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Privacy Policy


1. Mitsubishi International Corporation and Data Privacy

1.1Mitsubishi International Corporation (referred to as the Company, we or our) are committed to protecting and respecting your privacy.

1.2This privacy statement will apply if you are employed or engaged by one of our customers or business partners and the Company processes personal data about you. This privacy statement sets out the basis on which we will process any personal data that we may collect or receive about you as a customer or business partner contact.

2. The Personal Data that We Collect About You

2.1We may collect and process the following information about you:

2.1.1Information that You Give Us

(a) Information about you that you give to us when giving us a business card or similar information, filling in forms that we ask you to complete, or corresponding with us by telephone, mail, email or otherwise, and information obtained when you sign up for or attend a webinar, meeting or networking event. This may include:

(i) Contact details such as your name, address, email address and phone number;

(ii) Details of relationship to actual or potential customer or business partner;

(iii) Communication with actual or potential customer or business partner;

(iv) Employment details;

(v) Your banking information, social security number; and

(vi) Biography.

(b) Information that are contained in any regulatory forms that we require you to complete for KYC, AML or similar purposes. This may include:

(i) Contact details such as your name, residential address, email address and phone number;

(ii) Government photo ID cards, including but not limited to a driver’s license and passport;

(iii) Passport numbers; and

(iv) Date of birth.

2.1.2Other Information

(a) We may also collect some information from other sources. For example:

(i) your colleagues or other business contacts may give us information about you such as your contact details or details of your role and biography at the customer or business partner; and

(ii) we sometimes collect information from third party data providers, background check providers or publicly available sources for anti-money-laundering, background checking, creating a database and similar purposes, and to expand our business relationship, protect our business and comply with our legal and regulatory obligations.

3. The Uses that We Make of Your Personal Data

3.1We may use your personal data for the following purposes:

3.1.1to operate, manage, develop and promote our business and, in particular, our relationship with the organization you represent (if any) and related transactions – this includes, for example, concluding trades and business and billing / payment purposes and responding to inquiries and any related activities that may result from your inquiries and communications with us;

3.1.2processing incidental to the management of the Company's business, including keeping proper records of communications and transactions; accounting activities; and managing our customer, partner and vendor relationships;

3.1.3background checks and searches on customers or business partners (and anticipated customers or business partners), including checks relating to their individual directors, officers and beneficial owners and to protect our business from fraud, money-laundering, breach of confidence, theft of proprietary materials and other financial or business crimes, or other regulatory non-compliance; and

3.1.4to comply with our legal and regulatory obligations; enforce our legal terms and policies; bring and defend legal claims; and when we believe use or disclosure is appropriate to protect ours or others' rights, property or safety.

3.2From time to time, we may review information about you held in our systems – including the contents of and other information related to your email and other communications with us – for compliance and business-protection purposes as described above. This may include reviews for the purposes of disclosure of information relevant to litigation; reviews of records relevant to internal or external regulatory or criminal investigations and/or review relating to compliance with internal policies and standards. These reviews will be conducted in a reasonable and proportionate way or otherwise in compliance with applicable law and approved at an appropriate level of management. They may ultimately involve disclosure of your information to a court, governmental agencies, regulatory bodies and litigation counterparties as described below.

3.3We may also be required by law to disclose or otherwise process your personal data. We will tell you, when we ask you to provide information about yourself, if provision of the requested information is necessary for compliance with a legal obligation or, on the other hand, if it is purely voluntary and there will be no implications if you decline to provide the information.

3.4If personal data is required to enter into a contract or otherwise provide products or services to the company you represent, we may be unable to enter the contract or provide such products and services if you fail to provide the requested personal data. We will inform you if this is the case.

3.5We may share your personal data to authorized third-party service providers or others who may perform services on our behalf, such as payment processing, data analysis, and customer service and support.

