MKI (U.K.) Limited (the ‘Company’) Privacy NoticeThis notice explains how information about you is used. The Company will be the data controller and can becontacted as follows:
By post: Data Protection Manager, MKI (U.K.) Limited, 8th floor, 1 St Martin’s-Le-Grand, London, EC1A 4AS
By e-mail: Kitaichi-isao@mki.co.jp
By phone: +44-20-7822-0382
The information we gather
The Company gathers certain information about you. When we do so we are regulated under the General Data
Protection Regulation which applies across the European Union (including in the United Kingdom), and theData Protection Act 2018, and we are responsible for that personal information for the purposes of those laws.
In this notice, references to ‘we’ or ‘us’ means the Company and our group companies.
Information that we gather about you may include without limitation your name, your title, and contact details.
The provision of information by you is entirely voluntary. If you do not provide your information it may not be
possible for us to provide any goods or services.
We may also obtain information about you from third parties, such as our service providers and agents.
We have appropriate security measures in place to prevent personal information from being accidentally lostor used or accessed in an unauthorised way. We limit access to your personal information to those who have agenuine business need to know it. Those processing your information will do so only in an authorised mannerand are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any
applicable regulator of a suspected data security breach where we are legally required to do so.
The legal basis and reasons for processing
This privacy notice sets out how we will process your data.
Processing can take place when it is necessary to perform a contract between us, or where we are both taking
steps to enter into a contract. It can also take place based on our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your information, so long as thisis not overridden by your own rights and interests. Our legitimate interests may be that we are carrying or may
carry on business with your employer. There is a limited privacy impact on you, and we think that you will
expect that we will process your data in this way. Sometimes processing will take place based on your consent,such as when you give us your clear and express permission to do something with your personal data.
Whenever you have given consent you can withdraw it at any time.
We process information about you for the following reasons:
What we use your information for

Our reasons

To provide our services

For the performance of our contract with you or to takesteps at your request before entering into a contract, orfor our legitimate interests if we are entering into acontract with your employer

Providingcustomer
services,
preferences and improving services

analysing

For the performance of our contract with you, for ourlegitimate interests or those of a third party, i.e. to be
as efficient as we can so we can deliver the best service

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for you at the best price, and to comply with our legal
and regulatory obligations
To improve user experience

For our legitimate interests or those of a third party, i.e.
to be as efficient as we can so we can deliver the best
service for you at the best priceOperational reasons, such as recordingtransactions, training and quality control, andensuring business policies are adhered to

For our legitimate interests or those of a third party, i.e.
to be as efficient as we can so we can deliver the best
service for you at the best price

Conducting checks to identify our customers andverify their identity, screening for financial andother sanctions or embargoes, and otherprocessing
necessarytocomplywithprofessional, legal and regulatory obligations,
corporate governance obligations and goodpractice that apply to our business, e.g. underhealth and safety regulation or rules issued byour professional regulator

For our legitimate interests or those of a third party, i.e.
to minimize fraud that could be damaging for us and foryou, and to comply with our legal obligations

Gathering information as part of investigations
by regulatory bodies or in connection with legal
proceedings or requests

To comply with our legal and regulatory obligations

Security vetting, preventing fraud, investigatingclaims, complaints and allegations of criminal
offences

For our legitimate interests or those of a third party, i.e.
to minimize fraud that could be damaging for us and foryou, and to comply with our legal obligations

Ensuring the confidentiality of commerciallysensitive information

For our legitimate interests or those of a third party, i.e.
to protect trade secrets and other commerciallyvaluable information, and to comply with our legal andregulatory obligations

Statistical analysis to help us manage ourbusiness, e.g. in relation to our financial
performance, customer base, product range orother efficiency measures

For our legitimate interests or those of a third party, i.e.
to be as efficient as we can so we can deliver the best
service for you at the best pricePreventing
unauthorised
modifications to systems

For our legitimate interests or those of a third party, i.e.
to prevent and detect criminal activity that could bedamaging for us and for you, and to comply with ourlegal and regulatory obligations

accessandUpdating and enhancing customer records

Ensuring safe working practices,administration and assessments

For the performance of our contract with you or to takesteps at your request before entering into a contract, tocomply with our legal and regulatory obligations, andfor our legitimate interests or those of a third party, e.g.
making sure that we can keep in touch with ourcustomers about existing orders and new products
staff

To comply with our legal and regulatory obligations,and for our legitimate interests or those of a third party,
e.g. to make sure we are following our own internal
procedures and working efficiently so we can deliver2

the best service to you
External audits and quality checks, e.g. for ISO or
Investors in People accreditation and the auditof our accountsFor our legitimate interests or a those of a third party,i.e. to maintain our accreditations so we candemonstrate we operate at the highest standard, andto comply with our legal and regulatory obligations

