Global Privacy Policy for Amano Enzyme Group

Effective date: [February 27th, 2024]

Last updated: [February 27th, 2024]

Amano Enzyme Group Companies (“Amano Enzyme Group Companies,” “we,” or “our”; meaning the companies set out in the Group Companies Information page of our website; the same applies hereinafter) process the personal data of customers and other similar trading partners of Amano Enzyme Group Companies (including potential trading partners and persons who access our websites; the same applies hereinafter) and shareholders of Amano Enzyme Group Companies and job applicants for Amano Enzyme Group Companies (for customers and other similar trading partners, and shareholders, that are companies, including the officers, employees, and the like of such companies; the same applies hereinafter) (collectively, “Data Subjects,” unless specified otherwise) as follows.

We may prescribe individual privacy policies, and in this case, if this Global Privacy Policy conflicts with an individual privacy policy, then such individual privacy policy will prevail to the extent that such conflict exists.

Amano Enzyme Group Companies process the following personal data (including, in this Article, personal information under the Act on the Protection of Personal Information of Japan).

• Personal identity and contact detail information.
  Name, address, name and location and division of the corporation to which the customer or other similar trading partner belongs, job type, job title, contact information such as telephone number, e-mail address, and fax number, facial portrait, ID card number, passport number, date of birth, gender, age, nationality, signature, and other information stated on the Data Subject’s business card, information on electronic systems or online information, information taken by a camera, and information on social media

• Business transaction information.
  Sales negotiation histories and information regarding details of transactions (including details of products and services to which a customer subscribed, details of sales negotiations, and details of inquiries and estimates)

• Website usage information.
  Cookies, IP addresses, provider information, terminal information, web browser information, user activities (time of day when the website was visited, session length, frequency, transitions, traffic sources, clicks in the website, and scrolling in the website), attributes (such as age, gender, interest categories, and affinity categories; for more information about interest categories and affinity categories, please see here (About Demographics and Interests – Analytics Help (google.com)))

• Other information
  Other personal data necessary for the purpose set out in section 2. below

• Contact detail and shareholding information
  Name, address, contact information such as e-mail address, number of shares owned, date of share acquisition, shareholder number, dividend payment history, account for dividends

• Personal identity information.
  ID card number, passport number, date of birth, gender, age, nationality, signature, information on electronic systems or online information, information taken by a camera

• Other information.
  Other personal data necessary for the purpose set out in section 2. below

• Personal identity and contact detail information.
  Name, address, contact information such as telephone number, e-mail address, and fax number, ID card number, passport number, date of birth, gender, age, nationality, signature, school history, job history, facial portrait, reason to work with us and other information stated on the documents for application (including in an electromagnetic manner) or provided with that documents as attachment, information on electronic systems or online information, information taken by a camera, information on social media

• Website usage information.
  Cookies, IP addresses, provider information, terminal information, web browser information, user activities (time of day when the website was visited, session length, frequency, transitions, traffic sources, clicks in the website, and scrolling in the website), attributes

• Other information.
  Other personal data necessary for the purpose set out section 2. below

Amano Enzyme Group Companies process personal data (including, in this Article, personal information under the Act on the Protection of Personal Information of Japan) for the following purposes and other similar purposes permitted by applicable laws and regulations. In addition, Amano Enzyme Group Companies may de-identify or aggregate personal data.

