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NITTO PRIVACY POLICY

Effective: December 30, 2019

Last Updated: July 31, 2024

Introduction

Nitto Tire U.S.A. Inc. and our affiliates ("the Company," "us" or "we") are committed to protecting the privacy and security of your Personal Information.

This privacy policy governs the information we may collect from you or that you may provide when you visit our websites, use mobile applications provided by us ("apps"), or otherwise as described in "When This Privacy Policy Applies" below (our "services") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

Please read this privacy policy carefully to understand our policies and practices regarding your information. We may change this privacy policy from time to time, but the version of the privacy policy in place when your information was collected applies to that information. Your continued use of our services after we make changes is deemed to be acceptance of those changes, so please check this privacy policy periodically for updates. This privacy policy is not a contract and does not create any legal rights or obligations.

When This Privacy Policy Applies

This privacy policy applies to information we collect:

Information We Collect About You and How We Collect It

We collect Personal Information from and about users of our services. "Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user or household. This can include information:

We collect this information:

Information You Provide to Us

The information we collect on or through our services that you provide to us may include:

We also may collect information that you submit to be published or displayed ("posted") on our website(s) or transmitted to other users of our services or to other companies (collectively, "user contributions"). Your user contributions are posted and transmitted to others at your own risk. We cannot control the actions of other users of our services with whom you may choose to share your user contributions.

Information We Collect Automatically

As you navigate through and interact with our services, we may use automatic data collection technologies to record how you interact with our services and collect certain information about your equipment, browsing actions and patterns, including:

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services. This practice is often called behavioral tracking.

The information we collect automatically helps us to improve our services and to deliver a better and more personalized service, including by enabling us to:

The technologies we use for this automatic data collection may include:

We may also collect and disclose certain "sensitive" personal information as described below:

Third-party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, are served by third-party companies, including advertisers, ad networks, ad servers, content providers and application providers. These companies may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our websites. The information they collect may be associated with other Personal Information we collect and may include information about your online activities over time and across different websites and other online services. We do not respond to "Do Not Track" signals. We may use this information to provide you with interest-based advertising or other targeted content.

We also use Google to understand how people use our services, to improve our services and websites, and to help us display advertisements that may be of interest to you. You can learn more about how Google uses your information here.

Children Under the Age of 16

Our websites and services are not intended for children under 16 years of age. We do not knowingly collect Personal Information from children under 16. If we learn we have collected or received Personal Information from a child under 16, we will delete that information. If you believe we might have collected any information from a child under 16, please contact us at inquiries@nittotire.com.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Information:

We may also combine and use your information collected from one or more services with other services interactive features, or in reports and analysis, all of which are owned and operated by the Company. We may also use and/or combine information that we collect offline or that we collect or receive from third-party sources to enhance, expand and check the accuracy of other information we collect about you. We may also use your information to contact you about our own and others' goods and services that may be of interest to you.

Disclosure of Your Information

We may disclose aggregated or deidentified information about our users without restriction. We will not attempt to reidentify the aggregated or deidentified information that we maintain about individuals, except and only as may be required to test whether our deidentification procedures are successful.

We may disclose Personal Information that we collect or that you provide as described in this privacy policy:

We may also disclose your Personal Information:

Choices About How We Use and Disclose Your Information

You may have choices regarding how we use and disclose your information:

How to Submit a Request

You may submit a request to exercise your rights by either:

If you disagree with our denial of a request, you may appeal our decision by contacting us with the subject line "Appeal."

Verification for Requests

Note that, as required by law, we will require you to prove your identity in connection with your request. We may conduct an identity verification by phone call or email. Depending on your request, we will ask for information such as your name, email, address, the last item you purchased from us, or the date of your last purchase from us. For request regarding categories of information, we will require at least two of these things to verify your identity. For requests to know specific pieces of Personal Information, we will require at least 3 of these things including your name and email address and we will also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete Personal Information about you in our files.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us.

Information for Authorized Agents

If you are an authorized agent submitting a request on behalf of an individual, you must attach a copy of a completed Authorized Agent Designation Form indicating that you have authorization to act on the consumer's behalf.

If we do not receive this information, the request will be denied.

Notice of California Consumer Data Collection and Sharing Practices.

The following is a description of our data collection practices, including the information we collect, the sources of that information, the purposes for which we collect information, whether we disclose that information to external parties, and what types of information are disclosed to those parties. We may use any and all of the information for any of the purposes described in this privacy policy, unless limitations are listed. The categories we use to describe the information are those enumerated in the CCPA. We do not sell or share your personal information.