3.6If we are involved in a (potential or actual) merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets or transition of services to another provider, your personal data may be disclosed in connection with the negotiation of such transaction, and/or sold or transferred as part of such a transaction as permitted by applicable law and/or contract.

4. Our Legal Bases for Using Your Personal Data

4.1We rely on the following lawful bases under data protection law for our use of your personal data for the purposes outlined above:

4.1.1Consent: You have given your consent to the processing;

4.1.2Performance of a Contract: It is necessary for the performance of and compliance with our contract with the organization you represent or in order to take steps prior to entering into that contract;

4.1.3Legal or Regulatory Obligation: We need to process your personal data in order to comply with a legal or regulatory obligation; or

4.1.4Legitimate Interests: It is necessary for our legitimate interests (or those of a third party). Please see section 5 (When do we have legitimate interests?) below for more information.

4.2Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. When Do We Have Legitimate Interests?

5.1We use your personal data where this is necessary for our legitimate interests (or those of a third party) (or, where, under applicable data protection law, we are entitled to assume your consent, or we are able to rely on an exemption from consent). This includes where use of your personal data is necessary to:

5.1.1Administer our operations and business in an efficient and effective way including undertaking management planning and improving and developing our products and services;

5.1.2Manage and administer our services and business arrangements, including with the organization you represent;

5.1.3Understand and respond to questions, complaints and feedback;

5.1.4Send direct marketing to business contacts;

5.1.5Transfer personal data in relation to an actual or proposed sale, transfer or reorganization of all or part of our business and the acquisition of the business;

5.1.6Ensure network and information security; and

5.1.7Enforce our legal rights and manage any dispute and legal claims and take legal or other professional advice.

6. Special Category/Sensitive Personal Data

6.1Certain types of personal data are more sensitive than others. This special category personal data about you includes information about health, disability, race, ethnicity, criminal offenses (or alleged offenses), political opinions, biometrics or religion.

6.2We rely on the following lawful bases under applicable data protection law for our use of your special category personal data:

6.2.1Data Related to Criminal Convictions and Offenses, or Related Security Measures.

(a) We will process this information based on our legitimate interest and compliance with legal or regulatory obligations as permitted by applicable law, including where necessary due to suspicion of terrorist financing or money laundering.

7. Disclosure and International Transfer of Your Personal Data

7.1Your personal data will be processed by our employees and contractors.

7.2There are also certain circumstances where we will transfer your personal data to third parties. These include:

7.2.1Mitsubishi Group Companies. We may share your personal data with other group companies if your inquiry or requirements would be best provided by a different group company.

7.2.2Service Providers. Third parties may process your personal data on our instruction. These include IT suppliers, cloud hosting providers, professional advisors, marketing agencies, database providers, background check and other KYC/AML check reference providers, backup and disaster recovery specialists and email providers.
Our suppliers and service providers will be required to meet appropriate standards on processing information and security when processing your personal data. The information we provide them, including your information, will only be processed in connection with the performance of their function. They will not be permitted to use your information for any purposes other than those outlined in this privacy statement.

7.3Your personal data may be transferred to other third-party organizations in certain scenarios, such as:

7.3.1If we're discussing selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality;

7.3.2If we are reorganized or sold, information may be transferred to a buyer who can continue to provide services to you;

7.3.3If we are required to by law, or under any regulatory code or practice we follow, or if we are asked by any court, public or regulatory authority, other governmental agencies, or litigation counterparties, in any country or territory, e.g. in order to assist fraud protection and minimize credit risk; or

7.3.4If we are defending a legal claim, your information may be transferred as required in connection with defending such claim.

7.4Your personal data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data.

7.5The above disclosures may involve transferring your personal data internationally.

7.6When providing your personal data you acknowledge that you are providing this to the Company in the US and that your personal data will be held and processed in the US.

