• This website is operated by Kokyu Alcohol Kogyo Co., Ltd. (hereinafter, the "Company"), and ESTENITY S.A.R.L, an affiliated company of the Company located in the European Economic Area. This "Handling of Personal Information" is to inform the handling policy of affiliated companies (together with the Company, hereinafter, "HAI Group"), including the Company, with regard to the information that may identify and individual (hereinafter "Personal Information") obtained on this website.

[Acquisition of Personal Information]

• If users of this website (hereinafter, "User(s)" or "you") wish to receive the Company's product samples, the Company requests the Users to be registered as members in order for the Company to continue to provide better service. At the time of membership registration, the Company may collect Personal Information, including the following information, for the purposes stated in "Use of Personal Information" below (hereinafter, "Purposes of Use"):

• (a) Details of name and address
• (b) E-mail address
• (c) User name and password
• (d) IP addresses and cookies
• (e) Employment information, resume, CV, etc.

• The scope of Personal Information of Users provided through membership registration shall be the minimum necessary, and HAI Group shall comply with relevant laws and regulations, including the "Act on the Protection of Personal Information" and relevant guidelines (hereinafter collectively, the "Act"), in handling such Personal Information.

[Use of Personal Information]

• HAI Group will use Users' Personal Information within the scope necessary to achieve the following purposes. If a User provides his/her Personal Information in relation to the provision of services by the Company, the User shall be deemed to have agreed to the Purposes of Use:

• (a) To provide Users with product information (catalog) and services handled by the Company;
• (b) To send the Company's product samples to Users;
• (c) To respond to questions, comments, and requests from Users; and
• (d) In addition, in order to implement various measures to facilitate the relationship between the Company and Users.

[Protection and Management of Personal Information]

• HAI Group will appropriately manage the Personal Information of Users and make efforts to prevent unauthorized intrusion, falsification, leakage and other risks based on reasonable standards.

[Provision of Personal Information]

• HAI Group will not provide Personal Information to a third party, except:

• (a) With the consent of the user
• (b) Pursuant to the Act and other laws and regulations
• (c) Where the Personal Information is provided in connection with entrustment of all or part of the handling thereof to a third party to the extent necessary to achieve the Purposes of Use;
• (d) Where the Personal Information is used jointly with a person stipulated in "Specific Joint Use"; or
• (e) Where the Personal Information is provided after being processed in such a way that the User cannot be specified or identified.

[Specific Joint Use]

• HAI Group will share Personal Information within HAI Group to the following extent in order to provide better services to Users:

• (a) Items to be shared
  Personal data of Users.
• (b) Scope of joint users
  HAI Group companies including the Company.
• (c) Purpose of use
  To analyze Users' use of this website.
• (d) Person responsible for the management of joint use
  The Company.

[Request for Disclosure of Personal Information]

• A User may request the Company to notify the User of the purpose of use, disclose, correct, add or delete the content, discontinue the use of, erase or discontinue the provision to a third party of, his/her Personal Information (hereinafter, "Disclosure Request"). If any User wish to make a Disclosure Request or have any other questions or complaints, the User will be requested to contact the following contact information. If any User makes a Disclosure Request, the Company will identify the User in the manner as prescribed by the Company and request the User to pay a fee as prescribed by the Company.

• (a) Contact
  Public Relations Office, Kokyu Alcohol Kogyo Co., Ltd.
• (b)Address
  1-7-7 Nihonbashi Ningyocho, Chuo-ku, Tokyo 103-0013
• (c) Phone
  03-3667-2801 (main phone number)
• (d) Fax
  03-3667-3980

[Improvement in Handling of Personal Information]

• When it becomes necessary to review this "Handling of Personal Information," the Company will make appropriate improvements.

• Kokyu Alcohol Kogyo Co., Ltd. (hereinafter, the "Company") and the Company's affiliated companies (together with the Company, hereinafter "HAI Group") are committed to protecting the privacy of users of this website (hereinafter, "User(s)" or "you"). Please read this Privacy Policy carefully before using the Site.

Article 1. Definitions

• The definitions of the following terms in this privacy Policy shall be as follows:

• (a) Applicable Privacy Laws
  Applicable data protection laws and regulations, including the EU General Data Protection Regulation ("GDPR") and relevant enforcement laws of respective countries.
• (b) Contracts
  Contracts regarding goods or services, etc. entered into between each User and the Company.
• (c) Personal Data
  Any information relating to an identified or identifiable natural person residing in the European Economic Area that is processed by the Company as set out in Article 3 of this Privacy Policy.
• (d) Privacy Policy
  This Privacy Policy.
• (e) Process or Processing
  A single operation or a series of operations carried out on Personal Data or a series of Personal Data, whether by automatic means or otherwise (including data collection, recording, editing, structuring, storage, modification, alteration, restoration, reference, use, disclosure by transfer, publicity or other provision, alignment, combination, restriction, erasure, destruction, etc.).
• (f) Controller
  Any natural or legal person, any governmental authority or any other person who, alone or jointly with others, determines the purposes for which and the means by which Personal Data is to be processed.
• (g) Site
  https://www.hai-global.com/
• (h) Company
  Kokyu Alcohol Kogyo Co., Ltd.
  Taiei Kogyo Danchi, 641-6 Kichioka, Narita, Chiba 287-0225

