Privacy Policy

1. About this Privacy Policy

The protection of your Personal Data is important to HENNGE K.K. ( “HENNGE”, “we” or “us”). Please read this Privacy Policy carefully to understand how HENNGE processes your Personal Data.   When used in this policy, Personal Data means any information relating to an identified or identifiable natural person. 

2. HENNGE’s roles and responsibilities

This Privacy Policy sets out how HENNGE collects or and processes Personal Data where we are the data controller. 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’ processing of your Personal Data other than in situations where the applicable law imposes duties on us. In order to know how your Personal Data is processed by our customers as data controllers, HENNGE recommends reading their service terms and conditions and privacy policies.

3. Personal Data that HENNGE collects and sources of such data 

We collect your Personal Data  that is legally required or necessary to initiate or maintain a business relationship with you and to provide you with our services. This data includes information you provide directly to us, information we collect automatically through your use of our websites or  services, and information we collect from other sources including but not limited to distributors, marketing companies that hold events sponsored by us, websites operated by third parties, and information aggregators and entities which have licensed HENNGE to use business contact information.  If you choose not to provide us with the necessary Personal Data, we may be unable to enter into or fulfill a contract with you and certain services or functions may not be available.

We collect the following categories of Personal Data:

  1. Personal Data of users of HENNGE’s services, including support services (collectively, the “Services”) 
    Name, phone number, email address, mailing address, the organization such person is affiliated with, job title, areas of expertise, call recording, payment information, username used on integrated external services, items listed in paragraph (ⅶ) of this section and other information collected in the course of providing our Services.
  2. Personal Data of employees of our third-party partners, including resellers, service venders and contractors:
    Name, phone number, email address, mailing address, the organization such person is affiliated with, job title, areas of expertise, payment information, individual identification number, username used on integrated external services, and other information collected in the course of entering into and performing contracts.
  3. Personal Data of shareholders and potential investors:
    Name, phone number, email address, meeting recording (audio, video), mailing address, the organization such person is affiliated with, job title, face photograph, bank account number, number of shares held, and other information collected in the course of administration of shareholders and shares.
  4. Job or Internship Candidates’ Personal Data: 
    Name, phone number, email address, mailing address, birth date, gender, face photograph, educational and work history, and other information described in the resume or otherwise collected in connection with applications for our job openings or internships, the subsequent recruitment process, and participation in our internship programs.
  5. Personal Data of Event Attendees:
    Name, phone number, email address, mailing address, the organization such person is affiliated with, job title, username used on integrated external services,  face photograph, feedback, interview content and other information collected in connection with attending or signing-up for events hosted or co-hosted by HENNGE, or at which we are an exhibitor.
  6. Personal Data of Individuals who have made inquiries about our Services, events, materials etc.:
    Name, phone number, email address, mailing address, the organization such person is affiliated with, job title, username used on integrated external services, inquiry details and history, call recording and other information collected in connection with inquiries.
  7. Personal Data of users of HENNGE’s websites and Services obtained through cookies:
    In our websites and Services, we use cookies and similar technologies (collectively “cookies”) to collect the types of information listed below. You can disable the collection of data by cookies by changing the browser settings. But please note that if you do so, you may be unable to access our websites or Services, or they may not function properly. 

Device data such as the operating system installed on user’s device, application information. 

Network information such as IP address, access history, user-agent. 

Metadata such as technical data about user activities on our websites or Services. 

Usage data such as the URLs visited by user, logs of user’s usage, logs about user’s login history, and timestamps.

Other information such as authentication credential information, location data etc.Information collected by third parties.  For example, Google Analytics, provided by Google LLC, collects data anonymously without identifying user’s personally.  For more information on Google Analytics, please review the information provided by Google LLC on its website. In addition, Microsoft may collect Personal Data to provide Microsoft Advertising.  For more information about Microsoft Advertising, please review the information provided in the Microsoft Privacy Statements (https://privacy.microsoft.com/en-us/privacystatement.)

We never acquire any personal data in a fraudulent or unlawful manner.

