Privacy Policy

MCC will comply with the California Consumer Privacy Act as amended (“CCPA”), and related laws and regulations, and will appropriately process and protect the privacy of personal information of California residents.

In addition to Chapter 1, the provisions of this Chapter apply to the handling of personal information of persons residing in the State of California, U.S.A. In the event the contents stipulated in Chapter 1 conflict with those stipulated in this Chapter, the provisions of this Chapter shall prevail.

1. 1.Personal Information We Collect
   MCC may collect, or may have collected in the preceding 12 months, personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual person or a household (“Personal Information”). MCC may also collect non-Personal Information that cannot be linked or associated with an individual person or household. When non-Personal Information is combined with other information so that it identifies an individual person, MCC treats that combination as Personal Information covered by this Policy. MCC may collect, use, store and transfer different categories of Personal Information about you, which MCC has grouped together, as follows:
   • Identifiers such as name, phone number, e-mail address, IP address, online identifiers etc.
   • Professional Information such as company name, department and title.
   • Internet or Other Electronic Network Activity Information, such as how you have used the MCC’s Food and Healthcare business website, browsing and trading history on such website
   • Email open history and related data.
   1. （1）Personal Information We Have Collected in the Preceding 12 Months
      MCC may have obtained the above collected categories of Personal Information in the preceding 12 months.
   2. （2）Children’s Privacy
      MCC’s services are designed and intended for adult use only and are not directed towards children, minors, or anyone under the age of 18. By accessing and/or using our services, you represent that you are at least eighteen (18) years old. If we obtain actual knowledge that a user is not at least eighteen (18) years of age, we will promptly delete information associated with that user.
      In all events, we do not knowingly collect information from or otherwise market to children under thirteen (13) years of age. If you are a parent or guardian of a child under the age of thirteen (13) and believe that your child disclosed Personal Information to us, please contact us at our inquiry form[別窓表示]. You may review and request the deletion of your child's Personal Information or prohibit the further use of such information.
2. 2.How Long We Retain Your Personal Information
   MCC will only retain your Personal Information for as long as reasonably necessary to fulfill the purposes for which MCC collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. MCC may retain your Personal Information for a longer period in the event of a complaint or if MCC reasonably believes there is a prospect of litigation in respect to our relationship with you.
   To determine the appropriate retention period for Personal Information, MCC considers the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which MCC processes your personal data and whether MCC can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.
3. 3.How We Collect Your Personal Information
   MCC uses different methods and sources to collect information from and about you, including through:
   1. （1）Information You Provide To Us:
      MCC may collect Personal Information from you that you voluntarily provide to us in various ways, including, but not limited to, either directly or through our contracted service providers when you:
      • Exchange business cards or respond to surveys at exhibitions, etc.
      • Fill in the website enquiry form or product literature download form
   2. （2）Information We Collect When You Use Our Services:
      Cookies are small files that we or our service provider transfers to your computer’s hard drive through your web browser that enables us or our service provider’s systems to recognize your browser and capture and remember certain information. We use cookies to help us understand how users use the Services. For example, cookies gather information about how long you spend on a web page so that we can understand what web pages are of most interest to users. If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off cookies by adjusting your browser settings. MCC does not use third party cookies.
   3. （3）Information We Collect From Third Parties:
      MCC may receive Personal Information from marketing companies. Personal Information that we may obtain from such marketing companies may include collect Personal Information you voluntarily provided to such marketing companies through telephone inquiries and other means. Such Personal Information may include name, phone number, e-mail address, company name, department and title.
   4. （4）Your ‘Do Not Track’ Browser Setting:
      Some web browsers incorporate a Do Not Track (“DNT”) feature that signals to the websites that you visit that you do not want to have your online activity tracked. At this time, our website does not respond to DNT signals. Other third-party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites
4. 4.How We Use Your Personal Information
   MCC uses the Personal Information set out in Section 1, Chapter 2, or non-identifiable information MCC collects, to facilitate the relationship MCC has with you, to comply with our legal and financial obligations, and to pursue our legitimate business interests, which include the business purposes set out below:
   • To provide sales contacts;
   • To send e-mail newsletters for product promotions and webinar invitations regarding product introductions; and
