HUNGRY CLIONE — PRIVACY POLICY

Last updated: 24 March 2026

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PART 1 — INTRODUCTION

1. Who We Are

1.1 This Privacy Policy explains how Hungry Clione ("we", "us", "our") collects, uses, stores, and protects personal data in connection with the website at https://www.hungryclione.com (the "Site").

1.2 Hungry Clione is an independent animation brand operated under Japanese law. For the purposes of data protection law, Hungry Clione is the data controller in respect of personal data collected through the Site.

1.3 The Site is built and hosted on Framer (Framer B.V., Rozengracht 175A, 1016 LZ Amsterdam, Netherlands). Framer acts as a data processor on our behalf in respect of data processed through the hosting infrastructure and contact form functionality. Framer's privacy statement is available at: https://www.framer.com/legal/privacy-statement/

1.4 Contact for privacy matters:

Email: support@hungryclione.com

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PART 2 — LEGAL FRAMEWORK

2. Applicable Law

2.1 This Policy is written to comply with the following legal frameworks:

(a) The Act on the Protection of Personal Information (個人情報の保護に関する法律, "APPI") — Japan

(b) Regulation (EU) 2016/679 — General Data Protection Regulation ("GDPR") — European Union

(c) The UK General Data Protection Regulation and the Data Protection Act 2018 — United Kingdom

(d) The Children's Online Privacy Protection Act ("COPPA") — United States

2.2 Where these frameworks overlap or conflict, we apply the most protective standard available to users in the relevant jurisdiction.

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PART 3 — WHAT DATA WE COLLECT

3. Data You Provide Voluntarily

3.1 Contact form — the Site includes a contact form powered by Framer. When you submit the form, we collect:

(a) Your name (if provided)

(b) Your email address

(c) The content of your message

This data is submitted through Framer's infrastructure and delivered to us at support@hungryclione.com. Framer processes this data as our data processor under their Data Processing Agreement.

3.2 Email correspondence — if you contact us directly at support@hungryclione.com, we collect your email address and any personal data contained in your message.

3.3 We do not require account registration or login to use the Site. No account data is collected.

4. Data Collected Automatically

4.1 When you visit the Site, the following data is collected automatically:

(a) By Framer (hosting infrastructure): IP address, browser type and version, operating system, referring URL, pages visited, date and time of access. This data is processed by Framer as our data processor for the purpose of delivering and securing the Site.

(b) By Google Analytics: see Section 7 (Cookies) for full details.

5. Data We Do Not Collect

5.1 We do not:

(a) collect personal data from passive visitors for marketing or profiling purposes beyond the analytics described in this Policy;

(b) knowingly collect personal data from children under the age of 13 (see Part 7);

(c) collect sensitive personal data such as health information, racial or ethnic origin, political opinions, or biometric data;

(d) sell, rent, or trade personal data to any third party.

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PART 4 — HOW WE USE YOUR DATA

6. Purposes and Legal Basis for Processing

6.1 We use personal data only for the following purposes:

Purpose: Responding to contact form and email enquiries

Data used: Name, email address, message content

Legal basis (GDPR): Legitimate interests (Art. 6(1)(f)) — responding to a user-initiated enquiry

Legal basis (APPI): Necessary for business operations

Purpose: Website analytics — understanding how users interact with the Site

Data used: Anonymised/pseudonymised usage data via Google Analytics

Legal basis (GDPR): Consent (Art. 6(1)(a)) — obtained via cookie consent banner for EU/UK users

Legal basis (APPI): Legitimate business interest where data is anonymised or pseudonymised

Purpose: Site security and infrastructure performance

Data used: Technical log data processed by Framer

Legal basis (GDPR): Legitimate interests (Art. 6(1)(f))

Legal basis (APPI): Necessary for business operations

Purpose: Compliance with legal obligations

Data used: Any relevant data

Legal basis (GDPR): Legal obligation (Art. 6(1)(c))

Legal basis (APPI): Legal obligation

6.2 We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects.

6.3 We do not use your personal data for direct marketing without your prior, freely given, informed consent.

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PART 5 — COOKIES AND TRACKING TECHNOLOGIES

7. Cookies

7.1 A cookie is a small text file placed on your device when you visit a website. The Site uses cookies through Google Analytics. No additional first-party cookies are set by us.

