Privacy Policy (GDPR、CCPA/CPRA)

We at Bando Chemical Industries, Ltd. (“we”, “us”, “our” or “Bando Chemical”) value your privacy and are committed to taking care of your Personal Data, which is a responsibility that we take very seriously.

This Privacy Policy explains how we may use, collect and manage the Personal Data when you visit our website, including https://www.bandogrp.com and their respective subdomains (collectively, the “Website”), inquire about our products, enter into contact with us through our Website or register for our events, campaigns and/or our marketing communications. It also explains how we comply with EU legislation related to data protection EU General Data Protection (“GDPR”) and the California Consumer Privacy Act (“CCPA/CPRA”) and what your rights are under these legal frameworks.

Bando Chemical Industries, Ltd is the data controller of the products and services offered through this website. Our registered office is at〒650-0047 6-6, Minatojima Minamimachi 4-chome, Chuo-ku, Kobe, Japan.

1．Definitions

Unless otherwise indicated, capitalized terms used in this Privacy Policy are defined in Annex 1. Most of the definitions are derived from the EU General Data Protection and the California Consumer Privacy Act.

2. What type of Personal Data do we collect from you?

Personal Data means any information relating to you which allows us to identify you, either directly from that data or because we combine that information with other data about you.

When you use our Website, inquire about our products, services or business, or we interact with you in relation to our products, you may provide us with your Personal Data, or we may obtain Personal Data about you.

We may process the following Personal Data:

▪Contact details and personal identifiers: such as your name, email address, telephone number, address, SNS account information, workplace information;

▪Records of your interactions with us: information such as, content of inquiry, purpose of the inquiry, content from event applications; other information provided during inquiries;

▪Internet information: including your use of and movements through our Website, the date and time of your visit or use of our Website, IP address, webpages viewed, your search and browse history, device ID, country of access, browser type and plug-ins, and other IT system identifying information;

▪Your marketing preferences: so that we know whether and how we should contact you.
You can stop receiving our marketing communications at any time, free of charge, through the methods displayed as part of any communication such as the unsubscribe link in our emails. Or further information on this please see the section below on Direct Marketing.

3. Where do we collect your Personal Data from?

We will collect Personal Data from several sources. These include the following:

▪Directly from you: when you use our Website, sign up for campaigns and events, contact us by email or communicate with us directly in some other way.

▪From our group members: our group members may collect and share your information with us. This may happen when you interact with them at events, exhibitions, or through business networking.

▪Our website: provides us with information about how you use it and the devices that you use to connect to our Website. Like many other Websites, we use so-called “cookies”. Cookies are small text files that are stored on your device (laptop, tablet, smartphone, etc.) when you visit our Website. If you have given your consent to our use of cookies, we do so to improve the use of our Website, analyze our Website or to display advertising on the Website. You can revoke your consent to our use of cookies any time. Please refer to our Cookie Consent Banner for more information on the cookies we use.

4. Why do we collect your Personal Data and on what legal basis?

The table below describes the main purposes for which we process your personal data, the categories of your information involved and our lawful basis for being able to do this.

Purpose Personal Data used Lawful basis
So that we can provide our website to you IP address, browser type, device ID, geolocation We have a legitimate interest in our website working properly
To improve our website security, offer IT support and troubleshooting IP address, date and time of your visit or use of our website, device information We have a legitimate interest in ensuring our systems are secure
To analyze our website usage Cookies, IP address, browser type, plug-ins device type and ID, country of access, pages visited, browsing history, time spent on the website, website activity We only process your personal data for analyzing purposes if you gave us your consent
To optimize our ad delivery on the website Cookies, IP address, browser type, plug-ins device type and ID, country of access, pages visited, browsing history, time spent on the website, website activity We only process your personal data for advertisement purposes if you gave us your consent
To deal with inquiries, and other communications from you Name, workplace information, country from where you inquire us, email address, telephone number, address purpose and content of inquiry This is necessary to fulfil our contract with you
To provide our services to you Name, workplace information, your location, email address, telephone number, address, other details entailed in the service application/ registration This is necessary to fulfil our contract with you
Shipping of our products, samples and documents to you Name, workplace information, your location, email address, telephone number, address, other details entailed in the application/registration, SNS account information This is necessary to fulfil our contract with you
Marketing our products and services which may be of potential interest to you Name, email address, workplace information, SNS account information We have a legitimate interest to provide you with information about our products and services including those that are the same or similar to the ones you have inquired about If we cannot rely on legitimate interest as our lawful basis for processing, then we will obtain consent from you
Shipping prizes to winners and participants of our campaigns Name, workplace information, your location, email address, telephone number, address, other details entailed in the application/registration, SNS account information This is necessary to fulfil our contract with you
Storage of records relating to you and also records relating to our business All the personal information we collect about you To be able to manage and fulfil our contract with you, we may have a legal and/or regulatory obligation to do so and we also have a legitimate interest to keep proper records

Some of your Personal Data may be required due to legal, contractual, or other obligations. Failure to provide this data may impact on our ability to fulfil our contract with you or comply with relevant legal obligations. For other Personal Data, whilst you may not be under an obligation to provide it to us, if you do not provide it, we may not be able to properly perform our services for you.

