Privacy policy

Effective Date: March 20, 2026
Last Updated: May 11, 2026

1. General Provisions

HASS Co., Ltd. (“HASS,” “we,” “us,” or “our”) is a corporation established under the laws of the Republic of Korea. HASS recognizes the protection of personal information as an important corporate responsibility and is committed to processing personal information lawfully, fairly, and transparently.

This Privacy Policy applies to HASmall and related websites, pages, online forms, and services operated by HASS (collectively, the “Services”).

HASmall is operated as a product information and purchase inquiry platform. HASmall does not provide direct online checkout, direct payment processing, direct shipment, or direct refund processing. Users may review product information on HASmall and proceed with purchase inquiries through an official HASS dealer in their selected country or, where no official dealer is available, through HASS headquarters or the relevant sales department.

We endeavor to comply with applicable privacy and data protection laws, including, where applicable:

  • Personal Information Protection Act of the Republic of Korea (“PIPA”)
  • General Data Protection Regulation of the European Union (“GDPR”)
  • California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA/CPRA”)
  • Other applicable privacy and data protection laws in relevant jurisdictions

For personal information processed through the Services, HASS acts as the data controller, unless otherwise stated.

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy.

 

2. Scope of Application

This Privacy Policy applies to personal information processed in connection with the Services, including personal information relating to:

  • Website visitors
  • Registered users
  • Prospective customers
  • Dental professionals
  • Dealers, distributors, and business partners
  • Users submitting inquiries, requests, or contact forms
  • Users seeking product information, dealer connection, or purchase inquiry guidance

This Privacy Policy does not apply to websites, services, or privacy practices of independent third parties, including official HASS dealers, external service providers, or third-party websites that may be linked from the Services.

 

3. Personal Information We Collect

3.1 Information Provided Directly by Users

We may collect personal information that users provide directly through the Services, including:

  • Name
  • Email address
  • Phone number
  • Country or region of residence
  • Address or business address, where applicable
  • Account registration and login information
  • Selected country information for dealer matching
  • Inquiry details and communication history
  • Company, clinic, laboratory, dealer, or distributor information
  • Occupation or professional information, where applicable
  • Product interest, purchase inquiry details, or requested support information

Users are advised not to provide unnecessary sensitive personal information through the Services. If sensitive personal information is provided voluntarily by a user, we will process such information only to the extent necessary for the purpose for which it was provided, unless otherwise required by applicable law.

3.2 Information Collected Automatically

When users access or use the Services, we may automatically collect certain technical and usage information, including:

  • IP address
  • Date and time of access
  • Browser type and version
  • Device information
  • Operating system
  • Referring and exit pages
  • Usage data and interaction data
  • Cookies, pixels, tags, and similar identifiers
  • General location information derived from IP address, where applicable

3.3 Information Collected from Third Parties

We may receive personal information from third parties where lawful and necessary for the operation of the Services, including:

  • Website hosting and platform service providers, including Shopify
  • Analytics service providers
  • Cookie consent management providers
  • Customer support and communication service providers
  • Official HASS dealers, distributors, or business partners, where applicable
  • Security, fraud prevention, and technical service providers

Because HASmall does not provide direct online checkout or direct payment processing, we do not intentionally collect payment card information through HASmall for direct product purchases. If payment-related information is processed by any third party outside HASmall, such processing is subject to the privacy policy and terms of the relevant third party, dealer, or seller.

 

4. Country Selection and Dealer Matching

HASmall allows users to select their country of residence through their account settings. The selected country may be used to provide country-based dealer matching, purchase inquiry guidance, regulatory information, customer support, and related communication.

Users may be allowed to select their country of residence only once, depending on the account structure and service settings. The selected country is used to help identify whether an official HASS dealer is available in the user’s country and to guide the user to the appropriate inquiry channel.

If an official HASS dealer is available in the user’s selected country, the user may be directed to contact that dealer for purchase inquiries. If no official HASS dealer is available in the user’s selected country, the user may be guided to contact HASS headquarters or the relevant sales department.

