when we no longer need it.
Note that we may retain some limited information about you even when we know that you haveleft the organisation that you represent, so that we can maintain a continuous relationship withyou if and when we are in contact with you again, representing a different organisation.
Your rights
You may have a right of access to the personal information that we hold about you, and to somerelated information, under data protection law. You can also require any inaccurate personal
information to be corrected or deleted. You can object to our use of your personal information
for direct marketing purposes at any time and you may have the right to object to our processingof some or all of your personal information (and require them to be deleted) in some othercircumstances.
Contact us
We welcome questions, comments and requests regarding this privacy statement and ourprocessing of personal information. Please send them to Metal One UK Ltd, 71 High Holborn,
Mid City Place, London, WC1V 6BA.
You can also lodge a complaint about our processing of your personal information the officeof the UK Information Commissioner (www.ico.org.uk).
Changes to this policy
Any changes we make to this privacy statement in the future will be posted to our website (atwww.mtlo.co.jp). Please check back frequently to see any changes.

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