Providing Personal Data for marketing communication and activities is optional. Refusal to provide this data has no negative consequences but means that we cannot offer personalised marketing communication or inform you about upcoming events and campaigns. If you gave us your consent for marketing purposes, you can revoke your consent or object the processing at any time by sending a message following the information in section “Contact Information”.

5. Who we share your Personal Data with?

In order to operate our Website and provide you with the products and services you have inquired us, we may need to share your Personal Data with third parties. This includes sharing your Personal Data with our group companies and companies engaged by us to manage our relationship with you and provide you the services described above.

We may share your Personal Data with the following recipients:

▪Sub-contractors: such as our analytical and tracking services, advertising and marketing platforms, consent and privacy management provider, search optimization services and other sub-contractors.

▪Group companies: We may share your personal data with our affiliated companies within our corporate group for internal administrative purposes.

We do not disclose Personal Data to anyone else except as set out above unless we have your consent, or we are legally obliged to do so. These recipients will only process your Personal Data to perform tasks and duties on our behalf and in compliance with this Privacy Policy and governing data protection laws.

6. Direct Marketing

From time to time, we may contact you by email or via social networking services with information about services, events and products we believe you may be interested in.

Marketing emails will only be sent to you if you tell us that you wish to receive marketing related messages, or when you have made use of similar services, or attended events and purchased products with us previously.

You can opt out any time if you do not wish to receive any marketing messages by clicking on the unsubscribe link in any marketing email you receive to unsubscribe from future marketing communications.

7. International data transfers

In the course of our operations, it may be necessary to transfer your Personal Data to recipients located outside the European Economic Area (EEA). These transfers may be to our service providers who are located in regions, such as the United States or Japan, with differing data protection laws than those in your country. When transferring your Personal Data internationally we implement appropriate safeguards to ensure the security and confidentiality of your data. These safeguards, when we cannot rely on an issued Adequacy Decision, may include for example Standard Contractual Clauses (SCCs) approved by the European Commission.

8. How long do we keep Personal Data for?

Generally, we will retain your Personal Data for as long as we need it for the purposes for which it was collected. The duration for which we retain your Personal Data will differ depending on the type of information and the reason why we collected it from you. However, in some cases Personal Data may be retained on a long-term basis: for example, Personal Data that we would need to retain for legal purposes will normally be retained in accordance with usual commercial practice and regulatory requirements.

In addition, we may be allowed to retain Personal Data whenever you have given consent to such processing (e.g. marketing emails), as long as such consent is not withdrawn.

9. Data security

We take the security of your information very seriously and only handle Personal Data as permitted by data protection regulations. We use a variety of technical and organizational measures to help protect your Personal Data from unauthorized access, disclosure, modification, loss or destruction in accordance with applicable data protection laws. When handling Personal Data, our employees are obliged to comply with the regulations of the GDPR.

10. Your rights in relation to your Personal Data

If you are located in the EU, you have the following rights in relation to your Personal Data:　

Right of Access - you have the right to be informed about how we are using your Personal Data and the right to access that data that we hold about you.

Right to Erasure or "Right to be Forgotten" - you have the right to ask us to delete your Personal Data provided that there are no valid grounds for us to keep it, for example we may have to keep some or all of the Personal Data to comply with legal obligation or in respect of any legal claims.

Right to Data Portability - you have the right to receive the Personal Data you have provided to us in a digital format or in certain circumstances and where technically feasible the right to ask us to transmit the data to another organization.

Right of Rectification - you have the right to ask us to amend the Personal Data that we hold about you where believe it is inaccurate or incomplete.

Right to Object - in certain circumstances, you have the right to object to the processing of your Personal Data and to ask us to block, erase and restrict our use of your personal data.

Automated Decision Making - we may process your Personal Data by solely automated means (without human intervention), including for profiling. Where such processing may have a legal or similarly significant effect on you, you have the right not to remain subject to any decisions based on such automatic processing, except as otherwise provided by law. You have the right to understand when and how automated decisions are made about you, and the factors involved and you have the right to challenge these decisions, request human intervention, express your point of view, and seek a review of the decision.

