THIRD PARTY PERSONAL DATA MANAGEMENT POLICY

At SCAE (hereinafter “SCAE”), we are keen to respect the privacy and security of our users, customers and suppliers, as well as their representatives, with respect to all products, services and websites provided by SUMITOMO CHEMICAL AGRO EUROPE SAS, Parc d’Affaires de Crécy, 10A rue de la Voie Lactée, 69370 St Didier au Mont d’Or, France.

If you have any questions or comments regarding this document, please contact the Person in charge of the Personal Data at this address: gdpr@sumitomo-chem.fr.

PERSONAL DATA

When you submit an application or send information to SCAE electronically, you are sometimes asked to provide certain information, including your name, title, company, address, phone number, email address and sector of activity. You can also provide us with data about your customer or supplier account, etc. This type of data is considered as personal data under the current data protection legislation, i.e. any information directly or indirectly identifying a natural person (hereinafter “Personal Data”).

PURPOSES OF THE PROCESSING

These are the main objectives of an IT application of personal data. Examples of purposes: customer management, satisfaction surveys, monitoring premises, etc.

Please refer to the table in Appendix A to see for what purposes SCAE processes your Personal Data (hereinafter “Processing”), as well as the legal basis of this Processing and the corresponding retention periods. Processing means: any operation, or set of operations, relating to such data, whatever the process used (collection, recording, organisation, retention, adaptation, modification, extraction, consultation, use, communication by transmission or any other form of provision, reconciliation or interconnection, locking, deletion or destruction, etc.) or the file containing Personal Data.

If you want to know all the types of Personal Data collected for each Processing concerning you, please contact the Person in charge of the Personal Data at this address: gdpr@sumitomo-chem.fr.

TRANSFERS OF PERSONAL DATA

Unless otherwise specified herein, SCAE does not sell, trade or rent your personal information to third parties.

This Personal Data may be transferred to other companies in the Sumitomo Chemical Company Group within or outside the European Union, as well as to any third party to whom SCAE subcontracts all or part of this Processing. This may include, for example, service providers, hosting providers and any other providers.

In case of the transfer of Personal Data to a country outside the European Economic Area, SCAE implements the procedures required to obtain the necessary guarantees to secure such a transfer in accordance with the regulations in force (particularly by using the standard clauses of the European Commission). You can request further information on these measures by contacting SCAE via the contact information provided on the 1st page above.

As part of certain proceedings, such as a search warrant, subpoena or court order or in order to protect its property rights, SCAE may be required to give access to any information provided to SCAE. If this is justified, SCAE may also disclose this information in case of risk to the physical safety of an individual.

Furthermore, SCAE reserves the right to disclose any information obtained from you or on your behalf to third parties in connection with a merger, acquisition, bankruptcy or sale of all or almost all of SCAE’s assets.

YOUR RIGHTS

You may request access, rectification, erasure or portability of your Personal Data in accordance with the applicable law, by submitting your request to the Person in charge of the Personal Data at this address: gdpr@sumitomo-chem.fr or by writing to this address: SUMITOMO CHEMICAL AGRO EUROPE SAS, for the attention of the Person in charge of the Personal Data, Parc d’affaires de Crécy, 10A rue de la Voie Lactée, 69370 ST DIDIER AU MONT D’OR, France. Remember to include your full name and a copy of your ID document with your request.

Please note that SCAE may reject excessive requests or any misuse of the right in question.

You have the opportunity to rectify or obtain the erasure of your Personal Data, provided that the applicable legal requirements are met. The right to erasure is subject to various exceptions, in particular regarding Personal Data for which Processing is necessary to support a dispute or to comply with the legal requirements for retention.

You also have the right to oppose the Processing of Personal Data on the basis of SCAE’s legitimate interests and to obtain, in certain cases, the limitation of the collection of certain types of Personal Data. In particular, regarding the Processing of Personal Data for the purposes of commercial prospecting, you have the right to oppose it at any time. When Processing is based on consent, you have the right to withdraw your consent at any time (without affecting the Processing before the withdrawal of your consent).

If you are not satisfied with our exchanges, you can contact the French National Commission for Data Protection and Liberties (CNIL) at this address: CNIL, 3 place de Fontenoy, TSA 80715 75334 Paris, France.

DATA ON MINORS

SCAE’s activity is not intended for minors. SCAE does not knowingly collect Personal Data relating to minors.

However, if SCAE identifies that the Personal Data of a minor has been collected, it will be erased by SCAE, except, for example, in an exceptional case when a third party has recruited a minor for an apprenticeship.

ACCEPTANCE OF THIS PERSONAL DATA MANAGEMENT POLICY BY THE USER

By visiting our Website, you acknowledge that you have had the opportunity to read SCAE’s Personal Data Management Policy (hereinafter “the Policy”).

We may change, modify, add or remove parts of this Policy at any time. We will notify you of any such changes in accordance with the applicable legislation regarding the protection of Personal Data.

Last modification: 1 January 2019

APPENDIX A: Categories of data and purposes of the processing

 

Common data processing

Purposes (for third parties)
Letters/files sent (such as information to distributors) Communicating with third parties
Directories and platforms: UIPP, ECPA, etc. Contacting a third party, networking, exchanging information
Greeting cards (list and cards) Sending and receiving greetings
Office documents and other media (paper boards, photos of slides or flip charts) external to the company External presentation
Provider invoices Paying providers
Visa application Non-French citizens coming to France.
Contracts and disputes Managing contracts and disputes.
Due Diligence Questionnaire for the prevention of corruption Ensuring that third parties are not corrupt, etc.
Invoices Accounting and paying invoices.
SAP Information on third parties.
List of scientific staff Constituting the CIR (Research Tax Credit).

Support services processing

Purposes (for third parties)
Access control security Allowing access to headquarters premises.
Anti-intrusion security Controlling access to headquarters premises (10A) through video surveillance
Risk management General information on the establishment – Security register
Supplier relations Providers contracts
Supplier relations Job sheet

Operational Departments processing

Purposes (for third parties)
SCAE customer records Managing customers.
Disclosure of the DG’s identity card or passport number to the freight forwarder or customs agent to show that the products comply with the regulations To be able to send our products abroad.
Provider records. Managing providers (CRO – Contract Research Organisation, Farmers, Technicians, Consultants, etc.).
Authorities records Managing files related to the authorities.