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This privacy policy ("Privacy Policy") governs the information collection, processing and usage practices of Hanon Systems ("the Company") in connection with the websites the Company operates or provides together with the Site (the "Services") in a controller capacity.

Hanon Systems regards the protection of users’ Personal Information as important, and complies with the provisions on protection of Personal Information pursuant to applicable laws and handle the Personal Information, collected, retained and processed according to the provisions in related laws, lawfully and appropriately to conduct business properly and to protect users' rights as data subjects.

This Privacy Policy details how users' Personal Information is used by Hanon Systems both actively and passively, when the users use the Site and Services. With this Privacy Policy, the Company intends to outline the basis on which any Personal Information is collected or provided, how it will be processed, including, what information may be collected via the Site and/or the Services, how it will be used and how it may be disclosed to third parties.

Generally speaking, Hanon Systems receives information because:

• The user has provided it to the Company; and/or
• It is collected by the Company from the user.

1. Questions About This Privacy Policy

Any questions or comments regarding privacy issues on the Site and/or the Services can be directed to privacy@hanonsystems.com.

2. Types of Information Collected

Hanon Systems collects both "Personal Information" and "Non-personal Information" about the Company’s suppliers, customers and visitors. Personal Information is information that can be used to contact or identify a user, such as full name, email address or phone number, as well as information that is linked to such information. "Non-Personal Information" is information that cannot be used to contact or identify a user, nor it is linked to any information that can be used to do so. It includes passively collected information about users' activities on the Site and/or Services or using Software, such as usage data, to the extent that information is not linked to Personal Information

3. Information Provided to the Company

Users may provide Personal Information to Hanon Systems in the following ways:

1. 3.1Account

   1. 3.1.1

      In order to use certain Services, users may be required to create an account ("Account") to access and conduct business using the Company’s Supplier Portal. In some cases, this can require or give the option to provide Personal Information, such as name and email address. In either case, Hanon Systems may send an email, text message, or other electronic message confirming the Account creation or otherwise instructing the user how to confirm the Account.

2. 3.2"Contact Us" Information

   Users seeking to contact the Company by submitting an online form or by sending an email to an address shown on a webpage, or by other means, may be required to provide the Company with certain information such as name and/or email address.

3. 3.3News, Surveys and Promotions

   The Site contains information about Hanon Systems including some of its products and services, financial information, news, and supplier and career opportunities. The Site also may offer users the opportunity to subscribe to receive information, participate in surveys and other promotional activities. User interaction (such as subscribing to receive news releases or investor information, expressing interest in becoming a supplier or in a career opportunity, or participating in a survey) may require certain Personal Information such as name and email address, together with any additional Personal Information the user chooses to provide to the Company.

4. Information the Company Collects from Users

Hanon Systems collects Personal Information and other non-Personal Information in the following ways:

1. 4.1Log Files; Device and Usage Data & IP address

   Hanon Systems collects information through server log files, but also by deploying tracking technologies within the Site and the Services that may associate this information with a user's Account. This is conducted to analyze trends, track user movement around the Site and Services, gather demographic information, and to generally collect information the Company may find insightful or helpful. The type of information collected may include (but is not limited to) internet protocol (IP) addresses (that may vary from session to session), MAC address, mobile network information including phone number, device type and hardware model, browser type, operating system type, type of browser, Internet Service Provider (ISP), date/time stamp of Site or Service use, referring/exit pages, and accessed pages. For example, the Site uses Google Analytics, more information on which you can find here: https://www.google.com/intl/en/policies/privacy/partners/.

2. 4.2Cookies

   In the interest of giving the Site an attractive appearance and in order to allow the use of certain functions, cookies are used on various pages of the Company’s Site. These are small text files stored on user’s computer. Most cookies are erased from the hard drive immediately after a browser session is closed ("session cookies").
   
