Privacy Notice

Last Revision Date: March 1, 2023

Saison Technology International (“Company,” “we“, “us” or “our“) maintains this Privacy Notice (“Privacy Notice“) that summarizes the treatment of information provided or collected on the sites where this Privacy Notice is posted, including, without limitation our website(s) at https://saison-technology-intl.com/ (our “Sites“). This Privacy Notice also describes how we treat information provided or collected through our services and other online and offline activities.

In the event of any discrepancy between this Privacy Notice and the Privacy Policy at https://saison-technology-intl.com/media/HULFT_Privacy_Policy.pdf, this Privacy Notice shall prevail.

We will not discriminate against California residents for exercising any of their rights under the California Privacy Laws.
We take your privacy seriously and do not sell or share any of your personal information.
We collect Sensitive Personal Information (“SPI”) to provide our service for our customers and do not collect SPI for general marketing purposes.

If you have any questions or concerns about our use of your information, then please contact us using the contact details provided at the bottom of this Privacy Notice.

CONTENTS

We recommend you read this Privacy Notice in full to ensure you are fully informed. However, if you only want to access a particular section of this Privacy Notice, then you can click on the relevant link below to jump to that section.

• Types of Information We Collect
• How We Collect Your Information
• How We Use Your Personal Information
• How We Share Your Personal Information
• Storage of Information and Security
• Marketing Opt-Out Provision
• Your Rights
• Notification of Changes
• Links to Third Party Websites, Services and Offers
• Protection of Children’s Privacy
• Special Note to Parents
• Users Outside United States
• Third-Party Processors

A. Types and Collection of Information

Our primary goal in collecting the information described below is to provide you, the user, with a customized experience and to deliver better service, products, and more relevant content to our customers, prospective customers, and visitors.

1. Types of Information We Collect

We collect two basic types of information in connection with our Service: (a) Personal Information and (b) Anonymous Information. Personal Information, Anonymous Information and Aggregated Information as used in this Privacy Notice are defined below:

“Personal Information” means information that identifies (whether directly or indirectly) a particular individual, such as the individual’s first and last name, home or other physical address, email address, and telephone number. Personal Information also includes identifiers, such as cookies, IP addresses and Mobile Device IDs that recognize individuals over time and across different websites or online services, where those identifiers can be reasonably linked to an identifiable individual.

“Anonymous Information” means information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual person. When Anonymous Information is directly or indirectly associated with or combined with any Personal Information, such Anonymous Information will also be treated as Personal Information.

“Aggregated Information” means information about groups or categories of persons, this can constitute Personal Information unless it does not identify and cannot reasonably be used to identify an individual person.

2. How We Collect Your Information

For the purposes described in Section B.1, we have collected, the following categories of Personal Information in the last twelve (12) months and will continue to do so:

Information Collected Directly From You

When you interact with us, we collect information (including Personal Information) you provide to us directly as described below:

Registration Information. When you register with us (including directly through Sites or your Mobile Device, or another similar manner) to create an account or profile on our Sites or for our services, you will be asked to provide:

(i) your first and last name;
(ii) your e-mail and mailing address;
(iii) user name, nickname, or password;
(iv) language preferences; and
(v) such other information (including Personal Information) necessary to complete the registration process.

Information Through Mobile Devices. When you access our Sites or services through your mobile telephone or other mobile devices (collectively, “Mobile Device“), we will collect:

(i) Mobile Device type and manufacturer;
(ii) mobile carrier;
(iii) Mobile Device identifiers or advertising identifiers (“Device ID“);
(iv) telephone number;
(v) Internet Protocol address;
(vi) geographic location/country/zip code;
(vii) platform version;
(viii) installation, navigation, access, interaction, impression and engagement information;
(ix) network connection type;
(x) browser type;
(xi) Mac address;
(xii) iOS advertiser ID; and
(xiii) such other information you voluntarily provide to us.

In addition, we collect information you provide when you sign up to have Short Message Service notifications sent directly to your Mobile Device. We use your Device ID to verify, audit and analyze your use of our Sites and services.