Article 2. Scope of Application of this Privacy Policy

• 2.1 This Privacy Policy applies to Processing of Personal Data collected through the use of the Site, to which Applicable Privacy Laws apply. The Controller for such Processing is the Company.
• 2.2 The Site may contain information of third parties (e.g., hyperlinks, etc.). The Company does not control the information of third parties and the Company is not responsible for compliance by third parties with Applicable Privacy Laws. Users are encouraged to carefully read the Privacy Policy on the third party website they are viewing.

Article 3. Personal Data to be Collected

• 3.1 The Company may collect the following Personal Data from Users:

• (a) Details of name and address
• (b) E-mail address
• (c) User name and password
• (d) IP address and Cookies
• (e) Employment information, resume, etc.

• 3.2 The Company does not collect sensitive Personal Data, including passport information or health data, through the Site, except as required by Applicable Privacy Laws.

• 3.3 The Company collects Personal Data when a User:

• (a) Registers on the Site;
• (b) Applies for employment through the Site; or
• (c) Otherwise uses the Site.

• 3.4 The Company will Process Personal Data only in accordance with Applicable Privacy Laws, as set out in this Privacy Policy.

Article 4. Purposes and Legal Basis of Data Processing

• The Company will Process the following Personal Data of Users on the legal basis set forth in the GDPR (Articles 6 and 7). In addition, the Company will Process sensitive Personal Data of Users, including religious beliefs and health conditions, in accordance with special standards set forth in the GDPR (Articles 9 and 10):

• 4.1 The Company collects and Processes Personal Data only for the purposes set out below:

• (a) Performance of Contracts, or response to requests by Users prior to conclusion of Contracts: If a User places orders through the Site, the Company may Process the Personal Data of the User in order to perform Contracts. The Company will not Process Personal Data beyond what is necessary to carry out the Contracts.
• (b) Communications: The Company may use the Personal Data of Users, (i) to communicate about the Company's products and services, (ii) to provide Users with information that is important to Users' accounts and/or use of the Site, and (iii) to respond to complaints. If a User creates an account on the Site, the Company will retain Personal Data so that the User will not have to enter it each time. Such Processing of Personal Data is necessary for the execution of Contracts and/or for the Company to obtain legitimate interests, in other words, to carry out its normal operations.
• (c) Customer service: If a User uses customer service, the Company may use the User's Personal Data to provide customer service. Such Processing of Personal Data is necessary for the performance of the Contracts and/or for the Company to obtain legitimate interests, in other words, to carry out its normal operations.
• (d) Application for employment: If a User applies for employment through the Site, the Company may use the User's Personal Data to respond to such application. The Processing of such Personal Data is necessary for the Company to obtain legitimate interests, in other words, to recruit people working for Kokyu Alcohol Kogyo Co, Ltd.

• 4.2 If the Company intends to further Process the Personal Data for any purpose other than the purposes of Processing upon collecting Personal Data, the Company will provide information about such other purposes and all relevant additional information before processing the Personal Data.

• 4.3 If the legal basis for the Processing of Personal Data is consent, the User has the right at any time to withdraw his/her consent in relation to his/her Personal Data. However, withdrawal of consent does not affect the validity of the Processing of Personal Data before withdrawal of consent.

• 4.4 The Company has not made any decisions based solely on automated data processing that would have a legal or similarly material impact on Users.

• 4.5 If a User does not provide Personal Data when using the Site, the User may not be able to use some functions of the Site.

Article 5. Transfer of Personal Data to Third Parties

• The Company will share the Personal Data of Users within HAI Group (including those located in countries outside the European Economic Area) for the purposes of use set out in this Privacy Policy. In this case, the Company will take appropriate protective measures, including by way of concluding standard contractual clauses with parties to which data is transferred that are located outside the European Economic Area. In addition, upon request, the Company will provide a copy of documents, etc., showing the details of those protective measures.

Article 6. Security

• 6.1 The Company will take appropriate organizational and technical security measures to protect the Personal Data of Users and prevent unauthorized use, loss or modification of such Personal Data. The Company also grants access to Personal Data only to employees, agents, contractors, and other third parties who need to access the data. Those persons have confidentiality obligations under contract of employment or the (data processing) contract.

