HEX Group Companies (“HEX Group Companies,” “we,” or “our”; meaning the companies set out in the Locations page of the HANKYU HANSHIN EXPRESS Co., Ltd. website and HANKYU HANSHIN LOGIPARTNERS Co., Ltd.; the same applies hereinafter) comply with the applicable personal information protection regulations of each country and process the personal information of the officers, employees, and the like of customers and other similar trading partners of, job applicants for, and resignees from HEX Group Companies (collectively, “you,” unless specified otherwise) as follows.

In addition to this Global Privacy Policy for HEX Group Companies (this “Global Privacy Policy”), the following country-specific exhibit may also apply to you depending on the areas in which HEX Group Companies that process your personal information are located and the area in which you reside or are located, so please refer to the country-specific exhibit. If this Global Privacy Policy conflicts with the exhibit, then the exhibit will prevail to the extent that such conflict exists.

Exhibit: EEA (European Economic Area) and the UK

Exhibit: China

中国附件

With respect to the processing of the personal information of the officers, employees, and the like of the HEX Group Companies, we separately provide relevant persons with notifications, public announcements, or clear statements regarding that processing.

HEX Group Companies process the following personal information and other personal information HEX Group Companies have obtained in relation to business activities (we will obtain such personal information after separately notifying you if required by applicable laws and regulations).

HEX Group Companies process the following personal information of the officers, employees, and the like of customers and other similar trading partners of HEX Group Companies (including potential trading partners and persons who access our websites). ・Name, job title, date of birth, birthplace, address, postal code, telephone number, mobile phone number, fax number, e-mail address, most recent education, hobbies, prefecture of residence, marital status, and family structure of the officer, employee, or the like himself or herself ・Name and location of the corporation, division, branch office, or factory to which the officer, employee, or the like belongs ・Names of the officers of and information about the representative (name, date of birth, birthplace, address, postal code, type of residence, telephone number, most recent education, and hobbies) of the corporation to which the officer, employee, or the like belongs ・Other information stated on the business card of the officer, employee, or the like ・Sales negotiation histories and information regarding details of transactions (including details of products and services to which you subscribed, details of sales negotiations, and details of inquiries and estimates) ・ Name, division, title, and e-mail address of the person in charge of sales for HEX Group Companies ・Cookies, IP addresses, provider information, terminal information, web browser information, user activities (time of day when the website was visited, session length, frequency, transitions, traffic sources, clicks in the website, and scrolling in the website), attributes (such as age, gender, interest categories, affinity categories, and in-market segments; for more information about interest categories, affinity categories, and in-market segments, please see here (About Demographics and Interests - Analytics Help (google.com))

HEX Group Companies process the following personal information regarding each company’s job applicants.

・Name, address, telephone number, e-mail address, date of birth, gender, facial portrait, name of school, faculty and department, work experience, public qualifications and licenses, aptitude test results, school grades, job-hunting status, account number, work visa information, information on dependent family members, and language skills

HEX Group Companies process the following personal information regarding each company’s resignees.

・Name, address, date of birth, telephone number, e-mail address, gender, facial portrait, term of office, salary and remuneration, amount of retirement allowance and retirement bonus, account number, division transfer history, and staff code

HEX Group Companies process your personal information for the following purposes and other similar purposes permitted by applicable laws and regulations. In addition, HEX Group Companies may de-identify or aggregate your personal information.