7.2 Google Analytics Cookies

The Site uses Google Analytics, a web analytics service provided by Google LLC ("Google"). Google Analytics sets the following cookies:

Cookie name: _ga

Purpose: Distinguishes unique users by assigning a randomly generated number as a client identifier

Duration: 2 years

Provider: Google LLC

Cookie name: _ga_[ID]

Purpose: Stores and counts page views for the specific Google Analytics property

Duration: 2 years

Provider: Google LLC

These cookies collect information about how visitors use the Site, including which pages are visited most often and how users navigate between pages. This information is used by us in aggregated, anonymised form to improve the Site. Google may also transfer this data to third parties where required by law or where such parties process data on Google's behalf.

Google's privacy policy is available at: https://policies.google.com/privacy

Google Analytics opt-out: https://tools.google.com/dlpage/gaoptout

7.3 We have enabled IP anonymisation in Google Analytics. This means that Google truncates your IP address before storing it, so that it cannot be associated with you individually.

7.4 Third-Party Platform Cookies

The Site embeds content from YouTube, TikTok, and Instagram. When you interact with embedded content (for example, by playing a video), those platforms may set their own cookies on your device. We do not control these cookies. Please refer to the relevant platform privacy policies:

YouTube / Google: https://policies.google.com/privacy

TikTok: https://www.tiktok.com/legal/page/row/privacy-policy

Instagram / Meta: https://privacycenter.instagram.com/policy

7.5 Cookie Consent

For users located in the EU or UK, Google Analytics cookies are non-essential and require your consent before being placed. A cookie consent banner is displayed on your first visit to the Site. You may withdraw or change your consent at any time by clearing your browser cookies or using your browser's cookie management settings.

For users in Japan and other jurisdictions, Google Analytics cookies are used on the basis of our legitimate interest in understanding Site usage, in compliance with APPI.

7.6 Managing Cookies

You can control and delete cookies through your browser settings. Instructions for common browsers:

Chrome: Settings → Privacy and security → Cookies

Firefox: Settings → Privacy & Security → Cookies and Site Data

Safari: Preferences → Privacy → Manage Website Data

Note that disabling cookies may affect the functionality of some aspects of the Site.

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PART 6 — SHARING OF PERSONAL DATA

8. Third-Party Processors and Partners

8.1 We do not sell, rent, or transfer your personal data to third parties for their own commercial purposes.

8.2 We share personal data with the following third parties only to the extent necessary:

(a) Framer B.V. — our website hosting provider and contact form processor. Framer processes data on our behalf under a Data Processing Agreement. Framer is based in the Netherlands (EU) and subject to GDPR. See: https://www.framer.com/legal/privacy-statement/

(b) Google LLC — provider of Google Analytics. Google processes anonymised usage data on our behalf. Google is subject to the EU-US Data Privacy Framework. See: https://policies.google.com/privacy

(c) YouTube / TikTok / Instagram — embedded content from these platforms may result in data being transmitted to them when you interact with that content. This occurs under their own terms and privacy policies, not ours.

(d) Legal authorities — we may disclose personal data where required by applicable law, court order, or governmental authority.

9. International Transfers

9.1 The Site is operated from Japan. Framer is based in the Netherlands (EU). Google LLC is based in the United States.

9.2 Japan has been recognised by the European Commission as providing an adequate level of data protection (Commission Implementing Decision (EU) 2019/419). Transfers between Japan and the EU are therefore lawful without additional safeguards.

9.3 Google LLC participates in the EU-US Data Privacy Framework, providing a lawful basis for transfers from the EU to the US.