Service and Support. When you communicate with us in connection with customer service and technical support, we will collect and store your contact information, information about your use of our Sites and services, your user ID and such other information you voluntarily provide to us in connection with such inquiry.

Profile Information. We provide areas on our Sites and in the provision of our services where you can post information about yourself and others and communicate with others or upload content. Such postings are governed by the applicable Terms of Service. In addition, such postings may appear on other websites or services, or when searches are executed on the subject of your posting. Also, whenever you voluntarily disclose Personal Information on publicly-viewable areas, that information will be publicly available and can be collected and used by others. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your Personal Information.

Information Received from SNS and APIs. When you access our Sites or services through an SNS, we access and obtain certain information from your profile through such SNS and the applicable SNS platform Application Programming Interface (“API“). The information we receive varies by the Application and by the privacy settings you choose for the SNS and may include Personal Information, including, without limitation, the following:

(i) your first and last name;
(ii) your profile picture or its URL;
(iii) your user ID number; which is linked to publicly available information such as name and profile photo;
(iv) the user ID numbers for your friends that are also connected to our Application(s);
(v) login e-mail you provided to the SNS when you registered;
(vi) your physical location and that of your access device(s);
(vii) your password; and
(viii) your gender.

When using our Sites or services through an SNS, we will collect, store and use/disclose any and all information you permitted the SNS could disclose to us through the API in accordance with your privacy preferences for the SNS. This may include Personal Information, and we will protect such information in accordance with this Privacy Policy.

Direct Email Information. We obtain the following information from the actions you take in response to web links attached to direct e-mails we send to you:

(i) history of opening direct e-mails;
(ii) history of clicking attached web links; and
(iii) subscription and deregistration from direct email.

Information Collected in Offline Activities. We may collect personal information, such as name, email address, company name, department, title, etc., through offline methods, such as the exchange of business cards during seminars and events.

Information Collected from B-to-B Databases

We use B-to-B Database services provided by third parties for advertising and marketing and obtain the following information registered in such databases:

(i) your first and last name;
(ii) your email and mailing address;
(iii) your phone number;
(v) your title and the company you work for; and
(vi) other information registered in the databases.

Information Collected by Automated Technologies

When you interact with us, we collect information, including Personal Information, through automated technologies including cookies, tracking technologies and log files, and external services such as Google Analytics and HubSpot. For more information about cookies and technologies we use, why, and how you can control them please see our Cookies Notice.

You are required to provide your personal information to us in order to enter into a contract to use our services. You must also provide personal information in order to use our services. If you refuse to provide your personal information, you may not be able to use some or all of our services.

B. Use and Disclosure of Personal Information

Unless otherwise permitted or required by law, or with your additional consent, we will use and disclose your Personal Information solely for the purposes set out in this Privacy Notice.

We have disclosed your personal information to the following categories of parties in the past 12 months:

(a) Saison Technology Co., Ltd. (name, email address, title, company, industry, and any data processed in the operation of our services);
(b) CRM service providers (name, email address, title, company, industry, and any data processed in the operation of our services);
(c) Cloud platform service providers (name, email address, and any data processed in the operation of our services)
(d) Web analytics service providers (IP address, country, browser, OS, and service provider); and
(e) Direct mail service providers (email opening history, clicks, and deregistration).

1. How We Use Your Personal Information

We use your Personal Information for any one or more of the following purposes:

(a) to allow you to register with us to create an account or profile within our Sites and when receiving our services;
(b) to operate, maintain and improve our Sites and services;
(c) to conduct market research analyses;
(d) to communicate with you concerning your account or, with your explicit consent or as permitted by law, to send you announcements, newsletters, promotional materials and other information about our Sites and services or offerings of our business partners, and to offer you opportunities to participate in surveys, campaigns, contests and sweepstakes;
(e) to prevent or investigate actual or suspected fraud, hacking, infringement, or other misconduct involving our Sites or services;
(f) to respond to customer service and technical support inquiries, troubleshoot problems, investigate incidents, and handle complaints;
(g) to advertise and conduct marketing to customers and prospective customers;
(h) to provide services to you and our customers;
(i) to complete payment and billing transactions;
(j) to comply with applicable laws, regulations, legal processes or enforceable government requests;
(k) to send notices, and to enforce applicable terms and conditions set forth in such policies;
(l) to enable user-to-user communications and other in-service communications and interaction;
(m) to enable us to deliver information to SNS when you use or access our Sites or services through such SNS; and
(n) to protect against harm to the rights, property or safety of the Company, its users or the public as required or permitted by law.

