MMC HARDMETAL UK LTD POLICY ON USING PERSONAL DATA
OF OUR BUSINESS PARTNERS

published: 09/12/2020
updated: 27/08/2021

This privacy policy is intended for those of you belonging to our current and prospect customers, suppliers, distributors and other business partners. We, MMC Hardmetal UK Ltd, take your privacy seriously. When we collect and use your personal data for various business purposes, we undertake to comply with applicable data protection laws including EU General Data Protection Regulation (the “GDPR”), UK General Data Protection Regulation (the “UK GDPR”) and Data Protection Act 2018 (DPA 2018). Please note that data transmitted via the internet (e.g. via email communication) may be subject to security breaches. Complete protection of your data from third-party access is not possible. Below is our policy on how we collet, use and protect your personal data. You can obtain the latest version of this policy at the following link:
https://www.mmc-hardmetal.com/en/bp-privacy-policy

• PERSON IN CHARGE (controller) / DATA PROTECTION OFFICER

  This privacy policy is issued by us, MMC Hardmetal UK Ltd. You can find more detailed information about MMC Hardmetal UK Ltd in the imprint of the above-mentioned website (https://www.mmc-hardmetal.com/en/site-notice). When we collect and use your personal data, we are the data controllers in the meaning of the UK GDPR and are responsible for protecting your rights with personal data.
  We have appointed a data protection officer (DPO) for the purpose of privacy and data protection, whom you can contact by the following e-mail address: This email address is being protected from spambots. You need JavaScript enabled to view it.

• EU REPRESENTATIVE

  As we are based outside of the EU, Article 27 of the GDPR required that we appoint an EU representative to handle certain data subject requests and queries. In compliance with this, we have appointed MMC Hartmetall GmbH to act as our representative. Any queries requiring the input of our representative, should please be directed to them as follows:

  • Sending an email to MMC Hartmetall GmbH This email address is being protected from spambots. You need JavaScript enabled to view it.
  quoting “MHUK” in the subject line; or mailing your request to the following address:
  Corporate Planning Department, MMC Hartmetall GmbH, Comeniusstraße 2, 40670 Meerbusch, Germany"

• PURPOSE AND LAWFUL BASIS (why and on what lawful ground we use your personal data)

  We collect and use the following categories of your personal data:

  • basic business contact information (name, company, position, email, phone, office address, etc.);
  • video image (e.g. Microsoft Teams Meeting)
  • user account data and usage history on our websites or online services;
  • access records to our buildings and facilities;
  • records of business communication in connection with our business operation (email logs, meeting logs, reports, audit interviews, event photos, etc.).

  We use your personal data for the following purposes on the lawful basis that it is necessary for the purposes of our legitimate interests, i.e. running our business efficiently and effectively.

  • Managing business contact data;
  • Conduct Web meetings (e.g. Microsoft Teams Meeting);
  • Sales and delivery of products and services;
  • Procurement of materials and services;
  • Providing technical support, training and seminars;
  • Providing information on new products, services, case studies, etc.;
  • Receiving feedback for quality control;
  • Organizing business and/or technical events;
  • Auditing of suppliers;
  • Facilitating any other business communication; and
  • Controlling access to our physical facilities and computer/network resources.

  We use your personal data for the following purposes based on the lawful basis that you give your consent. Please note that you may withdraw your consent at any time.

  • Managing the registration data of the digital event platform
  • Conduct Web meetings for training/seminar (e.g. Microsoft Teams Meeting)
  • Contact by staff for the purpose of providing targeted advice.

• SENSITIVE PERSONAL DATA

  Where we collect and use sensitive categories of your personal data as defined in Articles 9 and 10 of the UK GDPR, we will obtain your prior and explicit consent. You may withdraw your consent at any time with effect for the future. An informal e-mail with this request is sufficient. The data processed before we receive your request may still be processed lawfully. Excepted from this consent is data where we are obliged to collect and use in order to fulfil our legal obligations or to protect vital interests of you or other persons in emergencies.

