Marklines Co., Ltd. (the "Company") places the utmost importance on protecting the privacy of persons who use the Company's information system (the "Users") and furthermore pays due diligence in appropriately administering and maintaining information that is personal to and individually owned by Users (the "Personal Information").
The Company maintains and operates for corporate use an Internet website (the "Website") on which is published, provided, and distributed information related to the automotive industry. All Users' Personal Information, which the Company collects, compiles, and discloses, is governed in accordance with this policy on privacy (the "Privacy Policy").
External websites linked to the Company's Website provide proprietary statements regarding privacy. The Company is neither obligated to nor liable for any terms & conditions and/or any activities performed by these external websites. It is the responsibility of Users to ascertain beforehand the terms & conditions and other specifics of these websites.

■Definition of Personal Information
Personal Information refers to any information of and owned by individual Users and includes, but is not limited to, names, e-mail addresses, and any other types of information which can specifically identify individual Users. Furthermore, Personal Information includes information that can result in identifying individual Users through association, regardless if the information itself does not identify specifically the individual Users.

■Personnel Accountable for Control and Maintenance of Personal Information
In order to protect Users' Personal Information, the Company assigns personnel accountable for controlling and maintaining Personal Information and ensures that the personnel appropriately control and maintain Personal Information and fully comply with all internal rules concerning the protection of Personal Information.

■Purposes for Collecting Personal Information
The Company collects Personal Information from Users for the purposes stated below. Personal Information collected from Users is limited to only Personal Information that is essential for the Company to conduct business.
(1) Distributing information updates, notices, and questionnaires
(2) Distributing Opt-in-Mail
(3) Collecting Personal Information such as, but not limited to, names and e-mail addresses of inquirers who directly contact corporate-member persons presenting information on the All Member Presentation Board and on the Solution (Japanese language only).
(4) Communicating with applicants and contact persons regarding the status of Website access and registration. (Note: outside of Japan applicants also serve concurrently as contact persons.)
(5) Conducting market surveys and analysis
(6) Verifying individual Users accessing membership services
(7) Servicing customers in order to provide membership services and other matters related thereto
(8) Responding to customer inquiries
(9) Verifying the existence of valid service agreements and verifying the terms and conditions of valid service agreements
(10) Sending correspondence related to IDs and passwords

■Updating Personal Information
Users may at any time change, add, or delete their Personal Information registered with the company.
- To change or add Personal Information, Users can access the Update User Profile page on the Company's Website and follow the procedures.
　　http://www.marklines.com/en/members/trans_top_mproupdin.jsp

- To delete Personal Information, the actual Users, applicants, or contact persons can send e-mail messages to Marklines Customer Support Center. Upon receipt of these messages, the Company deletes the Personal Information as requested.
　 << Marklines Customer Support Center >>
　　support@marklines.com

■Disclosing Personal Information to Third Parties
The Company does not disclose Users' Personal Information to third parties without the prior consent from the actual Users, except under the specific circumstances stipulated in this Privacy Policy. The Company discloses Personal Information upon obtaining prior consent from the actual Users after giving notification to Users as to the identify of third parties to whom Personal Information is to be disclosed and as to the nature of the Personal Information that is to be disclosed.

The Company has the right to disclose Personal Information without the prior consent of Users under the following circumstances as long as the disclosing of Personal Information does not violate any laws and ordinances.
(1) When Users, in the Company's opinion, would place third parties at undue disadvantages.
(2) When obtaining the consent of the actual Users is needed but is difficult in cases involving life and death situations and in protecting persons and assets from harm.
(3) When obtaining the consent of the actual Users is needed to cooperate with, but would hinder or would be deemed to possibly hinder, national government bodies, local public organizations, or persons having the authority of these bodies and organizations to perform duties prescribed by law.
(4) When obtaining the consent of the actual Users is specifically needed but is difficult in cases to improve public health and support sound education of children.
(5) When courts, public prosecutors, police, bar associations, consumer centers, or any organizations vested with the authority in these bodies, demand that Personal Information be disclosed.
(6) When the actual Users request that Personal Information owned by them be expressly disclosed to third parties.
(7) When corporate service agreement applicants or contact persons request that Personal Information be disclosed or provided.
(8) When disclosing or providing Personal Information is permitted by law.
(9) When providing or disclosing Personal Information, in the Company's opinion based on reason, is required in order to provide Service to other Users.

■Scope of Providing Personal Information to Third Parties
The following circumstances are excluded from the scope of providing Personal Information to third parties.
(1) When the Company in the course of conducting business outsources the handling of Personal Information in whole or part to third parties under condition that the Personal Information is solely used for the specific purposes by which the Company outsourced the handling. However, the Company shall be liable for the handling of Personal Information by these third parties.
(2) When Personal Information is provided in the course of the Company being acquired by, merged into, or otherwise succeeded by another company or under any other such similar circumstances.