The Company processes Personal Information on our servers in the United States of America, Japan and in other countries. In some cases, we may process Personal Information outside of your country. For more information please see our section titled ‘International Data Transfers’.

2. How We share Your Personal Information

Third Party Service Providers. We may disclose your Personal Information to third party service vendors and partners in connection with our provision of our Sites and services. Such third party service vendors and partners may be located in countries other than your country of residence and provide such services as payment processing, data analysis, e-mail delivery, hosting, order fulfillment, infrastructure and network storage, customer service, technical support, auditing, content licensing and promotional services.

Advertising of Third Party Products and Services. We may share (i) Aggregated Information; (ii) Anonymous Information; and (iii) certain technical information with third party advertisers for their direct marketing purposes, including, without limitation, to develop and deliver targeted advertising in our Sites and on the websites of third parties.

Affiliates. We may disclose Personal Information to our “Affiliates” (which shall mean subsidiaries, parent companies, joint ventures and other corporate entities under common ownership located in the United States, Japan or Europe for the purpose of transferring and processing such Personal Information based on our instructions and such purposes as described in this Privacy Notice.

Ownership Change. In the event Company combines with another company in the future through a corporate merger, sale, acquisition, liquidation or other similar process, your Personal Information may be transferred with the business or a part of it, or may be sold as an asset of the business, to the successor organization in such transaction. If material changes to the Company’s privacy practices will occur as a result of such transaction, you will be notified via prominent notice on our Sites of any change in ownership or uses of your Personal Information, as well as choices you may have regarding your Personal Information.

Termination of License Arrangements. Upon the expiration or a termination of any third party license arrangements involving one or more parts of our Sites or services, your Personal Information may be transferred to the subject third party licensor in accordance with the terms of the applicable license agreement. In advance of such transfer to a third party licensor, the Company will notify you and other users in writing in the manner described in this Privacy Notice.

Security. Your Personal Information, and communications you make within our Sites or when receiving our services, may be accessed and disclosed if we believe that our Sites or services are being used in the commission of a crime, when we believe in good faith that there is an emergency that poses a threat to the safety of you or another person and when necessary either to protect our rights or property including to enforce our Terms of Service, or for us to render the service you have requested.

Legally Required Disclosures. We may also disclose Personal Information when required by law, regulation or regulatory body, to a government agency or on receipt of a court order, or in response to a subpoena or litigation discovery request, or in the good faith belief that such action is necessary in order to conform to the edicts of the law or comply with a legal process served on us. In addition, we will make any legally required disclosures to government authorities.

Consent. We may also disclose Personal Information to another person with your consent.

C. Storage of Information and Security

Storage of Information and Security

We employ appropriate technical and organizational measures to protect the security of information we collect from you. Such information is housed in secure databases, equipment and servers located in the United States, Japan and United Kingdom. The databases, equipment and servers we utilize may be owned by third party providers. To prevent unauthorized access, loss, or misuse, maintain data accuracy, and ensure the appropriate use of information, we have put in place physical, electronic, and managerial procedures to safeguard and secure the information we maintain. We use industry-standard technology, such as firewalls, to protect the confidentiality of your Personal Information. Moreover, in addition to password protection offered in connection with your account, we encrypt your transmission of sensitive information to us via SSL (secured socket layer) protocol in the interest of heightened privacy protection and information integrity.

Although we take reasonable precautions against possible security breaches of our Sites, databases, equipment or servers, and records, we cannot guarantee that unauthorized access, hacking, data loss, or other security breaches and factors beyond our control will never take place and result in disclosure of your Personal Information. We strongly urge you to take reasonable measures at all times (online and offline) to protect your Personal Information.

