PRIVACY POLICY
TOYO PRIVACY POLICY
Effective: December 26, 2019
Introduction
Toyo Tire Holdings of Americas Inc. and our affiliates and subsidiaries (“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. By accessing or using our services, you agree to this privacy policy. We may change this privacy policy from time to time. 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:
· Regardless of whether you are accessing our services or websites via a personal computer, a mobile device or any other technology or devices now known or hereafter developed or discovered (each, a “device”);
· Regardless of whether you are accessing a website as a registered user (if offered) or other user of our website(s);
· On this website or through apps provided by us;
· In email, text and other electronic messages between you and this website, our apps, and/or services we provide, or by any other means between you and us;
· When you interact with our advertising and applications on third-party websites and services that include links to this privacy policy; and
· From sources other than you, such as personal information associated with you that may be provided to us by our service providers or business partners, as described below.
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:
· By which you may be personally identified, such as name, postal address, email address or telephone number.
· Other information provided by you or derived from your interactions with us or our services, such as device and advertising identifiers and information collected through cookies, web beacons or other tracking technologies.
· About your internet connection, the equipment you use to access our services, and usage details.
We collect this information:
· Directly from you when you provide it to us.
· Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons and other tracking technologies.
· From third parties such as our business partners.
Information You Provide to Us
The information we collect on or through our services that you provide to us may include:
· Information that you provide by filling in forms on our website(s). This includes information provided at the time of registering to use our services by creating a profile, subscribing to our service, posting material or uploading content, submitting job applications or requesting further services. We may also ask you for information when you enter a contest or promotion, or attend an event, that we sponsor, and when you report a problem with our services.
· Registration or correspondence requesting to receive alerts or requesting more information.
· Records and copies of your correspondence (including email addresses and telephone numbers), if you contact us.
· Your responses to surveys that we might ask you to complete.
· Details of transactions you carry out through our website(s) or related to our services, including for fulfillment of your orders. For example, you may be required to provide payment information before placing an order through our website.
· Your search queries on our website(s) or other services.
· Any other situation where you submit Personal Information on or through our website(s) or services.
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 collect certain information about your equipment, browsing actions and patterns, including:
· Details of your visits to our websites, including traffic data, location data, logs and other communication data and the services or resources that you access and use on the websites.
· Information about your computer and internet connection, including your IP address, operating system and browser type.
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:
· Estimate our audience size and usage patterns.
· Store information about your preferences, allowing us to customize our services according to your individual interests.
· Streamline your experience with our services.
· Recognize you when you return to our services.
· Provide you with content that is compatible with your interests.
· Research our users and develop new features and enhancements that will provide better services.
The technologies we use for this automatic data collection may include:
· Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser or using the cookie management options (the “Do Not Sell My Information” button) we provide on our websites. If you access our services from a new web browser, or clear all cookies from your web browser, we may not be able to access and apply the cookie management preferences you have set. If you do not accept cookies you may be unable to access certain parts of our services.
· Flash Cookies. Certain features of our websites may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our websites. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information on disabling Flash cookies, please visit Adobe’s website. Please be aware that if you disable or remove these technologies, some parts of our websites may not work.
· Web Beacons. Pages of our websites and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit the Company to, for example, count users who have visited those pages or opened an email and for other related website statistics (such as recording the popularity of certain website content and verifying system and server integrity).
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 may use this information to provide you with interest-based advertising or other targeted content. You may refuse to accept browser cookies by activating the appropriate setting on your browser or using the cookie management options (the “Do Not Sell My Information” button) we provide on our websites. If you access our services from a new web browser, or clear all cookies from your web browser, we may not be able to access and apply the cookie management preferences you have set. If you do not accept cookies you may be unable to access certain parts of our services.
Advertisers and service providers that perform advertising-related services for us and our partners in connection with our U.S. services may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. These companies may allow you to exercise certain choices regarding targeted advertising, including in relation to your use of mobile apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). You can learn more about the NAI and opt-out options on the NAI’s website.
Please be aware that, even if you opt out of certain kinds of targeted advertising, you may continue to receive other types of ads.
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 privacy@toyotires.com.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any Personal Information:
· To present our services, website(s) and content to you.
· To provide you with information, products or services that you request from us.
· To fulfill any other purpose for which you provide it.
· To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
· To notify you about changes to our services or any products or services we offer or provide though it.
· To allow you to participate in interactive features on our website(s) and services.
· To verify your identity.
· To detect, investigate and prevent activities that may violate our policies or be illegal.
· To perform statistical, demographic and marketing analyses of users of our services.