Right to Withdraw Consent or Right of Opposition - if you have provided your consent to the collection, processing and transfer of your personal data, you have the right to fully or partly withdraw your consent. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there is another legal ground for the processing.

Right of Limitation - you have the right to request the limitation of the Processing of your Personal Data, in the form of: (i) suspension of Processing or (ii) limitation of the scope of Processing to certain categories of Personal Data or purposes of Processing.

Right to complain - you have the right to complain to the supervisory authority, in addition to us.

The period for handling a request is 30 days unless it is a particularly complex request.

Once our specified retention period has expired, we shall delete the relevant Personal Data. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of such retention period.

11. Processing data in relation to children

Bando Chemicals does not knowingly collect Personal Data from persons who are not legally permitted to use our services without obtaining parental consent. If it comes to our attention that we have collected or processed Personal Data from such a person, we may delete this information without notice. If you have reason to believe that this has occurred, please contact us using the following address: info@bando.de

12. Changes to our data protection provisions

We may need to make changes to this Privacy Policy to ensure that it complies with current legal requirements or to implement changes to the services detailed in the Privacy Policy, e.g., when introducing new services and products. In this case, your future visits to our Website will be subject to the updated Privacy Policy.

13. California Residents

At Bando Chemical Industries, we are committed to protecting your privacy and ensuring transparency in how we handle your personal information. This section outlines your rights under the California Consumer Privacy Act (“CCPA/”CPRA”), the types of personal information we collect, how we use it, and your options for managing your personal information.

What personal information we collect and disclose

This section provides details about the categories of personal information we have collected from consumers over the past 12 months. It also outlines the sources of this information, the business or commercial purposes for its collection, and whether we have disclosed, sold or shared, any categories of personal information to third parties during the same period.

Categories of personal information Source from which we collected information Purpose for collecting the information Categories of third parties to whom the information was disclosed Information shared
Identifiers, such as name, billing address, email address, IP address, SNS account information ・Directly from you ・Provide you with our marketing communication ・Marketing and media and service technology providers ・yes
・To deal with inquiries, and other communications from you
・To optimize our ad delivery on our website
・To provide our services and products to you
Personal information such as telephone number ・Directly from you ・To deal with inquiries, and other communications from you ・Marketing and media and service technology providers ・n/a
・To provide our services and products to you
Commercial information, such as the services browsed or searched for, purchasing or consuming tendencies, about vehicles or models owned (related to chosen services) ・Directly from you ・To deal with inquiries, and other communications from you ・Marketing and media and service technology providers ・n/a
・To provide our services and products to you.
Internet or other electronic network activity information, such as your browsing history, time spent and activities on our website, pages visited, your browser type, plug-ins, IP address, URL and pages viewed, cookies ・Directly from you ・To analyze our website usage in order to improve and enhance our services ・Marketing and service technology providers ・yes
・To optimize our ad delivery on our website
Geolocation data, such as the country of your access ・Directly from you ・To optimize our ad delivery on our website ・Marketing and service technology providers ・yes
・To analyze our website usage in order to improve and enhance our services
Professional or employment-related information such as, information on your workplace; department, industry and company name Directly from you ・PTo deal with inquiries, and other communications from you ・Marketing and media and service technology providers ・n/a

No sale of personal information
We did not sell any personal information in the preceding 12 months. Bando Chemical Industries does not sell any personal information.

No sale or sharing of minors' personal Information
We do not have actual knowledge that we sell or share personal information about minors under the age of 16.

Sensitive personal Information
We do not use or disclose sensitive personal information for purposes other than those specified in Section 7027(m) of the CCPA regulations.

Consumer rights under the CCPA/CPRA
If you are resident in California, you have the following rights in respect of your Personal Information:

Right to Know - you have the right to request that we disclose what personal information we collect, use, disclose, sell or share. Specifically, you may request that we disclose to you the following:

・The categories of personal information we have collected about you.

・The categories of sources from which the personal information is collected.

・The business or commercial purpose for collecting, selling or sharing personal information.

・The categories of third parties with whom we disclose personal information.

・The specific pieces of personal information we have collected about you.

You may also request that we inform you about:

・The categories of personal information that we have shared about you and the categories of third parties to whom the personal information was shared, by category or categories of personal information for each third party to whom the personal information was shared.

・The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

Right to deletion - you have the right to request that we delete any personal information about you which we have collected from you. If it is necessary for us to maintain your personal information for certain purposes, we are not required to comply with your deletion request. If we determine that we will not delete your personal information when you request us to do so, we will inform you and tell you why we are not deleting it.

Right to Correct Inaccurate Personal Information - you have the right to request that we correct inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.