• RETENTION (how long we retain your personal data)

  We will retain your personal data as long as we have business relation with the company or any other entity you belong to at the time when we collect your personal data. Thereafter we keep them as may be required by applicable laws related to audit or tax issues or until we receive your objection to our retaining your personal data.
  If you have given your consent to the processing, we will retain your personal data until you withdraw your consent to the processing (but no longer than 12 months if your account has been inactive), unless other legal provisions require us to retain the data for a longer period. If you do not withdraw your consent, we will delete your personal registration data as soon as your account has been inactive for 12 months.

• DISCLOSURE (who we share your personal data with)

  We disclose certain categories of your personal data in so far as may be necessary for the purposes above to the following entities:

  • to other Mitsubishi Materials group companies as may be necessary for business purposes, e.g. expand business activities; your registration data of the digital event platform may be processed by the European Headoffice (MMC Hartmetall GmbH, Meerbusch, Germany) for the generation of statistics and reporting
  • where we provide you with user accounts for our computer/network services and resources, to Mitsubishi Materials Corporation, Tokyo (MMC), which provides us with such services and resources;
  • competent public authorities to which we are obliged to disclose your personal data as required by applicable laws; and
  • our service providers including those providing us with cloud computing, electronic mail or other application, business travel arrangement, courier, receptionist, conference/event arrangement, etc.

  where such service providers are “data processors” in the meaning of the UK GDPR, we make sure that such data processors have in place appropriate data protection measures by virtue of data processing contracts signed between such processors and us in compliance with Article 28 of the UK GDPR.

• TRANSFER TO NON-EU COUNTRIES

  We may disclose your personal data to other Mitsubishi Materials group companies that are located in countries outside of the European Economic Area, where data protection law with a level of privacy and data protection equivalent to that of the UK GDPR is not in force. In cases where such data transfer happens, we protect your personal data by virtue of data transfer agreements with such data recipients pursuant to Article 46 of the UK GDPR, which impose on such recipients contractual obligations to ensure adequate level of data protection equivalent to those laid down by the UK GDPR.

• YOUR LEGAL RIGHTS

  Provided that certain conditions are met, you have legal rights to request from us the following:

  • Access to your personal data and to certain supplementary information covered by this notice;
  • Correction of your personal data if inaccurate or incomplete;
  • Erasure of your personal data in certain circumstances;
  • Suspension of using your personal data in certain circumstances;
  • Stopping processing your personal data in certain circumstances; and
  • Obtaining your personal data in a structured, commonly used, and computer-readable format.

  If you wish to exercise any of your rights or have further questions about data protection, please contact us or our DPO, whose e-mail address can be found in the below abstract “INQUIRY”.

• WEBSITE

  If you visit our website, please note that there is a separated privacy notice available, explaining about the processing of your personal data during and / or after the visit of the website.

• COMPLAINT

  You can lodge complaints about our way of processing your personal data with data protection supervisory authorities. If there has been a breach of data protection legislation, the person affected may file a complaint with the competent regulatory authorities. The competent regulatory authority for matters related to data protection legislation in the UK is the data protection officer of the ICO (Information Commissioner’s Office). A list of data protection officers and their contact details can be found at the following link: https://ico.org.uk/

• INQUIRY

  For further information and inquiry, please contact:
  Person in charge:
  MMC Hardmetal UK Ltd
  Galena Close, Amington Heights
  Tamworth, Staffs, B77 4AS
  E-Mail: This email address is being protected from spambots. You need JavaScript enabled to view it.

  Data protection officer:
  E-Mail: This email address is being protected from spambots. You need JavaScript enabled to view it.

  The responsible body is the natural or legal person, which alone or jointly with others decides on the purposes and means of processing personal data (e.g. names, e-mail addresses, etc.).