Privacy Statement - Marubeni Europe

Marubeni

Website Privacy Statement

1. Introduction

This privacy statement provides information about the processing of personal data in the contexts described in section two below.

Unless otherwise stated herein, Marubeni Europe plc (“MEU”) and Marubeni International (Europe) GmbH (“MEG”) act as independent controllers for that processing. Which of the two entities acts as controller for the processing in question will generally depend on which entity you are engaging with.

If you would like to contact MEU about data protection matters, then please email eur-privacy@marubeni.com or send a letter to: Marubeni Europe plc, 95 Gresham Street, London, EC2V 7AB

If you would like to contact MEG about data protection matters, then please email eur-privacy@marubeni.com or send a letter to: Marubeni International (Europe) GmbH, Benrather Strasse 18-20, 40213, Düsseldorf, Germany

You may also contact the data protection officer for MEG by emailing dpo-meg@fieldfisher.com

2. Processing purposes, types of data processed, sources of data, recipients of data and legal bases for processing

The subsections below explain key details about the processing that will occur in different contexts. The types of processing operations that will occur include collection, storage, use, sharing, deletion and any other processing that is necessary to achieve the purposes described.

We will use the personal data only for the purposes described in this privacy statement or for purposes that we explain to you at the time of collecting your personal data. However, we may also use your personal data for other purposes that are not incompatible with the purposes we have disclosed to you (such as statistical purposes) if and where this is permitted by applicable data protection laws.

a ) Website visitors

The controller for the processing that occurs when you visit the https://europe.marubeni.com website is MEU and the controller when you visit the https://marucomp.de/en/ website is MEG. For further information that is specifically about Cookies we use, please also see the cookie notice for https://europe.marubeni.com here and the cookie notice for https://marucomp.de/en/ here.

Purposes for the processing	Types of data processed	Sources of the data	Recipients of the data	Legal basis for the processing
Fulfil your website requests	IP address, Webpages/domain names requested Device type Unique device identification numbers Broad geographic location (e.g. country or city-level location) Types of web browsers Types of operating systems used Timestamps Requests made Cookie data Other technical information	You / your device	Marubeni Group entities Service providers	Our overriding legitimate interest in ensuring our website is rendered correctly to you.
Website security				Our overriding legitimate interest in ensuring our website is secure.
Preventing fraud				Our overriding legitimate interest in ensuring our website and business is not subject to fraud.
Analysing your use of our website	IP address, Cookie data, Website usage behaviour, Browser type, Device type, Timestamps, Other technical information Demographic information about you that informs aggregate statistics that we receive from Google as our website analytics provider.	You / your device Google	Marubeni Group entities Google	Your separately obtained consent

