Privacy Policy for the Service Agreement for the ClarionMiND Internet Portal
and ClarionMiND Products and Services

1    Consent declaration to the processing of my personal data
Clarion Co. Ltd and Clarion Europe SAS (Clarion) complies with European data protection laws in every process relating to personal data. The following declaration provides an overview, which kind of data we collect, in which manner these data are processed and transferred, which security measures we have adopted and how you may obtain information on your personal data.
Personal data will be transferred to Clarion Co Ltd. in Japan. Clarion points out that not in all cases will Japanese data protection rules provide the same standard of data protection than the standard under European data protection laws. However, all companies of the Clarion Group ensure the application of the same level of data protection while processing your personal data as according to European laws.
Personal data means individual data about personal or factual conditions of a specific or determinable person such as name and address, telephone number and IP-address, as well as membership name and password.
Please read the Consent Declaration set out below carefully.


I hereby consent to


1.1    Clarion Europe S.A.S., Z. I. du Pre a Varois, 54670 Custines, France  (Clarion) and Clarion Co. Ltd., 7-2 Shintoshin, Chuo-ku, Saitama-shi, Saitama, 330-0081, Japan, to collect personal data and to transfer them to the Clarion Group, to save, use and process personal data for the conclusion, performance and processing of the service agreement concluded between me and Clarion for the use of the ClarionMiND Internet Portal under URL http://my.clarion.com and ClarionMiND products and services (Service Agreement).
1.2    other corporations affiliated to Clarion to process and to use personal data which has been saved and collected by Clarion Group to the extent necessary for the conclusion, performance and winding-up of the Service Agreement.
1.3    Clarion to collect, process and use personal data by employing cookies for the navigation on the ClarionMiND Internet Portal including my personal account.
1.4    Clarion to process and use my IP-Address during my use of the ClarionMiND Internet Portal.
1.5    Clarion to employ my personal data for marketing measures (e.g. sending newsletters) and to Clarion to transfer personal data to third parties, which have been obligated to abide with Clarion’s Privacy Policy. I confirm that I have been informed of the possibility to cancel the receipt of marketing measures in my personal profile with immediate effect under https://my.clarion.com/en-gb/inquiry/10000. I further consent to Clarion collecting and using my personal data in order to tender me personalized offers of the Clarion Group fitted to my interests. I have been informed of the possibility to cancel these offers with immediate effect at https://my.clarion.com/en-gb/html/account.
1.6    Clarion to disclose my membership name and comments on the ClarionMiND Internet Portal membership forum.
1.7    Clarion to transmit personal data to third parties for the conclusion, performance and processing of the Service Agreement, e.g. to provide further customer services. I have been informed of the possibility to cancel the transmission of my personal data to third parties under https://my.clarion.com/en-gb/inquiry/10000.
1.8    Clarion, if necessary for the case at hand, to collect, process and use my personal data which is required to detect and prevent criminal or illegal acts or breach of contract under the Service Agreement.
1.9    Clarion, to the extent not already provided by law, to process and to transfer personal data to the criminal or public authorities competent for public security and criminal prevention and prosecution.
1.10    Clarion, to the extent that the transfer of my personal data is not already provided by law, to transfer my name and address to any third party to the extent necessary for the adherence to legitimate interests of aforementioned third party. A disclosure of personal data is not necessary if the third party is a Member and may contact me directly via the ClarionMiND Internet Portal or if criminal investigation proceedings have been or may be initiated.
    I have been informed that I may at any time at URL https://my.clarion.com/en-gb/html/account or through ClarionMiND, Clarion Europe SAS, 18 rue Grange Dame Rose, 78140 Velizy-Villacoublay, France, Tel. 0033 1 39 45 19 20, clarionmind_pp[at]clarion.fr review the personal data saved by Clarion related to my person, my data’s origin and recipient as well as the purpose it has been collected, processed and used for.
I have been informed that I may at any time revoke this declaration of consent with effect from the day of revocation. Upon my request sent per e-mail from the URL https://my.clarion.com/en-gb/inquiry/10000, all personal data collected by Clarion in connection to the Service Agreement will be deleted or disabled immediately.

2    Privacy Policy of Clarion  for use of the ClarionMiND Internet Portal and ClarionMiND Products and Services
The Clarion Group knows that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. This Policy describes our privacy policy with respect to information that we collect as the result of your use of Clarion’s Mobile Internet Navigation Device or other Clarion products and devices (collectively, the ClarionMiND Product) and the associated ClarionMiND Internet portal located at URL http://my.clarion.com (the ClarionMiND Internet Portal).
What Information Do We Collect And How Do We Use It?
The information we gather falls into two categories: (1) personal information you supply, and (2) anonymous tracking information collected as you use the ClarionMiND Product and navigate through the ClarionMiND Internet Portal.
As used in this Privacy Policy, Personal Information is information about you that is personally identifiable, such as your name, address, e-mail address, or phone number.

