1. About this privacy policy

The protection of your personal data is important to HENNGE K.K. (the "Company" or "HENNGE"). HENNGE processes your personal data to whom those regulations apply (referred to as "you" in this privacy policy) in accordance with the applicable EU member States' regulations on data protection, particularly the General Data Protection Regulation 2016/679 (the "GDPR"). This privacy policy sets out how HENNGE processes your personal data, as the data controller. Please read t his privacy policy carefully in order to understand how HENNGE processes your personal data.

2. HENNGE's roles and responsibilities

Please note that this Privacy Policy does not apply to the extent that HENNGE processes personal data as a data processor on behalf of our customers, including where HENNGE provides our customers with our cloud services. In that case, each of our customers, not HENNGE, controls your personal data, and HENNGE is not responsible for our customers' use of your personal data other than the applicable law that imposes duties on us. In order to know how your personal data is used by our customers as data controllers, HENNGE recommends reading their terms and conditions and privacy policies. HENNGE strictly follows the customers' instructions in processing your personal data as a data processor in accordance with the agreements between the customers and us.

3. Personal data HENNGE collects and data sources

1. Contact Data:
   1. HENNGE will collect this data from you or from other sources including but not limited to distributors, marketing companies that hold events sponsored by us, websites including contents about us, and information aggregators and entities which have licensed HENNGE to use business contact information. It may include your name, username, photo, telephone number, email address, mailing address, the organization you are affiliated with, your job title, your occupation, areas of expertise, industry, third-party platform usernames, and other identifying information.
2. Shareholders' Personal Data:
   1. HENNGE will collect this data directly or through the administrator of the shareholders' register, such as the names and addresses of shareholders, the number of shares held by the shareholders and the days when the shareholders acquired the shares.
3. Employees' Personal Data (including employees who resigned and retired from HENNGE):
   1. This data may include your name, e-mail address, family structure, phone number, birth date, gender, face photograph and any other information that we need for the purpose described below.
4. Job Candidates' Data:
   1. HENNGE will collect your personal data from you when you apply for a job or internship with HENNGE, or other sources such as staff agencies or public open sources. It may include your name, e-mail address, phone number, birth date, gender, face photograph, educational and work history, and other information described in your resume or otherwise related to you.
5. Payment Data:
   1. HENNGE will collect this data from you or your organization such as billing name, billing address and payment card details, in connection with some of our products and services.
6. Event Attendees' Data:
   1. When you attend an HENNGE event, HENNGE will collect your information that you provide us, and HENNGE may record some or all of that event, take photos at the event, and interview you at the event.
7. Device Data and Metadata:
   1. HENNGE will collect this data when you use our website or services. Device data includes the operating system installed on your device, IP address, user-agent and browser version. Metadata includes technical data about your performance and use of our website or services. Please see "10. Use of Cookies" to know how HENNGE collects metadata by Cookies.
8. Other Customer Data and Usage Data:
   1. HENNGE will collect, in the course of your usage of our products or service, additional customer data and usage data, such as the URLs you visit, logs of your usage, logs about your login history, and timestamps.

4. How HENNGE use your personal data

Categories of personal data	Purpose for processing
Contact Data	Communicate related to our products and services Keep safety and security of our products and services Promote our products and services Process payments
Support-related Data	Communicate related to our products and services Keep safety and security of our products and services Improve our products and services Promote our products and services Process Payments
Shareholders' Personal Data	Execution of rights and performance of obligations by the shareholders based on the provisions of the Companies Act of Japan Generating data and processing statistics based on applicable laws and regulations Responding to inquiries from shareholders.
Employees' Personal Data (including employees who resigned and retired from HENNGE)	Work related to employment management (including employees' family members, employees who are loaned to other companies and employees who are transferred) Work related to payment of remuneration Work related to Employees' welfare program Work related to health and safety of Employees Procedures upon resignation/retirement of Employees Other necessary procedures and communications based on applicable laws and regulations as well as from work perspectives
Job Candidates' Data	Conducting the recruitment procedure, such as assessing applications, evaluating and improving our recruiting system, our application tracking and recruiting activities.
Contract and Payment Data:	Communicate related to our products and services Keep safety and security of our products and services Promote our products and services Process payments
Event Attendees' Data	Promote our products and services
Device Data and Metadata	Keep safety and security of our products and services Improve our products and services Promote our products and services
Other Customer Data and Usage Data	Communicate related to our products and services Keep safety and security of our products and services Improve our products and services Promote our products and services

5. Legal bases for processing personal data

HENNGE only processes your data based on one of the legal bases provided for in the GDPR (Articles 6 and 7). Particularly, in case HENNGE processes personal data that needs special care, HENNGE will obey special rules settled in the GDPR(Article 9 and 10).