We may share any of the above-listed information with service providers, which are external parties that we engage for business purposes and are restricted from using Personal Information for any purpose that is not related to our engagement. The categories of service providers with whom we share information for business purposes and the services they provide are:

We may also disclose information to other external parties who are not listed here when required by law or to protect the Company or other persons, as described in this privacy policy. For example, we may share Personal Information with public safety and/or regulatory authorities.

Notice of Financial Incentive for California Residents.

We offer an incentive program for dealers that provides certain perks, such as bonus incentives, and program benefits (the "Incentive Program"). When you sign up for the Incentive Program we will ask you to provide your name and email address. Because our Incentive Program involves the collection of personal information, it might be interpreted as a "financial incentive" program under California law. The value of your personal information to us is related to the value of the free or discounted products or services that you obtain through the Incentive Program. This value is based on the expense related to offering those free or discounted products or services. You may withdraw from participating in the Incentive Program at any time. Visit the Terms and Conditions page to view full program rules, including how to join.

Data Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of websites, such as message boards. The information you share in public areas may be viewed by any user.

In the event of a data breach involving your information, we may contact you in a variety of ways to inform you of the breach. This includes contacting you through any contact information we have for you or that is publicly available.

Governing Law

Our services and websites are produced and published in the United States. We attempt to protect the Personal Information of all users of our services and we attempt to comply with local data protection and consumer rights laws to the extent they may apply to the Company's services, but our services are located and targeted to United States residents and our policies are directed at compliance with United States laws. If you are uncertain whether this privacy policy conflicts with the applicable local privacy laws where you are located or you do not want your Personal Information governed by United States law, you should not submit your Personal Information to us.

How Can We Transfer Your Personal Information?

Your information collected through the services will be stored and processed in the United States. The Company and its service providers may transfer information that we collect about you, including Personal Information, across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the United States or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including Personal Information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.

Accessibility

If you are visually impaired, you may access this notice through your browser's screen reader.

Changes to Our Privacy Policy

We reserve the right to revise this privacy policy at any time for any reason in our sole discretion by posting an updated privacy policy without advance notice to you. Such revisions shall be effective upon the date specified in the updated privacy policy, and if you use the services after such revisions become effective it will signify your agreement to be bound by the changes. We encourage you to check this privacy policy and our Terms of Use often for updates.

Contact Information

If you have questions, comments, or complaints about this privacy policy or our privacy practices, or if you do not understand any information about how we collect, maintain, use, or share your Personal Information, you may contact us directly by sending an email to inquiries@nittotire.com. For all requests, please include the name and URL (if applicable) of the website, application or other interactive service, and include the description "Privacy Request" in the subject of the email. We shall not accept requests via postal mail or facsimile. We are not responsible for notices that are not labeled or sent properly and may not be able to respond if you do not provide complete information.

COMPLIANCE AND ETHICS HOTLINE

The Company is committed to high standards of ethical and legal business conduct with emphasis on open and transparent communication. The Company expects employees and business partners to report known or suspected misconduct involving the Company, its employees, customers and/or vendors, even if they are not involved with the misconduct itself. The Company can only do something about misconduct if it knows about it.

When concerns about integrity arise, we encourage employees to go to their supervisors, local Human Resources managers or in-house counsel. If their integrity concerns are not resolved, or they do not feel comfortable discussing them with anyone within the company, they can report their concern by phone to the Compliance and Ethics Hotline. Employees can find additional information on how to report integrity concerns in the Company's Compliance and Ethics Hotline Policy.

The Company's suppliers, contractors and other business partners can also report any business misconduct and ethics concerns via the Compliance and Ethics Hotline.

The Compliance and Ethics Hotline is managed by a third-party company and is available 24 hours a day, seven days a week. Anonymous reports may be made.

The Company investigates all Hotline reports and is committed to maintaining confidentiality to the maximum extent possible. The Company strictly prohibits retaliation against anyone who makes a good faith report.

Compliance and Ethics Hotline - Call Toll Free: (844) 465-0371

SECURITY & LEGAL

Phishing & Other Suspicious Emails

WARNING: Fraudulent Email Scam. Our parent company, Toyo Tire Corporation, has learned that its company name and/or those of its executives have been used in connection with email phishing scams. Such scams are intended to deceive or defraud by enticing recipients to provide sensitive information.

Reporting Suspected Phishing Attempts and Other Suspicious Emails. If you receive or have received such unsolicited email communications, please notify us immediately at Report@ToyoTires.com. Do not respond to these emails or communicate with the sender, and do not provide the sender with any personal or financial information. Also, do not click on any links included in the emails, or the attachments, as doing so may result in malware or a virus being loaded on the recipient's computer.

Protect the Security of Your Personal Information. Email scams and other internet security risks are not uncommon, and we recommend that you take steps to protect the security of your Personal Information and technology devices.