JX METALS PRIVACY POLICY

Last updated: May 30, 2023

JX Metals Corporation (hereinafter referred to as "JX Metals", "we","us" or "our") and companies of JX Metals Group (hereinafter collectively referred to as "our group") have established the following privacy policy for the treatment of personal data within JX Metals Group. JX Metals Group will comply with this policy as well as the Act on the Protection of Personal Information of Japan ("APPI"), the General Data Protection Regulation ("GDPR") and other applicable laws and regulations (hereinafter collectively referred to as "applicable data protection laws"). For more information about JX Metals Group, please visit the JX Metals website.

We may provide further details required by applicable data protection laws in appendix(ces). In the event of a conflict between this privacy policy and the appendix(ces), the appendix(ces) shall prevail to the extent of such conflict.

1. PERSON IN CHARGE (Controller)

JX Metals and each JX Metals Group company are in charge of the processing of your personal data.

2. WHAT DATA DO WE COLLECT?

We collect the following categories of your personal data:

  1. (1)The user's name, email address, zip code, address, telephone number, etc.
  2. (2)The user's age, date of birth, gender, job, company name, etc.
  3. (3)The user's hobbies or interests, magazines to which the user subscribes, etc.
  4. (4)Services the user uses, the user's interests and hobbies, etc.
  5. (5)Where you are candidates for employment, education background, employment background, preference for employment pattern or compensation, information included in curriculum vitae, resume and any supporting documentation, background check information, communication with us in hiring process.

We collect your personal data either directly from you or from our JX Metals Group companies which have direct business relations with you.

3. PURPOSE

We process your personal data described above for the following purposes:

  1. a.For contact / responses to business partners (including personal customers and businesses that may become business partners; hereinafter the same shall apply) regarding work / transactions.
  2. b.To propose and notify, give information about, and provide products and services to business partners.
  3. c.To carry out subcontracted work in cases where JX Metals Group receives products or services from a business partner or is entrusted with processing of personal information.
  4. d.To plan, research and develop, and improve the products or services of JX Metals Group.
  5. e.For hiring activities of JX Metals Group.
  6. f.To respond to legal obligations or demands (including reports to domestic and international regulatory bureaus, judicial / administrative agencies, and stock exchanges and responding to audits thereof).
  7. g.To enable users who use our membership services to login without having to input their password each time they visit this website
  8. h.To statistically process data on users' activity on this website for the purpose of improving our services
  9. i.To provide users with services that are relevant to their interests and to customize services to satisfy each individual user
  10. j.To identify the source of and solve any server related problems that arise
  11. k.For administration of this website

4. LAWFUL BASES FOR PROCESSING YOUR PERSONAL DATA

We process your personal data for the purposes above on the following lawful bases:

Purpose of Processing Your Data Lawful Basis
a. For contact / responses to business partners regarding work / transactions. Legitimate interest of customers/prospect customers and us
b. To propose and notify, give information about, and provide products and services to business partners. Legitimate interest of customers/prospect customers and us
d. To plan, research and develop, and improve our products or services. Our legitimate interest
e. For hiring activities. Taking steps at your request prior to entering into an employment contract
f. To respond to legal obligations or demands. Compliance with legal requirements
g. To enable users who use our membership services to login without having to input their password each time they visit this website Legitimate interest of customers/prospect customers and us
h. To statistically process data on users' activity on this website for the purpose of improving our services Our legitimate interest
i. To provide users with services that are relevant to their interests and to customize services to satisfy each individual user Legitimate interest of customers/prospect customers and us
j. To identify the source of and solve any server related problems that arise Our legitimate interest
k. For administration of this website Our legitimate interest

5. SENSITIVE PERSONAL DATA

We do not usually collect your sensitive personal data (also known as special categories of personal data) as defined in applicable data protection laws. When we collect your sensitive personal data, we will obtain your explicit consent in accordance with applicable data protection laws.

