PRIVACY POLICY

“K” Line Logistics(Japan)Ltd. (“We”) considers it as a very important social responsibility to appropriately protect every piece of personal information collected or kept by us in compliance with the Personal Information Protection Act and the Use of Numbers to Identify a Specific Individual in Administrative Procedures Act. To that end, we have mapped out the following protection policy by which we will manage to strictly protect personal information:

1. Fundamental Concept for Protection of Personal Information

In recognition of the importance of personal information, we will handle personal information through appropriate protective measures in the course of carrying out our business. We will ensure that all officers and employees comply with acts and in-house rules concerned so that each of us conforms in accordance with social confidence and expectations.

2. Collection of Personal Information

When collecting personal information, we will first make clear why it is needed and then collect it within necessary limits. Collection will be carried out with a priority to legality and fairness.

3. Providing Personal Information to a Third Party

We will appropriately administer the handling of collected personal information and will neither disclose nor pass it to any third party, except in the following cases. Neither we will disclose nor pass the Specific Personal Information to any third party, except in the law and ordinances:

1. （１）where the person himself or herself agrees to disclosure or passing it on;

   
   

   （２）where it is recognized that in reply to inquiries by the person himself or herself, we have no alternative than to disclose his or her personal information to any member of our group company;.

   
   

   （３）here there is an urgent need for disclosure of his or her personal information with a view to an impending danger to human life, body or property;

   
   

   （４）where disclosure of personal information is legally necessary.

4. Administration of Personal Information

Personal information is being put under appropriate administration with required and reasonable protective measures under way to guard against unfair access, loss, falsification, leakage, etc. from the perspective of proper information technology and administration. If any negligence in administration were to occur, such as leakage of such data, we would be in a position to take immediate and effective countermeasures.

5. Imposing a Duty on Those Entrusted with this Service

We will commit ourselves to imposing a duty on any third party who is provided with personal information. On a contract basis, they will be required to strictly manage any personal information provided to them just as appropriately as we ourselves will do.

6. Reviewing How to Comply with Relevant Acts and Norms

We are committed to continuous improvements in the above items to assure complete protection of personal information, as well as to complying with every act and norm concerned.

7. For further details

Kindly contact Department of General Affairs and Human Resources.

“K” LINE LOGISTICS, LTD. (hereinafter referred to as the “Company”) is committed to process the Personal Data of the Data Subject in the EEA, in accordance with the following policies.

1. Personal Data

In this Privacy Policy, the Personal Data means any data which are able to identify natural person (hereinafter referred to as “Data Subject”)., including but not limited to his or her names, addresses, birth dates, telephone numbers, e-mail addresses, nationalities, occupations, company names, IP addresses and MAC addresses.

2. The purpose of the Processing of the Personal Data in the Company

The Personal Data is possessed by the Company for the purposes as follows:
Communicating with the Data Subject, arranging the shipping and delivery, reporting to relevant agencies, notifying the shipping and delivery information, submitting quotation, service proposal and presentation, managing customer relationship, and accounting.

3. Legal Grounds for Processing the Personal Data

The Company relies on the following legal grounds to process the Personal Data:
Consent - The Company may process the Personal Data for the purposes listed above based on explicit permission from the Data Subjects to do so, and without such provision, the Company may not provide appropriate services to, or fulfil necessary obligations under contracts with the Data Subjects. The Data Subjects may withdraw their consent to this processing at any time. However, this will not affect the lawfulness of any processing carried out before withdrawal of the consent.
Performance of a contract – The Company may need to collect and process the Personal Data to enter into a contract with the Data Subject or to perform obligations under a contract with them.
Legitimate interest – The Company may process the Personal Data for our legitimate interests.
Compliance with law or regulation – The Company may process the Personal Data as necessary to comply with applicable law/regulation.

4. Transfers

The Personal Data may be transferred to entities in countries or jurisdictions outside the EEA such as Japan. Please note that such countries or jurisdictions may not have the same data protection laws as the EEA and would not afford many of the rights conferred upon the Data Subjects in the EEA.