Marketing our business and those of our group

For our legitimate interests or those of a third party, i.e.
to promote our business to existing and former
customers

Promotional communications
We may use your personal information to send you updates (by email, text message, telephone or post) about
our products and services, including promotions or new products or services. We have a legitimate interest inprocessing your personal information for promotional purposes (see above). Where consent is needed, we will
ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never share it with otherorganisations outside our group for marketing purposes. You have the right to opt out of receiving
promotional communications at any time by contacting our Data Protection Manager.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further
products or services in the future, or if there are changes in the law, regulation, or the structure of ourbusiness.
Information about third parties
Information we process as described in this notice may also include information about third parties such as
whose details you supply to us.
Systems used to process data
We gather information directly from you and also via other technical systems. These may include, for example,
our: computer networks and connections, communications systems, trading platforms, email systems, intranet
and Internet facilities, telephones, and other hardware and software owned, used or provided by or on behalfof us and our group companies.
Cookies
When you use our website we may gather information about you through Internet access logs, cookies andother technical means. ‘Cookies’ are text files placed on your computer to collect Internet log information anduser behaviour information. These are used to track website usage and monitor website activity and for otherdata processing reasons set out below.
Some of the cookies we use are essential for parts of the site to operate and have already been set. You may
delete and block all cookies from this site, but parts of the site will not work. To find out more about thecookies we use and how to delete them, please contact kitaichi-isao@mki.co.jp by email.
Disclosures and exchange of information and transfers outside the EEA
We may disclose and exchange information with our group companies, service providers, representatives andagents, as well as with law enforcement agencies and regulatory bodies for the above reasons. We only share
information with such service providers if we are happy that they take appropriate measures to protect yourpersonal information.

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We may also need to share some personal information with other parties, such as potential buyers of some or
all of our business or during a re-structuring. Usually, information will be anonymised but this may not always
be possible. The recipient of the information will be bound by confidentiality obligations.
Information may be held at our offices and those of our group companies, and third-party service providers,representatives and agents as described above. Information may be transferred internationally to othercountries around the world, including those without data protection laws equivalent to those in the UK, for thereasons described above. We have security measures in place to seek to ensure that there is appropriate
security for information we hold including those measures detailed in our information security and dataprotection policies, which are available on request.
Japan has received a finding of adequacy from the European Commission, so you can be satisfied that you
continue to enjoy equivalent data rights whenever your data has been transferred to Japan. For otherinternational data transfers outside the European Economic Area are protected by Standard Contractual
Clauses, as per GDPR Article 46(2).
If you would like further information please contact our Data Protection Manager (see above). We will nototherwise transfer your personal data outside of the EEA or to any organisation (or subordinate bodies)governed by public international law or which is set up under any agreement between two or more countries.
Retention periods
Your data will be held for as long as it is genuinely useful to us, in accordance with the Company’s retention
policy, which is available on request. In general, your data may be stored for the duration of your contractual
relationship with us, plus 6 years.
Further enquiries
Please contact the Data Protection Manager if you would like to correct or request (in accordance withapplicable law) information that we hold relating to you or if you have any questions in relation to the above.
Your rights
You have a number of important rights, which can be exercised free of charge. You have the right to request:

access to your personal information and to certain other supplementary information that this Privacy
Notice is already designed to addressrequire us to correct any mistakes in your information which we holdrequire the erasure of personal information concerning you in certain situations

receive the personal information concerning you which you have provided to us, in a structured,commonly used and machine-readable format and have the right to transmit those data to a third
party in certain situations



object at any time to processing of personal information concerning you for direct marketing

object to decisions being taken by automated means which produce legal effects concerning you orsimilarly significantly affect youobject in certain other situations to our continued processing of your personal informationotherwise restrict our processing of your personal information in certain circumstances.

We will not do anything with your data not outlined in this notice.
For further information on each of those rights, including the circumstances in which they apply, see theGuidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data
Protection Regulation.

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

If you would like to exercise any of these rights, or if you have any complaints, please contact ourData Protection Manager, providing enough information to identify you and let us know which
information to which your request relates.

If you are not satisfied with any complaint you have with us, you also have the right to make a complaint to theInformation Commissioners Office, which is the supervising authority in the UK in relation to data processing.
You can contact the Information Commissioner at ico.org.uk/concerns/ or by telephone: 0303 123 1113 forfurther information about your rights and how to make a formal complaint.
We may change this privacy notice from time to time, when we do we will inform you via updates on ourwebsite.

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