6. PERSONAL DATA OF CHILDREN

When we collect personal data of a child, we will we ask the child to provide explicit consent or the parent or guardian to provide consent in accordance with applicable data protection laws.

7. USE OF COOKIES

We use cookies for the following reasons.

  1. (1)To prevent users who use our membership services from having to input their password each time they visit this website.
  2. (2)To statistically process data on users' activity on this website for the purpose of improving our services.
  3. (3)To provide users with services that are relevant to their interests and to customize services to satisfy each individual user.

Notice Regarding Cookies:

A cookie is a small amount of data sent to your browser from a web site and stored on your computer's hard drive as a file.
A web site may use cookies to track the pages you have visited, in order to customize and enhance services.
A membership website may offer services suitable to the needs of each customer, by using cookies and the information registered by the customer.


8. REJECTION OF COOKIES

You can choose whether to allow us or third-parties (e.g. our analytics partner) to set cookies which are not strictly necessary for the functioning of the website via the cookie banner or the Cookie Settings button below.




In addition, your browser can be set to block cookies or to display a warning message when cookies are received. Most services on this website can be used without cookies. However, without cookies the services may be limited, and you may not be able to use some services.

9. RETENTION - How long do we retain your personal data?

We retain your personal data as long as it is necessary for the purposes described in section 3 above or consistent with applicable laws. We will delete or anonymize your personal data when we no longer need it in accordance with applicable data protection laws and our established procedures.

10. DISCLOSURE - Who do we share your personal data with?

As shown in the table below, we disclose certain categories of your personal data in so far as necessary for the purposes described above to the respective recipients.

Categories of Jointly Used Personal Data Recipients Country of establishment of the recipients
  • Your basic personal data to identify and contact you
  • Your business interaction with us
  • Your inquiries
JX Metals Group companies Available in the same webpage
  • Your interaction with our website
Google, our web-analytics service provider Google: USA

We may also disclose your personal data to our local distributors or sales agents to provide you with our products or services.

Where such recipients are data processors who process data on behalf of us, we make sure that such data processors have in place appropriate data protection measures by virtue of data processing contracts between such processors and us in compliance with applicable data protection laws.

11. CROSS-BORDER DATA TRANSFER

Where our disclosure of your personal data as described in section 10 above constitutes cross-border transfer of personal data to a country without a decision by a relevant authority that the county ensures an adequate level of personal data protection, we take appropriate data protection measures as required by such applicable data protection laws. If you have any inquiry about such data protection measures, please contact us as described in section 17.

12. ENTRUSTMENT OF PROCESSING PERSONAL DATA

We may entrust the processing of your personal data to our group companies or other third parties (collectively referred to as “entrusted entities”) to the extent necessary to achieve the purposes as described in section 3 above. In these cases, we take appropriate measures to ensure that such entrusted entities processing your personal data with reasonable and appropriate safeguard, including selection of proper entrusted entities and conclusion of agreements on the processing of personal data.

Where our disclosure of your personal data to entrusted entities constitutes cross border data transfer, we take appropriate measures to protect your personal data as described in section 11 above.

13. JOINT USE OF PERSONAL DATA

We jointly use your personal data as shown in the table below.

Categories of personal data to be disclosed Those described in section 2 of this privacy policy
Scope of Joint Users JX Metals Group companies

ENEOS Holdings, Inc.

Purpose for Joint Use Those described in section 3 of this privacy policy
Entity Responsible for Joint Use JX Metals Corporation

14. HOW DO WE KEEP SECURITY OF YOUR DATA?

JX Metals Group takes the following measures that are necessary and appropriate to prevent divulgence, loss, impairment, and any other mistreatment of personal data.

Formulation of Basic Policy

In order to ensure the proper processing of personal data, JX Metals Group has formulated this privacy policy concerning matters such as compliance with applicable data protection laws and points of contact for inquires.