   Other cookies remain saved to the computer's hard drive and enable the Company to recognize the computer in the event of later visits to the Site ("persistent cookies"). These cookies allow the Company to make the Site more user-friendly, effective and safe. The data collected through these files, for example, makes it possible to display information specifically suited personal preferences on a certain webpage. These cookies erase automatically after one year.
   
   The legal ground for processing cookie information consists of the execution of the agreement as well as of the Company’s rightful interest toward the safe and user-friendly presentation of this Site.
   
   For the same reason, the Site use cookies to distinguish individual users from others. Hanon Systems may use a cookie file, which is stored on the browser or hard drive of a computer and/or a mobile device, to obtain information about general Internet usage. Cookies contain information that is transferred to a computer's and/or mobile telephone device's hard drive, which enables companies to improve the Site and the Services. They
   enable Hanon Systems:
   
   

   • to estimate Hanon Systems' audience size and usage pattern and perform other analytics;
   • to store information about user preferences and so allow Hanon Systems to customize the Site and/or Services according to individual interests;
   • to continually improve the Company’s services; and
   • to recognize users when they return to the Site.

   
   Users may block cookies by activating the browser settings that allow users to refuse the setting of all or some cookies. However, selecting this setting may render the user unable to access certain sections/pages of the Site. Unless browser settings have been adjusted, it will refuse cookies. The Company’s system will issue cookies upon log in to the Site and/or use the Services or its Software. To learn more, visit http://www.aboutcookies.org/.
   
   The help function in the menu of most browsers explains how to prevent browsers from accepting cookies, how to signal to browsers to the reception of a new cookie and how to erase all collected cookies and block future cookies.
   
   Internet Explorer:
   

   1. 1.Select the item "Internet Options" from the "Extras" menu in the toolbar.
   2. 2.Select the "Privacy" tab.
   3. 3.Choose the safety settings for the Internet zone and select the cookies that are to be accepted or denied.
   4. 4.Select "OK" to confirm the settings.

   
   Firefox:
   

   1. 1.Select "Settings" from the toolbar.
   2. 2.Click "Privacy"
   3. 3.Select "Use custom settings for history" from the drop-down menu.
   4. 4.Select whether cookies are to be accepted and for what duration to store the cookies. Users also may add exceptions and determine the websites that are always or never allowed to store cookies.
   5. 5.Select "OK" to confirm these settings.

   
   Google Chrome:
   

   1. 1.Select the menu icon in the browser toolbar.
   2. 2.Select "Settings"
   3. 3.Select the link "Show advanced settings..."
   4. 4.Select "Content Settings..."
   5. 5.In the "Cookies" section, select from the following settings:
      
      • - Erase cookies
      • - Block cookies by default
      • - Erase cookies and website data by default after ending your browser session
      • - Accept exceptions for cookies from certain websites or website domains.

   
   
   In the event a computer has limited cookie settings, users will no longer have the ability to use all functions this Site to the fullest extent possible.
   
   Analysis Tools and Internet Technologies:
   The legal basis for the processing the data of users – along with collective analytical tools and Internet technologies – is the Company’s rightful interest toward an analysis of activities on the Hanon Systems website, and the user's and surfer's behavior on the Site, as well as the Company’s interest.
   
   Google Analytics
   This Site uses Google Analytics, a web analysis service provided by Google Inc. ("Google"). Google Analytics makes use of so-called "cookies" or text files stored on a user’s computer that allow an analysis of the visitor’s website usage. In principle, this information – as displayed by the cookie – is transferred and stored on the Google server in the U.S. The company activated a so-called IP anonymization on this website, which means that Google shortens the IP addresses from within EU Member States or from other EEA treaty states before they are exported to the U.S. server. Only in exceptional cases, the full IP address may be transferred to the U.S. Google server before it is shortened in the U.S.
   