· In any other way we may describe when you provide the information.
· For any other purpose that is consistent with the purpose for which we collected the information, or with your consent.
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 may disclose Personal Information that we collect or that you provide as described in this privacy policy:
· To our subsidiaries and affiliates.
· To service providers, which are entities we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
· To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or a similar proceeding, in which Personal Information held by the Company about our users is among the assets transferred. If this happens, the recipient of the Personal Information will continue to honor the promises made in this privacy policy, or else provide you notice of any changes.
· To third parties to market their products or services to you if you have not opted out of these disclosures.
· To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our websites), we will transmit the contents of that email and your email address to the recipients.
· For any other purpose disclosed by us when you provide the information.
· For any other purpose that is consistent with the purpose for which we collected the information, or with your consent.
We may also disclose your Personal Information:
· To comply with any court order, law or legal process, including to respond to any government or regulatory request.
· To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
· If we believe disclosure is necessary or appropriate to protect the rights, property or safety of the Company, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Choices About How We Use and Disclose Your Information
You may have choices regarding how we use and disclose your information:
· Tracking Technologies and Advertising. You may refuse to accept browser cookies by activating the appropriate setting on your browser or using the cookie management options (the “Do Not Sell My Information” button) we provide on our websites. If you access our services from a new web browser, or clear all cookies from your web browser, we may not be able to access and apply the cookie management preferences you have set. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you do not accept cookies you may be unable to access certain parts of our services.
· Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your Personal Information with unaffiliated or non-agent third parties for promotional purposes, you can opt out by checking the relevant box located on the form on which we collect your data or by sending us an email stating your request to privacy@toyotires.com.
· Promotional Offers. If you do not wish to have your email address and/or contact information used by the Company to promote our own or third parties’ products or services, you can opt out by sending us an email stating your request to privacy@toyotires.com. If we have sent you a promotional email, you may use the email link to update your profile or send us an email asking to be omitted from future email distributions. This opt-out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.
· Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you may set your browser to refuse cookies or adjust your cookie management preferences (the “Do Not Sell My Information” button) on our websites. If you access our services from a new web browser, or clear all cookies from your web browser, we may not be able to access and apply the cookie management preferences you have set. If you do not accept cookies you may be unable to access certain parts of our services.
Accessing and Correcting Your Information
You may send us an email at privacy@toyotires.com to request access to, correct or delete Personal Information that you have provided to us. In some cases, we may not be able to delete specific information we have collected or may be required to also delete your user account (if applicable). We may not accommodate a request to delete or change information if we believe the change would violate any law or legal requirement, interfere with the Company’s ability to provide services or assert or defend its legal interests, or cause the information to be incorrect.
If you delete your user contributions, copies may remain viewable in cached and archived pages, or might have been copied or stored by other users. Please review our Terms of Use.
Information for California Residents
The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of Personal Information, as well as rights to access and control Personal Information. Certain information we collect may be exempt from the CCPA because it is considered public information (because it is made available by a government entity) or covered by a federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.
To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below in our California Privacy Notice.
California Privacy Notice:
Right to Information Regarding the Categories of Data Collected, Sold, and Disclosed
You have a right to obtain information regarding the Categories of Personal Information we have collected, sold, or disclosed. This information is provided below.
Right to Access Information
You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collected it, and the third parties and service providers with whom we shared it. To protect our customers’ Personal Information, we are required to verify your identify before we can act on your request.
Right to Request Deletion of Information
You have the right to request in certain circumstances that we delete any Personal Information that we have collected directly from you. To protect our customers’ Personal Information, we are required to verify your identify before we can act on your request. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.
Right to Information Regarding Participation in Data Sharing for Financial Incentives
You have the right to be free from discrimination based on your exercise of your CCPA rights. We may run promotions from time to time whereby we incentivize a consumer to share certain pieces of information with us; for example, we may offer a one-time discount if consumers sign up for our email marketing list. Participation in these incentives is voluntary, and you may opt out of the data sharing at any time.
Right to Opt Out of Sale of Personal Information to Third Parties
You have the right to opt out of any sale of data by the Company to third parties. To exercise this right, please visit our “Do Not Sell My Personal Information” webpage. Please note that your right to opt out does not apply to our sharing of data with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the data only for that function.
Right to Information about Certain Third-Party Disclosures
Residents of the State of California also have the right to request information regarding third parties to whom the Company has disclosed certain categories of Personal Information during the preceding year for the third parties’ direct marketing purposes.
