This Privacy Policy was last updated: January 29, 2009

This Privacy Policy is effective as of: February 3, 2009

NAVITIME JAPAN Co., Ltd (“Navitime”) is committed to protecting your privacy as set forth in this Privacy Policy (“Policy”). This Policy details certain policies implemented throughout Navitime governing Navitime’s use of personal data collected through the Navitime website located at: www.navitime.com (“Website”), as well as through Navitime’s proprietary GPS mobile application, “NAVITIME” (collectively, the “Software”) and any service provided by Navitime on the Website or in connection with the Software, including “Total Navi™” and customer support services (any Navitime services and the Software with collectively be referred to as the “Services”).

1.1		Collection of Personal Information. You can generally visit the Website without revealing any personally identifiable information about yourself. In certain sections of the Website and when you provide data to our servers or conduct transactions through the Services, however, Navitime may ask you to complete a registration form and invite you to ask us questions, provide us with feedback or request information. When you register for a user account, you will need to provide certain personal information such as your e-mail address, password, credit card number and/or PayPal ID and registered areas and routes. We may also collect information about you from the log-in process, your use of our Website and/or Services, cookies, chat or message boards, surveys or questionnaires or communications initiated by us or you via e-mail, phone or postal mail or in-person, including, without limitation, information that you voluntarily submit to us about third party affiliate or partner companies (e.g., telecom operators), such as your Access Log (as defined below), subscriber identity module card number (“SIMM-ID”), and/or user device information (e.g., smart phone type).
1.2		Access Logs. When you use the Services, Navitime servers automatically track information from server transactions such as your search history (including routes), web request, internet protocol address, browser type, browser language and/or the date and time of your request (“Access Logs.”). Navitime may use information from Access Logs to analyze trends, administer the Website and Services, track users’ movement, and gather broad demographic information. Navitime may combine personally and non-personally identifiable information to enable us to attribute usage of the Services to a particular computer or network for internal business purposes only. Navitime will not share such correlated information with third parties.
1.3		Cookies. When you visit the Website through browsers of certain devices (such as personal computers), Navitime sends one or more cookies to such devices. “Cookies” are small text files containing a string of characters that are stored on the user’s hard drive containing information about the user. Navitime uses cookies so that Navitime can uniquely identify your device and improve the quality of the Services and overall Website experience. Most browsers are initially set up to accept cookies. You can reset your browser to refuse all cookies or to indicate when a cookie is sent to you. In such cases, however, you will not be able to use some functions of the Services.
1.4		Other Web Sites. This Policy applies only to websites and services controlled or operated by Navitime. Navitime has no control over any external website or resource linked from hyperlinks contained on or in the Website. Such links do not constitute an endorsement by Navitime of those external websites. You acknowledge that Navitime is providing these links to you only as a convenience, and further agree that Navitime is not responsible for the content of such external websites. Your use of external websites is subject to the terms of use and privacy policies located on the linked to external websites.
1.5		You may decline to submit personal information, however, such refusal may prevent you from engaging in certain activities on the Website and/or receiving the Services.

2.1		Navitime may use your personal information to:
	(a)	Register you to download our Software;
	(b)	Contact you to provide you with Services or information you have requested, including the display of customized content;
	(c)	Provide you with notices regarding goods or services that you have purchased;
	(d)	Provide you with notices regarding goods or service that you may wish to purchase in the future[, provided that you have opted-in to receive these future product communications by checking the box during the registration process];
	(e)	Verify your authority to enter the Website,
	(f)	Develop new Navitime services and improve the content and general administration of the Website and Services; and
	(g)	Send you targeted advertising.
2.2		If Navitime uses your personal information for any purpose other than those for which it is collected and described in this Policy, Navitime shall ask for your consent prior to such use through an opt-in process on the Website or through the Software.

3.1		Navitime restricts access to personal information to Navitime directors, officers, employees, contractors and agents who need to know such information for the purposes described in this Policy and for operation, administration, development and/or improvement of the Website and/or Services. These individuals are bound by confidentiality obligations to Navitime.
3.2		Navitime employs procedural and technological security measures to protect against unauthorized access to or unauthorized disclosure, alteration or destruction of personal information. These measures include firewalls, password protection, secure socket layer and internal restriction on who in the company may access your personally identifiable information.

4.1		You consent that Navitime may or will share or transfer your personal information and the data generated by cookies and aggregate information with other companies and individuals outside of Navitime in the following circumstances:
	(a)	To vendors and service agencies that Navitime may engage to assist us in providing the Services to you. For example, when you use any fee-based Services, Navitime will provide your personally identifiable information (including, without limitation, internal user ID and product number) toPayPal, Inc. (and all their affiliate companies in the respective countries) and/or other payment processing companies, that Navitime chooses in its sole discretion from time to time, to process your payment. Such third-party entities may be obligated to protect your personally identifiable information consistent with the terms of this Policy.
	(b)	If Navitime reasonably believes that it is required to do so to: (i) by applicable law, regulation or governmental authority, (ii) enforce the Navitime Terms of Service, including investigation of potential violations thereof, or (iii) protect the rights, property or safety of Navitime’s licensors and/or users of the Website and Services.
	(c)	To a successor entity upon a merger, consolidation or other corporate reorganization in which Navitime participates or to a purchaser of all or substantially all of Navitime’s assets to which this Website relates.

5.1

Navitime recognizes the privacy interests of children, and Navitime encourages parents and guardians to take an active role in their children’s online activities and interests. The Services and the Website are not intended for children under the age of 13, and Navitime endeavors not to collect any personally identifiable information from children under the age of 13. Navitime targets its Services and this Website to adults and not to children under 13.

6.1

Due to the Internet’s rapidly evolving nature, Navitime may need to update this Policy from time to time. If so, Navitime will post its updated Policy on the Website on this page and post notice of the change so it is visible when users log-on for the first time after the change is posted so that you are always aware of what personally identifiable information we may collect and how we may use this information. Navitime encourages you to review this Policy regularly for any changes. Your continued use of this Website and/or continued provision of personally identifiable information to Navitime will be subject to the terms of the then-current Policy.

7.1

Navitime provides you with the ability to review, correct and delete certain of the personally identifiable information that you have provided to us; provided, however, that Navitime will retain a copy in its files of your name, contact information, credit card number or PayPal ID and password, Access Log, SIMM-ID, user device information and [registered areas and routes], even if removed, in order to resolve disputes or enforce Navitime’s Terms of Service. If you wish to review, correct or request the deletion of any information you have provided to us, contact us:

By e-mail: contact@navitime.com

By mail: Customer Support Div. - Personal Information Issues

Minami Aoyama Tokyu Bldg. 3-8-38 Minami Aoyama

Minato-ku, Tokyo 107-0062, Japan

If you have any questions about this Policy, please contact us via e-mail or at the address set forth above.