Privacy Policy NGK and Group Companies in Japan

Basic Policy on Personal Data Protection

NGK Insulators, Ltd. and NGK group companies in Japan (hereinafter referred to as “NGK” or “we”) have established the following principles to process personal data we collect.

• (1) We handle personal data in accordance with applicable laws and regulations on the protection of personal data.
• (2) We collect personal data in a lawful and fair manner.
• (3) We use personal data within the scope of the purposes specified in advance.
• (4) We don’t provide personal data to third parties unless otherwise permitted by applicable laws and regulations on the protection of personal data or without consent from the data subject.
• (5) We aim for thorough personal data management by implementing internal rules and organizational structures to protect against personal data breaches, leaks, or loss, and by providing education to our employees.

Policy on Personal Data Processing

We process personal data of our customers, clients, and shareholders, etc. (hereinafter referred to as “customers, etc.,” “you” or “your”) based on the following policy (hereinafter referred to as “Policy”).
Please refer to here (Link) for information on the processing of personal data in the recruitment activities of NGK Insulators, Ltd.

1. Controller of Processing of Personal Data

We are the controller of the processing of personal data of customers, etc. Please refer to “12. Contact Us” below for our contact details.

2. Collection of Personal Data

1) We collect the following personal data directly from customers, etc. or indirectly from third parties other than customers, etc. (e.g., other NGK group companies, clients, business partners, and contractors) depending on the relationship between customers, etc. and us.

• (1) Identity verification information such as names, company names, department and/or sections, and titles
• (2) Contact information such as addresses, email addresses, telephone numbers, and fax numbers
• (3) General information such as personal or professional interests, inquiries about our services and products, transaction details, and designations for contact methods

2) In addition to the above personal data, we may collect the following personal data through access to our website by customers, etc.

• (1) Technical information such as IP addresses, browser types, operating systems, system languages, access times, and reference source website address
• (2) Cookies

NOTE:Technical information is collected in anonymized form. However, if personal data is provided by customers, etc., via our website, the technical information of customers, etc. may be linked to other personal data.

Cookies are data that are sent from websites to customers, etc.’s browsers and stored on their computers. Customers, etc. can refuse to use cookies by changing their browser settings.

3) If customers, etc., provide personal data of other data subjects to us, they represent that they have the authority to provide such personal data and allow us to use it according to this Policy. If necessary, we will contact such other data subjects and notify them of the Policy.

4) The use of our products and services may require the provision of certain personal data. You may refuse to provide personal data to us, but in such cases, access to our services may be limited.

3. Legal Basis for Processing Personal Data

We process personal data of customers, etc. based on the following legal basis.

1) Contract: When processing personal data of a customer, etc. is necessary to fulfill a contract with the customer, etc., or to take pre-contractual steps based on the requests of the customer, etc.

2) Legal obligations: If we need to comply with legal obligations

3) Legitimate interests: When processing personal data of a customer, etc. is necessary for legitimate interests pursued by us or third parties, such as those listed below; provided that such interests is not overridden by the fundamental rights and interests of the customers, etc.

• (1) Quality assurance, product support, and development
• (2) Implementation of marketing and sales promotion activities
• (3) Management of customer or business relationships, including complaint handling
• (4) Provision of personalized services

4) Consent: In the event that we obtain the consent of customers, etc. to process their personal data

4. Purpose of Use of Personal Data

1) We use personal data for the following purposes:

• (1) Verifying the identity of customers, etc. (Legal basis: performance of contract, legitimate interests)
• (2) Marketing and selling our products and providing our services (Legal basis: performance of contract, legitimate interests)
• (3) Providing, obtaining, and researching information about our products (Legal basis: legitimate interests)
• (4) Providing maintenance and after-sales services for our products (Legal basis: performance of contract, legitimate interests)
• (5) Guidance for seminars and exhibitions in relation to our products (Legal basis: legitimate interests, consent)
• (6) Distribution of newsletters, etc. in relation to our products and our businesses (we do not send commercial e-mails without consent that violate applicable laws and regulations.) (Legal basis: legitimate interests, consent)
• (7) Research, development and improvement of our products and services (including new products development) (Legal basis: legitimate interests)
• (8) Procurement of goods or services necessary for our products and services (Legal basis: performance of contract, legitimate interests)
• (9) Responding to and dealing with customer requests and inquiries (Legal basis: legitimate interests, consent)
• (10) Our internal records (Legal basis: legal obligations, legitimate interests)
• (11) Optimizing the content of our website for customers, etc. in consideration of the devices they use for the best user experience (Legal basis: legitimate interests, consent)
• (12) Responding to exercise of shareholder rights (Legal basis: Legal obligations, legitimate interests)
• (13) Other services related to the above (Legal basis: performance of contract, legal obligations, legitimate interests, consent)
• “Our products” refers to products of our businesses.