   As instructed by this Site's operator, Google will use the information for the purpose of analyzing use of the Company’s Site, to compose reports on Site activities and to provide further services to the website's operator related to the use of the website and the Internet. The IP address transferred to users by the browser and that is shortened before storing for the purposes of Google Analytics will not be added to other Google data. Users can prevent the storage of the cookies through the applicable browser settings; however, we remind you that, in certain instances, users may not be able to use all functions of this Site to the fullest extent possible.
   
   More Internet Technologies
   This Site collects and stores information related to the visitor’s s' surfing conduct in an anonymized way, through the use of various Internet technologies. This data is in no way used to personally identify the visitor of a webpage. The data stored is only used to improve this Site. Therefore, all IP addresses are shortened and thus processed in an anonymous way. It is not used in a different way or disclosed to third parties.
   
   Users can generally revoke their consent for the collection, processing and the use of data by analytics or retargeting technologies commissioned by this website, with altering consequences for the future. It will save a cookie opt-out to the user’s device. This revocation will remain effective as long as the user does not erase this cookie.
   
   

3. 4.3Clickstream Data

   While browsing the Internet, a trail of electronic information is left at each website visited. This information, which is sometimes called "clickstream" data, can be collected and stored by a website's server. Clickstream data can tell companies the address of the website from which the user linked to the Company’s Site, and in some instances, the user’s email address. We may use clickstream data to determine how much time visitors spend on each page of the Site and how users navigate the Site. This information will only be used to improve the Site.

5. How Personal Information is Used

1. 5.1All of the ways in which the Company uses (or “processes”) Personal Information, as described below in this clause or elsewhere in this Privacy Policy, is based on one of the several legal conditions provided for under applicable data protection laws. Typically these will include:
   
   

   1. 5.1.1

      processing that is necessary for a contract by which the Company has entered or is entering with the user or another company

   2. 5.1.2

      processing that is based on the user's consent – for example, when users voluntarily provide the Company with contact information to respond to a query raised;

   3. 5.1.3

      processing that is within the Company’s legitimate interests as the operator of the Site and Services – for example, associating browser generated information with your Services so that we can tailor or improve the Services for you;

   4. 5.1.4

      processing that is necessary to comply with the company’s legal obligations;

   5. 5.1.5

      processing that is necessary to protect the company’s rights and interests.

2. 5.2In addition to the uses of Personal Information described elsewhere in this Privacy Policy, Hanon Systems also uses Personal Information in the following ways:
   
   

   1. 5.2.1

      To generally provide the user with the Services

   2. 5.2.2

      Hanon Systems will use Personal Information to:
      
      

      1. 5.2.2.1 administer and provide the Site and Services to users;
      2. 5.2.2.2 further develop and improve the Site and Services;
      3. 5.2.2.3 respond to communications with users;
      4. 5.2.2.4 offer customer support;
      5. 5.2.2.5 identify or authenticate access and use of the Site or a Service; and/or
      6. 5.2.2.6 send users news releases or investor information as requested by the visitor.

3. 5.3Transfer to Affiliates
   
   

   Hanon Systems may send or otherwise share Personal Information to/with the Company’s local or foreign subsidiaries or affiliates for the purpose of storing such information on the Company’s behalf, or carrying out other processing on the Company’s behalf. These entities may be located in other countries to Hanon Systems and servers supporting these entities may be located anywhere in the world. The Company requires these entities to agree to process such Personal Information in accordance with this Privacy Policy.

4. 5.4Transfer to Third Parties
   
   

   Hanon Systems sends or otherwise shares Personal Information to/with various third parties that help the Company conduct business operations and help the Company understand how users use the Site and Services for the purposes of Site development and improvement. Also, just as with the Company’s third party hosting providers, these third parties may be based – along with the server locations – anywhere in the world.
   
   The Services may not be hosted by the Company - all or some of the hosting is conducted by third party service providers under contract by the Company. This means that data provided by users or that the Company collects (including any Personal Information – information the Company can use either directly or indirectly – to identify a visitor as a natural person, is hosted by such third party service providers on servers owned or controlled by those third parties. Regardless of where such third party service providers are located those servers may be located anywhere in the world. Site visitor data may even be replicated across multiple servers located in multiple countries.

