To Our Customers in the EEA*Region

NOTICE(RE: Handling of Personal Data of Our Customers in the EEA*Region)
SUBARU TECNICA INTERNAIONAL INC. (“we”, “our company”) places emphasis on our customers’ privacy, andendeavors to protect our customers’ personal data in accordance with laws and regulations applicable to thehandling of personal data, including the General Data Protection Regulation. We hereby notify you on ourhandling and use of personal data of our customers in the EEA Region.
*EEA: European Union member states and European Economic Space (EU, Iceland, Lichtenstein and Norway)
１． Personal Data of Our Customers
The personal data of our customers which we collect, handle and use is as follows.
(ⅰ)

Name, job title, age, user name, address, telephone number, email address;(ⅱ)

Information connected to the products and services provided by our company;(ⅲ)

Information concerning the type and language of the internet browser, operating system, internet
protocol address and cookies used by our customers; and(ⅳ)

Other personal data separately set forth.

２．Purpose of Use of Personal Data of Our Customers
We use the personal data of our customers within the extent of the following purpose of use.
(ⅰ)

To announce products and services handled by our company and various events and campaigns heldby our company;(ⅱ)

To plan quality improvement, market analysis, plans and developments and sales measures of theproducts and services, etc. handled by our company or to consider plans to improve customer
satisfaction, and to conduct surveys for these purposes;(ⅲ)

To carry out recalls, remediation measures and service campaigns, etc.;(ⅳ)

To respond to various contacts, requests, consultations and complaints;(ⅴ)

To perform services accepted by our company;(ⅵ)

To comply with laws and regulations, bylaws and other regulations; and(ⅶ)

For use within the extent of the purpose of use clearly specified or notified upon the acquisition of
the personal data of our customers.

３．Handling of Personal Data of Our Customers
We collect, handle and use (“Handling”, "Handle") the personal data of our customers in the following
events.
(ⅰ)

When our customer consents to the Handling of its own personal data for one or more
specific purposes;(ⅱ)

When Handling is required for the performance of an agreement to which our customer is a party, or
when Handling is required for the implementation of proceedings at the request of our customer prior
to the execution of an agreement;(ⅲ)

When Handling is required for compliance with legal obligations to which we should be subject to;(ⅳ)

When Handling is required for the protection of the material interest of our customer or any otherperson;(ⅴ)

When Handling is required for carrying out services for exercising public interests or publicauthority entitled to our company; and(ⅵ)

When Handling is required for legitimate interests sought by our company or a third party.

４． Handling by a Third Party
1) A third party may Handle the personal data of our customers in the following events.
(ⅰ)

We may entrust part of our services to a third party such as marketing companies and IT service
providers, and such third party may Handle the personal data of our customers. In such case, theHandling of personal data of our customers will be carried out in line with the purpose of use of thepersonal data of our customers in Paragraph 2 under our instructions.

(ⅱ)

Personal data of our customers may be Handled by affiliates of our company in order to promptly
and smoothly respond to our customers’ requests.

2) We will ensure that such third party and affiliates take measures for safety management in Paragraph 6even in the events of (i) and (ii) above.
５．Disclosure and Provision to a Third Party
We may disclose the personal data of our customers to a third party in the following events.
(ⅰ)

If disclosure of personal data of our customers is required by laws and regulations; and(ⅱ)

If such disclosure is otherwise set forth in laws and regulation;

６．Measures for Safety Management of Personal Data of Our Customers
We will take appropriate technical, physical and organizational safety management measures for theprevention of unauthorized access to personal data of our customers, loss, destruction, falsification,divulgence, etc. of personal data of our customers and other safety management of personal data of ourcustomers. We will assume no liability for the security of personal data of our customers in the website ofother companies linked in our website. The handling of the personal data of our customers in the linked
websites may also be confirmed at such linked websites.
７．Exercise of Rights Concerning Personal Data of Our Customers
You may exercise the following rights with respect to your own personal data, to the extent within theapplicable law.
(ⅰ)

Right to object to our collecting, handling or using your personal data;(ⅱ)

Right to receive necessary information when we collect your personal data;(ⅲ)

Right to access your personal data ;(ⅳ)

Right to request for amending your personal data;(ⅴ)

Right to request for the deletion of your personal data;(ⅵ)

Right to request for restrictions on the handling of your personal data;(ⅶ)

Right to seek data portability of your personal data; and(ⅷ)

Right to withdraw your own consent at any time.

Please contact the following when you seek to exercise any of the rights above. We will respond to your requests
within one (1) month, in principle. We may reject your offers to the extent permitted by laws and regulations,etc. You may file a complaint to the Data Protection Supervisory Authority if you have any complaints against ourresponse to your requests or if you have any complaints with respect to our method of handling your personal
data.
Customer Support, Sales Department, Subaru Tecnica International Inc.
3-9-6 Osawa Mitaka Tokyo 181-0015 Japan
８．Retention Period of Personal Data of Our Customers
The retention period of the personal data of our customers which we collect shall apply to either of thefollowing: (i) the period required for using the personal data of our customers to the extent within thepurpose of use and (ii) the period required under laws and regulations.

９．Cookies
Part of the contents of our website uses cookies and other automated information collection means toimprove services and to provide more appropriate services to our customers. While the cookies function
may be disabled by setting your browser, certain functions of our website may not operate without cookies.
10．Amendments to this Notice
We retain the right to amend or update this Notice, without restricting the rights set forth herein.
Final Revision on September 17, 2019
Chief Privacy Officer
President

Yasuo Hiraoka