2) If it becomes necessary to collect or process personal data of customers, etc. for purposes other than the purpose of use above and those notified or publicly announced by us, we will notify customers, etc. of such purpose and obtain their consent (Legal basis: consent).

3) Notwithstanding the foregoing, we may process personal data of customers, etc. in order to comply with applicable laws and regulations or to respond to court orders and legal proceedings (Legal basis: legal obligations, legitimate interests).

5. Use of Cookies

Please see the cookie policy posted on each website for details on the use of cookies, etc. on our websites.

6. Disclosure and Joint Use of Personal Data

1) We may disclose personal data of customers, etc. to the following persons within the extent of the purposes stated in “4. Purpose of Use of Personal Data” above.

• (1) Other NGK group companies
• (2) Contractors or agents
• (3) Our customers, etc.

2) We may disclose personal data of customers, etc. to other third parties (e.g. regulatory authorities, governmental authorities, courts and attorneys) in connection with compliance with applicable legal obligations, exercise of rights and claims, defense or proof thereof.

3) We may disclose personal data of customers, etc. to third parties in the event that any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or part of our business, assets or shares (including those related to bankruptcy or similar proceedings) is planned or actually carried out.

4) We may jointly use your personal data pursuant to the Act on the Protection of Personal Information of Japan. When sharing your personal data with a group company located in a foreign country, we will handle it in accordance with “8. Transfer of Personal Data Abroad”.

Scope of Entities Jointly Using Personal Data	NGK group Companies For more details, please refer to List of NGK Group Companies ()
Purpose of Use	Please refer to above “4. Purpose of Use of Personal Data”.
Personal Data to be Jointly Used	Name, address, telephone number, fax number, email address, company name, department/section, title, and inquiry/transaction details, etc.
Responsible Entity	NGK Insulators, Ltd. (Please refer to here (Link) for the company details.)

7. Safety Management Measures

To prevent unauthorized external access, loss, leakage, or falsification of personal data, we implement safety management measures, including the development of internal rules, regular employee training, internal audits, and access controls for personal data, both in terms of tangible and intangible measures.

8. Transfer of Personal Data Abroad

1) Since we are global organizations, we may transfer personal data of customers, etc. to a third party located in a country other than the country of residence of customers, etc. within the extent of the purposes stated in “4. Purpose of Use of Personal Data” above. In this case, we will comply with applicable laws and regulations on the protection of personal data by, for example, securing one of the following or obtaining the consent of customers, etc.

• (1) The country/region to which personal data will be transferred is designated as a country/region that ensures an adequate level of protection for the rights and freedoms of customers, etc. with respect to personal data under applicable laws and regulations on the protection of personal data.
• (2) The third party has entered into contracts with us regarding the transfer of personal data as required by applicable laws and regulations on the protection of personal data.

2) For further details on the protection afforded when personal data is transferred to a country other than customers, etc.’s country of residence, please contact us at the contact details listed in “12. Contact Us” below.

9. Retention Period

We will retain your personal data for the period necessary to achieve the above “4. Purpose of Use of Personal Data”. However, this does not apply if a longer retention period is required by applicable laws and regulations.
In order to determine appropriate retention period of personal data, we shall take into account the quantity, nature and sensitivity of the personal data, the likelihood of damage due to unauthorized use or disclosure of personal data, the purpose for which we process personal data, whether we can achieve these purposes through other means, and any matters required by applicable laws and regulations.

