This is the privacy policy (“Privacy Policy”) that governs how we, the funds of Hanaco (“Hanaco”, “we”, “our” or “us”), use Personal Information (defined below) that we collect, receive and store about individuals in connection with the use of the website www.hanacovc.com, and any other website that we operate (each, together with its sub-domains, content and services, a “Site”). This Privacy Policy also applies in connection with Personal Information we receive through the Site or other communication channels (such as, electronic, written or any oral communications). We have implemented this Privacy Policy because your privacy, and the privacy of other users, is important to us. This Privacy Policy explains our private information practices and the choices you can make about the way your Personal Information is collected and used in connection with the Site or other communication channels with Hanaco.

“Personal Information”. Means any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, a personal profile, an email address, a home or other physical address, telephone number, tax information, bank account details or other contact and/or financial information.

Terms of Use. This Privacy Policy is a part of our Terms of Use. Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in the Terms.

Consent and Modification. You are not legally obligated to provide us with Personal Information, and you hereby confirm that providing us with Personal Information is at your own free will. By using the Site or providing the Personal Information to Hanaco though other communication channels, you consent to the terms of this Privacy Policy and to our collection, processing and sharing of Personal Information for the purposes set forth herein. We reserve the right, at our discretion, to change this Privacy Policy at any time. Such change will be effective ten (10) days following posting of the revised Privacy Policy on the Site, and your continued use of the services thereafter shall mean that you accept such changes

What Personal Information We Collect:

1. We collect Personal Information from/or about Site users concerning use of the Site when you visit our Site and/or view our social media platforms (e.g., Facebook, Instagram, Twitter, LinkedIn).
2. We collect cookies, analytic tools and log files for the purpose of analytics, analysis, to provide you with information that is customized for you and to improve our Site.

   Cookies and Other Tracking Technologies

   . Our Site may utilize “cookies”, anonymous identifiers and other tracking technologies in order for us to present you with information that is customized for you. A “cookie” is a small piece of code that may be used to collect
   
   Google Analytics. The Site may use a tool called “Google Analytics” to collect information about usage of the Site. Google Analytics collects general usage information such as how often users visit this site, what pages are visited, and what other sites are visited prior to coming to this Site. We use the information we get from Google Analytics to maintain and improve the Site and our content. We do not combine the information collected through Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Optout Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/. 
3. When you subscribe to our newsletter: Hanaco may ask you to subscribe to our Newsletter. We collect your name and email address for the purpose of sending you Hanaco’s communications/Newsletter.
4. When you contact us: By submitting an online form that we make available or by sending an email to an email address that we display, you may be required to provide us with certain information such as your name and email address, company name and any other data you decide to provide us with for the purpose of receiving an answer to your question/s or any other communication you may have with Hanaco.
5. When you are an existing or potential portfolio company, an existing or potential investor, and other third party and provide us with Personal Information.

   If you are one of our existing or potential portfolio companies, you may send us basic contact information (including, names, surnames, job titles and benefits, email addresses and phone numbers) as well as documents and presentations related to the topic you would like to discuss with us, as well as other information which includes Personal Information. We will process such Personal Information for the purpose of maintaining our communication and business relations with you, to provide our services to you, to enter and/or perform any contractual rights and obligations under any agreement with you/our organizational and operational documents.

   If you are an existing or potential investor, we collect certain information such as your name, company name, email address, personal profile, home or other physical address, telephone number, tax status/forms, bank account details or other contact and/or financial information for the purpose of your admission to any of the funds of Hanaco, maintaining our communication and business relations with you, providing our services to you, entering and/or performing any contractual rights and obligations under any agreement with you/our organizational and operational documents or any other transaction that you are doing with Hanaco. We may ask you to complete questionnaires and/or other kinds of forms and any other information that you decide to provide us.

   As an existing investor, you will be added to our web portal for investors whereby you receive certain information regarding your investments in Hanaco funds. Please note that we work with service providers who assist us with the provision of such initiatives, and they may also be exposed to your Personal Information. By engaging in these initiatives, to the maximum extent permitted by law, you consent to the transfer of your Personal Information to such service providers. In such a case, Hanaco will use your Personal Information in accordance with this Privacy Policy.

   You only submit information which is relevant and accurate with respect to the topic you would like to discuss with us; Your Personal Information and other information you provide us with does not and shall not violate, breach or infringe any third party right or applicable law; You have displayed all the required privacy policies, and have all the required permissions from, all the relevant individuals mentioned in, or related to, the Personal Information or such other information to permit Hanaco to use the Personal Information and the information included therein in accordance with this Privacy Policy.

6. When you attend a marketing event and provide Personal Information; We will collect your full name, email address, company name, phone number, job position and any other data you decide to provide us with for the purpose of establishing a business connection and providing you with more information about Hanaco and its portfolio companies. We will use your Personal Information to send you marketing communications that we believe may be of interest to you and contact you in connection with certain programs or offerings that you may have registered for.
7. When you exchange business cards with us; We will collect your full name, email address company name, phone number, job position and any other data you decide to provide us for the purpose of establishing a business connection and providing you with more information about Hanaco and its portfolio companies. We will use your Personal Information to send you marketing communications that we believe may be of interest to you and contact you in connection with certain programs or offerings that you may have registered for. 