b ) Customers / prospective customers and their staff

Purposes for the processing	Types of data processed	Sources of the data	Recipients of the data	Legal basis for the processing
Direct marketing by email, post or phone	Names Contact details Job title Occupation Employer Organisation you represent	You Third party marketing contact vendors	Marubeni Group entities Service providers	Your separately requested consent or, where applicable, our overriding legitimate interest in undertaking direct marketing activities.
Fulfilling customer orders	Contracts Details of products and services ordered	You Your employer Organisation you represent Distributors Agents	Marubeni Group entities Microsoft (Outlook Suite) Other service providers	Performance of a contract with you and, if that is not applicable, our overriding legitimate interest in conducting a business.
Background screening	Names Contact details Job title Occupation Employer Organisation you represent Correspondenc Internal notes Relatives Titles	You Your employer Organisation you represent Distributors Agents Subscription services Companies House Reports or other databases Marubeni staff	Marubeni Group entities Service providers	Our legal obligation to undertake background screening of suppliers, as well as our overriding legitimate interest in ensuring that we uphold our internal background screening obligations under our internal bribery rules.
Correspondence	Names Contact details Job title Occupation Employer Organisation you represent Content of correspondence	You Other parties to business correspondence	Marubeni Group entities Microsoft (Outlook) Other service providers	Performance of a contract with you and, if that is not applicable, our overriding legitimate interest in conducting a business.
Payment and accounting	Names Contact details Job title Occupation Employer Organisation you represent Payment details Invoices Receipts	You Your employer Organisation you represent Distributors Agents	Marubeni Group entities Service providers	Performance of a contract with you and, if that is not applicable, our overriding legitimate interest in conducting a business.
Internal notes and documentation	Names Contact details Job title Occupation Employer Organisation you represent Content of notes and documentation	Marubeni staff	Marubeni Group entities Microsoft (Outlook, teams, word) Service providers	Performance of a contract with you and, if that is not applicable, our overriding legitimate interest in conducting a business.
Maintaining a customer relationship management database	Names Contact details, Job title Occupation Employer Organisation you represent Correspondence Contracts Internal notes Details of products services ordered Payment details Invoices Receipts	All sources named above	Marubeni Group entities Service providers	Our overriding legitimate interest in conducting a business.
Fulfilling know your client requirements	Details related to the organisation you represent Full name Relationship to the company Nationality Country of Residence Date of birth Job title Signature	You Your employer Organisation you represent	Marubeni Group entities Service providers	Our overriding legitimate interest in conducting know your client activities.
Maintaining compliance obligations	Full Name. Contact details Company Employer / organisation you represent Your department. Your job title. Answers to questions Correspondence Internal notes	You Your employer / organisation you represent	Marubeni Group entities Service providers	Compliance with a legal obligation to which the controller is subject or our legitimate interest in complying with internal policies (as relevant)

c ) Suppliers / prospective suppliers and their staff

Purposes for the processing	Types of data processed	Sources of the data	Recipients of the data	Legal basis for the processing
Fulfilling supplier orders	Names Contact details Job title / occupation Employer / organisation you represent Contracts Details of products services to be supplied Payment details Invoices Receipts	You Your employer / organisation you represent Distributors / agents	Marubeni Group entities Microsoft (Outlook Suite) Other service providers	Performance of a contract with you or, if that does not apply, our overriding legitimate interest in undertaking procurement processes
Background screening	Names Contact details Job title / occupation Employer / organisation you represent Relatives Titles	You Your employer / organization your represent Distributors / Agents Subscription services Companies House Reports or other databases	Marubeni Group entities Service providers	Our legal obligation to undertake background screening of suppliers, as well as our overriding legitimate interest in ensuring that we uphold our internal background screening obligations under out internal bribery rules.
Correspondence	Names Contact details Job title / Occupation Employer / organisation you represent Content of correspondence	You Other parties to business correspondence	Marubeni Group entities Microsoft (Outlook) Service providers	Performance of a contract with you and, if that is not applicable, our overriding legitimate interest in conducting a business.
Payment and accounting	Names Contact details Job title / occupation Employer / organisation you represent Bank account details Invoices Receipts	You Your employer / organisation you represent Distributors / agents	Marubeni Group entities Service providers	Performance of a contract with you and, if that is not applicable, our overriding legitimate interest in conducting a business.
When completing certain credit limit assessments, director information is noted	Name address contact details date of birth nationality	You Your employer / organisation you represent Distributors / agents	Marubeni Group entities Service providers	Our overriding legitimate interest in conducting credit limit assessments
Internal notes and documentation	Names Contact details Job title / occupation Employer / organisation you represent Content of notes and documentation	Marubeni staff	Marubeni Group entities Microsoft (Outlook, teams, word) Service providers	Performance of a contract with you and, if that is not applicable, our overriding legitimate interest in conducting a business.
Maintaining a supplier relationship database	Names Contact details Job title / occupation Employer / organisation you represent Correspondence Contracts Internal notes Details of products services ordered Payment details Invoices Receipts	All sources named in this table	Marubeni Group entities Service providers	Our overriding legitimate interest in conducting a business.
Fulfilling know your client requirements	Details related to the organisation you represent Full name Relationship to the company Nationality Country of Residence Date of birth Job title Signature	You Your employer Organisation you represent	Marubeni Group entities Service providers	Our overriding legitimate interest in conducting know your client activities.
Maintaining compliance obligations	Full Name. Contact details Company Employer / organisation you represent Your department. Your job title. Answers to questions Correspondence Internal notes	You Your employer / organisation you represent	Marubeni Group entities Service providers	Compliance with a legal obligation to which the controller is subject or our legitimate interest in complying with internal policies (as relevant)