・To confirm the details of the products and services to which you subscribed ・To confirm the existence, status, and the like of invoice and payment of usage fee of products and services to which you subscribed
・To provide products and services to which you subscribed and services associated therewith
・For communications with a customer regarding provision of products and services to which the customer subscribed
・To conduct various notifications and procedures for international transportation
・To respond to various inquiries, feedback, and requests
・To upgrade and improve existing products, services, and promotional activities and to develop new products and services (including upgrading, improvement, and development based on questionnaire surveys, market research, analysis of customer trends, and other such necessary analysis)
・To send announcements related to HEX Group Companies’ products and services
・For communications regarding sales negotiations and arrangements
・To share personal information with HEX Group Companies for the purposes stated in (3) of “8. Joint use of personal information” below ・For the security management of buildings and the like whose management falls under our responsibility
・To use your personal information for the smooth operation and improvement of the services provided in our websites such as by analyzing your information that we obtain when you access our websites

・For contacting, conducting employment screenings for, and sending notices regarding employment to, job applicants

・To respond to various inquiries from resignees

HEX Group Companies process your personal information in accordance with applicable personal information protection regulations. Please refer to the country-specific exhibit for details regarding our legal basis for processing in the country in question.

The provision of your personal information may be mandatory for various reasons, such as being a statutory or contractual requirement or being a necessary condition for entering into a contract. Specific details are as follows.

・The provision of your name (in Japanese and in English), job title, date of birth, birthplace, address, postal code, telephone number, mobile phone number, e-mail address, most recent education, hobbies, prefecture of residence, marital status, and family structure of the officer, employee, or the like himself or herself is a necessary condition for entering into a contract with HEX Group Companies. If you do not provide us with this personal information, you might not be able to use any products or services of HEX Group Companies.
・The provision of your sales negotiation histories and information regarding details of transactions (including details of products and services to which you subscribed, details of sales negotiations, and details of inquiries and estimates) is necessary condition for inquiries and requests for estimate. If you do not provide us with this personal information, HEX Group Companies might not be able to answer inquiries or provide estimates.
・The provision of information such as cookies that are strictly required for the use of HEX Group Companies’ websites and user activities obtained by those cookies, IP addresses, and types of web browsers is necessary condition for using our websites. If you do not provide this information, you might not be permitted to use our websites.
・In any other case where you do not provide us with your personal information despite the fact that the provision of that personal information is a necessary condition, HEX Group Companies might not be able to provide you with products, services, or the like of HEX Group Companies (including our websites).

・The provision of your name, address, telephone number, e-mail address, date of birth, gender, facial portrait, name of school, faculty and department, work experience (only for mid-career recruitment), public qualifications and licenses, aptitude test results, school grades (only for recruitment of new graduates), job-hunting status, account number, work visa information, information on dependent family members, and language skills may be become necessary condition for applying for employment. If you do not provide us with this information, you might not be permitted to participate in the recruitment activities of HEX Group Companies.

・The provision of your name, address, telephone number, e-mail address, date of birth, gender, facial portrait, term of office, salary and remuneration, amount of retirement allowance and retirement bonus, account number, division transfer history, and staff code may become necessary condition for various inquiries. If you do not provide us with this information, we might not be able to respond to various inquiries.

In order to decide the appropriate retention period for personal information, HEX Group Companies consider the following: the volume, nature, and confidentiality of the personal information; the potential risk of damage caused by unauthorized use or disclosure of the personal information; the purposes for which HEX Group Companies process the personal information, and whether HEX Group Companies can achieve those purposes by other means; and applicable legal requirements. If your personal information collected by HEX Group Companies becomes no longer necessary, HEX Group Companies will delete or anonymize your personal information, or if such measures are impracticable (for example, if your personal information has been stored in back-up archives), we will retain your personal information safely until its deletion becomes practicable and ensure that any new processing will not be conducted with respect to your personal information.

HEX Group Companies obtain your personal information directly from you (including in cases where personal information is obtained automatically). However, we may obtain your personal information indirectly from a third party other than you in the following cases.

・Other companies within HEX Group Companies (who provide information stated in (1) of “8. Joint use of personal information” below)
・Website traffic analysis service providers, such as Google LLC (who provide Cookies, IP addresses, provider information, terminal information, web browser information, user activities, attributes)

・Recruitment support service providers, such as Mynavi Corporation ・Career change support service providers such as Recruit Co., Ltd. and PERSOL TEMPSTAFF CO., LTD (who each provide information about the services they have provided to you).