• To introduce and sell products and services to customers

• To execute agreements with a customer, to confirm the details of the products and services, and to provide products and services to which a customer subscribed

• To request various questionnaires to customers

• For sales promotion of products and services and for PR activities of Amano Enzyme Group Companies

• To respond to various inquiries, feedback, and requests

• For communications and interviews regarding executing agreements, sales negotiations, and arrangements with trading partners (suppliers, service providers, etc.), and placing orders and engaging in communication with trading partners

• For conducting direct marketing activities including sending e-mail newsletters and advertising e-mails

• To confirm the existence, status, and the like of invoices and payment of usage fees for products and services of customers and any other trading partners

• To upgrade and improve existing products, services, and promotional activities and to develop new products and services (including upgrading, improvement, and development based on questionnaire surveys, market research, analysis of customer trends, and other such necessary analysis)

• To use Data Subjects’ information for the smooth operation and improvement of the services provided in our websites such as by analyzing Data Subjects’ information that we obtain when a customer accesses our websites

• To report, submit, cooperate, and conduct various procedures to government agencies and various industry organizations

• For audit, operation of internal report system, and to otherwise prevent and deal with unjust acts

• To manage health and safety, such as preventions or countermeasures relating to communicable diseases or epidemics, etc.

• To upgrade or update, etc. computers and systems, etc. of Amano Enzyme Group Companies

• To perform obligations and exercise rights under applicable laws

• To conduct administrative work regarding shares

• To deal with exercise of rights by shareholders

• To perform obligations and exercise rights under applicable laws (including the Companies Act)

• To manage health and safety, such as preventions or countermeasures relating to communicable diseases or epidemics, etc.

• To upgrade or update, etc. computers and systems, etc. of Amano Enzyme Group Companies

• To communicate other matters

• For recruitment and screening of applicants of Amano Enzyme Group Companies

• To use Data Subjects’ information for the smooth operation and improvement of the services provided in our websites such as by analyzing Data Subjects’ information that we obtain when a customer accesses our websites

• To report, submit, cooperate, and conduct various procedures to government agencies and various industry organizations

• For audit, operation of internal report system, and to otherwise prevent and deal with unjust acts

• To manage health and safety, such as preventions or countermeasures relating to communicable diseases or epidemics, etc.

• To upgrade or update, etc. computers and systems, etc. of Amano Enzyme Group Companies

• To perform obligations and exercise rights under applicable laws

• To communicate other matters

Amano Enzyme Group Companies process the personal data in accordance with the legal bases under the applicable data protection regulations (such as the consent of the Data Subject, performance of contractual obligations, legitimate interests, and compliance with laws and regulations).

The provision of the personal data may be mandatory for various reasons, such as being a statutory or contractual requirement or being a necessary condition for entering into a contract. Specific details are as follows.

• The provision of information such as cookies that are strictly necessary for the use of Amano Enzyme Group Companies’ websites and user activities obtained by those cookies, IP addresses, and types of web browsers is a necessary condition for using our websites. If the Data Subject does not provide this information, the Data Subject might not be permitted to use our websites.

• In any other case where the Data Subject does not provide us with the Data Subject’s personal data despite the fact that the provision of that personal data is a necessary condition, Amano Enzyme Group Companies might not be able to provide the Data Subject with products, services, or the like of Amano Enzyme Group Companies (including our websites). If the Data Subject does not provide personal data of job applicants for Amano Enzyme Group Companies required by Amano Enzyme Group Companies, the Data Subject may not be able to apply for employment at, or be considered for any hiring or screening conducted by Amano Enzyme Group Companies.

• The provision of the name, address, e-mail address, number of shares owned, date of share acquisition, shareholder number, dividend payment history, and account for dividends of the shareholder is mandatory as a contractual requirement. If the shareholder does not provide us with this information, the shareholder might not be able to exercise rights or perform obligations under the Companies Act or other laws or regulations.

In order to decide the appropriate retention period for personal data, Amano Enzyme Group Companies consider the following: the volume, nature, and confidentiality of the personal data; the potential risk of damage caused by unjust use or disclosure of the personal data; the purposes for which Amano Enzyme Group Companies process the personal data, and whether Amano Enzyme Group Companies can achieve those purposes by other means; and applicable legal requirements. If the Data Subject’s personal data collected by Amano Enzyme Group Companies becomes no longer necessary, Amano Enzyme Group Companies will delete or anonymize the personal data, or if such measures are impracticable (for example, if the personal data has been stored in back-up archives), we will retain the Data Subject’s personal data safely until its deletion becomes practicable and ensure that any new processing will not be conducted with respect to the Data Subject’s personal data.