d) Office visitors

Purposes for the processing	Types of data processed	Sources of the data	Recipients of the data	Legal basis for the processing
Visitor list	Names Contact details Employer / organisation you represent Purpose of your visit Name of anyone you are visiting	You Your colleagues	None	Our overriding legitimate security interest in knowing who is visiting our premises.
CCTV	Video images of you Time stamps	You	Marubeni Group entities Service providers	Our overriding interests in preventing security incidents and being able to investigate them and take appropriate action if they happen.

e) Emergency contacts

Purposes for the processing

Types of data processed

Sources of the data

Recipients of the data

Legal basis for the processing

To contact you in case of emergency in relation to the Marubeni staff member that you act as emergency contact for.

Names
Telephone number
Information provided by you if contacted

The Marubeni staff member you act as emergency contact for
You

None

Our overriding legitimate interests in informing you about emergency situations related to the Marubeni staff member that you act as emergency contact for and in seeking information that may help with the emergency situation.

f ) Event participants

Purposes for the processing	Types of data processed	Sources of the data	Recipients of the data	Legal basis for the processing
Invitation to events	Names Contact details Employer / organisation you represent Correspondence RSVP details	You	Marubeni Group entities Microsoft (Outlook service provider) Service providers	Our overriding legitimate interest in undertaking events that promote our business
Sharing of contact details with event participants for networking purposes	Names Contact details Employer / organisation you represent	You	Event attendees Service providers	Our and other event participants overriding legitimate interest in sharing event participant details for networking purposes.

g ) Business research

Purposes for the processing

Types of data processed

Sources of the data

Recipients of the data

Legal basis for the processing

Various Marubeni business units obtain publicly available research material in order to collate various business reports, undertake internal research and compile business reports.

Names
Content of the material

Publicly accessible websites

Marubeni Group entities
Service providers

Our overarching legitimate interest in undertaking business research.

h ) Other enquiries

Purposes for the processing

Types of data processed

Sources of the data

Recipients of the data

Legal basis for the processing

Responding to your enquiries

Names
Contact details
Employer / organisation you represent
Correspondence
Content of notes and documentation

Marubeni Group entities
Microsoft (Outlook)
Other service providers

Our overarching legitimate interest in responding to enquiries that are directed to us.

i ) Call/meeting records

Purposes for the processing

Types of data processed

Sources of the data

Recipients of the data

Legal basis for the processing

In case needed to assist with any future compliance obligations

Caller/participant identity
Call/meeting time and duration

Communications tool provider

Marubeni Group entities
Service providers

Our overriding legitimate compliance interest in knowing these details regarding calls and meetings in case needed to assist with any future compliance obligations.

j ) Online meeting recordings

Purposes for the processing	Types of data processed	Sources of the data	Recipients of the data	Legal basis for the processing
Allow staff to retrieve an accurate video/audio record of the meeting in case any details need to be checked in future by relevant Marubeni staff.	Names of the attendees Voice recordings of the attendees Video recordings of the attendees Any information about other persons mentioned by the attendees Time stamps	You Other attendees of meetings	Meeting attendees Marubeni Group entities Microsoft	The overriding legitimate interests of the respective Marubeni entities in providing its staff with simpler, more effective and more efficient ways of undertaking everyday business tasks.
Allow people who were unable to attend the meeting to review exactly what occurred.
Allow material to be disseminated to a wider audience.

