Handling of Personal Data in the UACJ Group – Privacy Notice

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UACJ Corporation and its subsidiaries*1 (collectively “UACJ”) are committed to protecting your privacy. We process your personal data in accordance with the applicable data protection laws, including Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“General Data Protection Regulation”), to the extent they are applicable to us.

Through this Privacy Notice we want to inform you on the way we collect and process your personal data and the choices that are available to you in relation to the collection, use, access, update and correction of your personal data.

1. Who are we?

UACJ manufactures and sells rolling products, casting products, forged products and precision-machined products of nonferrous metals, including aluminum and copper, and alloys thereof.

UACJ Corporation determines the purposes and means of the processing of personal data that has been collected via our website, or associated sites or pages (“UACJ Website”).

With regard to any other personal data that UACJ holds, UACJ Corporation and/or any of its subsidiaries and/or affiliated companies, alone or jointly with others, determine the purposes and means of the processing of such personal data.

2. What does this Privacy Notice apply to?

This Privacy Notice applies to information we collect about:

  • visitors of UACJ Website;
  • current, former and prospective customers and other business partners;
  • current shareholders;
  • applicants and participants to our events, factory tours, work experience programs;
  • individuals who make inquiries, comments or requests for materials;
  • job applicants;
  • current employees and officers as well as their family members; and
  • former employees and officers.

3. How do we use your personal data?

(1) Visitors of UACJ Website

  • Use of cookies
    When a visitor accesses UACJ Website we use third party service Google Analytics to collect internet log information and details of visitor behavior patterns. We do this to find out things such as the number of visitors to the various sites or pages of UACJ Website.

    You can read more about how we use cookies on our Cookie Policy

  • Security and performance
    We use a third party service to help maintain the security and performance of UACJ Website. To deliver this service we process the IP addresses of visitors to UACJ Website.

It is in our legitimate interest to use your personal data to improve our knowledge of the visitors of UACJ Website and, as a result, be able to provide the most clear and appropriate information, as well as the best products and services to you. It is also in our legitimate interest to ensure network and information security so as to prevent personal data breaches.

(2) Current, former and prospective customers and other business partners

We process personal data that you voluntarily submit to us in relation to our products and services for the following purposes:

  • Notification of various types of services;
  • Fulfillment of various types of contracts;
  • Provision and introduction of products and services;
  • Surveys and analysis on product development and service improvements such as usage conditions of products and services and satisfaction surveys;
  • Notification of events, campaigns and exhibits; and
  • Responses to various types of inquiries.

It is necessary for us to process your personal data in order to perform our obligations in accordance with any contract that we may have with you; or, in order to take steps at your request to enter a contract we may have with you. It is also in our legitimate interest to use your personal data to provide the best products and services to you as well as for our internal administrative purposes.

(3) Current shareholders

We process personal data of our current shareholders for the following purposes:

  • Exercise of rights and fulfillment of obligations under the laws and ordinances;
  • Implementation of various types of measures (including questionnaires) for shareholders; and
  • Management of shareholders (including preparation of shareholders data) under the laws and ordinances.

It is necessary for us and in our legitimate interest to comply with the legal obligations to which we are subject.

(4) Applicants and participants in events, factory tours, work experience programs

When you register to participate in our events, factory tours or work experience programs, we process personal data that you voluntarily submit to us for the following purposes:

  • Smooth operation of events;
  • Notifications and announcements; and
  • Use of photos, video and audio shot at any of the events, factory tours and work experience programs in public relations and advertisements of UACJ (posting them in newspapers, magazines, pamphlets, and on posters and webpages).

It is necessary for us to process your personal data to perform our obligations arising from any contract that we may have with you. It is also in our legitimate interest to use your personal data to provide the best products and services to you.

(5) Individuals who make inquiries, comments or requests for materials

When you contact us to make inquiries, comments or requests for materials, we use your personal data for the following purposes:

  • Responses to inquiries and comments;
  • Surveys or confirmation required for responding to inquiries and comments;
  • Sending of materials; and
  • Contacts and follow-up after sending materials.