Establishment of Personal Data Processing Rules

JX Metals Group has formulated regulations regarding how to process persona data, responsible persons, their duties, and other items related to the processing of personal data for each stage, including collection, use, retention, provision, and deletion and disposal of personal data.

Institutional Safety Management Measures

In addition to appointing a person responsible for the processing of personal data, JX Metals Group has clarified the employees who process personal data and the scope of personal data processed by such employees according to the type, content, and importance of the personal data processed. JX Metals Group has also established a system for reporting to the person responsible when employees identify any violation of laws or our processing regulations, or signs thereof.

Personnel Safety Management Measures

JX Metals Group provides employees with necessary and appropriate training on matters they should keep in mind regarding the processing of personal data. In addition, matters concerning confidentiality of personal data are set out in the processing regulations.

Physical Safety Management Measures

In areas where personal data is processed, JX Metals Group monitors the entry into and exit of employees from relevant rooms as well as restricts the equipment and other devices they bring in, alongside implementing measures for preventing unauthorized persons from accessing personal data. In addition, JX Metals Group takes measures to prevent theft or loss of equipment with personal data, electronic media, and documents, and implements measures to ensure personal data is not easily identified when such equipment, electronic media, and documents are carried around, including their transfer within the office.

Technical Safety Management Measures

JX Metals Group controls access to personal data in order to limit the scope of persons in charge and of personal information databases that are processed. In addition, JX Metals Group has mechanisms in place for protecting information systems that process personal data from unauthorized external access or unauthorized software.

15. REQUEST FOR NOTICE CONCERNING THE PURPOSE OF USE, DISCLOSURE, AMENDMENT TO AND SUSPENSION OF USE OF PERSONAL DATA

If JX Metals Group is requested from a person to disclose, amend, add, delete or suspend the use of or cancel, or stop providing to any third party or give notice concerning the purpose of use of, his/her Personal Data held by JX Metals Group pursuant to applicable data protection laws, JX Metals Group will confirm that such person who made such request is the person of the relevant personal information and respond to such request properly in accordance with applicable data protection laws.

If you would like to exercise any of these rights, or if you have any inquiries about your rights, please contact us using the contact information in section 17 below.

16. COMPLAINT

You can lodge complaints about our way of processing your personal data with data protection supervisory authorities in accordance with applicable data protection laws.

17. INQUIRIES

In the case of any inquiry regarding this privacy policy or any processing of personal data in JX Metals Group, please contact the following:

  1. (1)Inquiries to JX Metals:Contact Us
  2. (2) Inquiries to other companies in the JX Metals Group
    Please refer to the contact information of the respective company here and contact the company. If you inquire at the location listed above in (1), please be aware we may forward your inquiry to the respective Group company.

18. AMENDMENT TO THIS PRIVACY POLICY

JX Metals Group may modify this privacy policy as necessary, and any such modification will be posted on this website.

APPENDIX: PRIVACY POLICY FOR CALIFORNIA RESIDENTS

Last updated: MM DD, 2023

This privacy policy for California residents ("CA privacy policy") supplements the JX Metals privacy policy, explains your privacy rights if you are a California resident and provides our notice at collection of your personal information. This CA privacy policy also describes how JX Metals Group collects, uses, discloses and protects personally identifiable information of California residents and any information related to it (collectively "personal information") both online and offline. In the event of a conflict between this CA privacy policy and the JX Metals privacy policy, this CA privacy policy prevails. Certain terms used in this CA privacy policy have the meanings defined in the California Consumer Privacy Act, as amended, and its regulations (collectively "CCPA").

