Privacy Policy

Privacy Policy for Customers and Trading Partners

USUI CO., LTD. (hereinafter referred to as the “USUI”) and its subsidiaries within our group (hereinafter collectively referred to as “USUI Group”) shall properly Handle any Personal Information provided by customers and trading partners in compliance with any laws relating to protection of Personal Information, EU General Data Protection Regulation and any other applicable laws and regulations, etc.

Section 1. (Definition)

<Table of Glossary>

Term	Definition
Personal Information	Any information regarding to an identified or identifiable natural person
Personal Data	Any Personal Information acquired by USUI Group listed in the Section 3 of this privacy policy that are contained in a systematically constructed material (such as personal information database) so that any specific personal information can be searched whether in paper or electronic media
Identical Person	Any individual who can be identified by Personal Information
Handle/Handling	An operation or a series of operations performed on Personal Data or a series of Personal Data whether or not by automated means, including but not limited to acquisition, record, compilation, structuring, save, amendment or modification, restore, reference, utilization, disclosure through transfer, publicizing or any other provision, sorting or combination, restriction, delete or discard of data
Sensitive Information	Any information regarding race, economic standing, health, body, sexual orientation, religion or thought and creed
EEA	Acronym of European Economic Area
GDPR	Acronym of General Data Protection Regulation

Section 2. Scope

This policy shall apply to any Handling of Personal Data obtained by USUI Group.

Section 3. Proper Acquisition of Personal Information

USUI Group shall acquire the Personal Information listed below by lawful and fair means to the extent such information is necessary for its business operations. USUI Group shall obtain prior consent from the Identical Person except as required by laws or regulations when it acquires Sensitive Information.

1. Personal Information acquired in executing and performing any contract with customers or trading partners;
2. Personal Information acquired through request for documents, etc. From customers or trading partners;
3. Information appearing on business cards, information acquired by questionnaires and Personal Information acquired through business activities such as exhibition, seminar or negotiation; and
4. Other Personal Information acquired through telephone talk, e-mail, and inquiry through our website or consultation.

Section 4. Basis of Legality

USUI Group shall Handle any Personal Data based on legitimate interests of USUI Group. The legitimate interest of USUI Group is to Handle any Personal Data necessary for ordinary business operations performed by USUI Group.

Section 5. Purpose of Use

USUI Group shall Handle any Personal Data only for the limited purposes specified below.

1. Process of orders in performing contracts with customers and trading partners, delivery of products or services, provision of supports, issuance of estimates/invoice, and management of business connections;
2. Notices of services, products and events of any kind of USUI Group;
3. Development of new products of USUI Group and carrying out of questionnaire aiming at improvement of services;
4. Response to inquiries about services, products and recruiting of USUI Group;
5. Messages of obeisance, celebration, get-well and greeting to customers and trading partners; and
6. Performance of any other business activities associated with those listed above.

Section 6. Disclosure and Provision to Third Parties

USUI Group shall not disclose or provide Personal Data to any third party except for cases falling into any of the specified below. Any Personal Data containing Sensitive Information shall not be disclosed or provided to any third party in any event except that it is stipulated by laws or regulations or expressly consented by the Identical Person. However, in the case of joint use of Personal Data by USUI Group and in the case of provision of Personal Data to the relevant outsourcing companies in outsourcing the Handling of Personal Data in whole or in part to the extent that it is necessary for accomplishment of the purpose of use, it shall not be concerned as the disclosure or provision to third parties.

1. The Identical Person’s consent is obtained;
2. Disclosure or provision is required for fulfillment of any statutory obligation;
3. The Identical Person’s consent is difficult to be obtained when it is necessary for protection of life, body or properties of any person;
4. Performance of any official work may be hindered by obtaining the Identical Person’s consent when it is necessary for cooperating with national or local government or autonomy, etc. In such performance of official work; or
5. Provision is made in association with merger, corporate division, and transfer of business or succession of business for any other reason.

Section 7. Joint Use

USUI Group may use Personal Data jointly within USUI Group companies listed below.

