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Privacy Policy
SUMITOMO CHEMICAL
Date: June 04, 2020
1. General notes on data protection
We thank you for your interest in SUMITOMO CHEMICAL.
SUMITOMO CHEMICAL takes the protection of your privacy and Personal Data very seriously. Therefore, we process your Personal Data strictly according to applicable data protection laws. The purpose of this policy is to explain the types of Personal Data that we collect, and how these Personal Data are processed by us (“Privacy Policy”).
This Privacy Policy will be contingent on the consent of the User (“User”), which will be given its authorization, or by clicking the “Accept” button, or by using any platform, software or service (“Services”) of SUMITOMO CHEMICAL. Accordingly, from that moment on, the User will allow access and handling of their personal data by SUMITOMO CHEMICAL, under this Policy.
Any reference to “SUMITOMO CHEMICAL” in this document means the domestic legal entity of SUMITOMO CHEMICAL with which you have contact, or with which you maintain a trade relationship, as well as any other companies of the group of legal entities of SUMITOMO CHEMICAL that legitimately process your Personal Data under this Privacy Policy. The list of local/domestic legal entities of SUMITOMO CHEMICAL is available at https://www.sumitomochemical.com/escritorios/
“Personal Data” means the personal identifiable information about an individual, such as their name, address, e-mail, phone number, or other identifier that may allow a direct or indirect identification of a specific individual, or as provided for in the applicable data privacy and security laws.
This Privacy Policy is applicable to you, as the data subject in your negotiations with SUMITOMO CHEMICAL, to wit: (i) visitors and users of websites and online services of SUMITOMO CHEMICAL (such as apps) (hereinafter collective referred to as “Online Services;” while visitors and users of said services are hereinafter referred to as “Users of Online Services”); (ii) relevant individuals at customers, distributors, suppliers, salespersons and other business partners of SUMITOMO CHEMICAL (“Business Partners Contacts”), and (iii) candidates to any position in SUMITOMO CHEMICAL (“Applicants”). Users of Online Services, Applicants and Business Partners Contacts are collective referred to in this Privacy Policy as “Data Subjects”.
If you supply Personal Data that belong to other Data Subjects, please share the information contained in this Privacy Policy with them, as you deem appropriate.
2. What information do we collect?
2.1. Users of Online Services
We collect the personal data of USERS upon their interaction with SUMITOMO CHEMICAL, third parties or other sources (Example: employer and publicly available sources).
SUMITOMO CHEMICAL obtains the personal data of USERS:
• Through their interaction with SUMITOMO CHEMICAL and its services: When the User buys or uses any service of SUMITOMO CHEMICAL; registers in an event; requests information from or calls the customer assistance service (recordings may be stored for compliance and quality assurance purposes).
• Through the USERS’ system/device, and upon their use of SUMITOMO CHEMICAL services: SUMITOMO CHEMICAL servers, logs and other technologies automatically collect information from the system/devices in order to assist in managing, protecting and improving SUMITOMO CHEMICAL services, as well as the USER’s experience.
• Through cookies and similar technologies included in SUMITOMO CHEMICAL services: SUMITOMO CHEMICAL may also use other standard technologies, such as cookies, pixel tags, beacons and local shared objects, to collect Users’ information and improve their browsing experience.
• Through third parties: SUMITOMO CHEMICAL also collects the personal information of USERS through third parties, such as: the USER’s employer, partners, suppliers and publicly available sources (public websites, open government databases, or other public domain data), aiming at keeping data accuracy and improving the services provided.
2.1.1. Personal Data collected directly from Online Service Users
In general, USERS are able to visit or use our Online Services without having to identify themselves or reveal their Personal Data. However, USERS may actively supply their Personal Data, for example, by registering to receive our e-mails; opening or answering our e-mails; participating in gift awards, contests and raffles; participating in promotions or special programs; participating in surveys; or registering to receive our publications. In this case, we collect the following Personal Data, as long as you supply them:
• Your name;
• Your company;
• Address, e-mail and phone number;
• Content and type of your request, or preferences;
• Date and time of your request;
• Your marketing preferences, including any consent given to us;
• Any other information that you may supply to us regarding the use of our Online Services.