HEX Group Companies shares and discloses personal information set out in “1. Categories of personal information subject to processing” above to third parties in order to fulfil the purposes set out in “2. Purpose of processing” above, in the following cases, if it is necessary to comply with laws and regulations or the like (Note 1), and in any other similar cases (Note 2).

（Note 1）In some instances, HEX Group Companies may be required to share or disclose your personal information to public and governmental authorities within or outside your country of residence in accordance with law and/or requests from such authorities. HEX Group Companies might also share or disclose your personal information if sharing or disclosure is necessary or appropriate, due to the purposes of law enforcement or handling other issues of public importance. HEX Group Companies might also share or disclose your personal information if sharing or disclosure is reasonably necessary to protect HEX Group Companies’ rights, to pursue available remedies, to enforce HEX Group Companies’ terms of use, to investigate fraud, or to protect the HEX Group Companies’ operations or you.

（Note 2）In any other cases, HEX Group Companies may also share your personal information with or disclose your personal information to a third party, including:
・When personal information is shared or disclosed as part of a corporate sale, merger, or acquisition, or other transfer of all or part of our assets, including as part of a bankruptcy proceeding; ・Cases in which there is a need to share or disclose your personal information in order to protect a human life, body or fortune of a third party or HEX Group Company and it is difficult to obtain your consent; ・With your consent;
・Other cases permitted under applicable personal information protection regulations of each country.

Please refer to “8. Joint use of personal information” below in the case of third-party provision on the grounds of joint use under the Personal Information Protection Act of Japan.

○Sharing with and disclosure to HEX Group Companies, etc.
・HEX Group Companies may share personal information with or disclose personal information to other companies within HEX Group Companies

○Sharing with and disclosure to processors (service providers)
・Sales support service providers, such as Microsoft Ireland Operations Limited
・International logistics management service providers, such as Wise Tech Global Limited
・Business card information management service providers, such as Yamato System Development Co., Ltd.
・Website traffic analysis service providers, such as Google LLC
・Other contractors that provide services necessary for the business activities of HEX Group Companies

○Sharing with and disclosure to processors (service providers)
・Contractors that provide services necessary for the business activities of HEX Group Companies

○Sharing with and disclosure to processors (service providers)
・Salary and retirement allowance related processing support service providers, such as Hankyu Hanshin Business Associate Co., Ltd.
・Corporate pension management service providers, such as Sumitomo Mitsui Banking Corporation
・Other contractors that provide services necessary for the business activities of HEX Group Companies

As a result of sharing and disclosure pursuant to “6. Sharing and disclosure of personal information” above, your personal information may be transferred to the following countries:

・United States
・Canada
・Mexico
・Brazil
・Germany
・United Kingdom
・Netherlands
・Italy
・France
・Belgium
・Czech Republic
・Russia
・United Arab Emirates
・South Africa
・Kenya
・Japan
・Hong Kong
・Taiwan
・China
・South Korea
・Singapore
・Thailand
・Philippines
・Malaysia
・Indonesia
・Vietnam
・India
・Myanmar
・Cambodia
・Bangladesh

Upon transferring personal information to any of the countries listed above, HEX Group Companies take appropriate protection measures required by the personal information protection regulations of that country. For protection measures in the country in question, please refer to the country-specific exhibit.

HEX Group Companies jointly use personal information related to officers, employees, and the like of customers and other similar trading partners with specified persons on the grounds of joint use under the Personal Information Protection Act of Japan as follows. However, if your consent is required under applicable personal information protection regulations other than the Personal Information Protection Act of Japan, we will obtain your consent.