10. Your Rights

1) We will respond appropriately to requests from customers, etc. regarding the processing of personal data in accordance with applicable laws and regulations on the protection of personal data. These rights may vary depending on the location of customers, etc. and applicable laws and regulation on protection of personal data with respect to the relationship between customers, etc. and us, but typically include the following:

• (1) Right to obtain information regarding the processing of your personal data, and to access the personal data we hold about you;
• (2) Right to request that we rectify your personal data if it is inaccurate or incomplete;
• (3) Right to request that we erase your personal data in certain circumstances;
• (4) Right to request that we restrict our processing of your personal data in certain circumstances;
• (5) Right to object to our processing of your personal data
• (6) Right to receive your personal data in a structured, commonly used, and machine-readable format and/or to request that we directly transmit such personal data to a recipient where this is technically feasible;
• (7) Where the processing is based on consent, the right to withdraw your consent to our processing of your personal data at any time (however, the withdrawal of your consent shall not affect the lawfulness of processing performed based on the consent before your withdrawal).

2) We usually do not make decisions based solely on automated decision-making. However, in some cases, in order to coordinate communication with customers, etc., we may profile the interest of customers, etc. in our products and services while monitoring the technical information of customers, etc.

3) You may exercise any of your rights by contacting us, using the information about us set forth in “12. Contact Us” below. You also may lodge a complaint with a competent data protection authority if you believe that we have infringed any of your rights.

11. Changes to This Policy

1) We may revise this Policy in response to revisions of laws or regulations and our business needs, etc. We may update our Policy by posting a new version online. You are encouraged to check our website as needed to confirm the changes.

2) If the contents of any change may have a material adverse effect on the protection of personal data of customers, etc., we shall use reasonable efforts to notify customers, etc. in advance and give customers, etc. a reasonable period of time to object to such changes.

12. Contact Us

If you have questions or concerns about this Policy, requests for disclosure, etc. of your personal data, and other inquiries on our practice of processing your personal data, NGK Insulators, Ltd. accepts them through the responsible department below or inquiry form on the website “Inquiry and opinion about NGK” (Link) , and NGK group companies accept them with contact details listed in the “About NGK network” (Link).

General Affairs Department
NGK Insulators, Ltd.
Address: 2-56 Suda-cho, Mizuho, Nagoya, Aichi 467-8530, Japan
Phone: +81-52-872-7125
Fax: +81-52-872-7135

For Customers, etc. in the European Economic Area (EEA) and the UK

This subsection applies to customers, etc. in the EEA and the UK. This subsection supplements the Policy and prevails over any conflicting provisions in the Policy.

Transfers of Personal Data Outside the EEA or the UK

1) Your personal data may be transferred to third parties outside the EEA or the UK. When we transfer personal data to a third party outside the EEA or the UK, we ensure that:

• (1) The recipient destination countries or regions has been subject to a finding from the European Commission or has been designated by the government of the UK as ensuring an adequate level of protection for the rights and freedoms that you possess in respect of your personal data; or
• (2) The recipient third party enters into with us standard data protection clauses that have been approved by the European Commission or the government of the UK.

2) By contacting our contact details stated in “12. Contact Us” of the Policy, customers, etc. can confirm further details of the protection afforded when personal data is transferred outside the EEA or outside the UK.

For Customers, etc. in California

This subsection applies to customers, etc. who are California consumers within the meaning of the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”). This subsection supplements the Policy and prevails over any conflicting provisions in the Policy.

1. Collection, Use, and Disclosure of Personal Information

A. Categories, Sources, and Purposes of Use of Personal Information Collected or to Be Collected

1) The categories of personal information (as defined in the CCPA) that we may collect or have collected during the last 12-month period are as follows:

• (1) Identifiers: Name, address, email address, telephone number, fax number, etc.
• (2) Other personal information: Personal or professional interests, designations for contact methods, etc.
• (3) Commercial information: Inquiries about our services and products, transaction details, etc.
• (4) Internet or other electronic network activity information: Technical information including IP addresses, cookies, etc.
• (5) Professional or employment-related information: Company names, department and/or sections, titles, etc.

2) For business or commercial purposes when collecting, using, disclosing, or sharing personal information, please refer to “4. Purpose of Use of Personal Data” of the Policy.

3) The following lists the categories of sources from which personal information was collected during the last 12-month period.

• (1) Directly from customers, etc.
• (2) Obtained automatically through our website
• (3) Obtained indirectly from other NGK group companies
• (4) Obtained indirectly from clients, business partners, and contractors

B. Sale, Sharing, and Disclosure of Personal Information

a) Sale of Personal Information

We do not sell, and have not sold during the last 12-month period, your personal information, including the personal information of consumers under 16 years of age.

b) Sharing of Personal Information

1) We may share personal information of customers, etc. with third parties for the purpose of targeted advertising. The table below shows (i) the category of personal information we shared during the last 12 month period, and (ii) the category of third parties with whom we shared personal information during the last 12 months.

