■Compliance with Laws, Regulations and Rules

The Company will comply with laws, regulations and other rules related to Personal Information.

■Establishment of Code of Conduct and Continuous Improvement

The Company will establish and implement a code of conduct for the proper handling of Personal Information from the viewpoint of compliance. In addition, the Company will regularly conduct an audit regarding the implementation and operation of this code of conduct and strive for its continuous improvement.

■Implementation of Safety Measures

The Company will implement reasonable security control measures against unauthorized access to Personal Information and loss, destruction, manipulation, leakage, and so on of Personal Information in order to secure the accuracy and safety of Personal Information. For information about the Company’s security control measures, please contact the “Contact Point” described in the "Response to Inquiries, etc." at the end of this Policy.

■Request for Disclosure, etc.

The Company will respond to requests for notification of the purpose of utilization, disclosure, correction/addition/deletion, cessation of utilization, or cessation of provision to a third party of Retained Personal Data or Records Provided to a Third Party (hereinafter "Request for Disclosure, etc."), as follows.

1. Notification of the Purpose of Utilization, or Disclosure of Retained Personal Data or Records Provided to a Third Party
   In the event that a specific individual identified by Personal Information (hereinafter "Principal") requests from the Company a notice of the purpose of utilization of the retained personal data (meaning "Retained Personal Data" as defined under PIPA) by which the Principal is identified or the disclosure of the Retained Personal Data by which the Principal is identified or the records provided to a third party (meaning "Records Provided to a Third Party" as defined in the PIPA), the Company will provide such notice or disclosure to the Principal without delay after confirming that such request is made by the Principal. Provided, however, that this will not apply to the case where the Company is not obliged to make such notice or disclosure under PIPA or any other laws and regulations.
2. Correction, Addition or Deletion
   n the event that the Principal requests from the Company the correction, addition or deletion (hereinafter "Correction, etc.") of the Retained Personal Data by which the Principal is identified, the Company will, after confirming that such request is made by the Principal, conduct the necessary investigation without delay, and, based on the results of such investigation, make Correction, etc. if such Correction, etc. is necessary and notify the Principal thereof.
3. Cessation of Utilization or Cessation of Provision to a Third Party
   In the event that the Principal requests from the Company the cessation of utilization, deletion or cessation of provision to a third party (hereinafter "Cessation of Utilization, etc.") of the Retained Personal Data by which the Principal is identified, the Company will, after confirming that such request is made by the Principal, conduct the necessary investigation without delay, and, based on the results of such investigation, conduct the Cessation of Utilization, etc. if such Cessation of Utilization, etc. is necessary and notify the Principal thereof. Provided, however, that this will not apply to the case where large costs are necessary for such Cessation of Utilization, etc. or any other case where it is difficult to conduct such Cessation of Utilization, etc., and when alternative measures necessary to protect the rights and interests of the Principal are taken.
4. Procedure
   For procedures related to a Request for Disclosure, etc., please contact the “Contact Point” described in the "Response to Inquiries, etc." at the end of this Policy.

■Acquisition, Retention and Utilization of Information

The Company may acquire, retain or utilize (hereinafter “Acquisition, etc.”) information (which may include Personal Information) for the following purposes in connection with the following operations:

1. Business Related Operations
   For the purpose of contacting customers or providing appropriate services to customers or providing information to customers, etc., the Company may conduct Acquisition, etc. concerning the contents of transactions with customers (including warranty contracts for CPC, GUARD COSME, etc.), purchase history of the Company’s products and services, information on inquiries and communications to the Company from customers, names, company names, section, title, telephone numbers, e-mail addresses, etc. of the customers or persons in charge.
2. Settlement Related Operations
   For the purpose of settlement with customers, the Company may conduct Acquisition, etc. concerning information on the accounts of financial institutions, settlement and the method thereof, etc.
3. Employment Related Operations
   For the purpose of contacting job applicants and conducting evaluations of job applicants, the Company may conduct Acquisition, etc. concerning the name, address, telephone number, e-mail address, resume, etc. of a job applicant.
4. IR Related Operations
   For the purpose of providing appropriate information to main investors, the Company may conduct Acquisition, etc. concerning the names, addresses, telephone numbers, and e-mail addresses, etc., of the investors or persons in charge.
5. Questionnaire Survey Operations
   When the Company conducts questionnaire surveys by mail, telephone, e-mail, etc. (hereinafter “Mail, etc.”) regarding the Company’s products, services or any other businesses, the Company may conduct Acquisition, etc. concerning the responses to the questionnaire survey for the purpose of considering product development or improvement of customer satisfaction, etc., and for the purpose of sending out prizes for the questionnaire.
6. Response to Opinions and Communications Operations
   In the event that the Company receives customer opinions or communications regarding the Company’s products, services or any other operations by Mail, etc., the Company may conduct Acquisition, etc. concerning such opinions or communications for the purpose of responding thereto or for the purpose of developing or planning the Company’s products or services or any other operations.

■Provision to a Third Party

The Company will not provide personal data (meaning "Personal Data" as defined under PIPA) handled by the Company to a third party without obtaining the Principal's consent in advance, except in the following
cases:

1. Cases based on laws and regulations.
2. Cases where there is a need to protect a human life, body or assets and when it is difficult to obtain the Principal's consent.
3. Cases where there is a special need to enhance public hygiene or promote the healthy nurturing of children and when it is difficult to obtain the Principal's consent.
4. Cases where there is a need to cooperate in regard to the performance of the affairs prescribed by the laws and regulations by a central government organization, a local government or a person entrusted by them and when there is a possibility that obtaining the Principal's consent would interfere with the performance of said affairs.
5. Any other cases permitted by law and regulations.

■Outsourcing

In the event that the Company outsources operations regarding Personal Information, the Company will clearly agree on the contents of utilization, scope of utilization, management method, etc. of Personal Information provided to such outsourcee, and will strictly and appropriately manage the outsourcee in order to prevent leakage, etc. of Personal Information provided to such outsourcee.

■Cookies, etc.

The Company uses cookies on the Company’s website for the purpose of improving quality for providing better services to customers, delivering advertisements, etc. In doing so, the Company uses a third party’s services/tools that involve the use of cookies.

The information stored in cookies does not contain information that identifies a specific customer.

Depending on the type of browser used by customers, customers can disable cookies by adjusting their browser settings. Please adjust the browser settings yourself if necessary. Please note that if cookies are disabled in a customer's browser settings, some of the functions of the Company’s website may not be usable.

■Responding to Inquiries, etc.

The Company will sincerely respond to complaints, inquiries, etc. regarding the handling of Personal Information.

*Contact Point: Tel: +81-6-6443-5189 Central Automotive Products Ltd. International Sales Division - Sales Planning Department