Right to opt-out of third-party sales and sharing - we do not sell your personal information; you have the right to opt-out of third-party sharing of your Personal Information for cross-context behavioral advertising purposes. This means that whenever you request us to stop sharing your data, we will abide by your request. Such request can be made freely, at any time, without submitting any verifiable request, contacting us through the web form available here: https://marketing.bandogrp.com/56-contact_EN_other.html.

Right to Limit Use and Disclosure of Sensitive Personal Information (SPI) - you have the right to limit the use and disclosure of your SPI to that which is necessary for us to perform the services or provide the goods we provide.

Right to Opt-Out of ADM technology - you have the right to opt-out of being subject to automated decision-making processes, including profiling.

No Discrimination - you have the right not to be discriminated against because you exercised any of your rights under the CCPA/CPRA set out in this section above.

The exercise of your rights is free of charge. The response to requests based on the provisions of the CCPA/CPRA should be provided within a maximum of 45 days. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. However, for requests to opt out or limit the use of sensitive personal information (SPI), we will respond within 15 days.

How you can exercise your rights under CCPA/CPRA
To exercise any of the rights described above, please send us a verified request using the methods listed below. Your request must:
・Include enough information for us to confirm your identity or the identity of your authorized representative.
・Clearly explain your request so we can understand, evaluate, and respond to it.

If we cannot verify your identity or authority to make the request, we will not be able to comply with your request. We will inform you if we cannot verify your identity or authority. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request.

14. Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, or your choices and rights regarding such use please do not hesitate to contact us by:

・Name: BANDO CHEMICAL INDUSTRIES, LTD.
・E-mail: info-marketing@bandogrp.com
・Post to: 〒650-0047 6-6, Minatojima Minamimachi 4-chome, Chuo-ku, Kobe, Japan

If you prefer, you can also contact below our local group companies listed below.

For customers located in the European Economic Area (EEA)
・Name: BANDO EUROPE GMBH. (Our representative according to GDPR)
・Address: Krefelder Strasse 671, 41066 Moenchengladbach, GERMANY
・Email: info@bando.de
・TEL: +49 (0) 2161 90104 0

For customers located in California, US
・Name: Bando USA, Inc.
・Address: 1149 West Bryn Mawr, Itasca, Illinois 60143, U.S.A.
・TEL: +1 (800) 829-6612

This Policy was last updated: August 18, 2025

Annex 1

ADM means Automated decision-making;
CCPA means the California Consumer Privacy Act (CCPA) signed into law on June 28, 2018, to amend Part 4 of Division 3 of the California Civil Code.
http://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180AB375
CPRA means the California Privacy Right Act of 2020
Contract Performance means concluding, maintaining, and completing of a contract concluded between the Controller and a Data Subject, including Processing activities which take place at the request of the Data Subject before entering into a contractual relation;
Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data; where the purposes and means of such Processing are determined by Union or Member State law, the Controller or the specific criteria for its nomination may be provided for by Union or Member State law;
Data Subject is any natural person whose Personal Data is being collected, held or processed. Examples of a Data Subject can be an individual, a customer, a prospect, an employee, a contact person, etc;
Direct Marketing means personal data processed to communicate a marketing or advertising message. This definition includes messages from commercial organizations, as well as from charities and political organizations;
General Data Protection Regulation (GDPR) is a regulation in EU law on data protection and privacy in the European Union (EU) and the European Economic Area (EEA); Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) https://eur-lex.europa.eu/eli/reg/2016/679/oj ;
Legitimate Interest means the Controller’s interest to process Personal Data in order to carry out tasks related to the Controller‘s business activities. The processing of Personal Data in that context may not necessarily be justified by a legal obligation or carried out to execute the terms of a contract with a Data Subject;
Personal Data means any information relating to an identified or identifiable natural person ('Data Subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Personal Information means information of the types set out in Section 1798.140. (v) (1-3) of the CPRA where it identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
Processing means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
Processor means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller;
Recipient means a natural or legal person, public authority, agency or another body, to which the Personal Data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as Recipients; the Processing of those Personal Data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the Processing;
Sell, Selling, Sale or Sold means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for monetary or other valuable consideration, according to Section 1798.140. (ad) (1-2) of the CPRA.
Share, Shared or Sharing means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged.
Sensitive Personal Information means personal information that reveals: the social security, driver’s license, state identification card, or passport number. An account log-in, financial account, debit card, or credit card number, or credentials allowing access to an account, the precise geolocation, racial or ethnic origin, religious or philosophical beliefs, or union membership, content of a consumer’s mail, email and text messages unless the business is the intended recipient of the communication, and genetic data, the processing of biometric data for the purpose of uniquely identifying a consumer, personal information collected and analyzed about a consumer’s health, sex life or sexual orientation according to Section 1798.140. (ae) (1-3) of the CPRA.