INTRODUCTION

Welcome to the Sumitomo Chemical Asia Pte Ltd’s (“Sumitomo“, “we“, “our“) privacy policy.

Sumitomo respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy here: [LINK]. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. NON-EU AND NON-SWISS DATA SUBJECTS RIGHTS
8. EU AND SWISS DATA SUBJECTS RIGHTS
9. DATA SECURITY
10. DATA RETENTION
11. SECURITY SAFEGUARDS
12. YOUR LEGAL RIGHTS
13. GLOSSARY

1. IMPORTANT INFORMATION AND WHO WE AREPURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how Sumitomo collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product or service OR take part in a competition OR other promotional activities organised by us.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policy and is not intended to override them.

CONTROLLER

We are the controller and responsible for your personal data.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: Sumitomo Chemical Asia Pte Ltd

Email address: dpo@sumitomo-chem.com.sg

Postal address: 3 Fraser Street, #07-28 DUO Tower, Singapore 189352

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. This version was last updated on 13 September 2018.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific wesbite feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Name, Contact, residential address, email and phone contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

      • apply for our products or services;
      • subscribe to our service or publications;
      • request marketing to be sent to you;
      • enter a competition, promotion or survey; or
      • give us feedback or contact us.

  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

    • Technical Data from analytics providers such as Google based outside the EU;

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

 

Type of data

 

Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity

(b) Contact

Performance of a contract or service with you
To process and deliver your order or service including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract or service with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Sharing your personal data with our authorised distributor and/or authorised installers

 

(b) Notifying you about changes to our terms or privacy policy

(c) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

 

(a) Performance of a contract or service with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

 

To enable you to partake in a prize draw, competition or complete a survey (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract or service with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table above.

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • Specific third parties such as our distributors and/or authorised installers for the performance of the contract or services that you have subscribed for.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Sumitomo’s regional headquarters for Asia Pacific is located in Singapore. We may share your personal data within the Sumitomo Company Group. This will involve transferring and/or storing your data outside of Singapore, your country of residence and outside the European Economic Area (“EAA“)

Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

If you are an EU or Swiss resident, where we transfer your personal data outside the EEA and Switzerland, this is done on the basis that it is necessary for the performance of the services or goods we provide you, or that the transfer is subject to the European Commission’s model contracts for the transfer of personal data to third countries (i.e. the standard contractual clauses), pursuant to the Decision 2004/915/EC and Decision 2010/87/EU as appropriate.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. NON-EU AND NON-SWISS DATA SUBJECT RIGHTS
If you are not a resident in the EU (Switzerland excluded), you may have certain rights in relation to your personal data we hold about you, which we detail as below.

Access

You have the right to know whether we process your personal data, and if we do, to access the personal data we hold about you and certain information about how we use it and who we share it with.

Where permitted by law, Sumitomo reserves the right to charge a reasonable administrative fee for this service. In exceptional circumstances, Sumitomo reserves the right to deny you access to your personal data and may provide an explanation as required by applicable laws.

Exceptional circumstances include (to the extent allowable under applicable law) where:

    • an investigating authority or government institution objects to Sumitomo complying with your request
    • the information may, in the exercise of Sumitomo’s reasonable discretion and/or assessment, affect the life or security of an individual; and
    • data is collected in connection with an investigation of a breach of contract, suspicion of fraudulent activities or contravention of law.

Correction

You have the right to correct any personal data held about you that is inaccurate.

Feedback and complaints

If you have any concerns, feedback or complaints about the use and/or sharing of your personal data, we are open to receiving your feedback or complaints.

Exercise of Rights

To exercise any of your rights, please contact dpo@sumitomo-chem.com.sg

8. EU DATA AND SWISS SUBJECT RIGHTS
If you are a resident in the EU or Switzerland, you may have certain rights in relation to the personal data we hold about you, which we detail below. Some of these apply in certain circumstances as set out in more detail below. We also set out how to exercise those rights.

These rights include:

Please note that we will require you to provide us with proof of identity before responding to any request to exercise your rights. We must response to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended by a further two months in certain circumstances). To exercise any of your rights, please use the following form: [LINK] and submit it to dpo@sumitomo-chem.com.sg

Complaints

In the event you wish to make a complaint about how we process your personal data, please contact us and will endeavour to deal with you request as soon as possible. This is without prejudice to your right to launch a claim with your data protection authority.

