Compliance with the Related Regulations

HENNGE will comply with all related regulations and guidelines including the Act on the Protection of Personal Information (“Personal Information Protection Law”) applicable to handling the personal information of Customers.

Definition

The definitions of personal information, personal data, etc. in this policy are in accordance with those stipulated in the Personal Information Protection Law.

Acquisition of Personal Information

HENNGE will never acquire any personal information in a fraudulent or unlawful manner.

Purpose of Utilization of Personal Information

HENNGE may utilize Personal information within the scope of purposes as set forth below;

1. Purposes of Utilization of Personal Information of Customers who Use HENNGE Products and Services
   1. Purposes stipulated in the terms of services of HENNGE products and services used by the customers
   2. Support of HENNGE products and services;
   3. Providing information on HENNGE products, services, events and seminars, etc.;
   4. Conducting customer surveys and analyzing their answers;
   5. Development of new HENNGE products and services, and analysis for the improvement and enhancement of HENNGE products and services;
   6. Communications related to our business or ancillary matters; and
   7. Responding to various inquiries and complaints.
2. Purposes of Utilization of Personal Information of Persons who Have Applied for or Participated in Events and Seminars, etc. Organized, Co-hosted, Sponsored or Participated in by the Company
   1. Organization, operation and management of events, seminars, etc.
   2. Providing information on HENNGE products, services, events and seminars, etc.
   3. Development of new products and services, and analysis for the improvement and enhancement of HENNGE products and services
   4. Responding to various inquiries
3. Purpose of Utilization of Personal Information of Applicants for Hiring
   1. Recruiting activities, selection of and other relevant communication to applicants.
   2. Planning of recruitment
   3. Review and analysis for future recruitment activities
   4. Responding to various inquiries
4. Purposes of Utilization of Shareholders’ Personal Information
   1. Execution of rights and performance of obligations by the shareholders based on the provisions of the Companies Act of Japan;
   2. Generating data and processing statistics based on applicable laws and regulations; and
   3. Responding to inquiries from shareholders.
5. Purposes of Utilization of Personal Information Common to those who Have Made Inquiries or Given us Feedback
   1. Responding to various inquiries
   2. Improvement for the quality of HENNGE’s response to inquiries and to accurately understand the content of inquiries
   3. Improvement and enhancement of HENNGE products and services

Prohibition of Inappropriate Use

HENNGE shall not utilize personal information provided by Customers using a method that has the possibility of fomenting or prompting unlawful or unfair acts.

Scope of Utilization of Personal Data

HENNGE shall not disclose nor provide personal data to any third party except for the following cases where;

1. Data subjects consent to the providing or to disclosure of personal data;
2. the relevant personal data is provided where the handling of such information is delegated to a third party, whole or a part, to the extent necessary to achieve the previously mentioned purpose of utilization;
3. the relevant personal data is provided while the business is succeeded due to merger or other reasons;
4. the relevant personal data is jointly utilized in accordance with the paragraph, “Joint Utilization of Personal Data” below; and
5. the disclosure is otherwise permitted by the Personal Information Protection Law and other applicable laws and ordinances.

Joint Utilization of Personal Information

HENNGE may share and jointly utilize personal data provided by Customers with its subsidiary, HENNGE Taiwan, Inc. under the previously mentioned “Purpose of Utilization of Personal Data”.

• Items of personal data which may be jointly utilized:
  Customer’s company name, address, full name, phone number, and email address
• Responsible person at HENNGE with respect to management of personal data which may be jointly utilized:
  HENNGE K.K.
  16-28 Daiwa Shibuya Square, Nampeidai-cho Shibuya,Tokyo Japan
  Representative Director
  Kazuhiro Ogura

Provision of Personal Data to Foreign Third Parties

We may provide personal data to our subsidiary HENNGE Taiwan, Inc. to the extent necessary to achieve the purposes of use of personal data described above. Our subsidiary has established a system that complies with the standards required by the Personal Information Protection Law, and we will take the necessary measures to ensure that this system is maintained on an ongoing basis.

• Name of foreign country to which personal information is provided
  Taiwan
• Information on the system for the protection of personal information in the foreign country to which the information is provided
  Please refer to the following website of the Personal Information Protection Commission.
  https://www.ppc.go.jp/enforcement/infoprovision/laws/offshore_report_taiwan/

Use of Tadrill (targeted attack email training service) User’s Personal Information

We handle personal information of users of Tadrill provided by us within the scope of purposes as set forth below;

1. confirmation and analysis of the contents of reports regarding targeted attack emails
2. creation of a list of targeted attack email training service targets to be provided to customers.

In this case, we may access and use personal information contained in third party services such as Gmail provided by Google LLC within the scope necessary to achieve the above purposes. This personal information includes the name and email address of senders and receivers (including CC and BCC), email contents such as header, subject and body of the email, and user information such as the Tadrill user's name, email address and organizational unit to which the user belongs.

We shall not provide or disclose the accessed information to any third party.

Use of Users’ Cookies and Other Information

HENNGE operates websites and some of HENNGE’s services that use users’ cookies and other information (e.g., your device, browser and application information, network information such as IP address, access history within our services, etc.) in the scope of the following purposes.

• To ensure the normal operation and functionality of the services provided by HENNGE and the websites operated and managed by HENNGE;
• To analyze usage trends for the development and improvement of services provided by HENNGE;
• To provide personalized services to visitors to the HENNGE’s websites; and
• To analyze usage trends in order to improve the content of the websites operated by HENNGE.

If you wish to stop the transmission of the above information, you may do so through the settings on your browser, smartphone, or other device. However, cookies and other information used for the purpose (1) above are essential for the operation of the service, and if you disable their transmission, you may not be able to use some functions of our service properly.

Additionally, those websites and some of HENNGE’s services use Google Analytics, an access analytics tool provided by Google LLC (Google Analytics^TM is a trademark of Google LLC.). Google Analytics uses cookies to collect data. This data is collected anonymously and does not identify Customers 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".

Secure Management of Personal Data

HENNGE will make efforts to keep personal data accurate and up-to-date to the extent necessary to achieve the purpose of utilization. Also, HENNGE will make efforts to delete personal data without delay in the event that HENNGE no longer needs to utilize such data. HENNGE will develop appropriate internal schemes and will implement appropriate security measures in order to prevent divulgence, loss, or damage of personal information as well as to manage security of personal information handled by HENNGE.

Disclosure, Correction and Stoppage of Utilization of Retained Personal Data

In the event that you wish HENNGE to disclose, correct, or stop utilization of your own retained personal data that is under the custody of HENNGE, based on the Personal Information Protection Law, you are able to make such a request anytime by the method designated by HENNGE. For details, please contact the “Point of Contact on Handling of Personal Information” as indicated below.

• Officer responsible for Personal Information management
  HENNGE K.K.
  16-28 Daiwa Shibuya Square, Nampeidai-cho Shibuya,Tokyo Japan
  Representative Director
  Kazuhiro Ogura
  
• Contacts
  privacy-info@hennge.com
  HENNGE K.K.
  Personal Information Management Staff

Continuing Efforts

HENNGE will review its operations with respect to the handling of personal information as appropriate, and make efforts to keep improving.

Revisions of This Policy

HENNGE may revise this policy as necessary. In the event of revision of this policy, the revised version will be made available on the HENNGE website and in other forms.