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Privacy Policy

 

 

SAE

Group

Rule 

Privacy Notice (External)

SAEG-Z-G-1

Effective Date:

April 2021

Revision 1.0

 

Reviewer: C. White,

Projects Director

Date Reviewed:

15.03.2021

Next review:

April 2022

Owner / Authoriser: K. Ichinose,

EVP & CFO

Date Authorised:

31.03.2021


The Privacy notice (external) is detailed on subsequent pages.
This cover page provides details relating to this document’s version control.

 

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal information about you. When we do so we are responsible as ‘controller’ of that personal information.
We have a branch in Germany, the details of which are set out below.

Key terms
It would be helpful to start by explaining some key terms used in this policy:

We, us, our

Sumi Agro Europe Limited (company number: 03073407)

Vintners Place, 68 Upper Thames Street, London EC4V 3BJ

Our EU branch

HRB 238742 Amtsgericht München

Bürgermeister-Neumeyr-Straße 7; 85391 Allershausen

Personal information

Any information relating to an identified or identifiable individual

Special category personal information

Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership

Genetic and biometric data

Data concerning health, sex life or sexual orientation

Personal information we collect about you

  • We may collect and use the following personal information about you:
  • your name and contact information, including email address and telephone number and company details
  • Information to enable us to check and verify your identity, e.g. your date of birth
  • your gender information, if you choose to give this to us
  • location data, if you choose to give this to us
  • your billing information, transaction and payment card information
  • your personal or professional interests
  • information to enable us to undertake credit or other financial checks on you
  • information about how you use our website, IT, communication and other systems
  • your responses to surveys, competitions and promotions

 If you do not provide your information it may not be possible for us to provide any goods or services.


How your personal information is collected
We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information:

  • from publicly accessible sources, e.g. Companies House;
  • directly from a third party, e.g.:
  • sanctions screening providers;
  • credit reference agencies; or
  • customer due diligence providers.
  • from a third party with your consent, e.g. your bank or building society
  • via our IT systems, e.g.:
  • door entry systems and reception logs; and
  • automated monitoring of our websites and other technical systems, such as our computer networks and connections, access control systems, communications systems, email and instant messaging systems.


How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

  • to comply with our legal and regulatory obligations;
  • for the performance of our obligations under a contract or to take steps before entering into a contract;
  • for our legitimate interests or those of a third party; or
  • where you have given consent.


A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. Our legitimate interests may be that we are carrying or may carry on business with your employer.
The table below explains what we use (process) your personal information for and our reasons for doing so:

 

What we use your personal information for

Our reasons

To provide products to you

For the performance of a contract or to take steps before entering into a contract

To prevent and detect fraud against you or us

For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for you

Conducting checks to identify our customers and verify their identity

Screening for financial and other sanctions or embargoes

Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator

To comply with our legal and regulatory obligations

Ensuring business policies are adhered to, e.g. policies covering security and internet use

For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you.

Operational reasons, such as improving efficiency, training and quality control

For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price

Ensuring the confidentiality of commercially sensitive information

For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information

To comply with our legal and regulatory obligations

Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures

For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price

Preventing unauthorised access and modifications to systems

For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you

To comply with our legal and regulatory obligations

Updating and enhancing customer records

For the performance of our contract with you or to take steps at your request before entering into a contract

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products

Statutory returns

To comply with our legal and regulatory obligations

Ensuring safe working practices, staff administration and assessments

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

Marketing our goods and/or services and those of selected third parties to:

—existing and former customers; 

—third parties who have previously expressed an interest in our goods and/or services;

—third parties with whom we have had no previous dealings.

For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers

Credit reference checks via external credit reference agencies

For our legitimate interests or those of a third party, i.e. to ensure our customers are likely to be able to pay for our products and goods and/or services

External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts

For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards

To comply with our legal and regulatory obligations

Promotional communications
We may use your personal information to send you updates (by email, text message, telephone or post) about our products, including exclusive offers, promotions or new products.
We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell it with other organisations outside the Sumi Agro group for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:

  • contacting us at  sumi@sumiagro.com; or
  • using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts.


We may ask you to confirm or update your marketing preferences if you instruct us to provide further products in the future, or if there are changes in the law, regulation, or the structure of our business.

 

Who we share your personal information with
We routinely share personal information with:

  • companies within the Sumitomo group, the details of which are set out at https://www.sumitomocorp.com/en/jp/about/company/scgroup/business/corporate
  • third parties we use to help deliver our products to you, e.g. payment service providers, warehouses and delivery companies;
  • other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
  • third parties approved by you, e.g. social media sites you choose to link your account to or third party payment providers;
  • credit reference agencies;
  • our insurers and brokers; and
  • our bank/s

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide goods and/or services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO or Investors in People accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

 

Where your personal information is held
Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
Some of these third parties may be based outside the European Economic Area or the UK. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the UK and EEA’.


How long your personal information will be kept
We will keep your personal information while you have an account with us or we are providing products to you/your employer. Thereafter, we will keep your personal information for as long as is necessary:

  • to respond to any questions, complaints or claims made by you or on your behalf;
  • to show that we treated you fairly; and/or
  • to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

 

Transferring your personal information out of the UK and EEA
To deliver goods and/or services to you, it is sometimes necessary for us to share your personal information outside the UK and/or European Economic Area (EEA), e.g.:

  • with our offices or other companies within our group located outside the UK/EEA;
  • with your and our service providers located outside the UK/EEA;
  • if you are based outside the UK/EEA; or
  • where there is an international dimension to the goods and/or services we are providing to you.


These transfers are subject to special rules under European and UK data protection law. This means we can only transfer your personal information to a country or international organisation outside the UK/EEA where:

  • the European Commission or the relevant UK authorities have issued an ‘adequacy decision’ in relation to that country or international organisation;
  • there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
  • a specific exception applies under data protection law.

 

Further information
If you would like further information about data transferred outside the UK or EEA, please contact us (see ‘How to contact us’ below).

Your rights
You have the following rights, which you can exercise free of charge:

Access

The right to be provided with a copy of your personal information (the right of access)

Rectification

The right to require us to correct any mistakes in your personal information

To be forgotten

The right to require us to delete your personal information—in certain situations

Restriction of processing

The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data

Data portability

The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

To object

The right to object:

—at any time to your personal information being processed for direct marketing (including profiling);

—in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.

Not to be subject to automated individual decision making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

If you would like to exercise any of those rights, please:

  • email, call or write to us - see below: ‘How to contact us’; and
  • let us have enough information to identify you;
  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
  • let us know what right you want to exercise and the information to which your request relates.

 

Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

 

How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
You have the right to lodge a complaint at any time with a supervisory authority, this may be where you work, normally live or where any alleged infringement of data protection laws occurred. The UK supervisory authority Information Commissioner who may be contacted at https://ico.org.uk/concernsor telephone: +44 303 123 1113.

 

Changes to this privacy policy
This privacy notice was published on 28.04.2021.
We may change this privacy notice from time to time — when we do we will inform you via our website.


How to contact us
Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.
Our contact details are shown below:

Our contact details

Vintners Place, 68 Upper Thames Street, London EC4V 3BJ

sumi@sumiagro.com