・Name (in Japanese and in English), job title, date of birth, birthplace, address, postal code, telephone number, mobile phone number, fax number, e-mail address, most recent education, hobbies, prefecture of residence, marital status, and family structure of the officer, employee, or the like himself or herself
・Name and location of the corporation, division, branch office, or factory to which the officer, employee, or the like belongs
・Names of the officers of and information about the representative (name, date of birth, birthplace, address, postal code, type of residence, telephone number, most recent education, and hobbies) of the corporation to which the officer, employee, or the like belongs
・Other information stated on the business card of the officer, employee, or the like
・Sales negotiation histories and information regarding details of transactions (including details of products and services to which you subscribed, details of sales negotiations, and details of inquiries and estimates)

HEX Group Companies

・To analyze and improve existing products, services, and promotional activities and to develop new products and services
・To provide products and services to which you subscribed and services associated therewith
・To confirm the existence, status, and the like of invoice and payment of usage fee of products and services to which you subscribed
・For communications with a customer regarding provision of products and services to which the customer subscribed
・To conduct various notifications and procedures for international transportation

HANKYU HANSHIN EXPRESS Co., Ltd. (For the address of HANKYU HANSHIN EXPRESS Co., Ltd. and name of its representative, please see Corporate Data.)

HEX Group Companies will take necessary and appropriate measures such as countermeasures against unauthorized access and countermeasures against computer viruses to prevent loss, destruction, falsification, leaking, and the like of personal information.

HEX Group Companies will exercise necessary and appropriate supervision over employees of HEX Group Companies, and contractors, etc. to protect personal data.

If you access our websites and when you activate cookies, etc. (including tracking technologies such as Flash Cookie and web beacon and any other technologies; “Cookies, Etc.”), we may obtain automatically information regarding PCs, mobile devices, tablets, and any other telecommunication units that you used. If HEX Group Companies obtain such information, we will handle the information as personal information. If you prefer to avoid the use of Cookies, Etc., you may change the settings in your web browser so that Cookies, Etc. are disabled.

Cookie 設定

○ Regarding the use of Google Analytics HEX Group Companies may work with third parties that collect data about your use of our websites over long periods of time. For example, the system may use Google Analytics for analytics and marketing purposes. With Google Analytics, customer information is collected using cookies, etc. For more information about how Google Analytics collects and uses information when you use our websites, please visit www.google.com/policies/privacy/partners. To opt out of Google Analytics, please visit tools.google.com/dlpage/gaoptout.

Our websites may provide you with links to websites or applications of third parties other than HEX Group Companies. We do not manage the handling of personal information by those websites or applications which are not covered by this Global Privacy Policy. You need to confirm the privacy policy of other websites or applications that you intend to use to know how those websites or applications handle personal information.

HEX Group Companies respect the rights you hold under the applicable personal information protection regulations of each country. For example, the Personal Information Protection Act of Japan grants the right to request the following in relation to retained personal data (meaning retained personal data prescribed in Article 16, paragraph 4 of the Personal Information Protection Act of Japan): notification of the purpose of use; disclosure; correction, addition, or deletion of content; suspension of use, erasure, or suspension of third-party provision; and disclosure of records of third-party provision (meaning third-party provision prescribed in Article 37, paragraph 2 of the Personal Information Protection Act of Japan). For rights granted under the personal information protection regulations of the country in question, please check the country-specific exhibit. If you wish to exercise your rights granted under the personal information protection regulations of the country in question, please contact us using the contact details stated in “13. Contact details” below.

For questions and inquiries regarding this Global Privacy Policy, please contact us using the contact details below:
HANKYU HANSHIN EXPRESS Co., Ltd.
　General Affairs & Human Resources Div.
　Address: KHD Tokyo Building 9th Floor, 3-3-9, Shinbashi, Minato-ku, Tokyo, 105-0004
　Telephone number: 03-6745-1451
　Office hours: 10:00 a.m. - 5:00 p.m. (closed on Saturdays, Sundays, and national holidays)

Please check Corporate Data for the address of HANKYU HANSHIN EXPRESS Co., Ltd. and the name of its representative.

