Europe Privacy Notice

S&B Foods Group may acquire your personal information to the extent necessary in the course of its business activities or when you make various requests to S&B Foods Group. In addition, your personal information may be obtained through a third party, such as our outsourcing companies, or from publicly available information.

In all of these cases, S&B Foods Group will acquire personal information through legal and appropriate means.

The main items of your personal information acquired by S&B Foods Group are as follows.

• Name
• Address
• E-mail address
• Social media account
• Telephone number
• Date of birth
• Gender
• Numbers for cashless payment
• Record of inquiries and other information acquired through contact with you or provided by you
• Data that can be used to identify you obtained using cookies
• Data that can be used to identify you obtained using advertising identifiers (IDFA/ADID)

In addition, the personal information obtained from you as an applicant (“Applicant”) in the S&B Foods Group's employment recruitment activities is as follows:

• Name, e-mail address, telephone number, educational background, work experience, qualifications held, current annual income, health examination results, whether the Applicant has a disability certificate, whether the Applicant has a residence card, self-promotional materials and other information provided in the application forms (regardless of format, documents provided by the Applicant to our company for the purpose of applying for employment activities, etc., such as resume, work history, entry sheet, etc.);
• Information contained in communications between our company and the Applicant for the purpose of interviews and other employment recruitment activities, in the form of conversations, telephone calls, e-mails, etc.; and
• information about application and participation in employment recruitment activities, as well as the results of selection for employment.

S&B Foods Group will use your personal information only within the scope necessary to achieve the purposes listed in the following items in the planning and development, production, and sales activities of spices such as curry, pepper and garlic, and seasonings such as spices in tubes, instant curry, instant stew, pre-packaged foods, chilled foods, fresh herbs, herb-related products, and other various food products, as well as in operations associated with such activities, and its internal recruitment operations.

1. Your personal information obtained through inquiries, campaigns, events, use of S&B Foods Group facilities
   1. Respond to inquiries and complaints regarding products and services, and retain records of responses
   2. Campaigns, confirmation of eligibility, draws, notification of winners, delivery of prizes
   3. Reception and guidance and emergency contact information for facility tours of S&B Foods Group
   4. Holding, managing and operating events and seminars
   5. Conducting surveys, including monitoring and questionnaires, and asking for cooperation
2. Your personal information obtained through mail-order sites
   1. Execution of operations related to sales, delivery, and payment of products, rights, and services of S&B Foods Group or a third party
   2. Information on products and services of S&B Foods Group or a third party
   3. Sending or providing gifts or other goods or services on behalf of you (personal information of the person designated as the recipient will be used for shipping and provision)
3. Your personal information obtained through membership registration, follower settings, e-mail delivery service registration, etc. for official websites, official social media accounts
   1. Notification of event information
   2. Information on products and services of S&B Foods Group
   3. Use of personal information on persons submitting or applying for information on websites operated by S&B Foods Group in the advertising materials of S&B Foods Group of postings or submissions on websites
4. Personal information on business partners in business activities (including businesses who have the potential to be business partners; hereinafter the same.)
   1. Development, improvement, and other quality improvement activities for products and services of S&B Foods Group or contractors of S&B Foods Group
   2. Confirmation necessary for business activities, business contacts, information provision, greetings
5. Personal information of shareholders and investors
   1. Exercise of rights and performance of obligations under the Companies Act
   2. Sending and communicating business reports, shareholder rewards and other documents
   3. Shareholder management such as preparing shareholder data according to prescribed standards based on various laws and regulations
   4. Implementation and investigation of possible improvement of shareholder services
   5. Provision of information and communications about S&B Foods Group
   6. Services related to each item above
6. Personal Information of Applicants
   1. Provision of information regarding employment recruitment activities and contact
   2. Implementation of employment recruitment selection procedures
   3. Confirmation of past applications to our company
   4. Management of Applicant’s information
   5. Analysis and consideration of employment recruitment strategies for more effective employment recruitment activities within the S&B Foods Group
7. Personal information regarding internships and retirees (Internship)
   1. Implementation of internship
   2. Operations related to business communication and equipment/facility management
   3. Operations related to labor management
   4. Operations related to education and training
   5. Operations related to safety, hygiene, health management, etc.
   6. Operations related to each item above
   (Retirees)
   1. Payment of retirement pension, etc.
   2. Communication necessary for business
   3. Provision of information on company status
   4. Fulfillment and communication of obligations under labor-related laws and regulations
   5. Operations related to each item above
8. Personal information related to officers, employees, etc. (Personal information on officers, employees (including non-regular employees and part-time employees) and their families)
   1. Operations related to business communication and equipment/facility management
   2. Operations related to personnel and labor management
   3. Operations related to wages, bonuses, retirement allowances, corporate pensions, welfare programs, etc.
   4. Operations related to education and training
   5. Operations related to safety, hygiene, health management, etc.
   6. Services under laws and regulations, such as employment insurance, social insurance, tax/ social security, etc.
   7. Services related to shareholding associations
   8. Services related to each item above
   (Personal information about dispatched employees received by our company)
   1. Operations related to business communication and equipment/facility management
   2. Operations related to labor management
   3. Operations related to safety, hygiene, health management, etc.
   4. Services related to each item above
9. Other common purpose of use
   1. Exercise of rights and performance of obligations by S&B Foods Group under contracts, laws, etc.
   2. Preparation of statistical information in a form that does not identify individuals for the purpose of improving product development, marketing activities, etc. of S&B Foods Group
   3. When delegated handling of personal information by a business partner, etc., execution of the delegated services (including shipping agency for products and communication, etc. associated with the shipment of products)
   4. Provision to partner companies that have been entrusted with website operation, data management, etc.
      1. Execution of the entrusted work
      2. Statistical analysis of data that cannot be used to identify individuals and linking it to your personal information, only for the development, improvement, and other quality improvement activities of the products and services provided by the partner companies
   5. Analysis of your personal information and development, advertising, promotion, and marketing activities and research and statistical analysis of marketing data of S&B Foods Group’s products and services by methods including but not limited to the following:
      1. Providing your personal information (*1) held by S&B Foods Group to a third party (*2) in a form that does not identify individuals and linking it to your personal information held by a third party and other information on you
      2. Method in which S&B Foods Group obtains your personal information held by a third party in a form that does not identify individuals and links this to your personal information held by S&B Foods Group and other information about you
      3. Method of performing (i) and (ii) together