1. Notice of Collection of Personal Information

1.1. Categories of Personal Information We Collect

We collect the following categories of your personal information from the following sources:

Categories of Personal Information Sources
(1) Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers.
  • You
  • JX Metals Group companies
(2) Characteristics of protected classifications under California or federal law (e.g., gender, age).
  • You
  • JX Metals Group companies
(3) Commercial information, including, products purchased or considered, or other purchasing histories or tendencies.
  • You
  • JX Metals Group companies
(4) Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with our website, mobile application, or advertisement.
  • You
(5) Geolocation data.
  • You
(6) Professional or employment-related information.
  • You
  • Recruiting service providers
(7) Audio, electronic, visual, thermal, olfactory, or similar information (e.g., recording of inquiry calls).
  • You
  • JX Metals Group companies
(8) Inferences drawn from any of the above information to create a profile about you reflecting your preferences.
  • You

1.2. Business or Commercial Purposes for Which We Collect Personal Information

We collect and use your personal information listed in section 1.1 above for the following purposes:

Purposes Categories of Personal Information
a. For contact / responses to business partners (including personal customers and businesses that may become business partners; hereinafter the same shall apply) regarding work / transactions. (1), (2), (3), (7)
b. To propose and notify, give information about, and provide products and services to business partners. (1), (2), (3), (7), (8)
c. To plan, research and develop, and improve the products or services of JX Metals Group. (3), (4), (5), (7)
d. For hiring activities of JX Metals Group. (1), (6)
e. To respond to legal obligations or demands (including reports to domestic and international regulatory bureaus, judicial / administrative agencies, and stock exchanges and responding to audits thereof). (1), (2), (3), (6), (7)
f. To enable users who use our membership services to login without having to input their password each time they visit this website (1), (4)
g. To statistically process data on users' activity on this website for the purpose of improving our services (1), (4)
h. To provide users with services that are relevant to their interests and to customize services to satisfy each individual user (1), (2), (3), (4), (5), (7), (8)
i. To identify the source of and solve any server related problems that arise (1), (4)
j. For administration of this website (1), (4)

1.3. Your Right to Opt Out of Sale of Sharing of Personal Information

You have the right to opt out of "sale" or "sharing" of your personal information to/with third parties. Those terms are defined in the CCPA. As described at section 2.5 below, we have not sold or shared and will not sell or share your personal information to/with third parties. If we sell or share your personal information, we will inform you about what categories of your personal information will be sold or shared for what purposes and how to exercise your right to opt out of the sale or sharing as required in the CCPA.

2. Right to Know About Personal Information Collected, Disclosed, Sold or Shared

2.1.
The CCPA states you have the right to request us to disclose what personal information we collect, use, disclose, sell and share.
2.2.
You can exercise your above-mentioned rights, unless you have exercised the rights within preceding 12 months. We endeavor to respond to you within 45 days of receiving a verifiable request. If you intend to exercise such rights, please refer to section 9.
2.3.
We use your information (unique personal identifier, such as name, postal address and date of birth) to verify your request.
2.4.
We have collected the categories of personal information listed in section 1.1 above about California residents in the preceding 12 months.
2.5.
We have not sold or shared in the preceding 12 months personal information including personal information of children to/with third parties and will not sell or share personal information to/with third parties.
2.6.
We have disclosed in the preceding 12 months and will disclose the following categories of personal information as below:
Categories of Personal Information disclosed Recipients
Identifiers
  • JX Metals Group companies
Characteristics of protected classifications under California or federal law
  • JX Metals Group companies
Commercial information
  • JX Metals Group companies
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with our website, mobile application, or advertisement.
  • Google, our web-analytics service provider
Geolocation data
  • Google, our web-analytics service providers
Professional or employment-related information.
  • JX Metals Group companies
Audio, electronic, visual, thermal, olfactory, or similar information (e.g., recording of inquiry calls).
  • JX Metals Group companies

2.7.
We only allow JX Metals Group companies and our service provider(s) to process your personal information when we have confirmed that they take appropriate measures to protect your personal information. We also impose contractual obligations on JX Metals Group companies and our service provider(s) to ensure that they can only use your personal information for purposes set forth in agreements with us as required in the CCPA. We may also provide personal information to external auditors.
2.8.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
2.9.
We may also need to disclose some personal information to other parties, such as potential buyers of some or all of our businesses or during a re-structuring. Usually, information will be anonymized, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations. We will not share your personal information with any third parties other than those described in this CA privacy policy.