6. Retention period of personal data

HENNGE will retain your personal data that HENNGE collects as long as it is necessary for the purpose to set out in this privacy policy unless a more extended period of retention is required by the applicable law.

7. Sharing and disclosure of personal data

HENNGE may share and disclose your personal data to our group entities and to the third party service providers in accordance with GDPR for the purpose stated in this privacy policy.

8. Transfers of personal data outside the European countries

Disclosure or sharing of personal data mentioned above Section 6 may involve transferring personal data out of the EEA. In such a case, HENNGE will implement proper safeguards, for example, by entering into the standard data protection clauses (Article 46 (2) (C) and (5) of the GDPR) approved by the European Commission. If you want to receive a copy of documentation related to these safeguards, please don't hesitate to get in touch with this privacy policy details. This disclosure or sharing may involve transferring personal data to the Company's subsidiary, HENNGE Taiwan. As a result of the sharing or disclosure to HENNGE Taiwan, in some cases your personal data may be transferred to Taiwan outside the EEA.

9. Your rights

You have the following rights regarding personal data obtained and processed by us as a data controller.

1. The right to obtain information regarding processing of data: You can obtain from us all the requisite information regarding our data processing activities that concern you (Article 13 and 14 of the GDPR).


2. Access to personal data: You can obtain from us confirmation as to whether personal data concerning you are being processed, and, if so, then access to the personal data and certain related information (Article 15 of the GDPR).


3. Rectification and erasure of personal data: You can have us rectify inaccurate personal data about you without undue delay and have us complete any incomplete personal data (Article 16 of the GDPR). Also, if certain conditions set out in the GDPR are satisfied, you can have us delete personal data about you without undue delay (Article 17 of the GDPR).


4. Restriction on processing of personal data: If certain conditions in the GDPR are satisfied, you can have us restrict processing your personal data about you (Article 18 of the GDOR).


5. Objection to the processing of personal data: If certain conditions set out in the GDPR are satisfied, you can object to the processing of personal data about you (Article 21 of the GDPR).


6. Data portability of personal data: If certain conditions set out in the GDPR are satisfied, you can receive personal data about you in a structured, commonly used, and machine-readable format and can transfer those data to another controller without hindrance from us (Article 20 of the GDPR).


7. Not to be subject to automated decision-making: If certain conditions set out in the GDPR are satisfied, you will have the right not to be subject solely to data-based, automated decision-making (including profiling) that produces any legal or similar material effect on you (Article 22 of the GDPR).


8. Withdrawal consent by the customers to processing personal data: The withdrawal of your consent will not affect the legality of any processing carried out before such withdrawal. If you withdraw your consent, HENNGE may not be able to provide certain products or services to you. HENNGE will advise you if this is the case at the time of such withdrawal by you.

If you intend to exercise any rights mentioned above, please inquire using the contact details of this privacy policy.

You can lodge a complaint in relation to our processing of your personal data with the Data Protection Supervisory Authority.

10. Use of cookies

HENNGE operates websites and some of our services that use cookies to improve their performance.
Additionally, those websites and some of our services (HENNGE One, CHROMO) use Google Analytics, an access analytics tool provided by Google LLC (Google AnalyticsTM is a trademark of Google LLC.). Google Analytics uses cookies to collect data. This data is collected anonymously and does not identify you personally.
The collection of data by cookies and by Google Analytics can be disabled by changing the browser's cookie setting. Please check your browser settings if necessary. For more information on how Google Analytics collects data, please see the page, "How Google uses information from sites or apps that use our services".

11. Children's personal data

If HENNGE collects and processes personal data from an under 16-year-old child or a child who has not reached the age limits under the EU member state's law, HENNGE will process his/her data appropriately.

12. Revisions of this privacy policy

HENNGE revises this privacy policy at any time. If HENNGE does so, HENNGE will notice you through this website.

13. Contact details

Please Contact us or our Data Protection Officer set out below, for questions and inquiries about this privacy policy.