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Privacy Notice for data subjects in EEA and the UK

1. About this notice

J-Oil Mills, Inc. (“we”, “us” and “our”) will process your personal data in compliance with all applicable laws and any laws that replace them in the future. In this notice, we have provided information for data subjects in member countries of the European Economic Area (“EEA”), and the UK based on such laws related to the processing of your personal data. This notice sets out the basis on which any personal data that you provide to us, or that we obtain about you from other sources, will be processed by us. Please take the time to read and understand this notice.

2. Definitions

In this notice:

  1. your “personal data” means any information relating to an identified or identifiable natural person (“data subject”);
  2. “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction; and
  3. “controller” means a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of processing of personal data.

3. Categories of personal data we will collect

We will collect following categories of personal data.

  1. Name
  2. E-mail address
  3. Telephone number
  4. Address
  5. Company name / position
  6. Gender
  7. Date of birth
  8. Academic background
  9. Photographic portrait
  10. Details of your communications, inquiries, and responses
  11. Cookies
  12. Technical information about your equipment to access our website
  13. Your interactions with our website
  14. Other personal data we will collect to pursue purposes of use in 4 below. We will notify categories of such personal data separately if required to do so.

4. How we will collect your personal data

We may collect your personal data directly from you or through third parties such as our service providers. When you visit our websites, we may automatically collect, store, and use technical information about your equipment to access our website and your interaction with our website. This information will be sent from your computer to us using a variety of cookies.

The provision of your personal data may be mandatory for reasons such as being a statutory or contractual requirement, or being a necessary requirement for entering into a contract. If you don’t provide such personal data, we may not be able to provide services or products to you.

5. Legal bases and purpose of processing personal data

  1. Legal Obligations. This refers to cases where we are required to comply with a legal obligation.
  2. Legitimate Interests. This refers to cases where the processing of your personal data is necessary for legitimate interests pursued by us or a third party, such as promoting our business, and your interests and fundamental rights do not override those interests.
  3. Contractual Obligations. This refers to cases where processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  4. Consents. This refers to cases where you have given your consent to us for purposes of processing your personal data. However, even if we obtain such consent from you, we may process your personal data based on other legal grounds. The withdrawal of your consent (please see Section 9(g) of this notice below) will not affect the lawfulness of us processing your personal data based on the consent given before your withdrawal.

We will use the personal data that we hold about you for the purposes below. We will only use your personal data to the extent that it is necessary to do so to fulfil the purposes described below.

  1. To provide our products and services ; based on (c) Contractual Obligations, but if it is not necessary for performance of or executing the contract, then based on (b) Legitimate Interests.
  2. To conduct sales promotion activities (including e-mail distribution) such as advertisement, promotion, and implementation of questionnaires for our products and services; based on (b) Legitimate Interests, but based on (d) Consents, if consent is required for e-privacy regulations especially direct marketing regulations.
  3. To develop and improve our products and services; based on (b) Legitimate Interests.
  4. To create statistical information regarding our products and services; based on (b) Legitimate Interests
  5. To communicating with you including responding to inquiries to us ; based on (b) Legitimate Interests
  6. To analyze information such as browsing history and purchase history obtained, and to advertise products and services in accordance with browsing and purchase trends; based on (b) Legitimate Interests, but based on (d) Consents, if consent is required for e-privacy regulations to require consents of data subjects for obtaining information stored in the terminal equipment of a user including cookies other than strictly necessary ones.
  7. To manage shareholders, to provide shareholders with information on our business activities, and to exercise rights, fulfill obligations, provide information, and communicate with shareholders in accordance with other laws and regulations; based on (b) Legitimate Interests.
  8. To conduct our recruitment activities; based on (b) Legitimate Interests.
  9. To comply with any laws and regulations applicable to us and to cooperate with relevant governmental authorities and agencies, including competent data protection authorities and those that are engaged in administrative or criminal investigations; based on (a) Legal Obligation if it is a legal obligation under the EU law, EU member state laws, or the UK law, but based on (b) Legitimate Interests for other cases.

If we process your “sensitive data” (information about your race, ethnic origin, religion, physical or mental health, political opinions, sexual life, any actual or alleged criminal offences, or genetic and biometric data), we will take necessary steps.