It is necessary for us to process your personal data in order to take steps, at your request to enter a contract we may have with you. It is also in our legitimate interest to use your personal data to provide the best products and services to you.

(6) Job applicants (including those who have registered at “Recruitment Information” on UACJ Website)

We use personal data you provide us during a recruitment process for the following purposes:

  • Provision and notification of recruitment information to you;
  • Assessment of your suitability for employment; and
  • Employment service management.

It is necessary for us to process your personal data in order to take steps at your request to enter a contract we may have with you; or, as the case may be, in order to comply with legal obligations to which we are subject. It is also in our legitimate interest to process your personal data to make the best recruitment decisions.

(7) Current employees and officers as well as their family members

We use personal data of our current employees and/or, when appropriate, that of their family members for the following purposes:

  • Procedures related to business communication, payment of wages, and social insurances, procedures for making applications and registrations required in business, including the preparation of various lists of names, provision of employee benefits, and acquisition of qualifications, and legally required procedures;
  • Evaluation of work performance, determination, deduction and payment of wages, payment of congratulatory and/or condolence money, tax payment procedures such as tax withholding at the source, grasping of reason for taking leave, provision of employee benefits, employment management, emergency contact, union fees deduction administrative work, and various procedures required under the laws;
  • Housing loan procedures;
  • Personnel performance evaluation, determination of assignment and transfer, preparation of notification of transfers, organization lists, and telephone directories, implementation of reward and punishment, procedures for retirement or resignation, and employee history management;
  • Appropriate health management and employment management; and
  • Other employment management.

It is necessary for us to process your personal data in order to perform our obligations arising from a contract that we have with you; or, as the case may be, in order to comply with legal obligations to which we are subject. It is also in our legitimate interest to process your personal data for internal administrative purposes.

(8) Former employees and officers

We use personal data of our former employees for the following purposes:

  • Execution and Notification of Obligations under Labor-Related Laws and Ordinances; and
  • Notification Related to the Association of Former Employees.

It is necessary for us to comply with legal obligations to which we are subject. It is also in our legal interest to maintain and manage relationships with former employees.

4. Who do we share your personal data with?

Within UACJ, we may share any data that we collect or that you provide to us.

We also may share your personal data with a variety of categories of third parties, including:

  • IT systems or software vendors and IT service providers, including website hosting and maintenance service providers;
  • Data storage providers;
  • Cookie-related service providers;
  • Postal or courier providers;
  • Government, regulatory or judicial authorities;
  • Payroll service providers; pension administrators; life insurance providers and medical insurance providers; financial and accounting advisers and consultants; and
  • Legal advisors.

We share personal data with third parties only to the extent necessary to achieve the purposes described in point 3 above.

We do not necessarily request your prior consent to share your personal data. It may be necessary for us to share your personal data in order to perform our obligations in accordance with a contract that we may have with you; or, as the case may be, in order to comply with legal obligations to which we are subject. It may also be in our legitimate interest to do so.

When we share personal data with a third party, we conduct necessary and appropriate supervision of the third party to ensure safe processing of shared personal data, including by entering into an agreement regarding the processing of personal data with the third party.

5. Where do we transfer your personal data to?

If you are located within the European Economic Area (“EEA”), we may transfer your personal data to locations outside the EEA, including UACJ Corporation. To do so, UACJ undertakes to implement appropriate safeguards, such as binding corporate rules or standard contractual clauses.

6. How long do we keep your personal data for?

We will only retain your personal data for as long as is necessary for the purposes described in point 3 above. This means that the retention periods will vary according to the type of the data, the reason that we have the data in the first place and the relevant data protection laws.

We have procedures in place regarding our retention periods, which are kept under constant review, taking into account the purposes for processing your personal data and the legal basis for doing so.