We will mark the mandatory fields, if any, in any contact form that is available on any Online Services. However, you may also choose to retain Personal Data from us, or supply information using a pseudonym. If you do not supply the Personal Data required, we may not be able to respond to or fulfill your requests, or to provide our Online Services correctly.
Any sensitive personal data collected by SUMITOMO CHEMICAL, and their purpose, will be informed separately to the DATA SUBJECT, who must give their consent for the specific use of these data by SUMITOMO CHEMICAL.
2.1.2. Personal Data automatically collected from Online Service Users through our Online Services
When you visit our Online Services, we collect your Personal Data automatically through your visit or use of our Online Services. These Personal Data may include, among others, the type of your browser, third-party websites that originated your visit to our Online Services; the search terms used in our Online Services; the specific pages that you visit on our website; Online Services and duration of your visits, your IP address, device ID, and other exclusive identifiers; and information on your operating system, adjustments and system settings.
2.2. Business Partners Contacts
In the case of a potential or existing trade relationship, we may process the following Personal Data of our Business Partner Contacts:
• Contact information, such as full name, business mail address, business phone number, mobile/phone number, business fax number, business e-mail and job title;
• Payment data, such as credit/debit card numbers, security code, taxpayer identification, and other collection-related information, as well as the data required to process payments and prevent fraud;
• Additional information that must be processed in the course of a project or contractual relationship with us, or that is voluntarily supplied by Business Partners Contacts, such as Personal Data relating to orders or payments made;
• Personal data that are collected from publicly available resources (for example, the names of shareholders or officers, professional identifiers, affiliation details, representatives or auditors); Other Personal Data, if this is required to analyze the compliance of our Business Partners or Business Partners Contacts, pursuant to the applicable law. This may include date of birth, identification numbers, identity documents and information on important lawsuits, or other legal proceedings against Business Partners, Business Partners Contacts, and other individuals related to Business Partners;
• Any other information that you may provide regarding your trade relationship with us.
2.3. Applicants
We process the Personal Data that we receive or obtain from Applicants as part of the application process. This includes:
• Information such as name, contact details, mail address, sex, nationality, eligibility to work in certain countries, and termination notice period;
• Additional information that the applicant may choose to supply during the application process, such as professional skills, professional experience, schooling and certifications, references, letters of introduction, work preferences, personal and family data (for example, marital status, information on children), and documents with related supporting information;
• Information obtained from public sources (for example, the press, Internet), or legally conveyed by other legal entities of SUMITOMO CHEMICAL or third parties (for example, criminal violation notices);
• Any other information supplied regarding your application.
During the recruitment process, we may request that the Applicant supply additional information or additional consent, so that we can make checks before hiring them, or make an improved analysis of the qualifications and suitability of the Applicant for the functions available at SUMITOMO CHEMICAL.
3. Processing objectives
We may process your Personal Data in the course of our interactions, or the Personal Data that you may choose to supply for the purposes described below.
• To provide and improve our services, or for compliance purposes;
• To fulfill a legal obligation;
• To manage our relationship with Data Subjects;
• To setup and manage the account of Data Subjects;
• To provide technical assistance, support and training to Data Subjects;
• To offer and suggest adapted content, such as news, surveys, reports and trade information. SUMITOMO CHEMICAL analyzes how the Data Subjects use its services, and suggest the features or services that it believes to be of interest to the Data Subjects;
• To customize the experience of Data Subjects in using the services. SUMITOMO CHEMICAL may retain Data Subjects’ browsing and use information in order to make service searches more relevant, and use the information to send ads;
• To share your personal information with other areas of the company, or other services that are made available, in order to make them more intuitive (Example: instead of requiring the same data several times, in a given moment data will already be stored in our bases and will be automatically populated).
• To contact Data Subjects to conduct surveys in which they can choose to participate, and analyze the data collected for market research purposes;
• To provide perceptions on the use of services to third parties that make our services available to Data Subjects (example: the Data Subject’s employer);
• For internal investigation and development purposes, and to improve, test and enhance the features and functions of SUMITOMO CHEMICAL services;
• To provide Data Subjects with marketing campaigns, as provided for in the law;
• To meet internal and external audit requirements, including the information security obligations of SUMITOMO CHEMICAL;
• To apply the Terms of Use shown in https://www.sumitomochemical.com/escritorios/
• To send e-mail messages in order to: a) confirm or cancel requests using the platform; and b) disclose updates and changes; include new data sources; and improve dashboards and platforms.
