Privacy policy
Introduction
Koeeru Global Inc. (hereinafter referred to as "Koeeru Global") attaches great importance on
the protection and security of your personal data, sensitive (special categories) personal dataand non-personal data.
Therefore, Koeeru Global strives to devote its attention to and protect the privacy of eachdata subject. Staying worthy of the trust of a data subject in Koeeru Global is what Koeeru
Global ought to achieve as a matter of its responsibility by putting utmost efforts on a daily
basis to yield the trust.
The steps taken by Koeeru Global in the field of privacy, the state of compliance with the Act
on the Personal Information Protection (Year 2003 Law No.57)(hereinafter referred to as the"Personal Information Protection Law") and other applicable laws in and outside of Japan,
and important information that a data subject needs to know when using the platform,
solution, systems, services and websites of Koeeru Global.
Definitions No. 1“Koeeru group of companies” / “Koeeru ” all references in this Privacy policy to Koeeru Global
include Koeeru Global and its parent, subsidiary and affiliated companies. All references to“us” or “we” refer to Koeeru, including but not limited:
Koeeru Inc. (Koeeru), a company incorporated and operating pursuant to the legal
Koeeru Global Inc. (Koeeru Global), a company incorporated and operating pursuant to thelegal
Koeeru LLC. (Koeeru Vietnam), a company incorporated and operating“Koeeru systems and platforms” means all the Koeeru systems and platforms and services
which are provided by Koeeru, to natural or legal persons, i.e. clients, users, respondents,
panellists, website visitors, other parties, third-parties and etc.
“Services” means services of Koeeru systems and platforms which are provided by Koeeru tonatural or legal persons, i.e. clients, users, respondents, panellists, website visitors, otherparties, third-parties, etc.
“Day” means any business day, which is not Saturday or Sunday or national holiday.
Definitions No. 2“Personal data” means any information relating to an identified or identifiable natural person(“data subject”); an identifiable natural person is one who can be identified, directly orindirectly, in particular by reference to an identifier such as a name, an identification number,
location data, an online identifier or to one or more factors specific to the physical,
physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Special categories of personal data” means sensitive personal data revealing racial or ethnic
origin, political opinions, religious or philosophical beliefs, or trade union membership, andgenetic data, biometric data for the purpose of uniquely identifying a natural person, data
concerning health or data concerning a natural person’s sex life or sexual orientation.
“Non-personal data” means any information and data which is not personal data, and fromwhich it is not possible to identify a data subject.
“Processing” means any operation or set of operations which is performed on personal dataor on sets of personal data, whether or not by automated means, such as collection, recording,organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use,
disclosure by transmission, dissemination or otherwise making available, alignment or
combination, restriction, erasure or destruction.
“Data subject” means an individual person whose personal data and special categories of
personal data was processed / is processed / will be processed by a data controller and / ordata processor.
“Data controller” means:
Koeeru or any of company which belongs to Koeeru indicated in Section “Definitions No. 1”
in definition “Koeeru”;
Natural or legal person, which orders services of Koeeru systems and platforms, and which,alone or jointly with others, determines the purposes and means of the processing of personaldata, and who receives and processes personal data in Koeeru systems and platforms inindividual cases when Koeeru helps / doesn`t help to process personal data.
“Data processor” means:a natural or legal person, public authority, agency or other body which processes personal data
on behalf of the data controller (Koeeru). Currently Koeeru uses below indicated dataprocessors which help to process personal data:
Amazon (AWS) https://aws.amazon.com/ (server provider)Interneto vizija https://klientams.iv.lt/ (server provider)
Google https://www.google.com/ (service provider)
Microsoft https://www.microsoft.com/ (service provider)
Koeeru or any of the company which belongs to Koeeru indicated in Section “Definitions No.
1” in definition “Koeeru” which processes personal data on behalf of the data controller, when
the data controller orders services of Koeeru systems and platforms.
“Consent of the Data subject” means any freely given, specific, informed and unambiguousindication of the data subject’s wishes by which he or she, by a statement or by a clear
affirmative action, signifies agreement to the processing of personal data relating to him or
her.
“Personal data breach” means a breach of security leading to the accidental or unlawfuldestruction, loss, alteration, unauthorised disclosure of, or access to, personal datatransmitted, stored or otherwise processed.
“General data protection regulation” means Regulation (EU) 2016/679 of the European
Parliament and of the Council of 27 April 2016 on the protection of natural persons withregard to the processing of personal data and on the free movement of such data, andrepealing Directive 95/46/EC (“GDPR”).
Information we collect
When a data subject visits Koeeru websites, Koeeru collects and stores information about thedata subject, data subject`s computer and / or device. More about this you can read in Cookies
policy on https://www.Koeeruintcdn.com/cookies-policy/. Basically, Koeeru collects: IP
address, the website from which you access our website, http answer code, data and time ofaccess, etc.
Personal data about Koeeru employees: e-mail, telephones No., name, surname, postal code,
date of birth, country, address, gender, bank account details, wage, CV (curriculum vitae),
photos, payments details, education data, holidays, etc. Personal data about data subjects, who
apply to open positions in Koeeru (https://www.Koeeruintcdn.com/job-career/): e-mail,telephones No., name, surname, postal code, date of birth, country, address, gender, CV(curriculum vitae), motivational letter, education data, experience data, hobbies, other skills,
etc.
Non-personal data – metadata (data / information that provides information about otherdata), when the data subject uses Koeeru websites or services, such as: status, creation date
and time, last modification date and time, files names, type, size, various identifiers, etc.
Personal data when data subject contacts Koeeru: name, e-mail, request, message content,
consents, etc.
When Koeeru conclude business (cooperation) relations, orders or agreements, Koeeru
processes: company name, address, registration number, e-mail, bank account details,
telephone No., VAT No., addresses of company`s websites, details of payments, data on
services provided, name and surname of authorized representative, signatures, etc.
When a data subject (if it is legal person) creates an account (including cases when Koeeru
creates an account by data subject request) to use services of Koeeru systems and platforms
or apply for the provision of other services, Koeeru might collect: e-mails, telephone No., user