3. Right to Request Deletion of Personal Information

3.1.
The CCPA states you have the right to request us to delete your personal information collected by us.
3.2.
You can exercise your above-mentioned rights, unless you have exercised the rights within preceding 12 months. We endeavor to respond to you within 45 days of receiving a verifiable request. If you intend to exercise such rights, please refer to section 9.
3.3.
We use your information (unique personal identifier, such as name, postal address, date of birth) to verify your request.

4. Right to Request Correction of Inaccurate Personal Information

4.1.
The CCPA states you have the right to request us to correct inaccurate personal information about you.
4.2.
You can exercise your above-mentioned rights, unless you have exercised the rights within preceding 12 months. We endeavor to respond to you within 45 days of receiving a verifiable request. If you intend to exercise such rights, please refer to section 9.
4.3.
We use your information (unique personal identifier, such as name, postal address, date of birth) to verify your request.

5. Right to Opt-Out of the Sale or Share of Personal Information

The CCPA states you have the right to opt-out of the sale or sharing of your personal information by us. We have not sold or shared and will not sell or share your personal information to/with third parties as described in section 2.5 above. If we sell or share of your personal information, we will inform you about what categories of your personal information will be sold or shared for what purposes and how to exercise your right to opt out of the sale or sharing as required in the CCPA.

6. Use and Disclosure of Sensitive Personal Information

We do not usually collect your sensitive personal information. If we collect your sensitive personal information, we do not use or disclose your sensitive personal information for any purposes other than performing the services or providing the goods requested by you, as authorized under the CCPA.

7. Right to Non-Discrimination for the Exercise of a Consumer›s Privacy Right

The CCPA states you have the right not to receive discriminatory treatment by us for the exercise of the privacy rights conferred by the CCPA.

8. Authorized Agent

8.1.
When you use an authorized agent to submit a request to know or a request to delete, we may require that you:
  1. a.Provide the authorized agent with written permission to do so;
  2. b.Verify your own identity directly with us; or
  3. c.Directly confirm with us that you provided the authorized agent with permission to submit the request
8.2.
We may deny a request from an agent that does not submit a proof that they have been authorized by you to act on your own behalf.

9. Contact us

Please contact us by either of the following ways if you have any questions or concerns about this CA privacy policy or the information we hold about you.

Online Inquiry Form
Or
Telephone: +81-3-6433-6000

10. Updates to the CA Privacy Policy

We may revise or update this CA privacy policy from time to time. Any changes to this CA privacy policy will become effective upon posting of the revised CA privacy policy on this website.

11. Additional California Privacy Rights

Pursuant to California Civil Code Section 1798.83, we only share personal information with third parties for those third parties› direct marketing purposes if you specifically opt-in or are offered the opportunity to opt-out and elect not to opt-out from such sharing at the time you provide personal information or at the time you choose to participate in a feature. If you do not opt-in or if you opt-out at the applicable time, we do not share your information with those identified third parties for those third parties’ own direct marketing purposes. If you are a California resident, and we do not have a notice of providing choices regarding certain kinds of sharing, as described above, you have the right to receive from us: (a) information identifying any third party(ies) to whom we may have disclosed, within the preceding calendar year, your personal information for that third party’s own direct marketing purposes; and (b) a description of the categories of personal information disclosed. If you are a California resident, please write to the contact point specified in section 9 above to obtain information free of charge regarding our compliance with this law. (Requests received by other means may result in a delayed response.) Please use "Your California Privacy Rights" in the subject line of your message. Please include your name, email address, postal address. We are not responsible for requests that are not labeled or sent properly, or do not have complete information. Please note that we are only required to respond to one request per customer each calendar year.