5. 5.5Merger, Sale or Bankruptcy
   
   

   In the event that Hanon Systems is acquired or merged with a third party entity, the Company may and hereby reserve the right to transfer or assign the Personal Information and other information the Company has collected or received. In the event of a bankruptcy, insolvency, receivership or some comparable event, the Company may not have control as to how user Personal Information is treated, transferred, assigned or used.

6. 5.6Enforcement
   
   

   The Company may send or otherwise share user Personal Information with any third party if the Company believes that disclosure of such information is helpful or reasonably necessary to: (a) comply with any applicable law, regulation, legal process, or governmental request; (b) enforce the terms of service/use governing the Site and/or Services, including investigations of potential violations thereof; (c) detect, prevent, or otherwise address fraud or security issues; and/or (d) protect against harm to the rights, property or safety of Hanon Systems including its subsidiaries and affiliates entities, other users, yourself or the public.

6. Aggregated Anonymous Information

"Aggregated Anonymous Information" is information the Company cannot use to contact or identify a visitor and is not linked to information that can be used to do so. It includes passively collected information about user's activities while using the Company’s Services or Software, such as usage data, to the extent that information is not linked to user's Personal Information.

7. Opt-Out Requests

Users may choose not to receive future emails by selecting an unsubscribe link on the Site or replying to the email itself. Duly note: opting out of receiving the foregoing emails, the Company may still respond to communications initiated by the user, as well as send administrative emails that are necessary to facilitate the use of the Site and/or Services (for example, emails confirming print completion).

8. Users Rights

Hanon Systems would like to maintain accurate Personal Information, and endeavors to comply with all rights users might have under data protection laws. In the event a user would like to delete, access or correct any Personal Information that may be stored, there may be tools available via the Services. Otherwise, contact the Company at privacy@hanonsystems.com to make the request by including adequate details. Hanon Systems will treat such requests in accordance with applicable laws.

9. Children’s Privacy

The Site and Services are not structured to attract children under the age of 13 years. Accordingly, Hanon Systems does not intend to collect Personal Information from anyone we know to be under 13 years. If the Company learns it has collected Personal Information from a child under 13 years,
Hanon Systems will use commercially reasonable efforts to delete that information as quickly as possible. If anyone that believes Hanon Systems might have such information, contact the Company at privacy@hanonsystems.com.

10.Job Applicants

Users submitting information in the form of a job application or CV/resume are by default agreeing that such Personal Information will be used as outlined in this Privacy Policy. Any visitor that does not wish for Personal Information to be used should not submit such information to Hanon Systems.

11.Security and Stability

Hanon Systems takes what the Company considers to be appropriate measures to protect Personal Information. However, no method of transmission over the Internet or method of electronic storage is 100 percent secure. As a result, the Company cannot guarantee its absolute security or confidentiality despite the Company’s efforts to use reasonably acceptable means to protect Personal Information of users. Hanon Systems cannot guarantee its absolute security or confidentiality. Questions about Site or Service security can be sent to the Company at privacy@hanonsystems.com.

12.Retention of User Personal Information

Hanon Systems shall retain user's Personal Information only for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws.

In principle, the Company will store user data as long as it is required to deliver the Services and for as long as the Company has the rightful interest toward saving it for an extended period of time (for instance, after fully executing a contract, the Company may still have a rightful interest toward the use of such data). Excluded from deletion is data required for the purpose of executing pending tasks where such data is required to realize the Company’s rights and claims, as well as certain data that must be stored for a legally mandatory extended period of time. When certain data is only saved due to a legally mandatory preservation term, the processing of such data by the Company is limited, even without the user's request.

13.Contact Hanon Systems

Hanon Systems has a team dedicated to handling inquiries related to protection of Personal Information. In the event of any questions or comments related to this Privacy Policy, contact the Company at privacy@hanonsystems.com.