Date Last Updated: April 3, 2023

DENSO CORPORATION (the “Company”) shall comply with Japanese Act on the

Protection of Personal Information, the law of the EU concerning the protection of Personal

Data including the GDPR and other related laws, ordinances and guidelines and

appropriately handle the Personal Data obtained from the user as follows for the protection

of the Personal Data.

If you are an individual in the European Economic Area (EAA, comprising the European

Union member states as well as Iceland, Liechtenstein and Norway), please read

Addendum for Individuals in EEA for additional information.

1. Personal Data to Be Processed

The Company shall process (meaning any operation or set of operations which is

performed upon personal data or sets of personal data, whether or not by automated

means, and such operation means acquisition, recording, organization, structuring, storage,

rectification, alteration, recovery, retrieval, consultation, use, disclosure by transmission,

dissemination or otherwise making available, alignment, combination, restriction, erasure or

destruction; hereinafter the same) the Personal Data of the user that you give us through

the service, including but not limited to the following information.

User ID, Nickname, Location information of user (including during background operation),

Use log of NaviCon and NaviBridge application (including location and time of use), and

History of access to Company’s server (including time, IP address and Cookie)

Since it is necessary for the Company to receive such information from the user to provide

the user with the service, the user who cannot provide such information may not use the

service.

2. Legal Basis for and Purpose of Processing Personal Data

We will process your personal data on the following legal bases unless such data

processing would conflict with applicable laws and regulations:

- Contract. When we need to process your personal data to perform a contract we

enter into with you.

- Legal Obligation. When we need to comply with a legal obligation.

- Legitimate Interests. When the processing of your personal data is necessary

for the fulfilment of legitimate interests pursued by us or a third party and your

interests and fundamental rights do not override those interests.

- Consent. When you have given consent for us to process your personal data.

However, even if we obtain consent from you, we may process your personal data

based on other legal grounds. The withdrawal of your consent shall not affect the

lawfulness of processing performed based on the consent before your withdrawal.

We use the personal data that we hold about you for the following purposes. We will

only use your personal data to the extent that it is necessary to do so to fulfil the

purposes described below.

- To provide merchandise or services that you request (based on contract or

legitimate interests)

- To improve our merchandise or services we provide to you (based on contract or

legitimate interests)

- To provide information and communications; to conduct questionnaires relating to

products, services, various events, campaigns, and

similar matters (based on legitimate interests)

- To conduct sales analysis, investigations, and research; to develop new services

and products (based on legitimate interests)

- To conduct web analytics (see our Cookie Policy)

- To ensure compliance with legal obligations (such as record keeping obligations),

export control and customs, compliance screening obligations (to prevent white-

collar or money laundering crimes), and our policies or industry standards (based

on legal obligation or legitimate interests)

- To solve disputes, enforce our contractual agreements and to establish, exercise

or defend legal claims (based on legal obligation or legitimate interests).

You may experience disadvantages if you refuse to provide your personal data, such

as being unable to make use of some of our services.

The Company shall keep the Personal Data of the user as long as it is necessary to provide

the user with the service but promptly erase it if it is no longer necessary.

3. Provision to Third Party

The Company shall provide the companies which the Company entrusts to develop and

operate the service to and ties up with to provide the service or new related service with the

Personal Data of the user for the purpose of accomplishing the purposes of use specified

above.

4. Ensuring of Accuracy

The Company shall endeavor to keep the Personal Data up to date and if it is inaccurate or

insufficient, rectify it.

5. Security

To prevent unauthorized access to Personal Data or divulgence of Personal Data, the

Company evaluates and determines the risk of breach of the Personal Data privacy in a

comprehensive manner after taking into account the category of Personal Data, degree of

sensitivity, influence including economic and mental damage to the user when the Personal

Data privacy is breached, and takes personnel, organizational and technical safety

management measures that are necessary and appropriate according to the risk of breach

of Personal Data privacy, set the process to inspect and correct such safety management

measures as necessary and makes ceaseless efforts to improve security.

6. Access to Personal Data, Rectification, Erasure, Restriction on Processing, Right

of Data Portability

The user may request the Company make the Personal Data concerning the user retained

by the Company available to the user, rectify or restrict the processing of such information

or take procedures for data portability within the scope which is recognized by the laws and

regulations of each county and region. Further, the user shall have the right to raise an

objection to the Company or data protection authority governing the location where the user

resides with respect to the processing of the Personal Data related to the user within the

scope which is recognized by the laws and regulations of each county and region. If the

user requires the procedures for exercising various types of rights granted to the user with

respect to the Personal Data, please contact us at the following e-mail address.

navicon@jp.denso.com

7. Amendment to Privacy Policy

The Company may amend the privacy policy at any time. If the Company amends this

8. Company’s Policy for Children

The Company makes sure to obtain the consent of a guardian when obtaining Personal

Data from the user under 16 years of age. The Company shall request the user under 16

years of age ask his/her guardian to give consent after his/her guardian has confirmed the

details of the privacy policy without fail, but shall not request the user himself/herself give

consent, before using the service. Further, if a guardian or other person finds the user

under the age of 16 who consents to the privacy policy and uses the service without

obtaining the confirmation and consent of his/her guardian, please notify the Company at

the following contact point.