7. Your rights

Under the General Data Protection Regulation, you have the following rights in respect of personal data:

  • to be informed about the processing of your personal data;
  • to have your personal data corrected if it is inaccurate and to have incomplete data completed;
  • to object to processing of your personal data;
  • to withdraw your consent at any time where we rely on it to process your personal data;
  • when fulfilling the prerequisite, to make your personal data portable,
  • if any, to restrict processing of your personal data;
  • under conditions, to have your personal data erased;
  • to request access to your personal data and information about how we process it; and
  • to object at any time to processing of your personal data for direct marketing purposes;
  • to object to automated decision making which produces legal effects concerning you or similarly significantly affects you; and
  • in certain circumstances, to request that we transfer your personal data to you or another service provider in a simple, structured format.

8. How to contact us

If you want to request information about this Privacy Notice or want to exercise your rights set out in point 7 above, please contact us:

  • by email or
  • by postal mail at: UACJ Group Personal Information Consulting Counter, General Affairs Department,
    UACJ Corporation
    Tokyo Sankei Bldg., 1-7-2, Otemachi, Chiyoda-ku, Tokyo 100-0004, Japan.

When you are located in the EEA or when your personal data is processed in the context of the activities of any of our European subsidiaries, you also have the right to complain about our use of personal data with the relevant data protection authority in the EEA.

9. Changes to this privacy notice

We may make changes to this Privacy Notice from time to time. This Privacy Notice was last updated on May 25, 2018.

*1 UACJ Color Aluminum Corporation, UACJ Nagoya Alupack Corporation, Sansen Co., Ltd., UACJ Fukaya Service Corporation, UACJ Trading Corporation, Izumi Metal Corporation, Metal Cut Co., Ltd., KAMAKURA INDUSTRY COMPANY LIMITED, ACE21 Corp., UACJ Marketing & Processing Corporation, UACJ Extrusion Corporation, UACJ Extrusion Nagoya Corporation, UACJ Extrusion Oyama Corporation, UACJ Extrusion Gunma Corporation, UACJ Extrusion Shiga Corporation, UACJ Foil Corporation, Nikkin Co., Ltd., UACJ Foil Sangyo Corporation, UACJ Foil Service Corporation, UACJ Foundry & Forging Corporation, HIGASHI NIHON TANZO CO., LTD., UACJ Copper Tube Corporation, UACJ Copper Tube Sales Corporation, Toyo Fitting Co., Ltd., UACJ Copper Tube Packaging Corporation, UACJ Metal Components Corporation, NALCO Koriyama Co., Ltd., UACJ Logistics Corporation, UACJ System Corporation, UACJ Green-net Corporation, Pt.Yan Jin Indonesia, PT. UACJ-Indal Aluminum, UACJ Australia Pty. Ltd., UACJ (thailand) Co., Ltd. ,UACJ Trading (Thailand) Co., Ltd. ,UACJ MH (Thailand) Co., Ltd. ,UACJ Extrusion (Thailand) Co., Ltd. ,UACJ Metal Components (Thailand) Co., Ltd. ,UACJ Trading Czech s.r.o. , UACJ EXTRUSION Czexh s.r.o. ,UACJ Trading (Shanghai) Co., Ltd. , UACJ Trading (Kunshan) Metal Products Co., Ltd. , UACJ Trading (HongKong) Co., Ltd. , UACJ Trading (Dalian.F.T.Z.) Co., Ltd. , UACJ (Shanghai) Aluminum Corporation, UACJ Extrusion (Tianjin) Corporation, UACJ Copper Tube (Guangzhou) Corporation, UACJ (Wuxi) Aluminum Products Corporation, SHANGHAI UACJ DONGYANGGUANG ALUMINUM SALES CORPORATION, UACJ ELVAL HEAT EXCHANGER MATERIALS GmbH, UACJ Trading (America) Co., Ltd. , UACJ Marketing & Processing America Inc. , UACJ Metal Components North America Inc. , UACJ Automotive Whitehall Industries, INC. , UACJ North America Inc. , Tri-Arrows Aluminum Holdings Inc. , Tri-Arrows Aluminum Inc. , UACJ Foundry & Forging (Vietnam) Co., Ltd. , UACJ Foil Malaysia Sdn. Bhd. , UACJ Cooper Tube (Malaysia) Sdn.Bhd. , UACJ Metal Components Mexico, S.A.DE c.V, and UACJ Metal Components Central Mexico, S.A.DE c.V