The selection of a country, display of a dealer, or provision of dealer contact information does not guarantee that any product is approved, registered, licensed, importable, available for sale, deliverable, or permitted for use in that country or region.

 

5. Purposes of Processing Personal Information

We may process personal information for the following purposes:

  • Provision, operation, maintenance, and improvement of the Services
  • Account registration, authentication, and user management
  • Country selection and country-based dealer matching
  • Guidance for purchase inquiries through official HASS dealers or HASS sales channels
  • Response to customer inquiries, requests, and support matters
  • Communication with users, prospective customers, dealers, distributors, and business partners
  • Provision of product information, regulatory notices, and service updates
  • Marketing communications, where consent is obtained or where otherwise permitted by applicable law
  • Website analytics, service improvement, and user experience enhancement
  • Cookie management and consent preference management
  • Security monitoring, fraud prevention, and prevention of unauthorized access
  • Compliance with legal, regulatory, accounting, tax, and recordkeeping obligations
  • Protection of the rights, property, and safety of HASS, users, business partners, and third parties

We do not use personal information collected through HASmall to process direct online product payments, because HASmall does not provide direct online checkout or direct payment processing.

 

6. Legal Basis for Processing Personal Information

Depending on the applicable jurisdiction and the specific processing activity, we process personal information based on one or more of the following legal bases.


6.1 Republic of Korea

Where PIPA applies, we may process personal information based on:

  • Consent of the data subject
  • Necessity for the performance of a contract or pre-contractual request
  • Compliance with legal obligations
  • Legitimate interests, where permitted by applicable law
  • Other grounds permitted under applicable Korean privacy laws


6.2 European Union, European Economic Area, and United Kingdom

Where GDPR or equivalent laws apply, we may process personal information based on:

  • Consent
  • Performance of a contract or steps taken before entering into a contract
  • Compliance with legal obligations
  • Legitimate interests pursued by HASS or a third party, provided that such interests are not overridden by the interests, rights, or freedoms of the data subject
  • Other lawful bases permitted under applicable law

 

6.3 California and Other United States Jurisdictions

Where CCPA/CPRA or other applicable U.S. privacy laws apply, we may process personal information for business purposes permitted by law, including providing and improving the Services, responding to inquiries, maintaining security, and conducting analytics.

We do not sell personal information. We do not knowingly share personal information for cross-context behavioral advertising where such sharing requires an opt-out mechanism, unless appropriate notice and opt-out rights are provided in accordance with applicable law.

 

7. Sharing of Personal Information

We may share personal information with the following categories of recipients where necessary and lawful:

  • Official HASS dealers or distributors in the user’s selected country or relevant region
  • HASS affiliates, branch offices, and related entities
  • Website hosting and e-commerce platform providers, including Shopify
  • Customer support, communication, and email service providers
  • Analytics and cookie management service providers
  • IT infrastructure, security, and maintenance service providers
  • Legal, accounting, tax, audit, and compliance advisors
  • Government authorities, courts, law enforcement agencies, or regulators where required by law
  • Third parties involved in a merger, acquisition, restructuring, asset transfer, or similar business transaction

Personal information is shared only to the extent necessary for the relevant purpose, such as service operation, inquiry response, dealer matching, legal compliance, or protection of rights.

 

8. Dealer Matching and Independent Dealers

Where a user’s selected country has an official HASS dealer, we may share relevant personal information with that dealer for the purpose of responding to purchase inquiries, product inquiries, or related support requests.

Official HASS dealers may be independent business entities. Such dealers may act as independent data controllers or independent businesses with respect to personal information they receive and process for their own purposes. HASS does not control the independent privacy practices of such dealers.

Users should review the privacy notices, terms, and policies of the relevant dealer before providing additional personal information or proceeding with any transaction.

Any purchase, payment, shipment, return, refund, exchange, or after-sales process conducted through an official HASS dealer is generally handled by the relevant dealer or seller, not directly through HASmall.