   • To provide information and advertisement delivery on products and services through analysis of browsing and trading history on MCC’s Food and Healthcare business, email open history and related data, etc.
   1. （1）Purposes For Which We May Use and We Have Used in the Preceding 12 Months Your Personal Information
      MCC may use or may have used in the preceding 12 months your collected Personal Information for the purposes below.
      • To provide sales contacts; and
      • To send e-mail newsletters for product promotions and webinar invitations regarding product introductions.
5. 5.How We Disclose Your Personal Information to Third Parties
   MCC may disclose your Personal Information to third parties only in the ways that are described in this Policy and with our business partners, suppliers and sub-contractors in order to perform any contract we enter into with them or you. MCC may disclose your Personal Information with third parties for the purposes described above.
   • Internal Third Parties
     MCC may disclose Personal Information described in “1 Personal Information We Collect” above to our parent company, subsidiaries, successors, assigns, licensees, affiliates, or business partners, etc.
   • Service Providers
     MCC may use third-party service providers to perform certain business services and may disclose Personal Information to such service providers as needed for them to perform these business services for the purposes described above. Service providers are only allowed to use, disclose or retain Personal Information to provide these services and are prohibited from selling or sharing Personal Information. Business services provided include, but are not limited to, hosting services, software as a service, document management services, communications services such as email, text, and chat services, software and app development services, collection services, payment processing services, accounting and audit services, compliance services, quality control services, analytics services, and call center services.
   • Business Transactions
     MCC may do business with third parties to whom MCC may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, MCC may seek to acquire other businesses or merge with them. If a change happens to our business, then your Personal Information may be disclosed or transferred to another company or entity, and the new owners may use your Personal Information in the same way as set out in this Policy.
   • Legal Process
     Subject to applicable law, MCC may disclose information about you: (i) if MCC is required to do so by law, regulation or legal process, such as a subpoena; (ii) in response to requests by government entities, such as law enforcement authorities; (iii) when MCC believes disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity.
   1. （1）No Sales or Sharing of Personal Information
      MCC does not sell or share your personal information.
   2. （2）Personal Information We Have Disclosed And To Whom In The Preceding 12 Months
      MCC has disclosed your Personal Information to the third parties listed below in the preceding 12 months.
      • Internal third parties.
6. 6.How We Protect Your Personal Information
   MCC has implemented and maintained generally accepted industry standards to protect against the unauthorized access, use, modification, destruction, or disclosure of your Personal Information both during transmission and once MCC receives it. MCC endeavors to keep your Personal Information confidential and protected against unauthorized access, misuse or alteration with commercially reasonable physical, technical, and administrative measures. However, as effective as these measures are, no security system is impenetrable. MCC cannot guarantee the security of electronic data nor can MCC guarantee that the information you supply will not be intercepted.
7. 7.Your California Privacy Rights
   California Consumer Privacy Act.
   CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
   • Right to Know/Access:
     Upon verification of your identity, you have a right to know what Personal Information MCC has collected about you in the immediately preceding 12-month period, including the categories of personal information, the categories of sources from which the Personal Information is collected, the business or commercial purposes for collecting, selling, or sharing Personal Information, the categories of third parties to whom MCC has disclosed Personal Information, and the specific pieces of Personal Information MCC has collected. You may exercise this right no more than twice in any 12-month period.
   • Right to Delete:
     You have the right to request that MCC deletes Personal Information that MCC collected from you and retained, subject to certain exceptions.
   • Right to Correct:
     You have the right to correct inaccurate Personal Information that MCC maintains about you.
   • Right to Opt-Out of the Sale/Sharing:
     You have the right to opt-out of processing Personal Information for the purposes of: (i) the sale or sharing of Personal Information, (ii) targeted advertising, or (iii) profiling in furtherance of automated decisions that produce legal or similarly significant effects. MCC does not sell or share your Personal Information.
   • Right to Limit the Use or Disclosure of Sensitive Personal Information:
     You have the right to request that MCC limits the use and disclosure of Sensitive Personal Information to specific business purposes approved by applicable law. MCC does not collect, use or disclose your sensitive personal information.
   • Right to Non-Discrimination:
     You have the right not to receive discriminatory treatment or retaliation for the exercise of your privacy rights. Unless permitted by applicable law, MCC will not discriminate against you for exercising any of your privacy rights under the applicable law, including by, but not limited to:
     1. (i)Denying you goods or services;
     2. (ii)Charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
     3. (iii)Providing you a different level of quality of goods or services; or
     4. (ⅳ)Suggesting that you will receive a different price or rate for goods or services or a different level of quality of goods or services.
   • Right to Appeal:
     You have the right to appeal any decision that includes a refusal to take action on a request. Appeals must be filed within 45 days of receipt of the decision. Any such decisions will be transmitted by email and will contain a link for submitting your appeal through our online form. You may also submit your request by calling us at +1-445-313-8177 or by contacting us at our inquiry form[別窓表示].
   • Other California Privacy Rights:
     California Civil Code Section 1798.83 permits California residents who have provided personally identifiable information to us or third-party advertisers and marketing partners, if any, to request certain information regarding our disclosure of personally identifiable information to third parties for direct marketing purposes. Requests should be submitted by using our inquiry form[別窓表示] and should include CALIFORNIA PRIVACY RIGHTS in the subject line. MCC will need your first and last name, mailing address, and email address in order to process your request. Please be aware that not all information sharing is covered by the requirements of Section 1798.83 and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.
   1. （1）Exercising Your California Rights
      Only you or an authorized agent may make a verifiable consumer request related to your Personal Information. You may also request deletion, correction, or to know, and exercise your rights of portability or appeal.
      Requests can be submitted by calling our toll-free number (+1-445-313-8177) or through our our inquiry form.[別窓表示]
      Please note that these rights apply only to persons in California.
   2. （2）Authorizing an Agent to Act on Your Behalf
      Except where you have provided an agent with a Power of Attorney pursuant to Sections 4000 – 4465 of the California Probate Code, when using an authorized agent, you must: (i) provide the agent with signed written permission clearly describing their authority to make a request on your behalf; (ii) verify your own identity; and (iii) directly confirm that you have provided the authorized agent permission to submit the request. MCC may deny a request from an authorized agent if the agent does not provide us with the signed written permission demonstrating that they have been authorized to act on your behalf.
   3. （3）Verifying Your Request
      The verifiable consumer request initiated by you or your authorized agent must:
      Include your full legal name, email, and phone number, which MCC will need to contact you in order to verify that you are the person about whom MCC collected Personal Information or an authorized representative.
      Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
      MCC cannot respond to your request or provide you with Personal Information if MCC cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. One of our representatives will contact you in order to verify your identity. You may need to provide additional information in order to verify your request. Depending on the nature of the request, MCC may require additional verification actions be taken, including but not limited to providing a signed declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request. MCC will only use this information to verify the requestor’s identity or authority to make the request.
   4. （4）Exceptions
      These rights are not absolute and are subject to certain exceptions. For example, MCC cannot disclose or permit access to specific pieces of Personal Information if granting your request would present a certain level of risk to the security of the Personal Information at issue, your account with us or the security of the website. MCC may deny your deletion request if retaining the information is necessary for us or our service providers and/or contractors to:
      • Complete the transaction for which MCC collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
      • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
      • Debug products to identify and repair errors that impair existing intended functionality.
      • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
      • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546).
      • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
      • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
      • Comply with a legal obligation.
      • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
   5. （5）Response Timing and Format
      MCC endeavors to respond to a verifiable consumer request to delete, correct or to know within forty-five (45) days of its receipt. If MCC requires more time (up to 90 days), we will inform you of the reason and extension period in writing. MCC does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If MCC determines that the request warrants a fee, MCC will tell you why MCC made that decision and provide you with a cost estimate before completing your request.
8. 8.Changes to this Policy
   MCC may modify or update this Policy from time to time. MCC encourages you to revisit this page often to remain fully informed of this Policy or you can contact us at any time to obtain the latest copy of this Policy.
9. 9.Questions about this Policy
   For questions or comments regarding this Policy, please use our inquiry form[別窓表示] .