If HEX Group Companies intend to amend this Global Privacy Policy (including the country-specific exhibit), we may amend all or part of, or make an addition to, this Global Privacy Policy by publishing that amendment or addition on our websites, sending an e-mail to that effect to our customers, or giving notice by any other method that HEX Group Companies deem appropriate (subject to applicable laws and regulations, if any). In such a case, the post-amendment version of this Global Privacy Policy will be applied from the earlier of the date on which you use a product or service of HEX Group Companies or access our websites for the first time after receiving such notice, or the date stated in such notice. If there are any necessary procedures under personal information protection regulations that are to be applied, such procedures will be taken.

Last update：April 1 , 2023

This Exhibit (a) applies to the processing of your personal information by HEX Group Companies if you are located or residing in the EEA (European Economic Area) or the UK, (b) applies to the processing of your personal information by HANKYU HANSHIN EXPRESS CO., LTD. (including REPRESENTATIVE OFFICE MILANO (Italy)), HANKYU HANSHIN EXPRESS (DEUTSCHLAND) GMBH (including PRAGUE office), HANKYU HANSHIN EXPRESS (UK) LTD., or HANKYU HANSHIN EXPRESS (NETHERLANDS) B.V. (including BRUSSELS office and PARIS office), and (c) refers to the GDPR and the UK GDPR (collectively, the “GDPR”).
This Exhibit includes information about your data protection rights, including a right to object to some of the processing which HEX Group Companies carries out. More information about your rights, and how to exercise them, is set out in “3.Your rights” below.

HEX Group Companies process your personal information pursuant to the following legal basis for the purposes stated in “2.” (Purpose of processing) of this Global Privacy Policy.

We may sometimes obtain consent from a customer in regard to that customer’s personal information, but even in this case the legal basis for processing are as stated in “When processing is necessary for the performance of a contract,” “When processing is necessary for pursuit of legitimate interests,” or “When processing is necessary for compliance with a legal obligation,” except where stated in “When we obtain consent to the processing from customers in advance (GDPR Article 6, Paragraph 1, Item (a))” below.

HEX Group Companies engage in direct marketing to customers upon consent from such customers if required under laws and regulations.

○When processing is necessary for the performance of a contract (GDPR Article 6, Paragraph 1, Item (b))

・To confirm the details of the products and services to which you subscribed
・To confirm the existence, status, and the like of invoice and payment of usage fee of products and services to which you subscribed
・To provide products and services to which you subscribed and services associated therewith
・For communications with a customer regarding provision of products and services to which the customer subscribed
・To conduct various notifications and procedures for international transportation
・To respond to various inquiries, feedback, and requests

○When processing is necessary for pursuit of legitimate interests (GDPR Article 6, Paragraph 1, Item (f))*

・To upgrade and improve existing products, services, and promotional activities and to develop new products and services (including upgrading, improvement, and development based on questionnaire surveys, market research, analysis of customer trends, and other such necessary analysis)
・To send announcements related to HEX Group Companies’ products and services
・For communications regarding sales negotiations and arrangements
・To share personal information with HEX Group Companies for the purposes stated in (3) of “8. Joint use of personal information” in the Global Privacy Policy
・For the security management of buildings and the like whose management falls under our responsibility
・To use your personal information for the smooth operation and improvement of the services provided in our websites (except if the basis for processing is consent from customers as stated below)

○When we obtain consent to the processing from customers in advance (GDPR Article 6, Paragraph 1, Item (a))

・To analyze your information that we obtain by Cookies that is not required strictly when you access our websites and use such information for the smooth operation and improvement of the services provided in our websites

○When processing is necessary for pursuit of the legitimate interests (GDPR Article 6, Paragraph 1, Item (f))*

・For contacting, conducting employment screenings for, and sending notices regarding employment to, job applicants

○When processing is necessary for the pursuit of legitimate interests (GDPR Article 6, Paragraph 1, Item (f))*
・To respond to various inquiries from resignees

*For details of the balancing test for legitimate interests (GDPR Article 6, Paragraph 1, Item (f)), please contact us using the contact details stated in “4. Contact details of representatives and data protection officers” below.