• To protect the rights of SUMITOMO CHEMICAL, privacy, security, networks, systems and third-party property or items;
• To prevent, detect or investigate crimes, fraud or other violation of the law;
• To comply with the requests made by the courts, police authorities, normative bodies and other public institutions and government authorities, including those that are outside your country of residence;
• To exercise the rights of SUMITOMO CHEMICAL; to defend the company in lawsuits; and to comply with legislation or regulations applicable to SUMITOMO CHEMICAL or third parties with which we work;
• To participate in sales, mergers, acquisitions, restructurings, joint ventures, assignments, transfers or any other action, as long as expressly designated, involving the business of SUMITOMO CHEMICAL in whole or in part (including reorganization or bankruptcy);
Please note that the platform may have links to other Internet pages whose policy for collection and use of information is different from that used by SUMITOMO CHEMICAL. Accordingly, SUMITOMO CHEMICAL is not liable for the data treatment used in these pages.
If we need to supply additional information to Data Subjects regarding the use of their personal data in certain services, we will use separate or additional privacy notices.
3.1. Users of Online Services
We process the Personal Data of Users of Online Services for the purposes below:
• As required to operate and manage our Online Services, and to enable your access to and use of our Online Services and all their functions;
• As required to supply the right content to you; answer your questions or requests; and communicate and interact with you;
• As required by SUMITOMO CHEMICAL to operate its business; notify you about changes in Online Services, in our Terms of use, or in this Privacy Policy; send e-mails confirming your registration; monitor the use of our Online Services products; improve and develop our Online Services; and for internal statistic or operational purposes, such as measuring and understanding demographic data, interests, purchases and trends of our Users of Online Services;
• As required to manage and conduct marketing campaigns, surveys, market analyses, contests, raffles or other promotional activities or events;
• To protect our rights and interests, as well as those of our Users of Online Services or any other person;
• To comply with the applicable legal and regulatory obligations (including, among others, use relating to legal claims), and for compliance, regulatory and investigation purposes (including the disclosure of such information in connection to legal proceedings or litigation).
3.2. Business Partners Contacts
In the context of potential or existing trade relationships with Business Partners, we will process your Personal Data for the purposes below:
• To inform you about our products and services, or to answer your questions or requests;
• To establish or comply with a contract entered into with you or one of our Business Partners, or answer a price quote or purchase order. This may include the delivery of products or services; verification of your identity, and of the financial solvency and credit risk of your company; collection of payments due to us, including the (re)financing of debt, and performance of accounting and audit activities;
• The management of our relationship with you and the Business Partner you represent;
• To manage and conduct marketing campaigns, surveys, market analyses, contests, raffles or other promotional activities or events;
• To comply with the applicable laws (such as record maintenance obligations), export and customs controls, compliance screening obligations (for example, anti-money laundering checks), and protect the legitimate trade interests and legal rights of SUMITOMO CHEMICAL, including, among others, any use in connection with legal and compliance claims, and for regulatory and investigation purposes (including the disclosure of information in connection to proceedings or lawsuits).
3.3. Applicants
In the context of recruitment processes, we process the Personal Data of Applicants for the following purposes:
• As required to manage, process and analyze the requests of applicants, or to analyze if they are suitable for the functions available, based on the Applicant’s profile created;
• If an Applicant supplies the details of a reference person or any other third party (for example, an educational institution) as part of the application, SUMITOMO CHEMICAL will be authorized to contact such person to validate the information provided by the Applicant.
4. Cookies when using Online Services
SUMITOMO CHEMICAL and its third-party suppliers use cookies and other similar technologies to store and manage the preferences of Data Subjects; provide targeted ads; approve contents; and collect analytical and use data, for example. The use of cookies and other tracking technologies is a standard procedure in websites and applications. They enable us to collect information on the activities of Data Subjects in applications, websites or other services.
A cookie is a small text file that is placed in a computer or other device, and used for identifying the Data Subjects, their device, and to collect information. Cookies can be divided in four categories, according to their function and purpose:
• Necessary Cookies: these are essential to enable the Data Subject to browse through a website and use its features.
