Personal Information Handling

This statement sets out how HCT SYSTEMS JSC handles personal information. It is written to meet the disclosure expectations of Japan’s Act on the Protection of Personal Information (APPI) and Korea’s Personal Information Protection Act (PIPA), and complements our Privacy Policy.

1. Business operator

Name	HCT SYSTEMS JSC
Address	237A/08 Dũng Sĩ Thanh Khê, Phường Thanh Khê, Thành phố Đà Nẵng, Viet Nam
Representative	Representative Director
Personal information manager	Privacy Officer — privacy@hct-systems.com

2. Purposes of use

We use personal information only for the purposes below. We do not use it for any other purpose without first obtaining consent.

Category of person	Information	Purpose of use
Enquirers	Name, email, company, message content	Responding to the enquiry; sending requested information; keeping a record of the exchange
Client contacts	Name, email, telephone, role, company	Performing the services agreement; project communication; invoicing and support
Applicants	Details in an application	Assessing the application and communicating about it
Website visitors	IP address, user agent, country	Delivering the site; preventing abuse; aggregate traffic analysis; suggesting a language
Suppliers	Contact and payment details	Managing the supply relationship and payment

Where we handle personal information on behalf of a client as part of a project, the client determines the purpose of use. We act only on their documented instructions, and the terms of that handling are set out in the services agreement between us.

3. Method of acquisition

We acquire personal information:

• directly from you, when you submit a form, email us, or exchange details with us;
• automatically, from your interaction with this website (section 2, “Website visitors”);
• from a client, where the client entrusts us with data for a project.

We do not acquire personal information through deception, and we do not purchase personal information from data brokers.

4. Provision to third parties

We do not provide personal information to third parties except:

1. where you have consented;
2. where required by law;
3. where necessary to protect a person’s life, body or property and consent is difficult to obtain;
4. where we entrust handling to a service provider within the scope of the purposes above (section 5).

We do not engage in joint use of personal information, and we do not provide personal information to third parties for their own marketing.

5. Entrustment of handling

We entrust limited handling to the providers below, each under a written agreement that restricts use to our instructions and requires appropriate security measures. We supervise them accordingly.

Provider	Entrusted handling	Country
Cloudflare, Inc.	Hosting, content delivery, WAF, bot mitigation, aggregate analytics	Global edge network
Mailgun Technologies, Inc. (Sinch)	Delivery of contact-form notification email	United States
GitHub, Inc.	Source-code repository for this website	United States

6. Cross-border transfer

Personal information handled by us may be transferred outside your country, including to Viet Nam (where we operate) and to the countries listed in section 5.

Before transferring, we confirm that the recipient maintains a standard of protection equivalent to that required by the applicable law, through contractual commitments including standard contractual clauses. Information on the personal information protection systems of the destination countries is available on request from privacy@hct-systems.com.

7. Security control measures

We take organisational, personnel, physical and technical measures to protect personal information. These are described in our Security Policy.

8. Your rights

You may request disclosure, correction, addition, deletion, suspension of use, or suspension of provision to third parties in respect of your personal information. The procedure is set out in Retained Personal Data.

9. Voluntary nature of provision

Providing personal information to us is voluntary. However, if you do not provide the information marked as required on our contact form, we will not be able to respond to your enquiry.

10. Complaints

If you are dissatisfied with how we handle your personal information, contact privacy@hct-systems.com. You may also lodge a complaint with the supervisory authority in your jurisdiction — in Japan, the Personal Information Protection Commission; in Korea, the Personal Information Protection Commission.

11. Contact

HCT SYSTEMS JSC — Privacy Officer privacy@hct-systems.com 237A/08 Dũng Sĩ Thanh Khê, Phường Thanh Khê, Thành phố Đà Nẵng, Viet Nam