k ) Online Meeting Transcriptions

Purposes for the processing	Types of data processed	Sources of the data	Recipients of the data	Legal basis for the processing
Provide an accurate written record of the meeting in case any details need to be checked.	Name of the attendees Voice recordings of the attendees Transcriptions of voice recordings of the attendees Any information about other persons mentioned by the attendees Time stamps	You Other attendees of meetings	Meeting attendees Marubeni Group entities Microsoft	The overriding legitimate interests of the respective Marubeni entities in providing its staff with simpler, more effective and more efficient ways of undertaking everyday business tasks.
Allow people who were unable to attend the meeting to review the transcription so that they know what occurred.
Allow the Microsoft Copilot functionalities for Microsoft Teams to be used.

l ) Online Meeting AI Functionalities

Purposes for the processing	Types of data processed	Sources of the data	Recipients of the data	Legal basis for the processing
Meetings: Copilot uses the transcript in real-time to answer questions from the user. Copilot answers questions only related to the meeting conversation from the meeting transcript in question.	Names of the attendees Transcriptions of the specific meeting Any information about other persons mentioned by the attendees User prompts Responses to user prompts Time stamps	You Other attendees of meetings	Meeting attendees Marubeni Group entities Microsoft	The overriding legitimate interests of the respective Marubeni entities in providing its staff with simpler, more effective and more efficient ways of undertaking everyday business tasks.
Chats: Copilot uses up to 30 days of the relevant chat to answer questions from the user. Copilot uses only the single chat thread as source content for responses.	Names of persons that are party to the chat Content of persons that are party to the chat Any information about other persons mentioned in the content of the persons that are party to the chat User prompts Responses to user prompts Time stamps
Compose: The compose function in Copilot allows users to rewrite and adjust their messages so they can communicate effectively and collaborate efficiently with their coworkers.	Name of user. Prompt of user. Response to prompt of user. Any information about any other person mentioned in the prompt or response to the prompt. Time stamps.

m ) Other persons incidentally mentioned in correspondence, internal notes and internal documentation

Purposes for the processing	Types of data processed	Sources of the data	Recipients of the data	Legal basis for the processing
Fulfilling any of the purposes named above.	Names and other identifiers. Content of the correspondence, internal notes and internal documentation	Any sources named in the tables above.	Marubeni Group entities Service providers	The overriding legitimate interests of the respective Marubeni entities in processing personal data related to other persons to fulfil the purposes named in the tables above.

n ) Mergers and acquisitions

Purposes for the processing	Types of data processed	Sources of the data	Recipients of the data	Legal basis for the processing
Providing a potential buyer (and its agents and advisers) with information that is relevant to its consideration of a potential merger or acquisition of a Marubeni Group entity	Any types of personal data named in the tables above.	Any sources named in the tables above.	Potential buyers, their agents and advisers Marubeni Group entities Advisers to Marubeni group entities Service providers	The overriding legitimate interests of the respective Marubeni entities in taking part in merger and acquisition processes.
Receiving from a potential seller information that is relevant to Marubeni’s consideration of a potential merger or acquisition	Any types of personal data named in the tables above.	Any sources named in the tables above.	Marubeni Group entities Advisers to Marubeni Group entities Service providers	The overriding legitimate interests of the respective Marubeni entities in taking part in merger and acquisition processes.

o ) Technical support

Purposes for the processing	Types of data processed	Sources of the data	Recipients of the data	Legal basis for the processing
Provide any necessary technical support to ensure that the programs in question are operating as they should be.	Any types of personal data named in the tables above.	Any sources named in the tables above.	Marubeni Group entities Service providers	The overriding legitimate interests of the respective Marubeni entities in providing technical support that is required.

p ) Establishment, exercise or defence of legal claims

Purposes for the processing	Types of data processed	Sources of the data	Recipients of the data	Legal basis for the processing
Establishment, exercise or defence of legal claims	Any types of personal data named in the tables above.	Any sources named in the tables above.	Marubeni Group entities Professional advisers Courts Government authorities Service providers	Our overriding legitimate interest in any processing of personal data that is necessary for the establishment, exercise or defence of legal claims.