5. Rights of the Data Subject

The Data Subject may request from the Company access to, rectification or erasure of, restriction of, receipt of or transmission to third parties of the processing of the Personal Data. The Data Subject may object to the data protection authorities with jurisdiction over the Company or the location of the Data Subject’s domicile with regard to the processing of the Personal Data.

6. Contacts

In the event of any questions or concerns regarding the Privacy Policy or the processing of the Personal Data by the Company, or any requests, etc., concerning the access to, rectification or erasure of, restriction of, receipt of or transmission to third parties of the Processing of the Personal Data, please contact the Company. The team in charge of data protection at the Company is the Legal Department.
The Company determines the purpose and means of the processing of the Personal Data. The contact information for the Company is as follows:

1. （１）The Company

   “K” LINE LOGISTICS, LTD.
   KLL Nihonbashi Bldg., 8-16, Nihonbashi Honcho 1-chome, Chuo-ku, Tokyo, 103-0023, JAPAN
   +81-3-5255-5070

2. （２）Representative

   The contact information for the Company’s representative is as follows:
   Legal Department [e-mail ; les@jp.klinelogistics.com]

7. Compliance with applicable laws

With respect to the processing of the Personal Data, the Company shall comply with the General Data Protection Regulation and related laws and regulations, and shall observe the guidelines of competent government agencies and industry guidelines.

8. Retention Period

The Company shall retain the Personal Data as long as the Company requires such data to provide the services to the Data Subject, but shall promptly delete the same in the case that such data is no longer necessary.

9. Safety management measures

With respect to the processing of the Personal Data, the Company shall properly take organizational safety management measures, and technical safety management measures.

10. Continuous improvement in the management system.

The Company shall regularly, continuously and flexibly revise the management system and rules according to the changes in technology and applicable law. The Company shall actively work towards the protection of the Personal Data by continuously improving the management system on a timely basis and in an appropriate manner.

11. Amendment to the " Privacy Policy"

The Company may amend the Privacy Policy by publishing the amended Privacy Policy on the Company’s website without any individual notice to the Data Subject.

“K” LINE LOGISTICS, LTD. (hereinafter referred to as “we,” “our,” or “us”) respects your concerns about privacy. This Privacy Policy for the California Consumer Privacy Act (hereinafter, “CCPA Privacy Policy”) applies solely to California consumers and addresses the Personal Information (as defined below) that we collect online and offline. This CCPA Privacy Policy does not apply to our job applicants, employees, contractors, owners, directors, or officers, where the Personal Information we collect about those individuals relates to their current, former, or potential role(s) at us.

This CCPA Privacy Policy uses certain terms that have the meanings given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”), including:

1. •“Personal Information,” which 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 consumer or household.

2. •“Sell,” “selling,” “sale,” or “sold,” which means the selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, your Personal Information by us to another business or a third party for monetary or other valuable consideration.

1. Our Collection, Use, and Disclosure of Personal Information

A. Categories, Sources, and Purposes of Your Personal Information Collected or to Be Collected

The table below describes the categories of Personal Information (as listed in the CCPA) that we may collect, and have collected during the 12-month period prior to the effective date of this CCPA Privacy Policy.

Business or Commercial Purposes. The following is a list of the business or commercial purposes for which the categories of Personal Information will be, or was, collected or used during the 12-month period prior to the effective date of this CCPA Privacy Policy:

1. •Performing services on our behalf or on behalf of another, including fulfilling transactions, processing payments, and other services

2. •Undertaking activities to maintain the quality or safety of, or improve, a service which we may control or provide

3. •Communicating with business partner contacts and group company contacts about the transportation services, including making arrangements for cargo shipments and exports/imports, issuing air waybills, sending pre-alerts, sharing information about cargo arrangement progress and break bulk charges, and introducing and developing the relevant systems

4. •Building up and managing business relationships with actual and potential business partners

5. •Submitting necessary documents for customs clearance to customs and other relevant authorities

6. •Evaluating and improving our website

Categories of Sources. The following is a list of the categories of sources from which Personal Information was collected during the 12-month period prior to the effective date of this CCPA Privacy Policy:

1. •Actual or potential employees and officers of our business partners

2. •Our group companies

3. •Website visitors and users

B. Sharing of Your Personal Information

(A) Sale of Your Personal Information

The table below describes: (i) the categories of Personal Information (as listed in the CCPA) that we may have sold during the 12-month period prior to the effective date of this CCPA Privacy Policy; and (ii) the categories of third parties to whom we have sold such Personal Information during the 12-month period prior to the effective date of this CCPA Privacy Policy.