Anonymous Information means information that is not associated with or linked to your Personal Information; Anonymous Information does not permit the identification of individual persons.
If you do not agree with the terms and conditions of this Privacy Policy we request that you immediately cease using and accessing the ClarionMiND Internet Portal or the ClarionMiND Product as well as the products and services for which you need to provide Personal Information. However, your consent to the transfer of personal data to third parties, especially for marketing purposes, is not a necessary requirement for the use of the Services.

Collection of Personal Information
The Personal Information we gather from you helps us learn about our visitors and customers. We use this information to provide you with our products and services and the products and services of our carefully selected partners, to develop new products and services, to better tailor the features, performance and support of our products and services, and to offer you additional information and opportunities.
We collect Personal Information that you submit to us voluntarily through our ClarionMiND Internet Portal, the use of the ClarionMiND Product, or your use of our other products and services. The types of Personal Information we collect are:
If you set up a membership account, you will be provided a membership ID, and we may ask you to submit the following information: your name, nickname, address, gender, your birthday (month and day only), the range of your age, email address, country of residence, occupation and hobbies. Some of this information will be submitted automatically by your ClarionMiND Product when you register it.
If you request customer support services for any of Clarion’s products and/or services, we will collect Personal Information to enable us to provide such customer support services to you, including your name, mailing address, phone number, email address, and contact preferences. We may also collect other information about the Clarion products you own, such as the serial numbers, date of purchase and information related to a support or service issue, some of which might be Personal Information.
By using a bulletin board or a chat room at our ClarionMiND Internet Portal, you should be aware that you are sharing all information you post on such bulletin boards or chat rooms with other users, including any Personal Information that you may choose to share. Please choose the information that you share carefully and accordingly. Clarion is not responsible for any use of information you provide on a bulletin board or in a chat room by any third party.
Clarion may collect Personal Information through surveys for market research purposes to gain a better understanding of our customers, to improve our products and services, and to develop new products and services. The information we collect in such instances depends on the survey, but might include your name, address, age, information about your use of our services and products and the like.
Any Personal Information which you supply to Clarion shall be true, complete and accurate in all respects. You agree to notify Clarion immediately of any changes to your Personal Information via our ClarionMiND Internet Portal.

Collection of Aggregate Information
When you use the ClarionMiND Internet Portal, we may collect Anonymous Information, such as your browser type, the type of operating system you use, the domain name of your Internet service provider, and pages visited on the ClarionMiND Internet Portal. None of this information identifies you personally; we collect it for aggregate reporting on site activity. For example, we may want to know how long the average user spends on the ClarionMiND Internet Portal, or which pages or features get the most attention. We use this information to make the site more useful to our customers.  
1. Web Beacons. We use "Web Beacon" (also known as "clear GIF", "pixel tag", "data tag" or "image tag") technology to collect Anonymous Information about how our site is used. We use this information to make improvements to our site and to help us plan for technical improvements. This information will not identify you or any other user of our web site as an individual.

2. E-Mail. We use clear gifs in our HTML - based emails that tell us whether or not you can accept HTML images and, if you can accept HTML, whether or not you viewed the e-mail.  We use this information to help us make e-mails about our products and services more useful and interesting. This process does not leave any information on your computer, nor does it collect information from your computer.  We do not sell this information to others, and we only use it to improve our e-mail communications with you.

3. Cookies. A cookie is a block of text placed in a file on your hard drive by a site you've visited. We use cookies to understand how our visitors click to our ClarionMiND Internet Portal and what pages they view during their visit. Cookies allow us to personalize your experience. We do not store any Personal Information in any cookie at any time unless you have agreed to do so. The “help” function on most browsers contains information on how to set your browser to notify you before accepting cookies or to disable cookies entirely. However, if you don’t accept cookies, you won’t be able to take advantage of various features on our site that are available to other visitors.

4. ClarionMiND Product. Clarion may gather Anonymous Information from your ClarionMiND Product when you are using it or when you are connecting it to a computer. This Anonymous Information may include information on how long it took you to travel certain routes, traffic patterns and on any technical glitches you may have encountered. The nature of the Anonymous Information that your ClarionMiND Product transmits to us will not enable us to trace it back to an identifiable person.

