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Privacy Policy

1. Introduction

This Privacy Policy (“Policy”) provides information on the personal data processing by Shin-Etsu Silicones Europe B.V. in the Netherlands, as well as in Germany, France, and Hungary. Shin-Etsu Silicones Europe B.V. is a private company with limited liability established under Dutch law, having its statutory seat in Almere, and its registered office at Bolderweg 32, 1332 AV Almere, the Netherlands. We collectively refer to ourselves as “Shin-Etsu,” “we,” or “us.”

You can reach Shin-Etsu via the following contact details:

Address: Bolderweg 32, 1332 AV Almere
Telephone number: +31-(0)36-5493170

Shin-Etsu is part of a global network, with its headquarters in Tokyo, Japan.

This Policy applies to the personal data that identify or may identify a natural person (“Personal Data”).

For queries and inquiries about this Policy, please contact the Data Privacy Officer (“DPO”):

Office phone: +31-(0)36-5493170
E-mail: gdpr@shinetsusilicones.eu

2. Handling of Personal Data

This Policy sets out the elements necessary for Shin-Etsu’s compliance with applicable privacy legislation, principles, and practices, including but not limited to the General Data Protection Regulation (GDPR) (“applicable laws”). The Policy is an external policy directed towards parties with whom Shin-Etsu conducts business, such as business partners, clients, vendors, customers, and suppliers of Shin-Etsu (“users” or “you”). This Policy applies to the processing of Personal Data, in which Shin-Etsu acts as the data controller, within the meaning of the applicable laws. This is the case when Shin-Etsu determines the purpose and the means for the processing of Personal Data of users. When conducting business with Shin-Etsu, you may be asked to provide your Personal Data (e.g., by email). If this is the case, Shin-Etsu and our partners shall be required to keep such information confidential.

Personal Data mentioned herein and defined by Shin-Etsu refers to information of all kinds related to each individual person that is transmitted to Shin-Etsu by users.

The categories of Personal Data that Shin-Etsu collects and processes include:

  • Full name
  • Company name
  • Business address
  • Business email address
  • Business telephone number
  • Mobile number
  • Position title
  • Country
  • Nationality
  • Location
  • Date and time of visit
  • Purpose of visit
  • Order history
  • Payment history
  • Video images (camera surveillance)
  • Business bank account number

Shin-Etsu processes Personal Data for the following purpose(s):

  • Order processing
  • Customs procedures
  • Client communication
  • Communication
  • Surveillance
  • Access control
  • Purchasing products
  • Delivery of products
  • Quality control
  • Incident reporting
  • Customer relation management
  • Supplier management
  • Credit limit management

Shin-Etsu processes these Personal Data because they are necessary for the performance of a contract, for the fulfillment of a legal requirement, or where there is a legitimate interest of Shin-Etsu or a third party. This includes conducting business activities or ensuring the security of personnel or premises of Shin-Etsu.

Shin-Etsu retains the Personal Data for no longer as necessary for the purposes for which the Personal Data are processed. This means that in Personal Data relevant for the financial administration of Shin-Etsu (such as contracts) will be retained for a period of 7 years after the ending of the contractual relationship. Customers, suppliers, clients, and guest/client administration records will not be stored longer than 2 years after the transaction is concluded.

4. Security of your Personal Data

Shin-Etsu handles your Personal Data carefully and confidentially, and uses all suitable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data.

5. Transfer of your Personal Data

Your information may be accessed or transferred by Shin-Etsu entities and other third parties as outlined in this Policy.

Group entities
Personal Data may be shared with Shin-Etsu’s group entities in compliance with applicable laws, for purposes consistent with this Policy. Where Shin-Etsu’s group entities qualify as processors or (joint) controllers, Shin-Etsu will enter into an agreement with them.

Vendors and suppliers
Shin-Etsu occasionally hires other companies to provide services on its behalf, including service providers. Shin-Etsu will only provide companies the information they need to deliver the service, and they are prohibited from using that information for any other purpose. Where these vendors and/or suppliers qualify as processors, Shin-Etsu will enter into a data processing agreement with them.

Law enforcement purposes
In certain circumstances, it is possible that Personal Data may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders. Shin-Etsu may disclose Personal Data in case such disclosure is mandatory under applicable laws or is reasonably judged to be essential in order to protect and safeguard the rights, property and safety of other users, Shin-Etsu itself, and/or Shin-Etsu's affiliates.

Sale or merger of business
Circumstances may arise where, whether for strategic or other business reasons, Shin-Etsu decides to sell, buy, merge or otherwise reorganise businesses. Such a transaction may involve the disclosure of Personal Data to prospective or actual purchasers, or receiving it from sellers. It is Shin-Etsu's practice to seek appropriate protection for information in these types of transactions.

Transfer of data to third countries
Shin-Etsu may transfer Personal Data to a third country or international organisations outside of the EU/EEA, which shall take place only in compliance with the applicable laws, and where appropriate safeguards are or will be in place that ensure the level of protection of users as required by the applicable laws. These safeguards include entering into EU Model Clauses with the recipient of the Personal Data who is established outside the EU/EEA.

6. Rights in relation to Personal Data

Users have the right of information, access, rectification, addition and erasure of Personal Data, and the right to object against or restrict the processing of Personal Data (or withdraw an earlier given consent), as well as the right to data portability (where applicable). The procedure of Shin-Etsu that enables you to exercise your rights, is described below.

You may file a request for access with Shin-Etsu, and Shin-Etsu shall respond as soon as possible, and in any event within one (1) month, about: a) whether Shin-Etsu holds any Personal Data relating to you; and, b) if so, information is provided on the purposes of the processing, the categories, the recipients (if applicable), retention periods, the rights of the Data Subject and the source(s) of the Personal Data.

With regard to exercising your rights please contact us via: gdpr@shinetsusilicones.eu.

You also have the right to correct, restrict, amend, add, erase and/or transport the Personal Data. Shin-Etsu informs within one (1) month after receiving the request whether the request shall be complied with (in time), and if not, accompanied with the reasons for the delay or rejection.

Shin-Etsu will comply with a legitimate request if the Personal Data are indeed factually incorrect, incomplete, or irrelevant for the purpose(s) of the data processing, or otherwise processed in violation with the applicable laws.

With regard to a request to erase Personal Data, it should be taken into account that Shin-Etsu shall not comply with such request, if it is incompatible with any legal obligations of Shin-Etsu.

If a request is allowed, Shin-Etsu shall execute the decision to correct, amend, erase and/or transport the Personal Data as soon as possible.

In the event of concerns about the handling of Personal Data, users also have the right to lodge a complaint with a local supervisory authority (in the Netherlands: Autoriteit Persoonsgegevens / in Germany: Bundesbeauftragte für den Datenschutz und die Informationsfreiheit(BfDI) / in France: Commission Nationale de l’Informatique et des Libertés (CNIL) / in Hungary: Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH)).

7. Modifications in this Policy

Shin-Etsu reserves the right to review and/or alter the Policy periodically, in order to comply with (local and/or European) legislation, and for any other purpose deemed reasonably necessary by Shin-Etsu. The latest version of this Policy can be requested at Shin-Etsu.

8. Questions and inquiries

For queries and inquiries about this Policy of Shin-Etsu, please contact: gdpr@shinetsusilicones.eu.