How to Submit a Request
You may submit a request to exercise your rights by either:
(1) Filling out the relevant Consumer Data Request Forms available below:
c. Opt Out of the Sale of Personal Information
(2) By calling us at 1-800-442-8696.
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, and whether we disclose that information to external 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.
· Personal Identifiers:
o We collect your name, phone number, email address and contact address when you create an account or complete a transaction. If you choose to create an account, you will also be asked to create a username, and we will assign one or more unique identifiers to your profile.
o You provide us with payment information, which may be your credit card number or a bank account, when you complete a transaction.
o We do not collect your Driver’s License number or Passport number.
o We do not collect medical information or health information about you unless you choose to submit it in connection with a complaint or claim.
o We collect your IP address automatically when you use our services.
o We collect your device identifier automatically when you use our services.
· Protected Classifications: We collect your age in order to comply with laws that restrict collection and disclosure of data belonging to minors. We also collect gender when you register for events, submit a form, or provide a review or other information related to our products or services. We do not collect your racial or ethnic origin or sexual orientation.
· Commercial Information: When you engage in transactions with us, we create records of goods or services purchased or considered, as well as purchasing or consuming histories or tendencies.
· Biometric Information: We do not collect information about your physiological, biological, or behavioral characteristics.
· Internet or Other Electronic Network Activity Information: We collect information about your browsing history, search history and information regarding your interaction with websites, applications, or advertisements automatically when you utilize our services.
· Geolocation Information: As described above, we collect your IP address automatically when you use our services. We may be able to determine your general location based on your IP address. When you use our services for the first time, we may ask for your permission to collect your precise location (e.g., your GPS coordinates) or for your zip code or city and state. If you provide, or allow your device to provide, us with this information, we use it to make improvements to our products and services, and to provide recommendations and deliver relevant advertising.
· Audio, electronic, visual, thermal, olfactory, or similar information: If you contact us via phone, we may record your call. We will notify you if a call is being recorded at the beginning of the call. We also collect the information you provide to us via email communications. We do not collect your image or any thermal, olfactory or similar information.
· Professional or employment-related information: We do not collect information about your current employer or your employment history, unless you are an employee, former employee, or job applicant. If you apply for or obtain employment with us, we will provide you with our Workplace Privacy Notice.
· Education information: We do not collect any information about the institutions you have attended or the level of education you have attained unless you are an employee, former employee, or job applicant. If you apply for or obtain employment with us, we will provide you with our Workplace Privacy Notice.
· Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics: We may analyze your actual or likely preferences through a series of computer processes and may use information provided by our service providers to determine such preferences. On some occasions, we may maintain these observations in a profile for our internal use.
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 and the services they provide are:
· Billing and collection providers, such as payment processors and organizations that assist us in assessing your credit and payment status.
· Auditing and accounting firms.
· Professional services consultants, such as firms that perform analytics, assist with improving our programming, provide legal services or supply project-based resources and assistance.
· Analytics services, including entities that analyze traffic to and on our websites, and assist with identifying and communicating with potential customers.
· Security vendors, such as entities that assist with security incident verification and response, service notifications, and fraud prevention.
· IT vendors, such as entities that assist with website design, hosting and maintenance; data and software storage; and network operation.
· Other business support services.
We also sell some information to third parties. A company may be considered a third party either because the purpose of sharing is not an enumerated business purpose under California law, or because our contract does not restrict them from using Personal Information for other purposes. To “sell” data means to disclose it to a third party for monetary or other benefit. The data that we sell is as follows:
· Personal Identifiers:
o We provide your contact information to directory services providers.
o We provide your IP address, device identifiers, and tracking information to our advertising partners.
· Geolocation Data: We provide the location data we collect about you as described above to our advertising partners and to our business partners.
· Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics: We provide our observations about you to our advertising partners.
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.
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.
How Long Do We Keep Your Information?
The Company and its service providers may retain information (including your profile information) for a commercially reasonable time for backup, archival and/or audit purposes. If you have any questions, please contact us directly at privacy@toyotires.com.
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. Wherever your Personal Information is transferred, stored or processed by the Company, we will take commercially reasonable steps to safeguard your Personal Information. By registering for and/or using the services you consent to the transfer of information to the United States or to any other country in which the Company or its service providers maintain facilities and the use and disclosure of information about you as described in this privacy policy.
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 or comments about this privacy policy 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 privacy@toyotires.com. For all requests, please include your name, street address, city, state, zip code and email address (your street address is not required if you wish to receive a response to your request via email), include the name and URL (if applicable) of the website, application or other interactive service, indicate your preference on how our response to your request should be sent (email or postal mail) 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.