PRIVACY POLICY

 

1. Data Controller

 

The Data Controller for the data collected through this Website is:

 

NIPPON GASES EURO-HOLDING, S.L.U. (hereinafter, "NIPPON GASES").

Calle Orense, número 11, 9ª planta, 28020 - Madrid, Spain.

datos.spain@nippongases.com

 

2. Purpose and legal basis of the data processing

 

The personal data of the User of this Website will be processed for the following purposes:

 

• Responding to information requests made and/or questions asked by the User. The data processed for this purpose will be retained until the information request and/or question has been answered and, after this, during the legally established periods for data retention and for the expiration of liability. The legal basis for the processing is the User’s consent in case of receiving the request through a form or the legitimate interest in responding in case of receiving the request by email.

   

• Informing the User, including through electronic means, of products, services, and updates from NIPPON GASES and the other companies in its business group (which can be consulted on this Website). The data processed for this purpose will be retained until the User withdraws their consent for receiving these communications and, after this, during the legally established periods for data retention and for the expiration of liability. The legal basis of the processing is the User’s consent.

   

• User account management for patients and healthcare Professionals to access the training platform. The data processed for this purpose will be retained until the User withdraws their consent. After this time, the data will be kept for the legally stipulated periods of conservation and prescription of responsibilities. The legal basis of the processing is the User’s consent.

 

3. Recipients

 

NIPPON GASES may disclose the User’s data to the following third-party recipients: Government Agencies for compliance with legal obligations. It may also disclose the data to the following categories of data processors: providers of electronic communications, office automation, hosting, housing, computer maintenance, auditing, and legal counsel. Some of these data processors may be located outside the European Economic Area, with whom appropriate safeguards will adopted for the security of the international transfer of personal data.

 

4. Rights

The User may exercise before NIPPON GASES their rights of Access, rectification, erasure, restriction of processing, data portability and objection.

 

Moreover, in data processing where the legal basis is the consent given by the User, the User has the right to withdraw such consent at any time, without this affecting the lawfulness of the processing based on the User’s consent prior to its withdrawal.

 

To exercise these rights, the User may send Their request to calle Orense, número 11, 5ª planta, 28020 - Madrid, Spain, or to the email address datos.spain@nippongases.com.

 

NIPPON GASES has designated a Data Protection Officer who can be contacted by standard mail at calle Orense, número 11, 5ª planta, 28020 - Madrid, Spain, or by email at datos.spain@nippongases.com.

 

In any event, the User is entitled to submit a claim to the relevant supervisory authority if they deem this appropriate.

 

1. Use of cookies on the website

    This website uses its own cookies and third-party cookies for analytical, technical, and profiling purposes, processing the data needed to create profiles based on the user’s browsing habits.

2. What is a cookie?

   This website uses cookies and/or similar technologies that store and retrieve information when you browse. In general, these technologies can be used for many different purposes, such as               recognizing you as a user, obtaining information about your browsing habits or customizing the way content is displayed. Below, we describe the specific ways in which we use these technologies.

   In addition, these technologies may be our own or of third parties. Own cookies are those that are sent to the user's terminal equipment from a computer or domain managed by the editor itself           and from which the service requested by the user is provided. Third parties cookies are those that are sent to the user's terminal equipment from a computer or domain that is not managed by the     publisher, but by another entity that processes the data obtained through cookies.

3. What kinds of cookies does this website use and who uses them?

 