• Performance Cookies: they collect information on how the Data Subject uses SUMITOMO CHEMICAL website; to improve their browsing activities; and enhance their experience. The information collected includes, for example, the internet browsers and operating systems used, the domain name of the previously visited website, the number of visits, the average duration of visits, and the pages viewed.
• Functional Cookies: they enable the website to remember the choices made by the Data Subject (such as their user name or ID, language preferences, or area or region where the Data Subject is located), and to provide enhanced and more personal features.
• Advertising Cookies: they track the browsing habits of Data Subjects, and are used to supply targeted ads. These cookies also limit the number of times that you see an ad, and measure the efficacy of advertising campaigns. They are also able to remember whether the Data Subject has already visited a website, and they share this information with other organizations, such as advertisers.
• Flash Cookies: they are developed to support browser content compatible with AdobeFlash. They are generally used for activating ads and video contents on websites. For further information on flash cookies, please visit http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html
Website cookies can be managed by the Data Subject through the browser, and they can be accepted, refused or excluded. If the Data Subject decides to change the settings, some SUMITOMO CHEMICAL features and services may not work as expected.
For further information on cookies, please visit: www.aboutcookies.org or www.allaboutcookies.org. For further information on how to disable and exclude cookies in some commonly used browsers, we recommend that Data Subjects contact the browser support team directly.
In addition to cookies, Data Subjects use other tracking technologies, such as:
Web Beacons: the Data Subject’s web pages may include electronic images known as “web beacons” (also called “single-pixel gifs” and transparent graphic images) that are used to help place cookies on Data Subjects websites; count the Data Subjects that visited these websites; provide services; and analyze the efficacy of advertising/marketing campaigns. Web beacons are also used in email marketing messages or information reports, to determine whether an e-mail was viewed, or whether a link was accessed.
Web Server and Application Records: SUMITOMO CHEMICAL servers collect certain information automatically in order to assist, manage and protect the services provided, as well as to analyze the use by and improve the experience of Data Subjects. The information collected includes:
• IP address and browser type;
• Device information, including Unique Device Identifier (UDID), MAC address, Identifier for Advertisers (IFA) and similar identifiers attributed by us or by third parties;
• The operating system of the device and other technical data;
• The city, state and country from where you are accessing the SUMITOMO CHEMICAL website;
• The pages visited and the contents that are viewed, stored and purchased;
• The information or texts typed in;
• The links and buttons clicked;
* The URLs visited before and after using the services of SUMITOMO CHEMICAL.
Connections through Social Networks: Some SUMITOMO CHEMICAL services may include social network features, such as Facebook’s “Like” button and widgets, “Share” buttons and interactive miniprograms. USERS may also choose to log in on some of our services through their own social networks, such as Facebook or Linkedin. If the USER decides to log in using a social network or similar service, SUMITOMO CHEMICAL may receive and store authentication information from these services in order to allow integration between these platforms. SUMITOMO CHEMICAL is not responsible for the privacy and security of information collected by these third parties, and USERS must review the terms of use and the privacy policy of third-party services to which they connect, and which they use or access.
5. To whom can we disclose Data Subjects information?
USERS agree and accept that SUMITOMO CHEMICAL share their personal data with the following recipient categories:
• Companies belonging to the SUMITOMO CHEMICAL group;
• The person that provides access to our services (example: the employer);
• Business partners, third-party service providers and other companies that help us offer our services, or that are entitled to make arrangements on our behalf and protect our rights, users, systems and services (Example: Law Firms);
• Third parties to which SUMITOMO CHEMICAL has an obligation, or is authorized to disclose information under the law (Example: government bodies, regulatory agencies, the judiciary branch, and other public authorities);
• Third parties that intend to participate in the sale, merger, acquisition, restructuring, joint venture, assignment, or transfer, in whole or in part, of SUMITOMO CHEMICAL’s business. In this case, Data Subjects’ data will be considered as an asset, and transferred as part of the negotiation;
• Third parties that need the data to protect the rights of SUMITOMO CHEMICAL;
• Any individual or legal entity to whom SUMITOMO CHEMICAL requests the portability of their data.
6. International transfer of Personal Data
The personal DATA of USERS can be stored and processed outside BRAZIL, as long as the country or international body that receives these data is able to provide an appropriate level of protection of personal data, as provided for in the Brazilian General Data Protection Law.