6. Disclosure of personal data to recipients

We may share your personal data with recipients in the situations described below:

  1. Internal Use by us: Our employees who are authorized and need to access such data.
  2. Affiliates: We share your personal data with our affiliates for internal administrative purposes and uses that are consistent with this notice.
  3. Service Providers: We share your personal data with third-party service providers who perform services, such as providing data servers.
  4. Legal Process and Safety: We may disclose your personal data to legal or government regulatory authorities as required by any applicable laws. We may also disclose your personal data to third parties as required by any applicable laws in connection with claims, disputes, or litigation, when otherwise required by any applicable laws, or if we determine that its disclosure is necessary to protect the health and safety of you or others, or to enforce our legal rights or contractual commitments that you have made.
  5. Business Transfers: Your personal data may be disclosed as part of a corporate business transaction, such as a merger, acquisition, company split, business transfer, joint venture, or the financing or sale of company assets, and could be transferred to a third party as one of the business assets in such a transaction. It may also be disclosed in the event of insolvency, bankruptcy, or receivership.

7. Transfer of personal data outside the European Economic Area and the United Kingdom

The personal data that we hold about data subjects in the EEA and/or UK may be transferred to, and stored by, a third party outside the EEA and/or the UK. In cases where we transfer such personal data outside the EEA and/or the UK, we will ensure that:

  1. the recipient destination has been subject to a finding by the European Commission that it ensures an adequate level of protection for the rights and freedoms that the data subjects possess in respect of their personal data and/or the Government of the UK has specified the recipient destination as a country that ensures an adequate level of protection as provided under the Data Protection Act 2018 (For adequacy decision to Japan, please refer here.); or
  2. the recipient enters into standard data protection clauses with us that have been approved by the European Commission and/or the Government of the UK.

You can obtain more details of the protection given to the personal data when it is transferred outside the EEA and/or the UK (including a copy of the standard data protection clauses which we have entered into with recipients of the personal data) by contacting us using the information about us indicated in Section 12.

8. Storage limitations of personal data

We retain personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for compliance and protection purposes.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

9. Your rights

You have a number of legal rights in relation to the personal data that we hold about you. These rights may vary depending on where you are located and which data protection laws apply to the relationship between you and us, but will typically include:

  1. the right to obtain information regarding the processing of your personal data and to access the personal data that we hold about you;
  2. the right to request rectification of your personal data if it is inaccurate or incomplete;
  3. the right to request erasure of your personal data in certain circumstances. This may include (but is not limited to) circumstances in which:
    1. it is no longer necessary for us to retain your personal data for the purposes for which we collected it;
    2. we are only entitled to process your personal data with your consent, and you withdraw such consent; or
    3. you object to our processing of your personal data for legitimate interests, and such legitimate interests do not override your own interests, rights, or freedoms;
  4. the right to request that we restrict our processing of your personal data in certain circumstances. This may include (but is not limited to) circumstances in which:
    1. you dispute the accuracy of your personal data (but only for the period of time necessary for us to verify its accuracy);
    2. we no longer need to use the personal data except for the establishment, exercise, or defence of legal claims; or
    3. you object to our processing of your personal data for legitimate interests (but only for the period of time necessary for us to assess whether such legitimate interests override your own interests, rights, or freedoms);
  5. the right to object to our processing of your personal data;
  6. the right to receive any personal data which we process about you on the basis of your consent (as opposed to any other legal ground) and where such processing is carried out by automated means in a structured, commonly used, and machine-readable format and/or to request that we transmit that data to a recipient where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;
  7. the right to withdraw your consent to our processing of your personal data at any time. However, this right only exists where we are relying on consent to process your personal data. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal. Please note that we may still be entitled to process your personal data if we can rely on another legal ground for doing so;
  8. the right not to be subject to automated decision-making: If certain conditions are satisfied, you have the right not to be subject to solely data-based, automated decision-making (including profiling) that produces any legal or similar material effect on you.

You can exercise your rights by contacting us using the information about us indicated below in Section 12. You can also lodge a complaint with the competent data protection authority here located in countries where you live, if you are in the EEA or to the Information Commissioner’s Office, if you are in the UK if you believe that any of your rights have been infringed by us.

10. Changes to this privacy notice

We may modify this notice from time to time and will post an updated notice as necessary. We recommend that you review this notice periodically. If we make any material changes to this notice, you will be provided with appropriate notice, such as notice of such change being posted on our website.

11. Links to Third-Party Websites

Our website may contain links to and from third-party websites. These websites and any services that may be accessible through them have their own privacy policies. We are not responsible for other websites’ privacy practices. Please take note when you leave our website and read the privacy policies applicable to third-party websites.

12. Contacts

Any questions, comments, or requests regarding this notice are welcome. Please contact us using the information below.

Name : J-Oil Mills, Inc.
Address : St. Luke’s Tower, 8-1 Akashi-cho, Chuo-ku, Tokyo, Japan
E-mail Address : privacy＠j-oil.com (*When sending e-mail, replace ＠ as one-byte characters (@).)