names, passwords, company’s name, addresses, registration number, bank account details,
VAT No., addresses of company`s websites, details of payments, data on services provided,
postal code, data about company’s employees, contact data of company`s data protection
officer, contact data of company`s representative, signatures, etc.
When a data subject (if it is natural person) creates an account (including cases when Koeeru
creates an account by data subject request) to use services of Koeeru systems and platforms
or apply for the provision of other services, Koeeru might collect: e-mail, telephone No., user
name, password, name, surname, postal code, date of birth, country, address, gender, bankaccount details, etc.
Personal data when data subjects (such as panellists, respondents and others users andmembers), register to participate in Panels, Surveys, market research, public opinion polls
and other market research activities: user name, password, e-mail, gender, age, postal code,
country, phone number.
Personal data and special categories of personal data when data subjects (such as panellists,
respondents and others) respond to Koeeru questionnaires: region where work, type of work,
shopping habits, travels, data about education, political view, religion view, health, languages,
etc.
When data subject participates in rewards systems and intends to get rewards, Koeeru
processes: e-mail, name, surname, bank details, user name, passwords, number of projects
that they participated in, etc.
Information about the operations and services performed with Koeeru systems and platforms
and other Koeeru products, such as: what services have been used, how much time, for what
purpose, etc.
Purposes for which we process information
Koeeru processes personal data, sensitive (special categories) personal data and non-personal
data for purposes of:Market and public opinion research;
Customers and consumer’s insights;
Loyalty and rewards programs;
Provide statistical information;
Provide data collection, processing and reporting solutions;
Submitting the best deals and get acquainted with Koeeru services;
Administer and manage agreements, orders, projects, other documents, services, etc.;
Implementation the requirements and provisions of the legislation;
Quality control purposes of performed services by Koeeru.

Period of storage of information
Koeeru stores your personal data, sensitive (special categories) personal data and nonpersonal data for no longer than it is required by the data processing goals or is stated in legal
regulations if there is a longer data duration provisioned. We aim not to store outdated orirrelevant information and ensure that personal data and other information would be updated
consistently and correctly.
The term of data storage may be from 1 (one) to 10 (ten) years, unless the law specifies and/ or is agreed otherwise.
For example:
Koeeru stores personal data about data subjects, who apply to open positions up to 1 (one)year, unless agreed otherwise;
Koeeru stores personal data about Koeeru employees up to 10 (ten) years, unless agreed
otherwise;
When data subject creates an account to use services of Koeeru systems and platforms, Koeeru
stores this data usually 3 (three) years, unless agreed otherwise, etc.
Koeeru periodically reviews all stored data and makes sure that inaccurate or out-of-date data
is not processed.
Use of personal data of minors
The website of Koeeru, the services of systems or platform and other services of Koeeru are
not intended for persons under 16 years of age.
Koeeru complies with the Act on the Personal Information Protection and other laws of Japan
and, to the extent necessary, the General Data Protection Regulation.
Therefore, according to the position taken by Koeeru, persons who are under 16 years of age
are not permitted to have access to the website of Koeeru or use the services of Koeeru.
At Koeeru, the information and data from/about persons under 16 years of age are notcollected. Those persons under 16 years of age who wish to have access to the website of
Koeeru or wish to use the services or other activities of Koeeru must present the consent andpermission of their guardians and fulfill the other requirements stipulated in the Act on the
Personal Information Protection ( and, to the extent necessary, the General Data Protection
Regulation).
In the event of the revelation that a person under 16 years of age has inappropriately provided
information to Koeeru, the incident will be notified from Koeeru to the guardians or legal
representatives of such person under 16 years of age, and the personal information of theperson under 16 yeras of age will be deleted from the records of Koeeru.