9.4 For UK users, we rely on the UK's equivalent adequacy and transfer frameworks.

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PART 7 — CHILDREN'S PRIVACY (COPPA)

10. Users Under 13 — United States

10.1 The Site is accessible to users of all ages, including children under the age of 13 in the United States. We comply with the Children's Online Privacy Protection Act ("COPPA").

10.2 We do not knowingly collect, use, or disclose personal information from children under 13 without verifiable parental consent.

10.3 Children can browse the Site and watch embedded video content without providing any personal data to us directly. The contact form is not directed at children under 13.

10.4 Google Analytics is configured with IP anonymisation enabled. We do not use Google Analytics data to build individual profiles of any users, including children.

10.5 If you are a parent or guardian and believe your child under 13 has submitted personal data to us via the contact form or email, please contact us immediately at support@hungryclione.com. We will delete such data without delay upon verification.

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PART 8 — DATA RETENTION

11. How Long We Keep Your Data

11.1 We retain personal data only for as long as necessary for the purpose for which it was collected, or as required by applicable law.

Contact form and email enquiries: maximum 2 years from the date of last correspondence, unless a longer period is required by law.

Google Analytics data: retained for 14 months within Google Analytics, after which it is automatically deleted. This is the minimum retention period offered by Google and has been set accordingly.

Framer hosting/log data: subject to Framer's data retention policy, available at https://www.framer.com/legal/privacy-statement/

11.2 When data is no longer required, we delete it securely or ensure it is anonymised.

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PART 9 — YOUR RIGHTS

12. Your Rights Under GDPR (EU and UK Users)

12.1 If you are in the EU or UK, you have the following rights:

(a) Right of access — request a copy of personal data we hold about you.

(b) Right to rectification — request correction of inaccurate or incomplete data.

(c) Right to erasure — request deletion of your data where there is no compelling reason to retain it.

(d) Right to restriction — request that we limit processing in certain circumstances.

(e) Right to data portability — receive your data in a machine-readable format where processing is consent or contract-based and carried out by automated means.

(f) Right to object — object to processing based on legitimate interests at any time.

(g) Right to withdraw consent — withdraw any consent given at any time, without affecting prior lawful processing.

12.2 To exercise any right, email support@hungryclione.com. We will respond within 30 days. We may verify your identity before processing requests.

12.3 You have the right to lodge a complaint with your supervisory authority:

EU: your national data protection authority

UK: the Information Commissioner's Office — https://ico.org.uk

13. Your Rights Under APPI (Japan)

13.1 Under Japan's APPI, you may request disclosure, correction, addition, deletion, or suspension of use of personal data we hold about you. Contact us at support@hungryclione.com.

14. Your Rights Under COPPA (United States — Children Under 13)

14.1 Parents or guardians may request to review, delete, or restrict further collection of personal data submitted by their child. Contact us at support@hungryclione.com.

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PART 10 — SECURITY

15. How We Protect Your Data

15.1 We implement appropriate technical and organisational measures to protect personal data, including:

(a) HTTPS/TLS encryption for all data transmitted through the Site

(b) Reliance on Framer's enterprise-grade hosting infrastructure with built-in security controls

(c) Limiting access to personal data to those who need it

15.2 No method of transmission or storage is completely secure. We cannot guarantee absolute security.

15.3 In the event of a personal data breach that is likely to result in risk to your rights, we will notify the relevant supervisory authority within 72 hours (as required under GDPR) and notify affected individuals where required.

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PART 11 — CHANGES TO THIS POLICY

16. Updates

16.1 We may update this Privacy Policy at any time. Changes will be posted on this page with an updated "Last updated" date.

16.2 Where changes are material, we will take reasonable steps to bring them to your attention.

16.3 Continued use of the Site following any update constitutes your acceptance of the revised Policy.

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PART 12 — CONTACT

17. Contact Us

Email: support@hungryclione.com

Website: https://www.hungryclione.com

Privacy Policy: https://www.hungryclione.com/privacy-policy

Instagram: https://www.instagram.com/hungryclione/

TikTok: https://www.tiktok.com/@hungryclione

We aim to respond to all privacy-related enquiries within 30 days of receipt.

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