In addition, while we strive to protect your Personal Information, you should know that information sent over the Internet, whether by e-mail or by using one of our on-line forms, is not necessarily secure against interception. Therefore, we cannot be responsible for such interception and cannot guarantee the security of such information.

We will investigate, attempt to resolve and take all reasonable steps necessary to ensure that your Personal Information and data is treated securely and in accordance with this Privacy Notice.

D. Your Privacy Rights

1. Marketing Opt-Out Provision

In addition to withholding your consent when requested and opting out, and subject to legal and contractual restrictions, you may withdraw your consent to allowing us to use and disclose your Personal Information for the purposes listed below at any time. You may do so by emailing us at support@saison-technology-intl.com and including your user ID or registered email address so that we can confirm your identity. We will use our commercially reasonable efforts to comply with your request. Please understand that withdrawing your consent may affect your ability to use certain features of our Sites.

(a) Receiving Marketing Communications from the Company. Receiving commercial electronic messages, including, without limitation, text and email messages, direct social media messages, announcements, newsletters and promotional materials or offers to participate in surveys, campaigns, contests or sweepstakes.

(b) Disclosing Personal Information to Affiliates. Our disclosure of your Personal Information to our Affiliates for marketing purposes.

(c) Disclosing Personal Information to Third Party Service Providers. Our disclosure of your Personal Information to authorized third party service providers for marketing purposes.

2. Your Rights

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Generally, you may review, update, correct or delete your Personal Information collected by or through our Sites by logging into your account. You may also be able to request information directly in accordance with your privacy rights.

Your California and Canadian Privacy Rights

Pursuant to the California Consumer Privacy Act and the California Privacy Rights Act (collectively, the “California Privacy Laws”), customers, prospective customers, and visitors to our Sites who are residents of the State of California have the right to request access to and the deletion and correction of their Personal Information that we have collected. Canadian federal and provincial laws provide a similar right of access.

If you are a resident of California or Canada and wish to request the above, please email us at support@saison-technology-intl.com with “California/Canadian Privacy Rights” in the subject line.

To exercise your rights to access, delete, or correct your Personal Information under the California Privacy Laws, please submit a verifiable consumer request to us.

Only you, a natural person, a person that you have authorized to act on your behalf who is registered with the California Secretary of State, or a person who has power of attorney or is acting as a conservator for you may make a verifiable consumer request in relation to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify that you are the person whose personal information we have collected or an authorized representative thereof; and
• Describe your request in sufficient detail to allow us to properly understand, evaluate, and respond thereto.

We will not discriminate against California residents for exercising any of their rights under the California Privacy Laws.
We take your privacy seriously and do not sell or share any of your personal information.
We collect Sensitive Personal Information (“SPI”) to provide our service for our customers and do not collect SPI for general marketing purposes.

We have not sold or shared any Personal Information in the preceding twelve (12) months. For the purposes of this Section, “selling” means disclosing your Personal Information to a third party for money or other valuable consideration, and “sharing” means disclosing your Personal Information to a third party for cross-contextual behavioral advertising, regardless of whether such sharing is provided for money or other valuable consideration.

Your EEA Privacy Rights

If you are a customer, prospective customer, or visitor from the EEA, you have the following data protection rights:

• If you wish to access, correct, update or request the deletion of your Personal Information, and you are not able to do so through logging onto your account, you can contact us using the contact details provided under the “Contact” heading below https://saison-technology-intl.com/contact/.
• In addition, you can object to processing of your Personal Information, ask us to restrict the processing of your Personal Information or request portability for your Personal Information. Again, you can exercise these rights by contacting us using the contact details provided under the “Contact” heading below https://saison-technology-intl.com/contact/.
• Similarly, if we have collected and process your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here

E. Additional Privacy Matters

1. Notification of Changes

We reserve the right to update and change the terms of this Privacy Notice at any time. If we decide to update and materially change the terms of our Privacy Notice, we will post those changes or on the applicable Sites, and in the updated Privacy Notice.