Legal grounds for using your personal data
Koeeru shall use your personal data only where we have a legal ground to do so. We determine
the legal grounds based on the purposes for which we have collected and used your personal
data. In every case, the legal ground will be one of the following:"Consent by data subject: for example, where you have provided your consent to create an
account to use services of Koeeru systems and platforms. You can withdraw your consent at
any time.
"
Legitimate interest of Koeeru: A case in point is when any need arises to ascertain the qualityof the services. For instance, we have a legitimate interest for an analysis of which services areused by the data subjects. Koeeru has a legitimate interest to determine which of the services
is likely to catch the attention of the clients or the customers, etc. Also, in order to comprehend
the ways the website of Koeeru is used, Koeeru analyzes which ones of the contents of its
website are looked at.
Performance of a contract / agreement with you (or in order to take steps prior to entering
into a contract with you): for example, Koeeru offers services and you are going to pay fees
for services. For this we need to use your contact details, etc..
Implementing other contracts and agreements under which personal data are processed.
Compliance with law: in some cases, we may have a legal obligation to use or keep yourpersonal data.
Principles of data processing
Koeeru ensures that personal data, sensitive (special categories) personal data and nonpersonal data shall be:processed lawfully, fairly and in a transparent manner in relation to the data subject(‘lawfulness, fairness and transparency’);"collected for specified, explicit and legitimate purposes and not further processed in amanner that is incompatible with those purposes (‘purpose limitation’);accurate and, where necessary, kept up to date; every reasonable step must be taken to ensurethat personal data that are inaccurate, having regard to the purposes for which they areprocessed, are erased or rectified without delay (‘accuracy’);adequate, relevant and limited to what is necessary in relation to the purposes for which they
are processed (‘data minimisation’);"kept in a form which permits identification of data subjects for no longer than is necessary forthe purposes for which the personal data are processed (‘storage limitation’);processed in a manner that ensures appropriate security of the personal data, including
protection against unauthorised or unlawful processing and against accidental loss,
destruction or damage, using appropriate technical or organisational measures (‘integrity andconfidentiality’).
Implementation procedure of data subject rights
Koeeru ensures that according to the General data protection regulation would be
implemented all rights of data subjects:
Right to be informed (General data protection regulation Art. 13 and 14);
Right to access (General data protection regulation Art. 15);
Right to rectification (General data protection regulation Art. 16);
Right to erasure (Right to be forgotten) (General data protection regulation Art. 17);
Right to restriction of processing (General data protection regulation Art. 18);
Notification obligation (General data protection regulation Art. 19);
Right to data portability (General data protection regulation Art. 20);
Right to object (General data protection regulation Art. 21);
Automated decision – making (General data protection regulation Art. 22).
"If you would like to implement any of these rights, or if you think that we process incorrect
personal data about you, or you have any other questions regarding your rights, please contact
by e-mail data-protection@koeeru.com.
We will deal with your request within 30 days. If your request is complicated or if you have alarge number of requests, it may take us longer. We will let you know if we need longer than
30 days to respond. If you ask us to delete your personal data or restrict how it is used, there
may be exceptions to the right to erasure for specific legal reasons which, if applicable, we will
set out for you in response to your request. We also have to inform, that we need specificinformation from you to help us confirm your identity, so please fill in all required information
about you and submit your request as clearly and understandable as possible."
If you are unable to resolve the issues with Koeeru and if Koeeru engagement or a lack there
of worries you that this privacy report or legal regulations requirements are not being adhered
to, you have the right to contact State data protection inspectorate of the Republic of
Lithuania (supervisory authority) or other institutions which are responsible for thesupervision and control of legal acts which regulate personal data protection andimplementation of data subjects rights.