      *1 “Your personal information” in this section includes the following information.

      ・Your personal information obtained by the S&B Foods Group, your purchase histories and other attribute information

      ・Your browsing history, etc. on S&B Foods Group’s websites, digital platform operators, and advertising companies, etc. collected by using cookies and advertising identifiers (IDFA/ADID)

      *2 “third party” in this section refers to business partners, etc., including advertising companies in the digital marketing field.

   6. Other conducting business legitimately

Your personal data will not be kept beyond the time strictly necessary to achieve the purposes pursued as set out in this Policy, in accordance with the Regulation and applicable laws. S&B Foods Group will retain your personal data only for the minimum period of time necessary to fulfill the purpose for which it was collected or to comply with the requirements of the Regulation and applicable laws, or other internal policies.

Your personal data is erased when the retention periods expire. Nevertheless, the personal data may be archived beyond the periods provided for the purposes of research, observation and prosecution of criminal offenses for the sole purpose of allowing, as necessary, the provision of data to the judicial authority. Archiving implies that the personal data will no longer be available online but will be extracted and stored on an autonomous and secure medium.

1. Management and protection of personal information

   Regarding the handling of personal information provided by you, we will establish security control measures to ensure appropriate and strict management and prevent the leak of personal information to outside parties. In addition, we will strive to protect personal information by implementing appropriate and reasonable levels of security measures against risks such as unauthorized external access.

2. Supervision of subcontractors

   S&B Foods Group may outsource the handling of personal information to subcontractors.
   In such cases, upon confirming the status of the handling of personal information, we will implement proper and strict management by taking measures such as entering into written agreements.

3. Security control measures

   For details of measures taken by S&B Foods Group for the management and protection of personal information and supervision of contractors, please contact the help desk described in XII. Contact for inquiries.

When necessary, your personal data may be transferred to service providers operating outside the European Union.

In particular, we may transfer your data to S&B Foods Group located in Japan (country subject to an adequacy decision by the European Commission).