 

9. Cross-Border Transfer of Personal Information

Because HASS operates globally, personal information may be transferred to, stored in, or processed in countries other than the user’s country of residence, including:

  • Republic of Korea
  • Other countries where HASS affiliates, offices, dealers, service providers, or business partners are located

Where required by applicable law, we implement appropriate safeguards for cross-border transfers of personal information. Such safeguards may include:

  • Obtaining consent where required
  • Providing required notices regarding the country, recipient, purpose, items transferred, retention period, and method of transfer
  • Entering into appropriate data processing or transfer agreements
  • Implementing Standard Contractual Clauses or equivalent safeguards for EU/EEA users where applicable
  • Applying technical and organizational protection measures
  • Taking measures required under applicable Korean privacy laws for overseas transfer of personal information

Users acknowledge that personal information may be processed in countries where privacy laws may differ from those of their country of residence.

 

10. Retention Period

We retain personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by applicable law.

In general, we may retain personal information for the following periods:

  • Account information: while the user account remains active and for a reasonable period thereafter as required for legal, operational, or dispute resolution purposes
  • Inquiry and communication records: up to 3 years, unless a longer period is required by law or necessary for dispute resolution
  • Dealer matching and country selection records: while the user account remains active and for a reasonable period thereafter as necessary for service operation and compliance
  • Marketing consent records: until consent is withdrawn or for the period required to demonstrate compliance
  • Website access logs and security logs: up to 12 months, unless longer retention is required for security, legal, or compliance purposes
  • Legal, accounting, tax, and compliance records: for the period required under applicable laws

When personal information is no longer necessary, we delete, destroy, anonymize, or securely retain it in accordance with applicable law and internal retention procedures.

 

11. User Rights

Depending on the applicable law and the user’s jurisdiction, users may have the following rights regarding their personal information.

 

11.1 Rights under Korean Privacy Law

Where PIPA applies, users may have the right to request:

  • Access to personal information
  • Correction of inaccurate personal information
  • Deletion of personal information
  • Suspension of processing
  • Withdrawal of consent
  • Other rights provided under applicable Korean privacy laws

11.2 Rights under GDPR

Where GDPR applies, users may have the right to request:

  • Access to personal data
  • Rectification of inaccurate personal data
  • Erasure of personal data
  • Restriction of processing
  • Data portability
  • Objection to processing
  • Withdrawal of consent
  • Lodging of a complaint with a competent supervisory authority

11.3 Rights under California Privacy Law

Where CCPA/CPRA applies, California residents may have the right to request:

  • Right to know what personal information is collected, used, disclosed, sold, or shared
  • Right to access personal information
  • Right to delete personal information
  • Right to correct inaccurate personal information
  • Right to opt out of sale or sharing of personal information, where applicable
  • Right to limit the use and disclosure of sensitive personal information, where applicable
  • Right not to be discriminated against for exercising privacy rights

We do not sell personal information. If we engage in activities considered “sharing” under applicable California law, we will provide appropriate notice and opt-out rights as required.

To exercise privacy rights, users may contact us using the contact information provided in Section 21.

We may request information necessary to verify the identity of the requesting user before responding to a privacy rights request.

 

12. Cookies and Similar Technologies

We use cookies and similar technologies for the following purposes:

  • Operation of the website and essential service functions
  • Account login and session management
  • Security and fraud prevention
  • Cookie consent preference management
  • Analytics and performance measurement
  • Improvement of user experience
  • Marketing or advertising purposes, only where applicable and permitted by law

Where required by applicable law, non-essential cookies are used only after prior consent is obtained. Users may manage cookie preferences through the cookie banner, cookie settings tool, browser settings, or other available mechanisms.

For more information, please refer to our Cookie Policy.

 

13. Global Privacy Control

Where legally required, we recognize and respond to Global Privacy Control signals or other legally recognized universal opt-out mechanisms.

If a user’s browser or device sends a legally valid opt-out signal, we will process such signal in accordance with applicable law.