• USUI CO., LTD.
• USUI International Corporation
• USUI INTERNATIONAL MANUFACTURING MEXICO, S.A. DE C.V.
• USUI International France S.A.S.
• USUI International Germany GmbH
• Shanghai USUI Engine Parts Co., Ltd.
• USUI Automotive Parts(Shanghai) Co., Ltd.
• USUI Automotive Part(Foshan) Co., Ltd.
• USUI PIPE SYSTEM (HEFEI) CO., LTD.
• JIAXING USUI TSURUMI PRECISION TUBE INDUSTRY Co.,Ltd.
• USUI International Korea Co., Ltd.
• USUI International Corporation (Thailand) Ltd.
• PT.USUI INTERNATIONAL INDONESIA
• USUI SUSIRA INTERNATIONAL PRIVATE LIMITED
• USUI INTERNATIONAL PHILIPPINES CORPORATION

Section 8. Outsourcing of Operations

USUI Group may provide Personal Data to the outsourcing companies to the extent it is necessary for accomplishment of the purpose of use under the Section 5 hereof. In such case, proper control and supervision of the outsourcing companies shall be done including but not limited to execution of agreement for Handling of Personal Data with the relevant outsourcing companies.

1. A part of Handling of Personal Data may be outsourced for distribution works such as warehousing and delivery;
2. A part of Handling of Personal Data may be outsourced to inspection companies for assurance of quality; and
3. A part of Handling of Personal Data may be outsourced to cloud service providers for utilization of general communication tools such as e-mail system, management system of business cards and web conference system in the course of negotiation or conference with business connections and management of points of contact.
4. A part of Handling of Personal Data may be outsourced to subcontractors that undertake parts manufacturing, shipping inspection, etc. within USUI Group’s facilities for executing contracts with customers or trading partners.

Section 8. Outsourcing of Operations

In the event that USUI Group transfers Personal Data to any third country outside the EEA including but not limited to outsourcing companies and joint users of such Data, USUI Group shall take any proper action required pursuant to standard provisions for data protection based on the GDPR as stipulated by EU.

• http://www.usui.co.jp/documents/internal/uif/SCC(C-C)UIF.pdf
• http://www.usui.co.jp/documents/internal/uig/SCC(C-C)UIG.pdf

Section 10. Ensuring Accuracy

USUI Group shall endeavor to keep any content of Personal Data up-to-date and correct it if there is any error or deficiency.

Section 11. Retention Period

USUI Group shall not retain Personal Data collected by USUI Group beyond the limit of time needed for the purpose of collection of such Data.

Section 12. Security

USUI Group shall take reasonable actions against such risks as unauthorized access to, divulgation of, loss or damage of Personal Data in order to ensure accuracy and security of Personal Data.

Section 13. Right of Identical Person

The Identical Persons shall have rights to access to his/her Personal Information held by USUI Group, to correct it, to erase it, to restrict the Handling of it and to make an objection against it. When the Identical Person wishes to proceed with exercise of any rights of these kind, please contact the contact point specified in the Section 14 hereof. In addition to the above, the Identical Person shall have a right to file an objection with a supervising authority.

Section 14. Contact Point

Any inquiry about Personal Information and Identical Persons’ rights should be directed to Usui_group_privacy@usui.co.jp.

Section 15. Modification of the Privacy Policy

USUI Group may revise this policy for protecting Personal Information or responding to changes of laws, regulations or any other rules. Consequently please acknowledge in advance that this policy may be subject to change without notices.

(supplement)
Documented and posted as of August 27, 2018.

USUI CO., LTD.

USUI International Corporation

USUI INTERNATIONAL MANUFACTURING MEXICO, S.A. DE C.V.

USUI International France S.A.S.

USUI International Germany GmbH

Shanghai USUI Engine Parts Co., Ltd.

USUI Automotive Parts(Shanghai) Co., Ltd.

USUI Automotive Part(Foshan) Co., Ltd.

USUI PIPE SYSTEM (HEFEI) CO., LTD.

JIAXING USUI TSURUMI PRECISION TUBE INDUSTRY Co.,Ltd.

USUI International Korea Co., Ltd.

USUI International Corporation (Thailand) Ltd.

PT.USUI INTERNATIONAL INDONESIA

USUI SUSIRA INTERNATIONAL PRIVATE LIMITED

USUI INTERNATIONAL PHILIPPINES CORPORATION