9. Inquiries

If the user has any matter for consultation or question with respect to the privacy policy or

the processing of the Personal Data by the Company, or request with respect to the access

to, rectification or erasure of the Personal Data, restriction on processing or right of data

portability, please contact the Company at the following website.

navicon@jp.denso.com

10. Administrator and Representative

The Company determines the purposes of use and method of processing of the Personal

Data of the user. The contact information of the Company is as follows.

DENSO CORPORATION

1-1, Showa-cho, Kariya, Aichi, Japan

navicon@jp.denso.com

Addendum for Individuals in EEA

Last Updated: April 3, 2023

If you are an individual in the European Economic Area (the “EEA”,

comprising the European Union member states as well as Iceland,

Liechtenstein and Norway), this addendum applies to you. This addendum

supplements our privacy policy (the “Policy”) and prevails over any conflicting

provisions in the Policy.

1. Legal Basis for and Purpose of Processing

Personal Data

We will process your personal data on the legal bases and for the purposes

outlined in the Policy (see item 2.). In addition, the following applies:

- Legitimate Interests. Our legitimate interests for processing your data

could be, in particular, to merchandise our services, to conduct market

research and to analyze trends, as well as to develop new services and

products (more information on the balancing test is available upon

request).

- Consent. In case we obtain consent from you, we may process your

personal data based on other legal grounds, but only as far as such

processing is not already covered by your consent.

2. Your rights

You have a number of legal rights in relation to the personal data that we hold

about you. The following is a summary of each of the rights you may exercise.

Please note that these rights might be limited under applicable national data

protection law.

* the right to obtain information regarding the processing of your personal data

and access to the personal data which we hold about you;

* the right to request that we rectify your personal data if it is inaccurate or

incomplete;

* the right to request that we erase your personal data in certain

circumstances. This may include (but is not limited to) circumstances in which:

- it is no longer necessary for us to retain your personal data for the

purposes for which we collected it;

- we are only entitled to process your personal data with your consent,

and you withdraw your consent (provided there is no other legal ground

for the processing); or

- you object to our processing of your personal data for our

legitimate interests, and our legitimate interests do not override your

own interests, rights and freedoms (if your personal data is

processed for direct marketing purposes, you have the right to

object at any time to the processing of your personal data for such

marketing);

* the right to request that we restrict our processing of your personal data in

certain circumstances. This may include (but is not limited to) circumstances

in which:

- you dispute the accuracy of your personal data (but only for the period

of time necessary for us to verify its accuracy);

- we no longer need to use your personal data for our processing, but you

require them for the establishment, exercise or defence of legal claims; or

- you object to our processing your personal data for our legitimate

interests (but only for the period of time necessary for us to assess

whether our legitimate interests override your own interests, rights

and freedoms);

* the right to object to us about our processing of your personal data;

* the right to receive any personal data which we process about you on the

basis of your consent or for the performance of a contract with you (as

opposed to any other legal ground) in a structured, commonly used and

machine-readable format and/or request that we transmit that data to a

recipient where this is technically feasible. Please note that this right only

applies to personal data which you have provided to us, and on the condition

that the processing is carried out by automated means;

* the right to withdraw your consent to our processing of your personal data

at any time. Please note, however, that we may still be entitled to process

your personal data if we can rely on another legal ground for doing so.

*You can exercise your rights by contacting us using the information about us

indicated in Section 10 of the Policy. You can also lodge a complaint with a

data protection authority if you think that any of your rights have been

infringed by us.

The provision of personal data is necessary for the conclusion of the contract

between us and/or the performance of the services provided by us, and it is

voluntary. However, if you do not provide the personal data, the provision of

the services might be delayed or impossible.

3. Data Transfer Outside EEA countries and UK

Personal data is transferred to us in Japan. The EU Commission has made

an adequacy decision to the effect that an adequate level of data protection

exists in Japan.

In the event that the recipients of your personal data are located in third

countries for which the EU Commission has not made an adequacy decision

to the effect that an adequate level of data protection exists in these third

countries, we will take other measures to implement appropriate guarantees

for the protection of your personal data in accordance with the GDPR.

Personal data is only transferred to external recipients in third countries if they

have concluded EU standard contractual clauses with us.

For further information on the respective guarantee, please refer to the

following link:

- EU Standard Contractual Clauses

Further information and a copy of the implemented measures can be obtained

upon request from us (see the information about us indicated in Section 10 of

the Policy).

4. Retention Period

Your personal data is stored by us and/or our service providers to the extent

necessary for the performance of our obligations and for the time necessary

to achieve the purposes for which the information is collected, in accordance

with applicable data protection laws. When we no longer need to use your

personal data to comply with contractual or statutory obligations, we will

remove it from our systems and records and/or take steps to properly

anonymize it so that you can no longer be identified from it, unless we need

to keep your personal data to comply with legal or regulatory obligations to

which we are subject, e.g. statutory retention periods which can result from

commercial and tax laws and usually contain retention periods from six to ten

years, or if we need it to preserve evidence within the statutes of limitation,

which is usually three years but can be up to 30 years.

5. Automated Decision-Making

We do not engage in automated decision-making in the context of data

processing as outlined in the Policy including this addendum to the Policy.

6. Contacts

If you have any questions about the Policy, this addendum, your rights, or any

other issues regarding the protection of your personal data, or if you wish to

exercise any of your rights, you may contact us as follows:

DENSO CORPORATION

1-1, Showa-cho, Kariya, Aichi, Japan

navicon@jp.denso.com