NaviBridge Privacy Policy

Date Last Updated: April 3, 2023

This privacy policy explains how DENSO CORPORATION (the “Company”) processes and

handles the personal data obtained from the user of the Company's app, "NaviBridge".

Please read this policy carefully to understand the Company's processing of personal data

of NaviBridge users.

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 or short name that you provide to DENSO, location information of user

(including during background operation), location information you register with DENSO's

app (e.g., favorite places), 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

- 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.

3. Duration of Processing and Retention of Personal Data

The Company processes and retains the personal data of the user for the duration of the

personal data retention period (i) set forth under the applicable laws, or (ii) the user

consented to. The Company retains the personal data of the user from the date it has

collected the relevant personal data until the expiry of [12] months after termination of the

service.

If required under the applicable law, the Company shall retain the personal data of the user

for the required period only for the purpose of storing such personal data in compliance

with the applicable law.

4. Deletion of Personal Data

The Company shall delete the personal data of the user without delay if it is no longer

required to retain the relevant personal data, including where the personal data retention

period has expired or the purpose for processing personal data has been achieved. If the

Company is required under the applicable law to store the personal data even after the

personal data retention period has expired or the purpose for processing personal data has

been achieved, such personal data must be stored under a separate database or storing

location.

* Personal data on printed copy: Destroy with a paper shredder or incinerate.

* Soft copy of personal data: Delete in a way it cannot be restored/recovered.

5. Cross-Border Transfer of Personal Data

* Information of data recipient (contact information): Please refer to Clause 14 above.

* The country to which personal data is transferred: Japan

* The purpose of use of the data recipient: Please refer to Clause 2 above.

* The data to be transferred: The entire personal data collected.

* Date and method of data transfer: Regular transfer of data collected through network

during the term of the service.

* Duration of use and retention personal data: [*] months from the termination of the

service.

6. Automatic Collection of Personal Data and Refusal to Accept Cookies

The Company uses cookies to provide customized services to the user which store and

retrieve user’s data.

Cookies are small blocks of data created by a web server used for the operation of a

website and placed on the user’s computer by the user’s web browser which may be stored

in the user’s PC hard drive.

* Purpose of cookies: It is used to provide optimized information to the user based on the

information of the services and websites the user accessed, the use behavior, popular

search keyword, and whether or not securely connected.

* Refusal to accept cookies: The users may refuse to accept cookies by opening at the top

of the web browser Tools > Internet Option > Personal Information.

* Customized services may be limited in case the user refuses to accept cookies.

Please refer to the company’s Cookie Policy for more details.

7. 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.

Third-party processor of personal data

The Company may engage a third-party data processor for efficient processing of the

user’s personal data. The Company supervises and manages the third-party data

processors pursuant to the Personal Information Protection Act.

* Third-party data processor name: Pasona Tech, Inc.

* The scope of work of the third-party data processor: Development and operation of

NaviBridge application server.

8. Ensuring of Accuracy

The Company shall endeavor to keep the personal data up to date and if it is inaccurate or

insufficient, rectify it.

9. 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.

10. 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. The user

may exercise his/her rights described above through his/her legal representative or agent.

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

11. Amendment to Privacy Policy

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

12. Company’s Policy for Children

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

data from the user under 14 years of age. The Company shall request the user under 14

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 14 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.

13. 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.

The department in charge: [*]

Contact information: navicon@jp.denso.com

14. 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