If HEX Group Companies transfer personal data to areas other than the EEA (European Economic Area) or the UK, HEX Group Companies (i) will be based on an adequacy decision (GDPR Article 45) in the countries where the adequacy decision is adopted or (ii) will take appropriate protection measures by executing the standard data protection clauses approved by the European Commission (GDPR Article 46, Paragraph 2, Item (c) and Paragraph 5) or the standard data protection clauses approved by ICO (UK GDPR Article 46, Paragraph 2, Item (d)) with the party receiving personal data in the countries where an adequacy decision is not adopted. Please contact the contact address stated in “4. Contact details of representatives and data protection officers” below if you wish to receive a copy of the documents relating to those protection measures.

HEXグループ各社が十分性認定に依拠して個人データを移転する国は、以下のとおりです。

The countries to which HEX Group Companies transfer personal data based on adequacy decisions are as follows:
・Canada (For details of adequacy decisions, please see here.)
・UK (For details of adequacy decisions, please see here.)
・Japan (For details of adequacy decision, please see here.)
・South Korea (For details of adequacy decisions, please see here.)

You have the following rights.

・Obtaining information regarding data processing: You have the right to obtain from us all necessary information regarding our processing of data concerning you (GDPR Article 13 and Article 14).
・Access to personal information: You have the right to obtain confirmation from us as to whether personal information concerning you is being processed, and, where that is the case, to access the personal information and certain relevant information (GDPR Article 15).
・Rectification and erasure of personal information: You have the right to have us rectify inaccurate personal information concerning you without undue delay and have incomplete personal information completed by us (GDPR Article 16). You also have the right to have us erase personal information concerning you without undue delay when certain conditions are met (GDPR Article 17).
・Restricting processing of personal information: You have the right to restrict our processing of personal information concerning you when certain conditions are met (GDPR Article 18).
・Objection to processing of personal information: You have the right to object to our processing of personal information concerning you when certain conditions are met (GDPR Article 21, Paragraph 1).
・Objection to direct marketing: You have the right to object at any time to our processing of personal information for direct marketing (GDPR Article 21, Paragraph 2).
・Personal information portability: You have the right to receive personal information concerning you in a structured, commonly used, and machine-readable format and to transmit that data to another controller without hindrance from us, when certain conditions are met (GDPR Article 20).
・Right to withdraw your consent: You have the right to withdraw your consent at any time by the means separately specified at the time we obtain your consent. However, your withdrawal of consent does not affect the lawfulness of processing conducted based on your consent before the withdrawal.
・Freedom from automated decision-making: When certain conditions are met, you have the right not to be subject to automated (meaning without human involvement) decision-making that produces legal effects or significant effects on you (GDPR Article 22).
・Regarding our processing of your personal information, you may lodge a complaint with the relevant data protection supervisory authority of the member state where your habitual residence, your place of work, or the place of the alleged infringement, is located (GDPR Article 77).

The contact details of representatives of HEX Group Companies and data protection officers of HANKYU HANSHIN EXPRESS (DEUTSCHLAND) GMBH (including PRAGUE office) are as follows.

・Representative in the EEA
HANKYU HANSHIN EXPRESS (DEUTSCHLAND) GMBH
Cargo City Sued, Geb. 570, 60549 Frankfurt am Main, Germany
TEL : +49-69-96-86-41-0

・Representative in the UK
HANKYU HANSHIN EXPRESS (UK) LIMITED
670 Spur Road, North Feltham Trading Estate, Feltham, Middlesex, TW14 0SL, U.K
TEL : +44-1753-686-116

・Data protection officer
Atsumi & Sakai Frankfurt　Mr. Frank Becker
OpernTurm, Bockenheimer Landstrasse 2-4 60306 Frankfurt am Main
frank.becker@aplaw.de

Last update：April 1 , 2023