Business or Commercial Purpose. The following is a list of the business or commercial purposes for which Personal Information was sold during the 12-month period prior to the effective date of this CCPA Privacy Policy:

1. •Performing the transportation services, including making arrangements for cargo shipments, exports/imports, and cargo collection

2. •Entering into an agreement regarding the use of our warehouse

Children’s Personal Information and Opt-In Right. We do not sell, and have not sold the Personal Information of minors under 16 years of age without their affirmative authorization if we have actual knowledge of the individual’s age.

(B) Disclosure of Personal Information for a Business Purpose

The table below describes: (i) the categories of Personal Information (as listed in the CCPA) that we may have disclosed for our operational business purposes during the 12-month period prior to the effective date of this CCPA Privacy Policy; and (ii) the categories of third parties to whom we have disclosed such Personal Information for our operational business purposes during the 12-month period prior to the effective date of this CCPA Privacy Policy.

2. Your Rights and Requests

If you are a California consumer, you have certain choices regarding your Personal Information, as described below:

Ⅰ. Acces: You have the right to request, twice in a 12-month period, that we disclose to you the following information we have collected, used, disclosed, and sold about you during the 12 months preceding your request:

1. (Ⅰ)The categories of Personal Information we collected about you;

2. (Ⅱ)The categories of sources from which we collected such Personal Information;

3. (Ⅲ)The business or commercial purpose(s) for collecting such Personal Information about you;

4. (Ⅳ)The categories of third parties with whom we shared such Personal Information;

5. (Ⅴ)The specific pieces of Personal Information we have collected about you; and

6. (Ⅵ)The categories of Personal Information we sold with regard to you and the categories of third parties to whom such Personal Information was sold.

Ⅱ. Deletion: You have the right to request that we delete certain Personal Information we collected from you.

Ⅲ. Sale: You have the right to opt-out of the sale of Personal Information.

How to Submit a Request. To make an access or deletion request (described above), please contact us by any of the following means:

1. ◦Toll Free Phone : 1-888-338-6686

2. ◦E-mail : HQ@us.klinelogistics.com

To prevent your Personal Information from being sold, you can contact us via the link below as well as to allow consumers to submit their opt-out requests.

1. ◦Sending via the web form on our website
   URL: https://www.us.klinelogistics.com/Kline/Contact
   ※Please write a message containing “Do Not Sell My Info” or “Do Not Sell My Personal Information”.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your Personal Information or complying with your request. Upon receiving an access or deletion request from you, we will first verify your identity by requiring you to submit your name and e-mail address, and by matching the information you provide with what we already have on file

If you designate an authorized agent to make an access or deletion request on your behalf, we may require you to (1) provide the authorized agent signed permission to do so, (2) verify your own identity directly with us (as described above), and (3) directly confirm with us that you provided the authorized agent permission to submit the request.

Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

3. Changes to this CCPA Privacy Policy

We may change this CCPA Privacy Policy from time to time. The “Date last updated” at the top of this page states when this CCPA Privacy Policy was last updated; any changes will become effective upon us posting the revised CCPA Privacy Policy.

We will post a prominent notice on the site to notify you of any significant changes to this CCPA Privacy Policy and indicate the date it was most recently updated.

4. Contact Us

If you have any questions or concerns regarding this CCPA Privacy Policy or our privacy practices, please contact us at:

“K” LINE LOGISTICS, LTD.
KLL Nihonbashi Bldg., 8-16, Nihonbashi-Honcho 1-chome,
Chuo-ku, Tokyo 103-0023, Japan
Toll Free Phone : 1-888-338-6686
E-mail : HQ@us.klinelogistics.com or les@jp.klinelogistics.com