IDEMITSU LUBRICANTS AMERICA CORPORATION
STATEMENT OF PRIVACY POLICY

Idemitsu Lubricants America Corporation (“ILA”) recognizes and respects your online privacy and is committed to providing adequate data protection and full compliance with applicable data privacy laws. This Idemitsu Lubricants America Corporation Statement of Privacy Policy (“Privacy Policy”) outlines our security structure and privacy procedures applicable to information obtained through the company's website pages. Privacy policies for information collected from any other source may be different than the policies expressed here. By visiting www.ilacorp.com and its related web pages (the “Site”), you are accepting the practices in this Privacy Policy.

How do we collect information?

At ILA, we do not collect any personally identifiable information about you through our website unless you voluntarily provide it. You may opt-out of providing such personally identifiable information by simply not providing it or discontinuing your use of the Site. However, certain Information may be automatically received when you visit our Site regardless of any direct communication you may have initiated. Such information may include: the name of the domain from which you access the Internet, the Internet protocol (IP) address of the computer you are using, the browser software you use and your operating system, the date and time you access our Site; the geographic location from which you access our Site the Internet address (URL) of the web site from which you linked directly to our Site and other similar information. We may use this information to monitor and analyze the usage of our Site for marketing, enhance our customers' browsing experiences, determine aggregate information about our user base and usage patterns, perform statistical analysis and profiling of our individual customers or for other similar purposes.

We may also collect information which you provide to us through email or other entries you make on the Site. You may give us general identity information about yourself (e.g., your name, company name, business address, business telephone number, business email address) and more detailed information for specific purposes (e.g., your shipping address, your credit card information (the card holder’s name, the credit card number, the expiration date of the card, the card security code on the back of the card), special interests in products or industries, your comments about the products, ILA, or the Site, etc.). Such information may be used by us to assist in providing goods and services to you, as well as for our internal purposes and for marketing purposes and for your purchasing from the Site. Information you provide to ILA via the Site may be distributed to sales, marketing or other appropriate ILA personnel, and a copy may be kept on file in ILA’s main office.

Do we use electronic mechanisms such as “cookies”?

“Cookies” are small files placed on your hard drive that assist many companies in providing their services. “Cookies” deliver customized visitor experiences and are used to analyze website user metrics.

What about children?

Children are not eligible to use this Site unsupervised and we ask that children do not submit any personal information to us. If you are under the age of 18, you may only use this Site in conjunction with, and under the supervision of, your parents or guardians.

How do we safeguard personal information?

We will strive to ensure that your personal information is adequately protected wherever it may be processed. Email sent via the Site resides on firewall-protected servers to which only authorized users have access. Files are stored in a physically and electronically secured web server environment. We do not currently receive any credit card information; credit card information is sent directly to a third party that processes the transaction and notifies us when the transaction is complete.

Will we disclose the personal information that we collect?

Data is collected and maintained by ILA’s website host, and accessed by appropriate parties at ILA, including, but not limited to, marketing/IT personnel and upper-level management, as well as ILA’s independent contractors who have executed a non-disclosure agreement to protect your information. The data collected on this Site is for the explicit use of ILA and affiliated persons and companies. We will not sell or rent your information to any third party. However, we will disclose personal information when required or permitted by law or for purposes relevant to our corporate policies. Procedures are in place, such as password changes and re-keying to prevent parties with access from taking data when they leave the organization, to prevent the loss or theft of personal information.

ILA reserves the right to perform statistical analysis of its customers in the aggregate. This means the personal information you provide, along with other customers, may be evaluated by ILA in order to measure interest in, and to support ongoing improvements and enhancements to, ILA’s Site. ILA also reserves the right to perform statistical analysis of its customers individually. This means the personal information you provide alone may be evaluated by ILA in order to provide services tailored directly toward you.

ILA reserves the right to transfer collected personal information upon sale of the business. ILA reserves the right to contact you via email, phone, fax, mail or other means to: inform you of new information and changes to the Site; to promote its goods and services; or otherwise as ILA sees fit consistent with this Privacy Policy. If you click on any links and banners which may appear on our Site that take you to third-party web sites (including, for example, sites which are not controlled by ILA), you will be subject to the third parties' privacy policies. ILA cannot be responsible for the actions of any third-party web sites. We encourage you to read the posted privacy statement of any other sites you visit.

How do we handle your credit card information?

As stated above, we will not collect any personally identifiable information about you, unless you provide it. If you submit credit card information in connection with making a purchase, such information is sent directly from you to a third party that processes the transaction. Such third parties will have access to your credit card information needed to perform their functions, but may not use it for other purposes.

How may I access my personal information?

You may contact us anytime to review the information which we collected about you and ask us to correct or delete it, if desired. Please see the contact information section below for more information.

