Privacy Policy

The Group has established and will maintain a framework to appropriately protect personal data; formulate a compliance program to ensure that its officers and employees fully protect personal data; and continuously implement and improve such framework and program.

In every process of obtaining, using, disclosing, and administering personal data, the Group will handle such personal data in a secure and accurate manner and in the most recent state, and thoroughly implement security control measures, including those enumerated below, to prevent the leakage of, and unauthorized access to, personal data:

1. (1)Establishment of basic policies
   To ensure the appropriate handling of personal data, the Group has established basic policies, including this Privacy Policy.
2. (2)Maintenance of rules on the handling of personal data
   The Group will maintain rules on obtaining, using, disclosing, and handling personal data, as well as internal rules and regulations that set forth the responsibilities of the persons handling personal data.
3. (3)Organized security control measures
   The Group will maintain the framework necessary to protect personal data, for which our president is ultimately responsible.
4. (4)Human security control measures
   The Group has implemented on-the-job trainings and other instruction courses on the handling of personal data.
5. (5)Physical security control measures
   The Group has implemented security control measures to prevent theft, loss, and the like of instruments, electronic media, documents, or the like that handle personal data.
6. (6)Technical security control measures
   The Group has implemented access controls where restrictions have been placed on the scope of access for the handling persons according to the content of the personal data.
7. (7)Understanding the external environment
   For cases where personal data is stored abroad, the Group has implemented appropriate security control measures after understanding the system in the relevant foreign country concerning the protection of personal data.

The Group may also contract out a part of its business and provide personal data to its consignees to the extent necessary to fulfill the purpose of the use of the personal data. In such cases, the Group will enter into an agreement with each consignee concerning the handling of personal data and appropriately administer and supervise them.

The Group collects the following personal data about customers from the customers themselves, companies belonging to the Group, the Group's business partners, and others, through written documents and web forms filled out by customers, business cards provided by customers, customers' use of the Group's products or services, and collaboration with the Group.
You are free to decide whether to provide personal data to the Group; however, if you do not provide the personal data required by the Group, you may not be able to use all or part of the Group's products or services.

1. (1)Customer information
   The name, email address, phone number, physical address, date of birth, age, sex, and nationality, as well as the name and location of, section and title/position in, the company a customer is working at, account information, including SNS, and other customer information.
2. (2)Details of transactions with the Group
   Information concerning the details of customers' transactions, purchase history, bank accounts, payment information of credit cards or the like, and other information generated in the course of customers' transactions with the Group.
3. (3)Information generated from the use of the Group's website
   The registered ID, password, IP address, browsing history of and date/time of access to the website, information concerning terminals/OS/browsers or the like that customers are using, location information, other status of use of the services, as well as analytical findings based on such information (such as information concerning the Group's products and services which customers are presumed to be concerned with or interested in), and other information generated from the customers' use of the Group's website.
4. (4)Information arising from collaboration with the Group
   Information regarding the work location, work hours, nature of work, and health and safety of customers affiliated with the Group's Partner Companies (which refers to entities that collaborate with the Group at factories, business offices, or other facilities managed by the Group based on a contractual relationship with the Group) during their collaboration with the Group, as well as other information provided to the Group by the customers themselves or by the Group's Partner Companies.
5. (5)Other information
   Information concerning the customers' comments, requests, inquiries, replies to surveys to and communication or the like with the Group, records of customers' entry into and exit from the Group's offices, security camera footage, and other information provided to the Group based on any involvement of the customers with the Group.

The Group will use the customers' personal data for the following purposes and for any other purposes separately notified to, or otherwise made known to, customers:

1. (1)Performance of contracts to which the Group is a party and related communications
   1. a.Providing and receiving products and/or services pursuant to the terms of the subject contracts, and settlements thereunder.
   2. b.Verification of identity and communication on requisite matters concerning the subject contracts.
   3. c.Arrangements, shipments, and after-sale services for products and/or services used by the customers.
   4. d.Responses to comments, requests, inquiries, and other matters concerning the contracts.
2. (2)Promotions regarding the Group's products and services.
   1. a.Information concerning products and/or services and promotions, including newsletters, mail magazines, and advertisements.
   2. b.Promotions on various campaigns, trade exhibitions, and the like.
3. (3) Planning/development/analysis/improvements of the Group's products, services and the like.
   1. a.Planning/development of new products/services
   2. b.Analysis, quality improvement of, and enhancement of customer service concerning existing products/services.
   3. c.Investigation and analysis of the status of sales and usage as well as planning and development using the results thereof.
   4. d.Implementation/analysis/measurement of effects/use of survey research associated with marketing activities.
4. (4)Improvement of, and other activities concerning, the Group's website.
   1. a.Improvement of user-friendliness and other qualities of the website.
   2. b.Planning/development of new services based on the usage status of the website.
5. (5)Responses to comments/requests/inquiries to the Group.
6. (6)Rendering services consigned to the Group.
7. (7)Implementation of safety measures by the Group.
   1. a.Crime prevention measures at offices, factories, business locations, and other facilities managed by the Group.
   2. b.Access control and other security measures regarding information systems, websites, applications, and other systems managed by the Group.
   3. c.Implementation of various safety-related measures—including labor management, occupational safety and health management, and response to workplace accidents—necessary for the Group and the Group's Partner Companies to conduct their business.
8. (8)Compliance with legal obligations and various requests applicable to the Group (including reporting to domestic and international regulatory authorities, judicial and administrative agencies, and exchanges; cooperation with audits conducted by such entities, verification of anti-money laundering and credit information; and responses to crimes, fraud, and other inappropriate conduct), conducting necessary investigations, other governance-related measures within the Group (including monitoring and auditing compliance with laws, regulations, and internal policies), and the exercise of the Group's rights.
9. (9)Implementation of other responses associated with fulfilling the aforementioned purposes.
   In order to achieve the above purposes, we may analyze personal data described in Section 3 above (such as personal attributes and service usage history) using AI and other technologies to provide recommendations based on customer's interests, preferences, and purchasing trends, and to improve our products, services, website, and other offerings.

Depending on the country or region where you reside and the nature of the Group's business activities, foreign laws may apply to our handling of personal data, in which case a legal basis for such handling may be required. The legal basis in such cases is as follows.

1. (1)Performance of contracts to which the Group is a party
   The Group uses customers' basic information and contact details to fulfill contracts to which the Group is a party.
2. (2)Promotions regarding the Group's Products and/or Services
   The Group uses customers' basic information and contact details to provide information on the Group's products and services. The legal basis for this processing is our legitimate interest in providing customers with better options by delivering information on products and services, or the customer's consent.
3. (3)Planning, development, analysis, and improvement of the Group's products, services, and other offerings
   The Group uses personal data regarding customers' usage of the Group's products and services, as well as their feedback, for the planning and development of the Group's products and services, and other offerings. The legal basis for this processing is our legitimate interest in continuously improving the safety and quality of our products and services we provide to customers.
4. (4)Improvements to the Group's website, etc.
   The Group may use personal data we collect when you use the Group's websites, products, and services to improve our websites and other services. The legal basis for this processing is our legitimate interest in making the Group's websites more convenient and user-friendly for customers.
5. (5)Responses to comments/requests/inquiries to the Group
   The Group may use the information concerning comments and other communications given it to respond to customers regarding the same. The legal basis for this processing is the performance of the contract with the customer, or the customer's consent.
6. (6)Rendering services consigned to the Group
   The Group may use the customers' personal data to render services consigned to the Group. The legal basis for this processing is the legitimate interest in providing more fulfilling services to customers.
7. (7)Implementation of Security measures by the Group
   The Group may use personal data regarding customers' usage of the Group's offices, information systems, and other resources to implement security measures within the Group. The legal basis for this processing is our legitimate interest in implementing more appropriate security measures or the Group's compliance with legal obligations.
8. (8)The Group's responses to statutory obligations and requirements
   The Group may use the customers' personal data to respond to statutory obligations.