2. Links to Third Party Websites, Services and Offers

Our Sites may contain links to other websites, services and/or offers from third parties. We are not responsible for, nor will we be liable to you or any third party for, your interaction with such third parties or the information requests initiated by such third parties or the subsequent use, treatment or dissemination of the information (including any Personal Information) you voluntarily chose to provide to them. You should review the applicable privacy policies and information practices of such third parties carefully before providing Personal Information to them. Moreover, if you have any questions or concerns, you should contact the third party directly.

3. Protection of Children’s Privacy

Company is committed to providing special protection for the privacy of children who may use our Sites and services. Our Sites and services are not intended for nor directed to children under the age of 16 and we do not knowingly collect, use or retain Personal Information from such children. If we discover that we have inadvertently collected Personal Information from children under the age of 16, we will take all reasonable measures to delete any records of such Personal Information that come to our attention.

4. Special Note to Parents

If you become aware that your child has provided us with Personal Information, please notify us so that we may delete such information from our records and discontinue any related features or services (see Opt-Out Provision above). We also urge parents to instruct their children never to give out their real names, addresses or phone numbers without parental permission when using the Internet. We appreciate your cooperation in assisting us to provide a safe and enjoyable online experience for your children.

5. Users Outside United States

International Data Transfers

The Company is a U.S. company and Company’s U.S. business operations are primarily conducted in the State of California, U.S.A. We operate our company and administer this Privacy Notice under applicable U.S. and California laws and regulations. If you use our Sites or services from outside United States, your Personal Information will be transferred to, stored in and be processed in the United States, Japan and/or in other countries by the Company and/or its Affiliates in the manner described in this Privacy Notice. Please note that privacy laws of the United States and the State of California may differ from the laws in the country where you are located and may not provide you the same rights or protections for your Personal Information as those laws. However, we have taken appropriate safeguards to require that your Personal Information will remain protected in accordance with this Privacy Notice. These safeguards include implementing the European Commission’s Standard Contractual Clauses for transfers of Personal Information with our third party service providers and customers, which require all parties to protect personal information they process from the EEA in accordance with European data protection law. Further details can be provided upon request.

Legal Basis for Processing Personal Information (for customers, prospective customers, or visitors from the EEA)

If you are a customer, prospective customer, or visitor from the EEA, our legal basis for collecting and using the Personal Information described in this Privacy Notice will depend on the Personal Information concerned and the specific context in which we collect it.

We will normally collect Personal Information from you only (i) where we need the Personal Information to perform a contract with you, (ii) where the processing is in our legitimate interests, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect Personal Information from you.

If we collect and use your Personal Information in reliance on our legitimate interest or those of a third party, this interest will normally be to operate the Sites and perform the services, communicating with you as necessary to provide our services, improving our platform or for the purposes of detecting or preventing illegal activities.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided under the “Contact Us” heading below.

6. Information Retention and Deletion

We retain Personal Information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

7. Third-Party Processors

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information.

8. Language

The controlling language of this Privacy Notice is English. If you have received a translation into any other language, it has been provided for your convenience only. The English version of this Privacy Notice shall govern to the extent of any inconsistency between the English version and any translated version.

9. Do Not Track. We do not respond to DNT (Do Not Track) signals.

10. Contact Us

Contact Information

If you have any questions, inquiries, requests, complaints, or comments regarding this Privacy Notice, or have other questions or suggestions about our information practices, including our practices respecting the storage and processing of Personal Information please contact us via e-mail at Policy@saison-technology-intl.com.

Representative in the EU

Our representative in the EU is PLANIT // LEGAL Rechtsanwaltsgesellschaft mbH. You can contact our representative at “mail@planit.legal”.

Data Protection Officer

Our Data Protection Officer is Keith Sheridan. You can contact our Data Protection Officer at “dpo@saison-technology-intl.com”.

The Privacy Notice applies to all of the services we provide. By using our services, you acknowledge that you have read and fully understood this Privacy Notice. If you do not consent to the terms outlined in this notice, we may not be able to provide our services to you.

Copyright © 2024 Saison Technology International. All rights reserved.