4. How HENNGE processes your Personal Data

a) Purpose of Processing.  HENNGE will process Personal Data for the purposes listed below. 

  1. Personal Data of users of HENNGE’s Services
  • Ensuring the normal operation and functionality of our Services
  • Maintaining safety and security of our Services
  • Performing analysis to improve, enhance and develop our Services
  • Processing payments
  • Providing information about and promoting our Services, events and seminars etc.
  • Conducting customer surveys and analyzing their answers for improvement and development of our Services
  • Communicating with you and responding to your inquiries
  1. Personal Data of employees of our third-party partners, including resellers, service venders and contractors
  • Ensuring the proper and smooth processing of transactions
  • Providing information about and promoting our Services, events and seminars etc.
  • Communicating with you and responding to your inquiries
  1. Personal Data of shareholders and potential investors
  • Providing information as part of our investor relations (IR) activities
  • Managing shareholders and shares
  • Providing information about and promoting our Services, events and seminars etc.
  • Generating data and processing statistics based on applicable laws and regulations
  • Enhancing and developing our IR activities
  • Communicating with you and responding to your inquiries
  1. Job or Internship Candidates’ Personal Data
  • Conducting recruitment work such as assessing applications, evaluating and improving our recruiting system, our application tracking and recruiting activities.
  • Communicating with you and responding to your inquiries 
  • Providing information about and promoting our Services, events and seminars etc.
  • Processing of payments
  1. Personal Data of Event Attendees
  • Organization, operation and management of events, seminars, etc.
  • Providing information about and promoting our Services, events, and seminars, etc.
  • Performing analysis to improve, enhance and develop our Services
  • Communication with you and responding to your inquiries
  1. Personal Data of Individuals who have made inquiries about our Services, events, materials etc.
  • Communicating with you and responding to your inquiries 
  • Providing information about and promoting our Services, events, and seminars, etc.
  • Performing analysis to improve, enhance and develop our Services
  1. Personal Data of users of our websites and Services obtained through cookies:
  • Communicating with you and responding to your inquiries
  • Ensuring the normal operation and functionality of our websites and Services 
  • Maintaining safety and security of our websites and Services 
  • Performing analyses on our Services usage, user adoption and other related information to improve, enhance and develop our websites and  Services 
  • Providing information about and promoting our Services, events, and seminars, etc.
  • Providing personalized services to visitors to our websites

b) Recording and Transcribing. We may record or transcribe our communications with you to confirm details and for quality improvement purposes.

c) Prohibition of Inappropriate Use.  We will not utilize Personal Data using any method that has the possibility of fomenting or prompting unlawful or unjust acts. 

5. Legal bases for processing personal data

HENNGE only collects and processes your Personal Data based on one of the legal bases provided for in the applicable law.  For example, in the European Economic Area (EEA) and the United Kingdom, we will process your Personal Data based on a legal basis set forth in the General Data Protection Regulation 2016/679  and the UK General Data Protection Regulation (collectively, “GDPR”), primarily under Articles 6 and 7.   Specifically, HENNGE will process (i) Personal Data of users of HENNGE’s Services  for the purposes listed above based on Article 6 (1)(b) and (f) of the GDPR and (ii) Personal Data of Event Attendees for the purposes listed above based on Article 6(1)(a) of the GDPR. Our legitimate interests pursued under Article 6(1)(f) are to provide Services, offer customer support, conduct business administration, ensure security, and fulfill other operational purposes.

6. Retention period of Personal Data

HENNGE will retain your Personal Data as long as it is necessary for the purpose set out in this Privacy Policy unless a longer period of retention is required by the applicable law.