Type of cookie	Who manages them?	Period of activity	More information
Technical cookies: these cookies allow the user to browse a website, platform or application and to use the various options or services on it. This includes cookies used by the editor to manage and operate the website and to enable its functions and services, such as controlling data communication and traffic, identifying the session, accessing sections with restricted access, remembering the elements that make up an order, carrying out the purchase process for an order, managing payment, controlling fraud connected to the security of the service, requesting registration or participation in an event, counting visits for invoicing purposes for the licenses of the software used for the service (website, platform, or application), using security elements during browsing, storing content for the reproduction of videos or sound, enabling dynamic content (for example, loading animation for text or images) or sharing content on social media. This category also includes, due to their technical nature, cookies that allow the most efficient management possible of advertising spaces that the editor has included in a website, application or platform, as an additional design or “lay-out” element of the service offered to the user based on criteria such as the published content. These cookies do not collect information from users for other purposes, such as customizing that advertising content or other content.	Windows Azure	Session	https://privacy.microsoft.com /es-es/privacystatement
	Microsoft	Session	https://privacy.microsoft.com/ es-es/privacystatement
	Google Tag Manager	Persistent	https://policies.google. com/technologies/ cookies?hl=es
Preferences or customization cookies: these cookies help remember information so the user can access the service with certain characteristics that can differentiate their experience from that of other users. For example, this includes language, the number of results to be displayed when the user performs a search, the appearance or content of the service based on the type of browser with which the user accesses the service or the region from which they access the service, etc.
Analytical or measurement cookies: these cookies allow the person in charge of cookies to monitor and analyze the behavior of users of the websites where they are used, including quantification of the impact of advertisements. The information collected with this type of cookie is used to measure the activity of the websites, application, or platform, in order to make improvements based on an analysis of data regarding how the service’s users make use of the service.	Sitecore	Persistent	https://www.sitecore.com /trust/cookie-policy
	Google Analytics	Persistent	https://policies.google. com/technologies/ cookies?hl=es
Behavioral advertising cookies: these cookies store information on users’ behavior, obtained through ongoing observation of their browsing habits. This enables the creation of a specific profile, in order to display advertising based on that profile.

  4. How can I block or delete the cookies used by this website?

    The user can allow, block or delete the cookies installed on their computer by configuring the options of the browser installed on their computer or through the settings panel provided to the user.        If you accept third-party cookies, you can also delete them by using the system offered by the third party.

    Next, we indicate how to modify the cookie settings according to the browser options installed on your computer:

- Google Chrome:

- Mozilla Firefox:

- Internet Explorer:

- Opera:

- Safari:

    Blocking the installation of the cookies does not prevent the user from effectively using the website.

    You can receive information regarding any transfers to third countries that may be carried out by the third parties identified in the table above in their respective policies. See the links provided in              the “More information” column.

    If you have any questions or queries regarding the use of cookies carried out through this website, you can address them to the following e-mail address info@nippongases.com.

In accordance with the Directive (EU) 2019/1937, Nippon Gases Euro-Holding, S.L.U. approved for the European Nippon Gases Group companies a Whistleblowing Policy and Procedure with the purpose to establish the necessary provisions for the Internal Whistleblowing System and the existing internal information channels.

 

This document summarizes the main points of the procedure:

 

 

1. Nippon Gases Internal Whistleblowing System

 

The Nippon Gases Internal Whistleblowing System is the main channel for reporting possible irregularities that may involve violations regarding acts or conducts referring to the areas of application indicated in the Corporate Policy on the Internal Whistleblowing System of the Nippon Gases Group.

 

Reports may be submitted with identification of the reporting person or anonymously.

 

This channel allows the submission of reports through:

 

• EthicsPoint external platform accessible through https://secure.ethicspoint.eu/domain/media/eseu/gui/105848/index.html

 

• E-mail: compliance@nippongases.com

 

• Compliance hotline (the numbers for each country are published in EthicsPoint platform)

 

At the request of the reporting person, reports may also be submitted verbally by means of a face-to-face or videoconference systems.

 

All reports will be received by the European Chief Compliance Officer and the European Human Resources Director who are both members of a collegiate entity performing the duties of the Internal Whistleblowing System Manager and will hereinafter be referred to jointly as System Managers.

 

It is also possible to file a report by communicating it to one's supervisor, the local Compliance Champion, or the Human Resources function or the Legal Department.

 

 

2. Stages of the procedure

 

2.1. Registration phase

 

Any report submitted to one of the aforementioned internal channels, in compliance with the principle of good faith, will be acknowledged within seven days of receipt.

 

The reporting person must provide the data he/she deems necessary. In case of choosing the EthicsPoint external platform, the reporting person must send the report by filling in the data collection form available.

 

 

2.2. Analysis phase

 

The reports received will be subject to an admissibility analysis. Excluded from the scope of the Internal Whistleblowing System are reports that:

 

• do not fall within the material scope of the Directive and/or do not relate to facts/conduct concerning violation of Nippon Gases Code of Conduct or irregularities that may involve violations of the internal regulations applicable to Nippon Gases Group companies;

 

• are based on mere rumors and/or are not based on specific facts;

 

• specifically concern the content of a file/document not accessible to the company and not provided in the communication.