In case a country or international body that receives the data is not able to provide a protection similar to that provided for in the Brazilian legislation, the transfer will only be allowed if the controller evidences compliance with the principles, subject’s rights and data protection regime provided for in the Brazilian legislation, in the form of:
a) contractual clauses specific to a certain transfer;
b) standard contractual clauses;
c) global corporate rules;
d) seals, certificates and regular issue of codes of conduct;
In addition to the cases above, international transfers of personal data will be allowed:
a) if the transfer is required for international legal cooperation between public intelligence, investigation and prosecution bodies, as provided for in international law instruments;
b) if the transfer is required to protect the life or physical integrity of Data Subjects or third parties;
c) if the national authority authorizes the transfer;
d) if the transfer has resulted from a commitment undertaken in the scope of an international cooperation agreement;
e) if the transfer is required to enforce public policies or legal responsibilities of public services;
f) if the subject has provided specific consent regarding the transfer, after receiving previous information about the international character of the operation and its purposes; or
g) in the other situations provided for in the Brazilian General Data Protection Law.
A copy of the relevant mechanism may be supplied upon request for your analysis. Please contact SUMITOMO CHEMICAL as per the contact information provided for in section 12 of this Privacy Policy.
7. Security of Personal Data
The security of your Personal Data is very important, no matter if they are processed in or outside BRAZIL, or if they are processed by SUMITOMO CHEMICAL or by service suppliers engaged by SUMITOMO CHEMICAL.
In order to avoid non-authorized access, disclosure, interference or undue use of Personal Data, we have implemented procedures and installed equipment to guarantee the security and confidentiality of your Personal Data. We are constantly reviewing and improving our security measures, to ensure that all reasonable and technically feasible steps are being taken at that time to protect your Personal Data. However, due to the very nature of the Internet, it is not possible to assure that ill-intentioned third parties will not succeed in accessing the information stored. If this situation arises, SUMITOMO CHEMICAL will take responsibility to the extent provided for in the law.
8. Direct marketing to Business Partners
We do not provide Personal Data of Business Partners Contacts to other entities or organizations for purposes of direct marketing.
We may send direct marketing communications to you upon your express consent. Upon your consent, we may use your Personal Data to send direct marketing communications that include promotions and information on our products and services. These communications will be sent basically by e-mail or mail, but they may also be sent by phone, SMS or fax.
You can opt out from receiving our market communications at any time by contacting us as per the details described in section 12, or using the “unsubscribe” function included in the marketing communications that you receive by e-mail. We will take the necessary measures to remove your Personal Data from our direct marketing database.
9. Data Subjects rights in connection with their Personal Data
As a Data Subject, you will generally have the following rights:
According to the Brazilian General Data Protection Law, USERS have the following rights regarding processing of their personal data:
• Confirmation Right: USERS have the right to receive a confirmation of whether SUMITOMO CHEMICAL processes any of their personal data;
• Right of Access: USERS have the right to send a written request asking for details on how their information is being used, as well as to obtain a copy of said information;
• Right to Rectification: USERS have the right to rectify or remove any incomplete, inaccurate or outdated information;
• Right to anonymization, Blocking or erasure: USERS may request the anonymization, blocking or erasure of unnecessary or excessive data, or of data that are not in compliance with the purposes for which they have given their consent;
• Exclusion Right: USERS may request the erasure of some data, other than those whose retention is provided for in the law;
• Right to be informed: USERS may request information about the public and private entities with which SUMITOMO CHEMICAL has shared their data, as well as about the consequences of not agreeing with the collection and treatment of their personal data;
• Right to Restrict Processing: USERS may limit the use of some data;
• Right to Object to Marketing: USERS may request the cancellation, at any time, of ads and other materials that are sent to them, through the link available in the email marketing forwarded to them.
• Right to Portability: USERS may request the transfer of personal data to themselves or to third parties, except for data that have been anonymized by SUMITOMO CHEMICAL.
• Right to Revoke Consent: USERS may cancel any consent that was previously given to SUMITOMO CHEMICAL regarding the use of their personal data. USERS are aware that this cancellation will not affect any use or sharing of data that took place before the consent revocation request.
The rights provided for in this chapter are not absolute, and USERS may exercise them whenever they wish by sending an e-mail to: dpo@sumitomochemical.com
The supply of Personal Data will be mandatory whenever this is required to fulfill legal or contractual obligations. If the information is not supplied, we may not be able to perform the contract or fulfill our obligations. In all other cases, the supply of the Personal Data requested is voluntary.