7. Provision and disclosure of Personal Data

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

  1. Data subjects consent to the provision or disclosure of their Personal Data;
  2. the relevant Personal Data is provided where the processing of such information is delegated to a third party, in whole or in part, to the extent necessary to achieve the aforementioned purpose;
  3. the relevant Personal Data is provided in connection with a business succession due to merger or other reasons; and
  4. the provision or disclosure is otherwise permitted by the applicable law

8. International Transfers of Personal Data 

Provision or disclosure of Personal Data mentioned above in Section 7 may involve transferring Personal  Data across international borders outside of the country where you are located, including to countries outside Japan, the EEA or the United Kingdom, that do not have laws providing specific protection for Personal Data or that have different legal rules on data protection. In such cases, HENNGE will ensure that there is a legal basis for such a transfer and that adequate protection for your Personal Data is provided as required by applicable law, for example, by entering into the Standard Data Protection Clauses (Article 46 (2) (C) and (5) of the GDPR) approved by the European Commission or by relying on the provisions of Article 28 of Japan’s Act on the Protection of Personal Information.

9. Your rights

a)  Subject to and to the extent provided for under applicable law, you may have the following rights regarding your Personal Data collected and processed by us.

  1. Right to obtain information regarding processing of your Personal Data: You can obtain from us all the requisite information regarding our data processing of your Personal Data.
  2. Right to access your Personal Data: You can obtain from us confirmation as to whether your Personal Data is being processed, and, if so, access your Personal Data and certain related information.
  3. Rights to rectification and erasure of your Personal Data: You may have the right to have inaccurate Personal Data concerning you rectified without undue delay and, taking into account the purpose of the processing, to have  incomplete Personal Data completed.  In addition, you may have the right to have your Personal Data deleted without undue delay under certain conditions.
  4. Right to restrict the processing of your Personal Data: If certain conditions under applicable law are satisfied, you have the right to restrict the processing of your Personal Data.
  5. Right to Data portability: If certain conditions under applicable law are satisfied, you can receive your Personal Data in a structured, commonly used, and machine-readable format and can transfer those data to another controller without hindrance from us.
  6. Right regarding automated decision-making: If certain conditions under applicable law are satisfied, you have the right to not be subject solely to data-based, automated decision-making (including profiling) that produces any legal or similar material effect on you.
  7. Right to withdraw your consent 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 services to you. HENNGE will advise you if this is the case at the time of such withdrawal by you.
  8. Right to object: If certain conditions under applicable law are satisfied, you can object to the processing of your Personal Data.

b) If you intend to exercise any rights mentioned in the previous provisions, please inquire using the contact details set forth in this Privacy Policy. You also have the right to lodge a complaint in relation to our processing of your Personal Data with competent supervisory authorities

10. Children’s personal data

HENNGE does not provide our Services for purchase by children.  HENNGE does not knowingly collect Personal Data from children under the age of 16. If you are under 16, you may use our Services only with the involvement of a parent or guardian. If you are a parent or guardian and believe that your child has provided HENNGE with Personal Data without your consent, please contact us by using the  contact details below, and HENNGE will take steps to delete such Personal Data from our systems.

11. Continuing Efforts

HENNGE will review its operations with respect to the processing of Personal Data as appropriate and make efforts to keep improving. 

12. Management of Personal Data

To the extent of and in accordance with the requirements of applicable law, HENNGE will keep Personal Data accurate and up-to-date to the extent necessary to achieve the specified purposes, and delete it without delay when it is no longer needed for such purposes, unless retention is otherwise required by applicable law. Furthermore, HENNGE will implement appropriate technical and organizational security measures in order to prevent unauthorized disclosure, access, loss, or damage of Personal Data processed by HENNGE. 

13. Revisions of this privacy policy

HENNGE reserves the right to revise this Privacy Policy at any time, and will provide notice of such revisions on this website.

14.Contact details

Please contact us or our representatives using the contact information set out below for questions and inquiries about this Privacy Policy.

Contact:
HENNGE K.K.
Attention: Data Protection Officer – Legal i Plus, and Legal Section, Business Administration Division
Daiwa Shibuya Square, 16-28 Nanpeidaicho, Shibuya City, Tokyo Japan 150-0036

General Data Protection Regulation (GDPR) – European Representative
Pursuant to Article 27 of the General Data Protection Regulation (GDPR), HENNGE K.K has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR: 

UK General Data Protection Regulation (GDPR) – UK Representative
 Pursuant to Article 27 of the UK GDPR, HENNGE K.K. has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR:

As of November 1, 2025

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