LAST UPDATED: March 25, 2020
- Through our service providers, including our marketing automation software
- In offline interactions you have with us
Collectively, we refer to our Websites, email messages, and offline activities as the “Services”).
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual.
Personal information includes:
- Contact information
- Email address
- Company affiliation
Collection of Personal Information
We and our service providers collect Personal Information in a variety of ways, including:
- Through the Services
- We collect Personal Information through the Services, for example, when you sign up for announcements, download a whitepaper or contact us through the Websites about a particular product.
- We collect Personal Information from you offline, for example:
- When you visit our booth at a tradeshow or provide data at industry events;
- When you visit our facilities;
- When you contact us over the phone or through postal mail;
- When you or someone on your behalf reports an adverse event with respect to one of our products.
- From other Sources
- We receive your Personal Information from other sources, for example:
- Publicly available databases and sources;
- Joint marketing partners, when they share the information with us.
Use of Personal Information
We and our service providers use Personal Information for legitimate business purposes including:
- Providing the functionality of the Services and fulfilling your requests.
- To provide the Services’ functionality to you, such as providing you with customer service;
- To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about our Services;
- To complete your transactions, and provide you with related customer service;
- To send administrative information to you, such as changes to our terms, conditions and policies.
We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
- Providing you with our newsletter and/or other marketing materials and facilitating social sharing
- To send you marketing related emails, with information about our services, new products and other news about our company.
We will engage in this activity with your consent or where we have a legitimate interest.
- Analysis of Personal Information for business reporting and providing personalized services.
- To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services;
- To better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests;
- To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.
We will provide personalized services either with your consent or because we have a legitimate interest.
- Aggregating and/or anonymizing Personal Information.
- We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.
- Accomplishing our business purposes.
- For data analysis, for example, to improve the efficiency of our Services;
- For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;
- For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
- For developing new products and services;
- For enhancing, improving, or modifying our current products and services;
- For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users;
- For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
Disclosure of Personal Information
We disclose Personal Information:
- You can consult the list and location of domestic subsidiaries and affiliates here and our overseas subsidiaries and affiliates here.
- Mitsui Chemicals America, Inc. is the party responsible for the management of the jointly-used Personal Information.
- To our third party service providers, to facilitate services they provide to us.
- These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
- To comply with applicable law and regulations.
- This can include laws outside your country of residence.
- To cooperate with public and government authorities.
- To respond to a request or to provide information we believe is important;
- These can include authorities outside your country of residence.
- To cooperate with law enforcement.
- For example, when we respond to law enforcement requests and orders or provide information we believe is important.
- For other legal reasons.
- To enforce our terms and conditions;
- To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
- In connection with a sale or business transaction.
- We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings.) Such third parties may include, for example, an acquiring entity and its advisors.
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual:
- Browser and device information
- App usage data
- Information collected through cookies, pixel tags and other technologies
- Demographic information and other information provided by you that does not reveal your specific identity
- Information that has been aggregated in a manner such that it no longer reveals your specific identity
If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.
Collection of Other Information
We and our service providers may collect Other Information in a variety of ways, including:
- Through your browser or device:
- Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
- Using cookies
- Using pixel tags and other similar technologies
- Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
- IP Address
- Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.
Uses and Disclosures of Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
CHOICES AND ACCESS
Your choices regarding our use and disclosure of your Personal Information
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by visiting our “Sign-Up” webpage, clicking the unsubscribe link at the bottom of our promotional emails, or notifying us in accordance with the “Contacting Us” section below.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
How you can access, change or delete your Personal Information
If you would like to request to review, correct, update, suppress, restrict or delete Personal Information, object to the processing of Personal Information, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us by telephone at +1 914-253-0777 or by direct mail at Mitsui Chemicals America, Inc., 800 Westchester Avenue, Rye Brook, NY 10573. We will respond to your request consistent with applicable law.
For your protection, we may only implement requests with respect to the Personal Information associated with the particular person and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase you may not be able to change or delete the Personal Information provided until after the completion of such purchase).
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.
The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
THIRD PARTY SERVICES
THIRD PARTY ADVERTISING
We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services.
Use of Services by MINORS
The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18.
Jurisdiction and CROSS-BORDER TRANSFER
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
ADDITIONAL INFORMATION REGARDING THE EEA: Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here [hyperlink to EU Commission’s adequacy list online: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en]. For information regarding our transfer mechanism from the EEA to countries not considered adequate, please contact us at: https://eu.mitsuichemicals.com/contact/index.htm
Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.
ADDITIONAL INFORMATION REGARDING THE EEA
You may also:
- Contact our Data Protection Officer (DPO) responsible for your country or region, if applicable. Please see https://eu.mitsuichemicals.com/siteinfo/privacy.htm for contact information.
- Contact our German DPO. Please see https://eu.mitsuichemicals.com/siteinfo/privacy.htm for contact information.
- Lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available at https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.