If, as a Business Partner or Data Subject, you wish to access, change, limit or query your data, please contact or send an e-mail to the local customer assistance service of SUMITOMO CHEMICAL in https://www.sumitomochemical.com/escritorios/, or globally in dpo@sumitomochemical.com.
To make a complaint, or report a data privacy violation, please send an e-mail to dpo@sumitomochemical.com. You may also file a complaint with a supervising authority, particularly, the National Data Protection Agency – ANPD.
10. Period of retention of the Personal Data of Data Subjects.
We will retain Personal Data for the duration of the relationship with Data Subjects, or as permitted or provided for in the applicable law. If we are processing a specific request that you have made, we will generally retain the Personal Data in question for the time required to process you request. Subsequently, we may retain your Personal Data for an appropriate period, in order to protect ourselves against legal claims; manage our business; or to the extent permitted in the applicable law, as a result of which we may have to retain your significant Personal data for a specific period. The Personal Data that is processed based on your consent will be deleted after the withdrawal of your consent. If a different retention period applies to any Personal Data, this will be specified in the moment that the data are being collected (for example, when we request your consent).
When the purpose for which the Personal Data were collected is achieved, and the period of retention is over, we will delete or anonymize your data in a safe manner, without unjustified delay.
If we are not able to delete your Personal Data completely due to legal retention obligations, or obligations relating to billing and accounting, your Personal Data will be “blocked” (this means that your Personal Data will not be used anymore) until expiration of the respective retention period, or until billing our accounting objectives are achieved.
11. Updates to this Privacy Policy
This Privacy Policy will be updated on a regular basis. SUMITOMO CHEMICAL will update the date shown at the top of this Privacy Policy, and encourage you to review this page periodically. In some occasions, SUMITOMO CHEMICAL may actively provide advice on specific data processing activities or significant changes in this Privacy Policy, as required in the applicable law.
In all cases, USERS who are the Data Subjects will be informed about this fact, as well as on the means to exercise their ownership rights as provided for in Art. 18 of the General Data Protection Law, that is, by giving their consent within a period of thirty (30) days.
12. Data controller, and how to contact us
In general, the Data Subjects’ Personal Data controller is the SUMITOMO CHEMICAL affiliate with which they maintain a relationship. The list of local/domestic legal entities of SUMITOMO CHEMICAL is available at https://www.sumitomochemical.com/escritorios/. In some cases, Personal Data can be under the responsibility of a different controller (for example, when a marketing campaign is conducted centrally). In this case, you will be informed separately about the identity of your data controller.
If you intend to access, change, delete or limit your data, or withdraw your consent, please send an e-mail to the local SUMITOMO customer assistance contact (https://www.sumitomochemical.com/escritorios/), or to dpo@sumitomochemical.com. If you wish to cancel your registration in any electronic direct marketing channel or Online Service, please send an email to dpo@sumitomochemical.com, or select any “exclusion” link shown in the instructions of the respective communication.
If you have any doubt about the privacy practices of SUMITOMO CHEMICAL or the content of this Privacy Policy, or if you want to make a complaint, or report the violation of data, please contact us:
• By mail, to the attention of the Data Protection and Privacy area, Legal department, at:
Sumitomo Chemical Latin America
Av. Paulista, 1.106 – Edifício Paulista 1100, 8º e 9º andares
CEP 01310-914
São Paulo – SP
Brazil
• By e-mail: dpo@sumitomochemical.com
We request that your complaints regarding privacy matters be made in writing for the sake of accuracy, and to help our investigations. We will respond and try to solve your complaints within a reasonable period of time, and according to the terms provided for in the applicable law.
If the USER is not satisfied with the responses given, they may file a complaint directly with the National Data Protection Authority (“ANPD”), through the contact channel that is made available by this body.
This Policy is governed, construed and conducted according to the laws of the Federative Republic of Brazil, regardless of any conflict between these laws and the laws of other states or countries, and the courts of the city of Maracanaú, State of Ceará, are hereby elected to solve any conflicts arising from this instrument. The User expressly agrees with the jurisdiction of said court, and hereby waives the jurisdiction of any other courts, however privileged they may be.