■Requests for the Company to Disclose Personal Information
The actual individual Users, applicants, or contact persons can send requests via e-mail to Marklines Customer Support Center asking for the Company to disclose Personal Information owned by the respective Users, applicants, or contact persons.
　　<< Marklines Customer Support Center >>
　　support@marklines.com

■Circumstances When the Company Shall Not Disclose Personal Information
The Company does not disclose Personal Information under the following circumstances and notifies the reason or reasons in writing.
(1) When the Company cannot verify that the persons contacting the Company are the actual persons identified with the Personal Information on record due to discrepancies in the Personal Information on record and the information sent by the persons contacting the Company.
(2) When any circumstances surrounding requests for the Company to disclose Personal Information do not corroborate with current Personal Information on record.
(3) When the disclosing of Personal Information harms or is deemed capable of harming the lives, bodies, assets or other interests of the actual Users or any third parties.
(4) When the disclosing of Personal Information significantly harms the Company's ability to maintain sound business operations.
(5) When the disclosing of Personal Information violates any laws.

■Hold Harmless Clause
The Company shall not be liable whatsoever for any Personal Information provided to or collected by third parties under the following circumstances.
(1) When the actual Users themselves enable their own Personal Information to become known or available through any functions on the Company's Website, through any means by specific companies or website content providers, or through any format that can be readily accessed by any persons.
(2) When the owners of Personal Information by any circumstance become specifically identifiable because of any information entered in the Company's Website by the actual Users themselves or any other Users.
(3) When the provision of Personal Information to external websites linked with the Company's Website is facilitated by Users providing Personal Information to these external sites. Note that also includes the use of the Personal Information provided by Users to these external websites.
(4) When persons other than the actual Users obtain any information such as, but not limited to, IDs and passwords that enables these persons to be identified as Users.

■Outsourcing
The Company may outsource the handling of Personal Information in whole or part to external parties. The Company sets standards in terms of these external parties' abilities to uphold and protect Personal Information, and these standards are prerequisite conditions to the Company's concluding any outsourcing agreements with these external parties. Furthermore, the Company enters into confidentially agreements with these external parties and performs necessary and appropriate monitoring of these external parties' control and maintenance of Personal Information.

■Use of Statistical Information
In order to gain insight as to trends in use of the Company's services, the Company, based on Personal Information provided from Users to the Company, compiles usage data and statistics. However, these data and statistics are formatted so that specific Users will be unidentifiable. Furthermore, the Company makes the data and statistics available for display and use without any limitations; however, the Company is the sole owner of all copyrights to these data and statistics.

■Direct Mailings
As part of the Company's services direct mailings may be sent to Users who have given prior consent to receive the direct mailings, which are sent via e-mail messages to Users registered under the Information-Transmission Tools on the Website. The direct mailings provide information about various products and services which are currently being provided or which will be provided in the future. The originators of these direct mailings can only be corporations that have entered into service agreements with the Company; however, the Company sends the direct mailings on behalf of these corporations and therefore the originators of the direct mailings are unable to know or obtain any Personal Information whatsoever of the Users to whom the direct mailings have been sent. Regardless that the direct mailings are sent by the Company, the originator is clearly identified in all cases. Users registered to receive direct mailings may at any time easily cancel receiving direct mailings or modify direct mail settings online. In addition, all direct mailings contain instructions for stopping direct mailings.

■Control and Maintenance of Personal Information
The Company incorporates both technical and organizational means to constantly maintain the precautions necessary to safeguard Personal Information from unauthorized access and from being lost, destroyed, altered, or leaked. The Company makes the best efforts to regularly provide employee training on how to control and maintain Personal Information. Furthermore, the Company fully complies with all laws, ordinances, industry codes of conduct and ethics, and customs on public order and morals dealing with Personal Information protection.

■Revisions to the Privacy Policy
The Company from time to time may review and without prior notice revise this Privacy Policy with the aim of improving the content. Whenever the Company revises this Privacy Policy, the date of the most recent update is written on the topmost page. Before the Company makes any major changes to these statements or to the ways in which the Company uses Personal Information, the Company shall give prior notice about the nature of these changes in a format that is clearly noticeable and identifiable. In order for persons to stay current on how the Company protects Personal Information, the Company advises persons to regularly review this Privacy Policy.

■Regarding the Use of Cookies
Since the Company uses cookies to identify Users, cookies will be saved to the hard disks of the personal computers first used to login to the Company's Website. Cookies are text files saved on computer hard disks by website servers and cannot be used to initiate applications or infect computers with viruses. Furthermore, Cookies contain absolutely no Personal Information.

■Secure Encryption
The Company's Website uses Secure Socket Layers (SSL) which function to encrypt information transmitted via the Internet using server IDs issued by Verisign. This function enables Users' Personal Information to be transmitted while preventing the Personal Information from being compromised in any way.

■Questions and Inquiries
The Company will respond to questions and inquiries when persons contact the following.

　　　<< Security Support >>
　　　TEL/FAX Monday - Friday 09:00- 18:00 (JST) (Except holidays)
　　　TEL : +81-(0)3-5114-8717
　　　FAX : +81-(0)3-5114-8715
　　　E-mail : security@marklines.com

April 1, 2005