2) We do not share, and have not shared during the last 12-month period, personal information of consumers we recognize as under 16 years of age, without their (or their parents’ or guardians’) consent.

c) Disclosure of Personal Information for a Business Purpose

We may disclose personal information of customers, etc. to third parties for business purposes. The table below shows (i) the category of personal information we disclosed for business purpose during the last 12 month period, and (ii) the category of third parties to whom we disclosed personal information for a business purpose during the last 12 month period.

2. Your Rights and Requests

1) If you are a California consumer, you have certain rights regarding your personal information, as described below:

• (1) Access:You have the right to request, twice in a 12-month period, that we disclose to you the following information about you which we have collected, used, disclosed, or shared during the last 12 month period:
  • The categories of personal information we collected or shared about you;
  • The categories of sources from which we collected such personal information;
  • The business or commercial purpose(s) for collecting or sharing such personal information about you;
  • The categories of third parties to whom we disclosed or shared such personal information; and
  • The specific pieces of personal information we have collected about you.
• (2) Deletion:You have the right to request that we delete certain personal information we collected from you.
• (3) Correct:You have the right to request that we correct inaccurate personal information we maintain about you.
• (4) Opt-Out of Sharing:You have the right to request that we stop sharing of your personal information.

2) To request access, deletion, or correction above, please contact us by using the telephone number or inquiry form below.

Telephone number:+1-888-797-3199
Inquiry form link:“Inquiry and opinion about NGK” ( Link)

3) To prevent personal information of customers, etc. from being shared with third parties for purposes of cross-context behavioral advertising, please contact us via the following link or via the telephone number or web form listed above.

If you access the above link from outside California, the “Do Not Sell or Share My Personal Information” statement will not be displayed in the cookie consent management tool on the linked page, but you will still be able to exercise your right to opt out of sharing with third parties in the same way as if you accessed it from within California.

4) We process opt-out preference signals from the Global Privacy Control (“GPC”). GPC is a browser-level technical specification, and it can be used to notify the website that customers, etc. will opt out of the sale and sharing of personal information. If you use GPC, our website will treat the browsers that customers, etc. use to access our website as having been requested to opt out of sale and sharing to the extent that we are involved in the processing. If you visit our website from another browser, you must install GPC in that browser. For details on how to set GPC, please refer to https://globalprivacycontrol.org/.

5) In order to protect the privacy of customers, etc. and maintain security, we will take measures to confirm the identity of customers, etc. before allowing access to your personal information, or responding to your request for deletion or correction. Upon receipt of a request for access, request for deletion, or request for correction from customers, etc. we shall first request the provision of personal information (name, e-mail address, etc.) already provided by customers, etc. to us, and confirm the identity of customers, etc. by comparing the information provided by customers, etc. with information already held by us. If the identity of the customers, etc. cannot be verified because customers, etc. do not provide such information, we may refuse the request from customers, etc.

6) If customers, etc. use an authorized agent to make an access request, deletion request, or correction request on behalf of customers, etc., we may ask the agent to submit a document certifying that customers, etc. have given the agent a signed permission to make the request. In addition, we may request customers, etc., either (i) to directly verify with us the identity of customers, etc. themselves, or (ii) to directly confirm with us that customers, etc. have provided the agent permission to submit a request.

7) Customers, etc. have the right not to be subject to discriminatory treatment from us even if customers, etc. exercise any rights under the CCPA.

8) We will not be subject to the right to limit use or disclosure of sensitive personal information because we will not use or disclose sensitive personal information of customers, etc. for any purpose other than those stipulated in the CCPA.

3. Changes to This Subsection

We may change this subsection from time to time. The “Last Updated” date at the bottom of this page states when this subsection was last updated; any changes become effective upon us posting the revised subsection.
We post a prominent notice on our website to notify you of any significant changes to this subsection and indicate the date it was most recently updated.

4. Contacts

If you have any questions or concerns regarding this subsection or our privacy practices, please contact us to the contact details stated in “12. Contact Us” of the Policy.

Updated April 1, 2025