Last Updated: 01/10/25

MCC will comply with the EU General Data Protection Regulation ("GDPR") and related laws and regulations, and appropriately process and protect the privacy of your personal data located in the European Economic Area ("EEA") consisting of EU Member States, Norway, Iceland and Liechtenstein, as well as in the processing of personal data located in the UK in accordance with the UK GDPR.
In addition to Chapter 1, the provisions of Chapter 3 shall apply to the handling of personal data of persons residing in the EEA and the UK. In the event the contents stipulated in Chapter 1 conflict with those stipulated in Chapter 3, the provisions of Chapter 3 shall prevail.

1. 1.Personal Data Collected and Processed
   MCC collects personal data either directly from you or indirectly through third-party service providers.
   The purpose of processing, legal basis and retention period of personal data obtained by MCC are as follows:

   Item of Personal Data	Purpose of Processing	Legal basis	Storage period
   Name, company name, department, title, phone number, e-mail address, etc.	To provide sales contacts To send e-mail newsletters for product promotions and webinar invitations regarding product introductions	For our legitimate interests (providing and improving our products and services)	Ongoing business relationships, including trading
   IP address, usage of MCC’s Food and Healthcare business website, including browsing and trading history, cookies and action logs, etc.	To provide information and advertisement delivery on products and services through analysis of opening history of e-mails, browsing and trading history, etc.	For our legitimate interests (providing and improving our products and services)	Ongoing business relationships, including trading

   Please note that where the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, you are required to provide such personal data. In the absence of such personal data, MCC may not be able to provide you with the products or services that you have requested.
   MCC will not collect and process your data of a sensitive nature, such as concerning race or ethnic background, religion, philosophical beliefs, political opinions, social status and trade union affiliation, health data and medical history, sexual life and preferences, genetic data, biometric data, criminal record, and the fact of having fallen victim to a crime, unless required by applicable laws or with your consent.
   MCC will not use personal data provided to make automated decisions, including profiling.
2. 2.Disclosure of Personal Data to Third Parties
   MCC may disclose your personal data to group companies within the scope of the purposes of processing.
3. 3.Your Rights
   You have the following rights to your personal data held by MCC:
   • Right to request access
   • Right to request rectification
   • Right to request deletion
   • Right to request restriction of processing
   • Right to request data portability
   • Right to object to processing (including for marketing purposes)
   • Right to withdraw consent at any time if the personal data is collected based on consent
   • Right to lodge a complaint with the data protection authority that has jurisdiction in the country where the processing of personal data relating to you is taking place (please refer to the list provided by the EDPB here[別窓表示])
4. 4.Transfer of Personal Data outside the EEA or the UK
   MCC may transfer personal data from the EEA or the UK to third parties located in countries outside the EEA or the UK within the extent of the purposes of processing. Both the European Commission and the UK government have issued adequacy decisions in respect of Japan in 2019. Some foreign group companies that receive personal data are located in third countries that are not recognized by the European Commission and UK government as having data protection laws which provide the same level of protection for personal data as the EEA or the UK, but MCC has entered into data transfer agreements with our group companies to ensure a sufficient level of personal data protection. In this case, MCC will take the appropriate safeguards necessary for international data transfer such as the EU standard contractual clauses.
5. 5.Inquiries If you have any questions or comments regarding this privacy policy, please contact the contact person at the following address:
   
   Data controller: Mitsubishi Chemical Corporation
   1-1, Marunouchi 1-chome, Chiyoda-ku Tokyo
   President & Chief Executive Officer
   Manabu Chikumoto
   

   Contact here for inquiries[別窓表示]

6. Last Updated: 01/10/25