Do We Share the Information We Receive?
Your Personal Information is used by Clarion in the following ways:
·    To Provide Services: Clarion may use your Personal Information to perform its obligations resulting from the delivery of Clarion products and/or services to you. Clarion uses your Personal Information to respond to your questions and to fulfil your requests or to manage interactive customer programs.
·    Third Party Uses: Clarion is entitled to contract third parties for its fulfilment of its obligations hereunder. These third parties may help Clarion to process information, fulfil customer orders, deliver products to you, manage and enhance customer data, provide customer service, assess your interest in our products and services or to conduct customer research or satisfaction surveys. These third parties are also obligated to protect your Personal Information in accordance with this policy. Clarion is and will remain responsible for the use of your Personal Information. Clarion will provide for the integrity of your personal data and only share, collect or process personal information with third parties for the conclusions, performance and winding-up of the Service Agreement, market research, marketing uses or the design of the ClarionMiND Internet Portal subject to your consent or where already permitted by law.
·    To Contact You: Clarion also uses Personal Information to contact you, always on an “opt-in” basis, via mail or via e-mail to inform you of our (new) products and/or services and the products and services of our carefully selected partners, promotions we may offer, to submit a customer survey and any other marketing activity. Clarion is entitled to contract third parties to perform its direct marketing activities. Clarion may use your Personal Information to conduct market research, to improve our products and/or services, to provide more responsive customer service and to improve our ClarionMiND Internet Portal, products and services subject to your consent.
·    To Comply with the Law: Clarion is entitled, if necessary for the case at hand, to collect, process and use personal data which is required to detect and prevent criminal or illegal acts. Further, Clarion is entitled to transfer personal data if required by authoritative or administrative order, to the extent permissible by data protection law. Clarion is also entitled to transfer the name and address of a member to a third party to the extent necessary for the adherence of the third party’s legitimate interests.
·    Between Clarion Entities: Clarion is entitled to exchange any Personal Information between the Clarion entities including, but not limited to, those based in countries within and outside the EU, for the purposes described in this Privacy Policy.
·    Transformative Uses: Clarion may create Anonymous Information records from Personal Information by excluding information (such as your name) that makes the information personally identifiable to you. We may use this Anonymous Information to analyze usage patterns, to improve our services and reserve the right to use and disclose Anonymous Information to third parties in its discretion.
·    Business Transfers:  As we continue to develop our business, we might develop, sell or buy subsidiaries or new business units. In such transactions, customer information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy (unless, of course, you consent otherwise). Also, in the unlikely event that Clarion, or substantially all of its assets are acquired, customer information will be one of the transferred assets.

How Secure is the Information that We Collect?
We recognize our responsibility to protect the Personal Information you entrust to us. We take precautions including administrative, technical and physical measures to safeguard your Personal Information against loss, theft, and misuse, as well as unauthorized access, disclosure, alteration, and destruction.  
Despite all these precautions, no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. You can also take precautions to protect your Personal Information when you are on the internet. Change your passwords often using a combination of letters and numbers, and make sure you use a secure internet browser.

How do I Opt Out or Change my Information?
You can access and update information in your membership profile at any time by logging in at the ClarionMiND Internet Portal with your email address and password. Once you have logged in, you can update your name, email, password, and/or change your address and preference to receive marketing information.  
We recognize that you may not want to receive offers or other information from Clarion or a third party. At any time you may request to discontinue receiving offers or other information from us or request that we not provide your information to third parties for such marketing purposes by updating your account profile, by following the instructions included in each communication, or by contacting customer service at https://my.clarion.com/en-gb/inquiry/10000.

Children’s Policy
We understand and share your concerns regarding your children’s access to the internet and the internet’s access to your children. We do not knowingly request or accept information submitted to this site by any visitor under 18 years of age.

Terms of Use, Notices, and Revisions
If you choose to visit or use the ClarionMiND Internet Portal, your visit and any dispute over privacy is subject to this Policy and our Terms of Use, including limitations on liability and damages, applicable laws, and the venue for addressing disputes.
Our business changes constantly, and our Privacy Policy and the Terms of Use will change also. We may e-mail periodic reminders of our notices and conditions, unless you have instructed us not to, but you should check our site frequently to see recent changes. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. We stand behind the promises we make, however, and will never materially change our policies and practices to make them less protective of customer information collected in the past without notifying affected customers, either by communicating directly with those customers or by posting the changes on this site.

Privacy Support
If you think that Clarion’s use of your Personal Information is inconsistent with the purpose for which you have provided it to Clarion, as described in this Privacy Policy, or if you have any questions or suggestions regarding this Privacy Policy, please contact:
    
Name/designation :     Solution planning department, Marketing division
Department :     Clarion Co., Ltd.
Address :     7-2, Shin-toshin, Chuou-Ku, Saitama-shi, Saitama, 330-0081, Japan
Phone Number :     0081-48-601-4535 (Only in English)
Email address :     clarionmind@clarion.co.jp (Only in English)