q ) Legal obligations

Purposes for the processing	Types of data processed	Sources of the data	Recipients of the data	Legal basis for the processing
Comply with any legal obligation that the respective Marubeni Group entities are subject to.	Any types of personal data named in the tables above.	Any sources named in the tables above.	Marubeni Group entities Professional advisers Government authorities Service providers	The processing is necessary for compliance with a legal obligation to which the controller is subject.

r) Protecting our interests or the interests of others

Purposes for the processing	Types of data processed	Sources of the data	Recipients of the data	Legal basis for the processing
When necessary to protect our interests or the interests of others (e.g. in cases of emergency, if needed to assist with any future compliance obligations, or so that Marubeni can better investigate any incidents, issues or concerns that arise, including potential breaches of criminal law, civil laws, employment obligations or internal company rules).	Any types of personal data named in the tables above.	Any sources named in the tables above.	Marubeni Group entities Professional advisers Government authorities Service providers	Our overriding legitimate interests in protecting our interests or the interests of others in the given situation (e.g. in cases of emergency or where an incident or concern is being investigated).

3. Data Security

Transmission of information via the internet is not always secure. We cannot guarantee the security of your data while being transmitted to our site; any transmission is at your own risk. However, after we have received your data, whether collected on our website or otherwise, we take appropriate technical and organisational security measures to prevent unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss of personal data once it is under our control. The measures we take are designed to provide a level of security appropriate to the risk of processing your personal data.

4. International Transfers of Personal Data

In order to conduct our business, including marketing activities, we may need to share your personal information with other companies within the Marubeni Group, and/or third party service providers that process data on our behalf (refer to section 2 above for more details). When we do this, we will take steps to ensure that your personal information is protected, such as imposing contractual restrictions on the ability of the recipient to process your personal information and contractually requiring them to apply security measures to protect it.

Since the Marubeni Group operates globally, we may want to transfer your personal information to other countries, including countries outside the European Economic Area (EEA) and the UK. However, while it is in our control, we always seeks to ensure that your personal information receives the same level of protection as it would had it stayed within the EEA and/or the UK, including seeking to ensure that it is kept secure and used only in accordance with our instructions and for the agreed purpose(s). The steps that we take in such circumstances may include implementing the Standard Contractual Clauses as approved by the European Commission from time to time and/or, in respect of transfers out of the UK, as approved by the relevant authority in the UK, or other steps designed to adduce adequate safeguards of protection when your personal information is sent outside the EEA and the UK.

For more information on the appropriate international data transfer mechanisms that we use or a copy thereof, please contact us through the details provided in section 1 above.

5. How long will the personal data be stored?

Your personal information will be retained securely by us so that we can better manage your relationship with us. We retain personal information we collect from you where we have an ongoing legitimate business, legal or regulatory need to do so.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.

Details of retention periods for different types of your personal data are available from us on request by contacting us using the contact details provided in section 1 above.

6. Your data protection rights

Depending on applicable law, you may have the following data protection rights:

The right to access, correct, update or request deletion of your personal data, restrict processing of your personal data or request portability of your personal data.
The right to object to processing of your personal data where it is being processed on the legitimate interest legal basis.
The right to opt out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt out” link in the marketing e-mails we send you. You may also opt out of other forms of marketing (such as postal marketing or telemarketing) by contacting us through the details provided in section 1 above.
If we have collected and process your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
The right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority. (Contact details for EU and UK data protection authorities are available hereand here.)

You can exercise any of these rights by contacting us through the details provided in section 1 above. You can also exercise your opt out right in relation to direct email marketing by clicking on the “unsubscribe” or “opt out” link in the marketing e-mails we send you.

7. Hyperlinks and Embedded Functionality

Our website may contain links to content or other functionality provided by third parties which is outside our control and is not covered by our privacy statement. If you access other websites using links or use other embedded functionality provided by third parties, the operators of those websites may collect information from or about you which will be used by them in accordance with their privacy statements or policies, which may differ from ours. We encourage you to read the privacy information provided by the operators of those websites. We do not accept any responsibility or liability for those policies.

8. Changes to this Privacy Statement

We may update this privacy statement from time to time. This privacy statement was last updated on 20 April 2026.