How We Use Personal Information – Purposes

In addition to the Personal Information and purposes described in each section above, we collect Personal Information and any other data you decide to provide us with for the purposes of:

• Compliance with any applicable law, regulation, legal process or governmental request including anti-money laundering and fraud prevention and compliance with applicable tax and regulatory reporting obligations;
• Compliance with our operational and organizational documents;
• Performing our day-to-day operational and business purposes including internal data analysis, risk management, training, record keeping, obtaining legal advice and internal compliance and policies;
• Providing you with information about Hanaco or any related services that might be of interest; 
• Communicating with you including responding to any queries, complaints or questions submitted to us; 
• To enable users to use the Site and its features, improve the quality of experience when you interact with our Site and identify you as a user on our Site;  
• Examining and analyzing any business offer or proposal you present to us, continue a business discussion and/or prepare or formalize a transaction with you as well as perform our agreements with you or any other relevant parties, or otherwise provide a service to you. Please note that even if any business information and/or proposal is dismissed or ignored at a certain point in time, we may store it for some time thereafter to consider potential business opportunities and for any other purpose as described in this Privacy Policy; and
• As may otherwise be required or permitted by applicable law.  

Information We Disclose

We generally do not disclose your Personal Information, we may however:

Share your Personal Information with our third-party service providers to comply with applicable law, regulation, legal process or governmental request, to comply with Hanaco’s agreements with its service providers in connection with such legal requirements, and to complete our business transactions. Such information may be transferred to other countries, according with applicable law.

Transfer your Personal Information to our funds, entities and/or affiliates for the purpose of storing or processing such information on our behalf in accordance with this Privacy Policy. Such information may be transferred to other countries, according with applicable law.

Disclose your Personal Information or any information you submitted through the Site or other communication channels if we have a good faith belief that the disclosure of such information is helpful or reasonably necessary to: (1) comply with any applicable law, regulation, legal process or governmental request; (2) enforce our Terms, including investigations of potential violations thereof; (3) detect, prevent, or otherwise address fraud or security issues; or (4) protect against harm to the rights, property or safety of Hanaco, our users, yourself or the public.

Transfer or assign your Personal Information in connection with any changes made to the structure of Hanaco or any of its funds, including by any merger, acquisition, reorganization, liquidation, dissolution, consolidation or any other corporate change.

We may use information which does not enable identification of an individual user, such as aggregated information about the use of our Site or disclose it to third party service providers in order to improve our Site and enhance your experience with the Site. We may also disclose such information (with or without compensation) to third parties, including advertisers and partners.

General Terms

Opting Out/deletion of Personal Information. You may choose not to receive future promotional, advertising, or other Site-related emails from us by selecting an unsubscribe link at the bottom of each email that we send. Please note that even if you opt out of receiving the foregoing emails, we may still send you a response to any “Contact Us” request as well as administrative emails that are necessary to facilitate your use of the Site. We will deal with all deletion requests in accordance with applicable law. We reserve the right to delete any information provided to Hanaco at our entire discretion.

Choice. At all times, you may choose whether or not to provide or disclose Personal Information. If you choose not to provide mandatory Personal Information, you may still visit parts of the Site, but you may be unable to access certain options, programs, offers, and services in connection with our interaction with you.

Access/Accuracy. To the extent that you do provide us with Personal Information, we wish to maintain accurate Personal Information. If you would like to delete or correct any of your other Personal Information that we may be storing, you may submit an access request by sending an email to gabi@hanacovc.com. Your email should include adequate details of your request. You may have certain rights under applicable law with respect to your Personal Information. These rights include: (i) the right to access and review your own Personal Information; (ii) to request that we rectify any information we hold about you that is inaccurate or misleading; (iii) the right to object, or to request restriction of the processing of your Personal Information; (iv) to request that decisions made about you that will not solely be based on processing by automated means; (v) to request to stop the processing of your Personal Information for direct marketing purposes; and (vi) a right to lodge a complaint with the applicable data protection supervisory authority. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority

Links to and Interaction with Third-Party Products. The Site may enable you to interact with, or may contain links to, other third-party websites, mobile software applications and services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third-Party Services. Please be aware that Third Party Services may collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third-Party Service that you choose to use or interact with.

Children’s Privacy. The Site is not structured to attract children under the age of 18 years. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 18 years. If we learn that we have collected Personal Information from a child under 18 years, we will generally delete that information as quickly as possible. If you believe that we might have any such information, please contact us at gabi@hanacovc.com.

Security. The security of Personal Information is important to us. We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect the Personal Information submitted to us. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use reasonable acceptable means to protect your Personal Information, we cannot guarantee its absolute security or confidentiality. If you have any questions about security, you can contact us at gabi@hanacovc.com.

Commitment. We are committed to protecting your privacy. Protecting your privacy online is an evolving area, and we are constantly updating our Service to meet these demands. If you have any comments or questions regarding our Privacy Policy, or your Personal Information that we may be storing and using, please contact us at gabi@hanacovc.com. Individuals who believe that their rights under the Data Protection Law, 2017 of the Cayman Islands have been infringed, have a right to complain to the Office of the Cayman Islands Ombudsman (https://ombudsman.ky).