7.7You should be aware that processing by us may also include transfers to other countries outside the country in which you are located (including outside the EEA and UK), which may not provide levels of data protection equivalent to your home jurisdiction. In those cases, where we transfer personal data internationally, we will take steps to ensure that the transfer complies with applicable data protection law including (where applicable) entering into data transfer agreements, designed to ensure that your personal data is protected, on terms approved for this purpose by the relevant data protection authority including the European Commission or relevant UK Government department (as applicable) – including the Standard Contractual Clauses. Please Contact us (see below) if you would like to know whether any such agreements are in place or, if so, to see a copy.

8. Retention and Deletion of Your Personal Data

8.1We will delete the personal data that we hold about you when we no longer need it. How long we keep personal data depends on the type of personal data and the purpose(s) for which we collected it and the applicable legal requirements. Unless otherwise prohibited by applicable law, we will keep personal data for as long as it is needed to provide our services, communications, or document our business relationship with you, and is reasonably necessary to comply with our legal obligations, resolve disputes, enforce our agreements, or as required by applicable law.

8.2Except to the extent prohibited by applicable law, we may retain some limited personal data about you even when we know that you have left the organization that you represent, so that we can maintain a continuous relationship with you if and when we are in contact with you again, representing a different organization. Please contact us if you need more information.

9. Legal Requirements

9.1Your personal data may be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in relation to court disclosures or the defence of a legal claim. We will not delete personal data if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

10. Your Rights

10.1 You may have a right of access to the personal data that we hold about you, and to some related information, under applicable data protection law. You may also be able to request that any inaccurate personal data to be corrected or deleted. You have the right to ask us to restrict processing of your personal data in certain circumstances. You can object to our use of your personal data for direct marketing purposes at any time and you may have the right to object to our processing of some or all of your personal data (and require them to be deleted) as well as the right to data portability in some other circumstances. If you want to exercise your right under the applicable privacy laws, please use the following request format.
Data Subject Rights Request Form
Authorized Agent Designation Form

10.2Depending on the country or territory where you reside, you may also have the right not to receive discriminatory treatment if you exercise the rights listed in this policy. You may also have the right, subject to certain exceptions under applicable law, to request that we do not sell or share your personal data. You may withdraw your consent at any time by contacting us at ml.mca.privacy@mitsubishicorp.com.

10.3Depending on the country or territory where you reside, you may also have a right to lodge a complaint with a supervisory or regulatory authority. You may lodge a complaint with the supervisory authority in the country or territory where you are habitually resident, where you work or where an alleged infringement of data protection legislation has taken place.

10.4These above rights may be limited, for example, if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have overriding legitimate interests in keeping. If you have any questions regarding these rights, please contact us at ml.mca.privacy@mitsubishicorp.com. Please note that we may request additional information to respond to or fulfil any requests regarding your rights under applicable laws or regulations.

11. Contact Us

11.1We welcome questions, comments and requests regarding this privacy statement and our processing of personal data. Please send them to
You can also use the following toll-free number:
+1 (888) 700-2011

11.2If you are located in the EEA, you can contact our GDPR EU Representative here: The DPO Centre Europe Limited
Alexandra House, 3 Ballsbridge Park, Dublin, D04C 7H2
Email: ml.eurep@mitsubishicorp.com
Phone number: +353 (1) 631-9460

11.3If you are located in the UK, you can contact our UK GDPR Representative here:The DPO Centre Limited
50 Liverpool Street, London EC2M 7PY, UK
Email: ml.ukrep@mitsubishicorp.com
Phone number: +44 (0) 203-797-6340

12. Changes to This Policy

12.1Any changes we make to this privacy statement in the future will be posted to our website (at Mitsubishi International Corporation (mitsubishicorp.com)). Please check back frequently to see any changes. You can tell when this privacy statement was last updated by looking at the date at the end of the privacy statement.

12.2If we make a change that significantly affects your rights or, to the extent we are permitted to do so, significantly changes how or why we use personal data, we will notify you by way of a prominent notice on our website or, if we have your email address, by email.

12.3Any changes to this privacy statement will become effective upon posting.

Issue Date: January 1, 2023