Access

You have the right to know whether we process your personal data, and if we do, to access your personal data we hold about you and certain information about how we use it and who we share it with.

If you require more than one copy of your personal data we hold about you, we may charge an administration fee.

We may not provide you with certain personal data if providing it would interfere with another’s rights (e.g. where providing personal data we hold about you would reveal information about another person) or where another exemption applies.

Portability

You have the right to receive a subset of the personal data we collect from you in a structure, commonly used and machine-readable format and a right to request that we transfer such personal data to another party.

The relevant subset of personal data is data that you provide us with your consent or for the purposes of performing our contract with you.

if you wish for us to transfer your personal data to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the personal data or its processing once received by the third party. We also may not provide you with certain personal data if providing it would interfere with another’s rights (e.g. where providing personal data we hold about you would reveal information about another person).

Correction

You have the right to correct any personal data held about that is inaccurate. Please note that whilst we assess whether the personal data we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below.

To exercise any of your rights, please use the following form: [LINK] and submit it to dpo@sumitomo-chem.com.sg

Erasure

You may request that we erase the personal data we hold about you in the following circumstances:

      • You believe that it is no longer necessary for us to hold your personal data
      • We are processing your personal data on the basis of our legitimate interest and you object to such processing. Please provide us with details as to your reasoning so that we can assess whether there is an overriding interest for us to retain your personal data
      • You no longer wish us to use your personal data in order to send you promotions, specials offers and marketing offers
      • You believe the personal data we hold about you is being unlawfully processed by us


Also note that you may exercise your right to restrict our processing of your personal data whilst we consider your request as described below.

Please provide as much detail as possible for your reasons for the request to assist us in determining whether you have a valid basis for erasure. However, we may retain personal data if there are valid grounds under law for us to do so (e.g., for the defense of legal claims or freedom of expression) but we will let you know if that is the case. Please note that after deleting the personal data, we may not be able to provide the same level of servicing to you as we will not be aware of your preferences. Where you have requested that we erase your personal data that we have made public and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying your personal data or providing links to your personal data to erase your personal data too.

To exercise your rights, please use the following form: [LINK] and submit it to dpo@sumitomo-chem.com.sg

Restriction of Processing to Storage Only.

You have a right to require us to stop processing the personal data we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal data, we may use it again if there are valid grounds under data protection law for us to do so (e.g. for the defence of legal claims or for another’s protection).

You may request we stop processing and just store the personal data we hold about you where:

      • you believe the personal data is not accurate, for the period it takes for us to verify whether the personal data is accurate;
      • we wish to erase the personal data as the processing we are doing is unlawful but you want us to just store it instead;
      • we wish to erase the personal data as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defence of legal claims; or
      • you have objected to us processing personal data we hold about you on the basis of our legitimate interest and you wish us to stop processing the personal data whilst we determine whether there is an overriding interest in us retaining such personal data.

Objection

At any time you have the right to object to our processing of your personal data in order to send you promotions, special offers, marketing messages, including were we build profiles for such purposes and we will stop processing the personal data for that purpose. You also have the right to object to our processing of personal data about you and we will consider your request in other circumstances as detailed below by using the following form: [LINK] and submitting it to dpo@sumitomo-chem.com.sg

You may object where we are processing the personal data we hold about you (including were the processing is profiling) on the basis of our legitimate interest and you object to such processing.

Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims. Also note that you may exercise your right to request that we stop processing your personal data whilst we make the assessment on an overriding interest by indicating this in our Data Privacy Right Form

9. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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 unauthorised 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, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

11. SECURITY SAFEGUARDS
Sumitomo takes the protection of your personal data seriously but, unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted through the website; and transmission is at your own risk.

12. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at dpo@sumitomo-chem.com.sg

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

13. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

INTERNAL THIRD PARTIES

Other companies in the Sumitomo Group acting as joint controllers or processors and who are based Singapore and Japan and provide IT and system administration services and undertake leadership reporting.

EXTERNAL THIRD PARTIES

  • Service providers acting as processors based in Singapore who provide IT and system administration services.

  • Professional advisers including lawyers, bankers, auditors and insurers based in the South East Asia region (including Singapore) who provide consultancy, banking, legal, insurance and accounting services.

  • Our authorised services providers, including distributors and/or authorised installers based in Singapore, Australia, Vietnam, Indonesia, Malaysia, Thailand, Philippines, Sri Lanka, Cambodia, Myanmar and India to perform or provide the products and services that you have subscribed for in your respective countries.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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