The Group shall not disclose or provide the personal data obtained thereby except for cases that fall under any of the following items:

1. (1)In cases where prior consent by the customer is obtained.
2. (2)In cases where it is necessary to protect the life, body, or property of an individual, and it is difficult to obtain the customer's consent.
3. (3)In cases where it is specifically necessary for the enhancement of public health or furtherance of the healthy nurturing of children, and it is difficult to obtain the customer's consent.
4. (4)In cases where it is necessary to cooperate with a national or local government or other entities in implementing public affairs and there is a risk of hindering the implementation of such public affairs by obtaining the customer's consent.
5. (5)In cases where the relevant third party is an academic research institution or a similar entity and such personal data is required to be handled for the purpose of using the same in academic research (including cases where a part of the purpose of handling the personal data is for academic research except where there is a risk of unjustly infringing on an individual's rights and interests).
6. (6)Other cases in accordance with applicable laws and regulations.

The Group may jointly use customers' personal information as follows:

1. (1)Joint use by the Group
   1. a.Personal data to be jointly used: The personal data specified in Section 3 above.
   2. b.Scope of the joint users: The Group (For a list of major group companies, please see here.).
   3. c.Purposes of use by the joint users: The purposes of use specified in section 4 above.
   4. d.The company in charge of administering the joint use of personal data: ENEOS Holdings, Inc.
2. (2)Joint use with the Group's Partner Companies
   1. a.Personal data to be jointly used: The personal data specified in Section 3 above.
   2. b.Scope of Joint Users: The Group and the Group's Partner Companies
   3. c.Purposes of Use by Joint Users: The purposes of use defined in Section 4(7) above.
   4. d.The company in charge of administering the joint use of personal data : ENEOS Holdings, Inc.

In cases where the Group provides personal data to a third-party in a foreign country, including a consignee of services and/or joint user, the Group shall take the necessary and appropriate measures to ensure the proper protection of personal data in accordance with applicable laws and regulations, such as entering into cross-border data transfer agreements or standard contractual clauses and verifying adequacy determinations.

The Group shall retain the customers' personal data only for the period necessary to fulfill the purposes of use of the customers' personal data, to comply with applicable laws and regulations or to address customers' requests. Upon termination of the retention period, the Group shall delete the customers' personal data or implement measures to retain such personal data in a manner where such personal data cannot be used to identify the customers.

A cookie is a small text file downloaded in the browser of a device (such as a computer or smart phone) and used when a customer accesses a website. Through the use of cookies, the Group can recognize the device of a customer, and obtain information concerning the customer's browsing history, status of use of the website, and other related information.
The Group uses "Google Analytics" of Google LLC and Microsoft Clarity. While Google Analytics and Microsoft Clarity collect, record, and analyze the user's status of using this service, the Group utilizes the findings therefrom to improve the Group's website.
For the structure in which data is collected and processed through Google Analytics and Microsoft Clarity, please see (https://policies.google.com/technologies/partner-sites) and (https://www.microsoft.com/en-us/privacy/privacystatement).

Depending on applicable laws and regulations, customers may be entitled to the following rights: In cases where an inquiry by a customer is received concerning the handling of his/her own personal data (limited to information specified as the subject of the disclosure or other similar rights by applicable laws and regulations, such as the "personal data held by the business" stipulated under Japanese law, hereinafter the same shall apply in this section 11), or cases where a request is made for the exercise of any of the following rights, the Group shall appropriately and quickly address the same after confirming that the inquiry or the request was made directly by the customer:

1. (1)Notification of purposes of use of personal data or disclosure of personal data.
2. (2)Correction, addition, or deletion of personal data.
3. (3)Suspension of use of personal data or the provision thereof to third parties.
4. (4)Objections regarding the handling of personal data, such as profiling and direct marketing
5. (5)Data Portability of personal data
6. (6)Withdrawal of consent
7. (7)Opting out of "sales" and "sharing" as defined by applicable laws and regulations
8. (8)Restrictions on the handling of sensitive personal data
9. (9)Filing an objection with the competent supervisory authority
10. (10)Not to be subjected to discriminatory treatment for exercising any of the foregoing rights

The Group may amend all or a part of this Privacy Policy. In case of an amendment, notice on the details thereof shall be provided on the Group's website.

ENEOS Corporation (the "Company") endeavors to provide more appropriate services to the customers who use its website (the "Website") while respecting their privacy by optimizing the user-friendliness thereof.
This Policy explains the details of the cookies used to make the Website easier to use as well as the measures taken to accommodate customers who do not wish to use such cookies.