When we transfer the personal data outside the European Union, we will always do so securely:

• Either by transferring the personal data to a recipient located in a country that has been the subject of an adequacy decision by the European Commission certifying that it has a level of protection equivalent to that offered by the Regulation.
• Either by executing or having executed the European Standard Contractual Clauses which have been approved by the European Commission as ensuring an adequate level of protection for personal data.
• Either through the use of Binding Internal Company Rules validated by the competent data protection authorities.
• Or by making use of all appropriate guarantees referred to in Article 46 of the GDPR.

You can access a copy or an extract of these documents by contacting us at the help desk described in Article XII of this Policy.

1. Provided by a third party

   S&B Foods Group will not disclose or provide your personal information to third parties except in the following cases, as well as disclosure and provision to the subcontractors listed in the above V. 2. and the person using jointly in the following VII.2.

   1. When providing personal information, for the purpose of communication with consumers and customers (including digital and social media communication, advertising, publicity, customer care, marketing activities including face-to-face contact and market research) of S&B Foods Group’s products and services as described in II. Purposes of Use of Personal Information above, to providers thereof
   2. When providing personal information necessary for the provision of settlement services and related services (including identity verification, billing address verification, credit checks, fraud detection and prevention, etc.) by settlement agents and credit card issuers to which S&B Foods Group outsources settlement services to settlement agents and credit card issuers
   3. When providing personal information necessary to perform outsourced services to logistics, legal, and IT support (website development and management, website hosting, general IT services, application development) and other auditing services, as well as to providers of specialized services in the fields of health, safety, hygiene, and technology, to perform the outsourced services
   4. When providing personal information to a party to whom the S&B Foods Group has assigned rights or obligations, or transferred contractual status, or to a potential buyer in the event of the sale of part of its business or assets
   5. When required by applicable laws and regulations, or by such bodies as governments, regulatory agencies, enforcement agencies, exchange institutions, or court authorities
   6. When otherwise with your consent
2. Joint use

   S&B Foods Group will jointly use your personal information as described below. Please note that the handling of joint use may be reviewed as necessary in the future. In that case, we will notify or make a public announcement in advance.

3. Item	Content
   (1) Scope of joint users	S&B Foods Group
   (2) Purpose of joint use	The same as the purpose of use described in II. Purpose of use of personal information above.
   (3) Items of personal information to be jointly used	The same as the items of personal information in above I. Collection of personal information
   (4) Name, address and name of the representative responsible for management of joint personal information	S&B FOODS INC. 18-6, Nihonbashi Kabuto-cho, Chuo-ku, Tokyo 103-0026 Japan Chief Information Officer Minoru Yokoi

S&B Foods Group may use for a purpose described in II. Purpose of Use of Personal Information related to personal information such as cookies and advertising identifiers (IDFA/ADID) about you acquired from other businesses (including, but not limited to, DMP providers and partner businesses in the digital marketing field), which are linked to your personal information and then obtained as personal data.

In accordance with applicable laws and regulations on the protection of personal data, you have a number of rights relating to your personal data, namely:

• A right of access and information: you have the right to be informed in a concise, transparent, intelligible and easily accessible manner of how your personal data is processed. You also have the right (i) to obtain confirmation that data concerning you is being processed and, where applicable (ii) to access this data and obtain a copy thereof.
• A right of rectification: you have the right to obtain the rectification of inaccurate personal data concerning you. You also have the right to complete incomplete personal data, by providing an additional declaration. In the event of exercise of this right, we undertake to communicate any rectification to all the recipients of your data.
• A right of erasure: you have the right to obtain the erasure of your personal data. However, this is not an absolute right and we may, in particular due to legal obligations, retain this data.
• A right to limit processing: you have the right to obtain the limitation of processing of your personal data.
• A right to data portability: you have the right to receive the personal data you have provided to us, in a structured, commonly used and machine-readable format, for your personal use or to transmit it to a third party of your choice. This right only applies when the processing of your data is based on your consent, on a contract or when this processing is carried out by automated means.
• A right to object to processing: you have the right to object at any time to the processing of your personal data for processing based on our legitimate interest and those carried out for commercial prospecting purposes.
• The right to withdraw your consent at any time: you can withdraw your consent to the processing of your personal data when this processing is based on your consent.
• The right to lodge a complaint with a supervisory authority: you have the right to lodge a complaint with the competent supervisory authority if you consider that your rights have not been respected. In France, this will be the CNIL.
• The right to give instructions concerning the fate of your data after your death: you have the right to give us instructions concerning the use of your personal data after your death.