Amano Enzyme Group Companies obtain the Data Subject’s personal data directly from the Data Subject (including in cases where personal data is obtained automatically). However, we may obtain the Data Subject’s personal data indirectly from a third party other than the Data Subject in the following cases.

• When obtaining personal data from other companies within Amano Enzyme Group Companies

• When a customer or any other similar trading partner is an entity, and Amano Enzyme Group Companies obtain the personal data of the entity’s officers and employees from the entity

• When obtaining personal data from website traffic analysis service providers, such as Google LLC

• Any other cases where personal data is lawfully obtained from a third party (including public information)

• When a shareholder is an entity, and Amano Enzyme Group Companies obtain the personal data of the entity’s officers and employees from the entity

• Any other cases where personal data is lawfully obtained from a third party (including public information)

• When obtaining personal data from employment agencies, job search websites, or the like

• Any other cases where personal data is lawfully obtained from a third party (including public information)

Amano Enzyme Group Companies may share personal data set out in “1. Categories of personal data subject to processing” above with third parties in the following cases:

• sharing of personal data with other Amano Enzyme Group Companies to fulfil the purpose stated in “2. Purpose of processing” above (*);

• sharing of personal data with processors (meaning service providers that provide services necessary for the business activities of Amano Enzyme Group Companies; including distributors of products and services, service providers that provide cyber security services, credit reference agencies, banks and financial institutions, employment agencies and job search websites, website traffic analysis service providers such as Google LLC, attorneys, accountants, financial advisors, and the like) to fulfil the purpose stated in “2. Purpose of processing” above;

• sharing of personal data associated with the corporate sale, merger, acquisition, or other transfer of all or part of our assets;

• sharing of personal data that is required by laws or orders of governmental agencies and the like;

• sharing of personal data with a third party that is (i) necessary for the protection of the life, body, or property of Amano Enzyme Group Companies, the Data Subject, or a third party, and (ii) permitted by applicable data protection regulations;

• sharing of personal data with the consent of the Data Subject; and

• sharing of personal data that is otherwise permitted under applicable data protection regulations.

(*) Regarding joint use of personal data under the Act on the Protection of Personal Information of Japan
With regard to the processing of personal data to which the Act on the Protection of Personal Information of Japan applies, Amano Enzyme Group Companies may jointly use personal data stated in “1. Categories of personal data subject to processing” above to fulfil the purpose stated in “2. Purpose of processing” above on the grounds of joint use under the Act on the Protection of Personal Information of Japan. Amano Enzyme Inc. (Address: 1-2-7 Nishiki, Naka-ku, Nagoya-shi, Aichi-ken, Japan 460-8630; Representative: Motoyuki Amano) shall be responsible for the management of personal data that is jointly used.

Amano Enzyme Group Companies may transfer personal data to the following countries and regions and other countries and regions to which transfer of personal data is required to fulfil the purpose stated in “2. Purpose of processing” above:

• United States

• United Kingdom

• Japan

• China

• Thailand

• Vietnam

Upon transferring personal data to any of the countries and regions listed above, Amano Enzyme Group Companies take appropriate protection measures required by the data protection regulations of that country or region.

Amano Enzyme Group Companies will take necessary and appropriate measures such as countermeasures against unauthorized access and countermeasures against computer viruses to prevent loss, destruction, falsification, leaking, and the like of personal data. Amano Enzyme Group Companies will exercise necessary and appropriate supervision over employees of Amano Enzyme Group Companies, and contractors, etc. to protect personal data.