Where can I obtain further information about this privacy statement?

If for any reason you have questions about this Privacy Policy, do not hesitate to contact ILA by mailing inquiries to:

Idemitsu Lubricants America Corporation
701 Port Road
Jeffersonville, IN 47130

What happens if this privacy statement changes?

We reserve the right to amend this data privacy statement at any time. The current version of the Privacy Policy can be reviewed by clicking on the “Privacy Policy” hypertext link located at the bottom of the front page of this Site. It is your responsibility to check for changes. Your continued use of ILA’s Site and its applications following the posting of changes to this data Privacy Policy will mean you accept those changes and terms of this Privacy Policy.

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Privacy Policy for California Residents

This Privacy Policy for California Residents conforms to the California Consumer Privacy Act of 2018 (the “CCPA”) and forms part of our Privacy Policy. It applies to the handling of personal information of our consumers who are residents of California (“consumers” or “you”).

1. Information We Collect

We collect information that identifies, relates to, describes, references, and is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from our consumers within the last twelve (12) months and will collect the following categories of personal information:

Category	Examples
A. Identifiers.	A real name, postal address, postal code, social security number, driver’s license number, passport number, date of birth, age, sex, email address, and other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, social security number, address, telephone number, passport number, driver's license number, education, employment history, bank account number, and any other financial information.
C. Protected classification characteristics under California or federal law.	Age (40 years or older), sex, and other protected classification characteristics.

We obtain the categories of personal information listed above from the sources indicated below:

• Directly from you. For example, from your business card: Categories A and B
• Directly from you. For example, from your job application form and interview and during your employment: Categories A through C

2. Use of Personal Information

We may use the categories of personal information from the list above, for one or more of the following business purposes indicated below:

• For communicating with business partners and customers in business negotiations, contract negotiations, etc.: Categories A and B
• For recruitment and employment management: Categories A through C
• For carrying out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and fulfillment: Categories A through C
• For responding to law enforcement requests and as required by applicable law, court order, or governmental regulations: Categories A through C

We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice thereof.

3. Sharing or Disclosure of Personal Information

We may share or disclose your personal information to a third party for business purposes or commercial purposes. When we disclose personal information to service providers for business purposes or commercial purposes, we enter a contract that describes such purposes and requires the service providers to both keep that personal information confidential and not use it for any purpose except for performing the contract.

In the preceding twelve (12) months, we have shared or disclosed the following categories of personal information from the above list to the following categories of third parties for business purposes or commercial purposes:

• Affiliates and service providers involved in the telecommunications business: Categories A through C

4. Sales of Personal Information

We have not sold any personal information in the preceding twelve (12) months.

5. Your Rights and Choices under the CCPA

The CCPA provides consumers (California residents) with specific rights regarding personal information. This Section 5 describes your CCPA rights and explains how to exercise those rights.

1. Access Right to Specific Information

   You have the right to request that we disclose certain information to you about our collection, sharing, disclosure or use of your personal information over the past twelve (12) months from the time of your request. Once we receive and confirm your verifiable consumer request, we will disclose to you the following information:

   • The categories of personal information we collected about you;
   • The categories of sources for the personal information we collected about you;
   • Our business or commercial purpose for collecting or selling that personal information;
   • The categories of third parties with whom we share or sell that personal information;
   • The categories of personal information sold by each third party who sold personal information;
   • The categories of personal information disclosed for business purposes or commercial purposes; and
   • The specific pieces of personal information we collected about you.

   Please note that we have not sold any personal information in the preceding twelve (12) months.

2. Deletion Request Rights

   You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

   We may deny your deletion request if retaining the information is necessary for us or our service providers to:

   • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
   • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
   • Debug products to identify and repair errors that impair existing intended functionality;
   • Exercise free speech, ensure the rights of other consumers to exercise their free speech rights, or exercise other rights provided for by law;
   • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
   • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
   • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
   • Comply with legal obligations; or
   • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

3. Opt-Out Rights

   We have not sold and will not sell any personal information collected from consumers.

4. Non-Discrimination

   We will not discriminate against California residents for exercising any of their rights under the CCPA. Moreover, unless permitted by the CCPA, we will not:

   • Deny you goods or services;
   • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
   • Provide you a different level or quality of goods or services; or
   • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

5. Exercising Access and Deletion Rights

   To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by contacting us in the manner set forth in Section 6 (Contact Us).

   Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

   The verifiable consumer request must:

   • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative (e.g. a copy of your passport, residence certificate, etc.); and
   • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond thereto.

6．Contact Us

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your information described above, or wish to exercise your CCPA rights, please do not hesitate to contact us at:

• Calling us at Toll Free：800-528-3588

Privacy Policy Last Updated and Effective: July 1st, 2020