 

Considering the above exclusions of inadmissibility, the person in charge will communicate the admission/ non-admission decision to the reporting person.

 

The analysis phase ends with the selection of the team/person responsible for the investigation, which will correspond to the local compliance department or to the person/s designated by the System Managers, depending on the object of the report. In any case, the team/person responsible for the investigation will never be related to the facts under investigation, so as to avoid any conflict of interest. Nevertheless, if one of the person appointed to conduct the investigation has a conflict of interest in relation to the matters brought to his or her attention, he or she shall refrain from handling them.

 

 

2.3. Research phase

 

The investigation will be initiated as soon as possible.

 

The investigation will be carried out in accordance with the defined internal procedures, in compliance with the guarantees provided for in the Nippon Gases Europe Policy on the Internal Whistleblowing System and, in any case, guaranteeing for all persons concerned:

 

• respect for the presumption of innocence and honor, as well as the right to defense;

 

• the right to be heard at any time;

 

• the right to be informed about the actions or omissions attributed to him/her.

 

• the preservation of their identity and the confidentiality of the facts and data of the proceeding.

 

The investigation procedure may include:

 

• personal interviews with the reporting person to gather more information;

 

• personal interviews with the departments and/or persons directly or indirectly involved in the events/conduct that are potentially irregular, as identified by the individuals responsible for the investigation;

 

• data analysis and information gathering;

 

• request for expert evidence from internal or external professionals;

 

• other investigative or evidentiary steps that are considered relevant and are the least burdensome possible in relation to the legal position of the person concerned.

 

2.4. Resolution phase

 

The System Managers shall make an assessment of the facts/conduct that is the object of the report, based on the investigation conducted, and shall communicate their findings to the parties concerned as soon as possible.

 

In the event of non-compliance by an employee, the System Managers will forward the file to the Human Resources Department for appropriate action to be taken.

 

The resolution period may not exceed three months from receipt of the communication or, if no acknowledgement of receipt was sent to the reporting person, three months from the expiration of the seven-day period after the communication was made, except in cases of particular complexity requiring an extension of the period, in which case, the period may be extended up to a maximum of three additional months.

 

 

3. Protection of personal data

 

The Internal Whistleblowing System is designed, established and managed in a secure manner, so as to guarantee the confidentiality of the persons involved in the reports and the actions carried out in the management and processing of these, as well as data protection.

 

Personal data will not be collected if it is manifestly not relevant to the processing of specific information or, if collected by accident, will be deleted without undue delay.

 

Personal data relating to the information received and to the internal investigations referred to in the preceding paragraph shall only be kept for such period as is necessary in accordance with applicable law.

 

 

4. Protective measures

 

The reporting persons shall be entitled to protection provided that none of the exclusions set forth in section 2.2 apply and provided that the following circumstances are met:

 

• he/she have reasonable grounds to believe that the information referred to is truthful, even if they do not provide conclusive evidence, and the said information falls within the scope of the Internal Whistleblowing System.

 

• the report has been made in accordance with the requirements set forth in the Corporate Policy on the Internal Whistleblowing System and in this Procedure.

 

Persons who have communicated information about actions or omissions anonymously, but who have subsequently been identified, are also entitled to protection.

 

Nippon Gases Group expressly prohibits acts constituting retaliation, including threats of retaliation and attempts to retaliate against persons who file a report that complies with the requirements of the Corporate Policy on the Internal Whistleblowing System and applicable law.

 

The good faith of the reporting person is a prerequisite for his/her protection. The legislation in this area excludes from protection persons who have knowingly submitted false or misleading information, as well as those who have obtained it unlawfully.

 

 

 

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¹Retaliation means any acts or omissions that are prohibited by law, or that directly or indirectly involve unfavorable treatment that places the persons suffering them at a particular disadvantage compared to another in the employment or professional context, solely because of their status as whistleblowers, or because they have made a public disclosure. Among others, the following are considered retaliation for the purposes of the Directive: suspension of the employment contract, dismissal or termination of the employment relationship, demotion or denial of promotion, intimidation, harassment, discrimination, or unfavorable or unfair treatment.

 

²The full document is available here