Security of your personal data
Koeeru has implemented appropriate technical and organisational controls to protect yourpersonal data against unauthorised processing and against accidental loss, damage ordestruction.
But we must inform, that you are responsible for choosing a secure password when we ask you
to set up a password to access parts of our sites, Koeeru systems and platforms. You should
keep this password confidential and you should choose a password that you do not use on any
other site. You should not share your password with anyone else, including anyone who works
for us. Unfortunately, sending information via the internet is not completely secure. Although
we will do our best to protect your personal data once with us.
If you suspect that passwords have been compromised, please inform about this immediatelyby e-mail info@Koeeruint.com and / or data-protection@koeeru.com.
International data transfers"Data we collect may be transferred to, stored and processed in any country or territory where
any of Koeeru companies exist or service / servers providers (data processors) are based orhave facilities. While other countries or territories may not have the same standards of dataprotection, Koeeru will continue to protect personal data that we transfer in line with thisprivacy policy and other procedures by Koeeru.
Whenever we transfer your personal data out of the European Economic Area (EEA), we
ensure similar protection and put in place at least one of these safeguards:"
We will only transfer your personal data to countries that have been found to provide anadequate level of protection for personal data;
We may also use specific approved contracts with our service providers, servers’ providers,data processors, data sub-processors, that are based in countries outside the EEA. These
contracts give your personal data the same protection it has in the EEA;
We have informed the supervisory authorities about these transfers if applicable;
We have received all necessary permissions and consents for transferring of personal data.
Koeeru informs you that for proper provision of services, your personal data may be accessedby the Koeeru companies having respective data processing agreements in place between thecompanies..
In most cases, Koeeru only provides non-personal data to other countries.

Who we share your personal data with
Depending on where you live, we may share your personal data but just in exceptional cases.
We do not share your personal data with other people or organisations that are not directly
linked to us except under the following circumstances:
We may reveal your personal data to any law enforcement agency, court, regulator,
government authority or other organisation if we are required to do so to meet a legal or
regulatory obligation, or otherwise to protect our rights or the rights of anyone else;
We may reveal your personal data to any other organisation that buys, or to which we transfer
all, or substantially all, of our assets and business. If this sale or transfer takes place, we will
use reasonable efforts to try to make sure that the organisation we transfer your personal data
to uses it in line with our privacy policy;
We may share your personal data in other specific cases, when we have the right to provide
this data, and the other party has the right to receive this data;
We will not share your personal data with anyone else in other cases unless we have yourpermission / consent to do this.
Concepts and meanings of your consents
In Koeeru systems and platforms and services, you can see the consents and permissions
which we ask you to mark.
In below we provide a broader and more detailed explanation of these consents andpermissions:“I agree to the Privacy Policy and Terms and conditions” and “By clicking “Register” I agree
to the Privacy Policy, Security Policy, Cookies Policy, DPO, Quality documentation andTerms of Use and I confirm that before I have read all these documents“ means that you haveread all these documents and you agree with the content and conditions set in these
documents.
“I agree to participate in surveys and other market research activities” means that you freely
and indecently agree to provide your opinion, personal data, answers to various questions
which we ask in surveys and questionnaires and you can get a reward for it.
“I agree to the collection and / or sharing of my mobile advertising identifiers or otheridentifiers” means you agree to help us analyse your information better, more detailed, clearly
understand your answers and provide better services.
“I agree to the use of third-party cookies for market research purposes” means you agree toget more special targeted and relevant surveys which should be more interesting for you.
“I agree to share my profile information with third-parties for market research purposes”

means you agree to get more surveys from our partners, from other parties, and also it meansthat you might get more rewards for this. When profile data can be shared, then the surveys
should be more relevant to you.
“I agree to share my sensitive data for market research purposes” means you agree that insurveys there could be questions about your special categories of personal data. In this case,surveys would be more adapted for you and more informative for us. It is likely that you will
receive more surveys that are relevant to you.
“I agree to get newsletters and notifications” means you agree to get information from us
about our services, offers, suggestions, news and changes.
Most of your consents can easily be revoked at any time by writing an email to dataprotection@koeeru.com, or you can easily revoke most of your consents in Koeeru systems
and platforms by yourself.
Data protection officers (DPO)
In adherence to the General Data protection regulation, Koeeru has assigned the following
Data protection officers:
Soji Nagano（CEO）
If you would like to contact Koeeru Data protection officers, you have questions related to theprocessing of your personal data, the protection of personal data, or other matters related topersonal data, please contact us by e-mail data-protection@koeeru.com
Applicable law and changes
This Privacy policy is governed by the laws of the Japan.
Any dispute, controversy, discrepancy or claim arising out of or in connection with thisPrivacy Policy, as well as any matters of failure of compliance with the Privacy Policy,
termination or validity or invalidity of contracts shall be resolved by mutual consultation.

Revised Date: October 2, 2023