 

14. Children’s Personal Information

The Services are intended for business users, dental professionals, dealers, distributors, and prospective customers. The Services are not directed to children.

We do not knowingly collect personal information from children under the age required by applicable law. In Korea, if we become aware that we have collected personal information from a child under 14 without the required consent of a legal representative, we will take appropriate steps in accordance with applicable law.

If you believe that a child has provided personal information to us, please contact us using the contact information provided in this Privacy Policy.

15. Security Measures

We apply reasonable technical, administrative, and organizational measures to protect personal information, including:

  • SSL encryption
  • Access control
  • Internal privacy and security management policies
  • Principle of least privilege
  • Monitoring of unauthorized access
  • Data backup and security management procedures
  • Employee training and internal access restrictions, where applicable
  • Use of trusted service providers and contractual safeguards, where applicable

Although we use reasonable safeguards to protect personal information, no method of transmission over the Internet or method of electronic storage can guarantee complete security.

 

16. Third-Party Websites and Services

The Services may contain links to third-party websites, platforms, dealers, service providers, or external resources.

We are not responsible for the privacy practices, content, policies, or security of third-party websites or services. Users should review the privacy policies and terms of any third-party websites or services before providing personal information.

 

17. Marketing Communications

Where users consent to receive marketing communications, or where otherwise permitted by applicable law, we may send information about HASS products, services, events, educational content, promotions, or updates.

Users may withdraw marketing consent or unsubscribe from marketing communications at any time by using the unsubscribe link provided in the communication or by contacting us.

Withdrawal of marketing consent does not affect the lawfulness of processing conducted before withdrawal.

 

18. Regulatory and Product Information Notice

HASmall may display information regarding dental materials, medical devices, dental products, or related services. The display of products or product information on HASmall does not mean that such products are approved, registered, licensed, importable, marketable, available for sale, deliverable, or permitted for use in every country or region.

Regulatory requirements, approval status, permitted uses, import restrictions, and distribution conditions may vary by country or region. Users should confirm applicable regulatory and product availability matters with the relevant official HASS dealer, HASS headquarters, or the relevant sales department before proceeding with any purchase inquiry.

Personal information processed in connection with regulatory or product inquiries may be used to respond to such inquiries, provide appropriate guidance, or connect users with the relevant dealer or sales contact.

 

19. Limitation of Liability Regarding Third-Party Processing

We apply reasonable safeguards in providing the Services. However, to the extent permitted by applicable law, HASS is not responsible for damages arising from:

  • The independent privacy practices of official HASS dealers or third-party sellers
  • User-provided inaccurate or incomplete information
  • Third-party websites, platforms, or services linked from the Services
  • Events beyond our reasonable control
  • Unauthorized access caused by reasons not attributable to HASS

Nothing in this Privacy Policy limits rights that cannot be excluded or limited under applicable law.

 

20. Changes to this Privacy Policy

We may amend this Privacy Policy from time to time due to changes in laws, regulations, business operations, service structure, technology, or internal policies.

If we make material changes, we will post the updated Privacy Policy on this page and update the “Last Updated” date. Where required by applicable law, we may provide additional notice or obtain consent.

Users are encouraged to review this Privacy Policy periodically.

21. Contact Information

If you have any questions, requests, complaints, or privacy-related inquiries, please contact us using the information below.

HASS Co., Ltd.

Head Office
77-14, Gwahakdanji-ro, Gangneung-si, Gangwon-do, Republic of Korea

R&D / Sales
A-1201, 60, Haan-ro, Gwangmyeong-si, Gyeonggi-do, Republic of Korea

U.S. Corporation
10400 Eaton Place, Suite 220, Fairfax, Virginia, USA

European Office
Ludwig-Erhard-Straße 30-34, 65760 Eschborn, Germany

China Office
Room 3A03, Dibao Building, No. 3998 Hongxin Road, Shanghai, China

Email: hasmall@hassbio.com