• 6.2 The Company has established an internal "Information Security Guidelines of Kokyu Alcohol Kogyo Co., Ltd.," which includes a data breach policy that defines how the Company responds to any breach of Personal Data. If required under Applicable Privacy Laws, the Company will notify relevant supervisory authorities and data subjects.

Article 7. Retention Period

• 7.1 The Company will not retain the Personal Data of Users beyond what is necessary for the purposes of data collection.

• 7.2 A User may, at any time, request the Company to delete his/her Personal Data. In addition, the Company will delete Personal Data if such data is no longer necessary for the purposes of collection or Processing of such data.

Article 8. Cookies

• 8.1 The Company uses cookies to ensure the proper functioning of the Site. Please check the Cookie Policy for a detailed explanation.

• 8.2 Cookies are information stored on Users' computers by browsers. The Company uses different types of cookies for different purposes to achieve the Company's legitimate interests.

• (a) Functional cookies: These cookies are required for the Website to function properly and include the cookies required to create an account.
• (b) Analytical cookies: These cookies are used to obtain information on how Users use (part of) the Website. This will allow the Company to improve the Website and make the Website as close to Users' interests and priorities as possible. The Company uses the data obtained through cookies to analyze the usage of the Website.
• (c) The Company uses third party cookies solely to improve the quality and effectiveness of the Website. For example, the Company uses Google Analytics, which is configured in a privacy-friendly manner. Google Analytics Processes IP addresses for the Company.

• 8.3 Most browsers have cookies enabled by default. Depending on your browser settings, you can disable cookies and display cookies when you send cookies. However, if cookies are disabled, features and services on the Company's and other websites may not function properly.

Article 9. Rights of Users

• 9.1 You have the right to request access to your Personal Data. You may then receive a copy of your Personal Data held by the Company.

• 9.2 You have the right to request corrections to your Personal Data held by the Company. This will allow you to correct any incomplete or inaccurate data relating to you.

• 9.3 You have the right to request the deletion of your Personal Data. This allows you to delete your Personal Data that the Company continues to Process without cause.

• 9.4 You have the right to object to the Company's Processing of your Personal Data for the Company's legitimate interests. If the Company is Processing Personal Data for direct marketing purposes, the Company will always accept your objections. If Personal Data is Processed for any other purpose, the Company will cease Processing the Personal Data unless there is any compelling reason for not doing so, which (i) is given priority to the interests, rights and freedoms of Users, or (ii) relates to the initiation or implementation of legal measures, or allegation or proof.

• 9.5 You have the right to request restrictions on the Processing of your Personal Data.

• 9.6 You have the right to request the transfer of your Personal Data to yourself or to a third party. The Company will provide your Personal Data to you, or to a third party designated by you, in a structured, commonly used, machine readable format. Please note that this right applies only to processing-automated information that was used by the Company with your initial consent or to perform your Contracts.

• 9.7 If certain requirements are met, you have the right to be subject to decisions based solely on an automated data Processing that will have a legal or similarly material impact on you (including profiling).

• 9.8 You have the right to obtain from the Company all necessary information concerning the Company's data processing activities relating to you.

• 9.9 There will be no charge for the exercise of the above rights. The Company will provide you with information regarding the status of response to your request within one month after receipt of your request. If it takes a long time depending on the content, the Company will notify you to that effect.

• 9.10　If your request is manifestly unfounded or excessive, especially if you are making repeated requests, the Company will make reasonable charges to you, or will refuse to accept your request.

• 9.11　In addition to the above rights, you have the right to file a complaint with the supervisory authority (In particular, the address, place of work of the user or the supervisory authority of the EU Member State where the GDPR is alleged to have been violated.) at any time. However, the Company requests that you contact us in advance so that we may have an opportunity to respond to your complaints before you contact our regulators.

Article 10 Contact Information

• If you have any questions or complaints or would like to exercise the rights described in Article 9 of this Privacy Policy, please contact:

• (a) Contact
  Public Relations Office, Kokyu Alcohol Kogyo Co., Ltd.
• (b) Address
  1-7-7 Nihonbashi Ningyocho, Chuo-ku, Tokyo 103-0013
• (c) Phone
  03-3667-2801 (main phone number)
• (d) Fax
  03-3667-3980

Article 11. General Provisions

• 11.1 The Company is authorized to delete your account at any time without prior notice. The Company will have no liability to you if your account is deleted.

• 11.2 The Company reserves the right to revise this Privacy Policy on a regular basis. It is your responsibility to check the applicable provisions periodically. This Privacy Policy was last revised in August 2020.

• 11.3 If any provision of this Privacy Policy conflicts with any law, then, to the extent permitted by law, such provision shall be replaced by a provision to the same effect, reflecting such intent. In such case, the remaining provisions shall continue to be unchanged and applicable.