Cookies and other technologies are used on the websites of Amano Enzyme Group Companies. A cookie is a technology used to identify the browser used to browse a website. If you prefer to avoid the use of cookies, you may reject cookies for the website in question, or change the settings in your internet browser so that cookies are rejected, deleted, or deactivated. Detailed information on the cookies used on our website can be viewed by clicking the gear icon on the lower left side of the page, where you can also configure your cookie preferences.

Amano Enzyme Group Companies may use Google Analytics for analytics and marketing purposes.

With Google Analytics, customer information is collected using cookies, etc. For more information about how Google Analytics collects and uses information when a Data Subject uses our websites, please visit http://www.google.com/policies/privacy/partners.

To opt out of Google Analytics, please visit https://tools.google.com/dlpage/gaoptout.

Amano Enzyme Group Companies respect the rights the Data Subjects hold under the applicable data protection regulations of each country or region. For example, to the extent granted under the applicable data protection regulations of each country or region, each of the Data Subjects may have rights such as the following: right to access; right to rectification; right to erasure; right to restriction of processing; right to objection to processing; right to withdraw consent (it may be granted if the Data Subject has given consent regarding certain types of processing activities; however, the Data Subject’s withdrawal of consent does not affect the lawfulness of processing conducted based on the Data Subject’s consent before the withdrawal.); right to data portability; and right not to be subject to automated decision-making. The Act on the Protection of Personal Information of Japan grants the right to request the following in relation to retained personal data (meaning retained personal data prescribed in Article 16, paragraph 4 of the Act on the Protection of Personal Information of Japan): notification of the purpose of use; disclosure; correction, addition, or deletion of content; suspension of use, erasure, or suspension of third-party provision; and disclosure of records of third-party provision (meaning records of third-party provision prescribed in Article 37, paragraph 2 of the Act on the Protection of Personal Information of Japan).

A Data Subject wishing to exercise the Data Subject’s rights granted under the data protection regulations of the country or region in question may contact us using the contact details stated in “11. Contact details” below.

For questions and inquiries regarding this Global Privacy Policy, please contact us using the contact details below:

Amano Enzyme Inc. Marketing Office, Business Development Div.

Contact Form

Please check section 6 above for the address of Amano Enzyme Inc. and the name of its representative.

If Amano Enzyme Group Companies intend to amend this Global Privacy Policy, we may amend all or part of, or make an addition to, this Global Privacy Policy by publishing that amendment or addition on our websites, sending an e-mail to that effect to our customers, or giving notice by any other method that Amano Enzyme Group Companies deem appropriate. In such a case, the post-amendment version of this Global Privacy Policy will be applied from the earlier of the date on which you use a product or service of Amano Enzyme Group Companies or access our websites for the first time after receiving such notice, or the date stated in such notice.

Amano Enzyme Group Companies process the following types of personal data for the following purposes, based on the legal bases set out below:

When Amano Enzyme Group Companies transfer personal data to countries or regions outside the EEA or the UK, such transfers will be (1) based on an adequacy decision adopted by the European Commission or the UK Government (such as transfers to Japan); (2) based on the European Commission’s Standard Contractual Clauses and/or the UK Addendum to those clauses approved by the UK Government; or (3) based on a derogation provided under applicable laws. If you would like further information about how we legitimize the transfer of your personal data or if you would like to see a copy of the relevant documents, please contact us at the details above in section 11 (Contact details).

Subject to applicable law, you have the following rights over your personal data:

• the right to obtain confirmation as to whether or not we process your personal data, and, where that is the case, the right to access your personal data and certain information about how we process your personal data;

• the right to have incomplete or inaccurate personal data corrected;

• the right to require us to delete your personal data in some circumstances;

• the right to restrict the use of your personal data;

• the right to ask us to stop processing your personal data;

• the right to request that we “port” the personal data you have provided to us in a structured, commonly used and machine-readable format to you or a third party (where this is possible); and

• the right to withdraw any consents you have provided at any time. Withdrawal of consent does not affect the lawfulness of prior processing of personal data based on that consent.