If S&B Foods Group receives a request from you for disclosure, correction, addition, deletion, suspension of use, etc., or any other request regarding personal information in accordance with the Act on the Protection of Personal Information and the GDPR, S&B Foods Group will promptly respond to such request within a reasonable scope in accordance with the prescribed procedures and no later than one (1) month after receiving the request. Please contact the help desk described in article XII. In case of doubt about your identity, we may ask you for proof of identity for the exercise of these rights.

1. Cookies

   S&B Foods Group’s website includes pages that use a mechanism called “cookies” for the purpose of understanding website use, distributing advertisements, obtaining statistical data, etc., for the purpose of providing better services to you. Cookies are one of the mechanisms by which website servers identify users. The browser used by you is identified thereby. You may set your browsers to refuse to accept cookies or to display a warning when cookies are received.

   You thus have the possibility of accepting or refusing cookies by using the mechanism integrated into the banner, and of modifying your choices at any time by clicking on the “Cookies Settings” tab at the bottom of the page of our website.

   Please note that you may not be able to receive some of the services on the website if you reject the request.

2. Types of cookies used by S&B Foods Group

   Different types of cookies are used on our website, which serve different purposes. Some are necessary to use the site, others are optional according to your choices.

   • Strictly necessary cookies

     These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

   • Performance cookies

     These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

   • Targeting cookies

     These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

3. Managing cookies

   The Internet user can manage the deposit of cookies as follows:

   • The deposit of strictly necessary technical cookies is activated by default and cannot be deactivated by the Internet user, these cookies being essential for the operation of the website;
   • The Internet user deactivates or activates the deposit of cookies subject to the collection of his consent (audience measurement cookies and targeting cookies) via the information banner displayed during his first connection or permanently available at the bottom of the page via the information banner displayed during his first use of the deposit of the cookie in question.

   If the Internet user activates the recording of cookies in his terminal, the cookies integrated into the pages and content he has consulted may be temporarily stored in a dedicated space on his terminal. They will be readable there only by their issuer. The consent given by the Internet user is only valid for a period of six (6) months from the first deposit in the equipment of the Internet user's terminal, following the latter's consent.

   If the Internet user deactivates the registration of cookies in his terminal or his browser, or if he deletes those which are registered there, he is informed that his navigation and his experience on the site could be different from other Internet users who have activated cookies (non-personalized content). S&B Foods Group declines all responsibility for the consequences linked to the degraded functioning of the site resulting from the refusal of cookies by the Internet user.

4. Services by third party business operators used by S&B Foods Group

   S&B Foods Group uses cookies and uses the services provided by the following third parties, and may provide the relevant third party with your information in case of your consent that, by itself, cannot identify individuals.

   If you wish to disable (opt out) the delivery of advertisements, etc. via third party cookies, you can do so from the following companies’ websites.

5. Third party Operator	Site
   Google LLC	https://myadcenter.google.com/home https://tools.google.com/dlpage/gaoptout/
   Meta Platforms, Inc.	https://www.facebook.com/policies/cookies/ (facebook) https://privacycenter.instagram.com/policy/ (instagram)
   LY Corporation	https://privacy.lycorp.co.jp/en/setting/
   X Corp.	https://help.x.com/en/business-and-advertising/how-x-ads-work
   Pinterest, Inc.	https://help.pinterest.com/en/article/your-privacy-and-data-settings

We may occasionally modify this policy, in order to comply with any regulatory, jurisprudential, editorial or technical developments. Where appropriate, we will change the "last updated" date and indicate the date on which the changes were made. When necessary, we will inform you and/or seek your consent. We advise you to consult this page regularly to take note of any changes or updates to our policy.

If you have any opinions, questions, or other inquiries regarding the handling of personal information, please contact us as follows.

https://global-support.sbfoods-worldwide.com/hc/en-001/requests/new

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