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PRIVACY STATEMENT FOR BUSINESS PARTNERS
The EU General Data Protection Regulation (GDPR) entered into force on 25 May 2018.
Therefore, with this privacy statement, we wish to seize the opportunity to inform you about our practices with regard to the processing of your personal data.
Data controller
The data controller is the natural or legal person determining the purposes and means of the processing of your personal data.
In the context of this policy, the data controller is Sumitomo Bakelite Europe (Barcelona), S.L.U., with registered offices at Calle Gran Vial, número 4, 08170 – Montornès del Vallès (“SBEB” or We).
Data subjects
This privacy statement applies to all business partners of SBEB, be it natural persons or collaborators of legal persons, and specifically to:
Purposes of processing and data processed
We only process your personal data in the context of our business relationship and we do not use it for other purposes.
Purpose | Legal basis |
Administration of orders placed with suppliers and of services requested to subcontractors | Necessity for the performance of contracts with suppliers and subcontractors |
Administration of orders from clients and the delivery of products | Necessity for the performance of contracts concluded with clients |
Administration of services provided to clients | Necessity for the performance of contracts concluded with clients |
Financial management of our business relationships | Legitimate interest |
Intra-group reporting | SBEB legitimate interest to ensure qualitative reporting on commercial activities and business relationships within the Group of Sumitomo Bakelite Co., Ltd. |
Risk management and compliance | SBEB legitimate interest to manage risk and compliance |
Arrangements for business meetings or other events | Necessity for the performance of the contract concluded with clients, suppliers and subcontractors |
Arrangements for business meetings or other events including meals | SBEB legitimate interest |
In exceptional circumstances, management of potential disputes which may arise from our business relationships | SBEB legitimate interest Necessity for the performance of the contract concluded with clients, suppliers and subcontractors |
Typically, the personal data we hold about you will include the following:
We do not conduct profiling activities nor take automatic decisions on that basis. Data we process about you will usually be obtained from yourself or from other companies of the Group of Sumitomo Bakelite Co., Ltd.
Retention of your personal data
Generally speaking, your personal data will be retained as long as necessary for the fulfilment of the above purposes. That is, we will retain your personal data until the business relationship ends and, after that moment, we will keep them at the disposal of Authorities for the legal time needed, to handle claims or litigation.
Communication of your personal data to third parties
It is informed that the company can count on the collaboration of third party service providers that may have access to your personal data and that will treat it on behalf of SBEB, as a consequence of their provision of the service. Normally, this could include data hosting service providers. SBEB follows a strict selection of service providers in order to comply with its data protection obligations and signs with them the corresponding data processing contract with, among others, the following obligations: apply appropriate technical and organizational measures, treat personal data for the agreed purposes and only according to the instructions, and delete or return the data once the provision of services ends.
Also, within our legal obligations, we must communicate your personal data to the Public Authorities that legally require it (for example, the Tax Agency, Tribunals and Customs Authorities).
In the event that, and to the extent that, your company is subject to a potential sale, your personal data may also be exchanged with potential acquirers in the context of routine due diligence processes prior to the acquisition.
Cross-border transfers of personal data
The technical processing and transmission of your personal data (whether within the Group of Sumitomo Bakelite Co., Ltd. or to third parties) may involve transmissions over various networks, including the transfer of your personal data to other countries.
That may also constitute a transfer to third countries outside the European Economic Area that do not provide an adequate level of personal data protection. In that case, SBEB shall take appropriate safety measures in order to ensure that your personal data are sufficiently protected (for example by concluding standard contractual clauses concerning the transfer of personal data).
Currently, such transfers take place within the Group of Sumitomo Bakelite Co., Ltd., with offices currently located in Japan, Hong Kong, Taiwan, Indonesia, Malasia, Singapur, Tailandia, South Corea, India, United States of America and Canada.
Your rights
You have the right to request access to your personal data, and its correction in the event of inaccuracies. You also have the right to request erasure of your personal data when that data is no longer relevant. Although you may request that your personal data be deleted at any time, we may have to retain certain personal data for contract performance purposes or in order to comply with statutory retention obligations.
In addition, you have the right to object to the processing of your personal data in relation to justified personal circumstances and to request the restriction of the processing in specific circumstances.
Finally, note that you have the right to receive the personal data you have provided to us, in a structured, commonly used and machine-readable format (data portability).
When the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time.
Contact information
If you have any questions or concerns about this statement, any concerns about your personal data being processed as outlined above, or would like to exercise the rights outlined above, please contact us through sending an email at protecciondatos@sumibe.eu, which is the single point of contact.
Data Protection Authority
Finally, please note you have the right to lodge a complaint with respect to the processing of your personal data with the Spanish Data Protection Authority, at www.aepd.es and in Japan at https://www.ppc.go.jp
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