If you wish to exercise any of the rights set out above, please contact us at the details above in section 11 (Contact details).

The contact details of representatives of Amano Enzyme Group Companies are as follows:

• Representative in the EEA: GvW Graf von Westphalen GmbH
  Email: dsb@gvw.com

• Representative in the UK: Amano Enzyme Europe Ltd.
  Contact Form

You may contact us at the details above if you have any questions about this Global Privacy Policy or if you would like to exercise any of your rights over your personal data.

You have the right to lodge a complaint about Amano Enzyme Group Companies’ practices with respect to your personal data with the relevant supervisory authority.

• If you are in the EEA, you can find contact details of your local competent data protection supervisory authority (“DPA”) here.

• If you are in the UK, you can contact the UK Information Commissioner’s Office here.

Detailed information on the cookies used on our website can be viewed by clicking the gear icon on the lower left side of the page, where you can also configure your cookie preferences.

This Exhibit contains disclosures required by the California Consumer Privacy Act of 2018, as amended by the California Rights Protection Act of 2020 (“CCPA”). This information should be read together with rest of the Global Privacy Policy, which more comprehensively discusses our processing activities.

Consistent with section 1 (Categories of personal data subject to processing), section 2 (Purpose of processing), section 5 (Sources of personal data), and section 6 (Sharing of personal data) of the Global Privacy Policy, we collect, process, and disclose certain categories and specific pieces of information about individuals that are considered “personal information” under the CCPA. In particular, we have collected and disclosed the following categories of personal data from consumers within the last twelve (12) months:

We also may use each of the categories of personal data described above, currently and within the last twelve (12) months, to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, for example, develop, improve, repair, and maintain our products and service; personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other business internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims. For information about the categories of personal data processed for each processing purpose, please see section 1 (Categories of personal data subject to processing) and section 2 (Purpose of processing) of the Global Privacy Policy.

We may collect certain categories of personal data from the sources described in section 5 (Sources of personal data) of the Global Privacy Policy, currently and within the last twelve (12) months.

Please note that in the preceding twelve (12) months, we have not sold your personal data or shared such information for cross context behavioral advertising. Amano Enzyme Group Companies do not have actual knowledge that they sell or share the personal data of individuals under 16 years of age.

If you are a California resident, you or your authorized agent may make the following requests subject to certain exceptions:

• Right to request notice of and access to certain information about our collection and use of your personal data. Once we receive and confirm your verifiable request, we may disclose to you:

• The categories of personal data we collected about you and the categories of sources from which we collected such personal data,

• The specific pieces of personal data we collected about you,

• The business or commercial purpose for collecting personal data about you, and

• The categories of personal data about you that we otherwise shared or disclosed, and, for each, the categories of third parties with whom we shared or to whom we disclosed such personal data (if applicable);

• Right to request that we correct personal data about you that is inaccurate; and

• Right to request that we delete your personal data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete or de-identify (and direct our service providers to delete or de-identify) your personal data from our records, unless an exception applies.

None of these rights are absolute and there may be circumstances in which we are required or permitted under applicable law not to address your request. Amano Enzyme Group Companies will not discriminate against you for exercising any of your rights permitted by law.

We do not provide a right to limit our use of sensitive personal data, because in the event that we collect certain sensitive personal data, we do not use it to infer characteristics such that we would be required to provide a right to limit.

If you are a California resident and wish to exercise any of the rights described in this section, you or your authorized agent may contact us at the details above in section 11 (Contact details).

You must include your name, street address, city, state, and zip code in your request. You may be asked to provide additional proof of identification so that we can verify your identity and validate the request.

To the extent that you elect to designate an authorized agent to make a request on your behalf, the above methods to submit a verifiable request apply. Your authorized agent will be required to provide proof that they are authorized to represent you and verify your identity. Please note that you are limited by law in the number of requests you may submit per year.