We recognize the need for, and are fully committed to, ensuring that all officers and employees are fully aware of and comply with laws and regulations regarding the processing of personal information in order to protect personal information we process and ensure its safety.

We have established a compliance program that includes elements relating to the processing of personal information and periodically review those elements and strive to continuously improve them.

This Policy applies to all personal information that we process in all countries and regions where we have business operations.

For details about our use of cookies, please refer to our “Cookie Policy.”

We collect and process the following personal information.

1. Contact information: name, address, telephone number, fax number, and email address;
2. Identifying information: date of birth (age), gender, nationality, place of origin, residence, licenses, photographs, passport, visas or other government-issued identification data, background (education, job history, etc.), company name, job title, and family structure;
3. Information for creating online accounts: username, password, and security questions and answers;
4. Financial information: invoice address, credit or debit card number or other payment-related data, and bank account information;
5. Details regarding use of services and details regarding inquiries made;
6. Locational information and actions on networks: IP address, mobile device locational information, access information for our home page, device settings, log information, usage time, browser version information, operating system, browsing history, user ID, types of information viewed, and cookie and similar data;
7. Audio and video information: The content of calls made to us to when making inquiries and images from security cameras when at our properties;
8. Credit information: Information that must be collected pursuant to relevant laws and regulations, such as information for identity confirmation purposes;
9. Customer preferences and hobbies; and
10. Any other information you elect to provide directly to us in connection with your use of services we provide.

We collect personal information through the following means:

1. Information provided by individuals: acquired though face-to-face, telephone, mail and e-mail interactions, acquired through the filing out of applications, contracts, online forms, and questionnaires;
2. Information provided by others: acquired through group companies, subcontractors, business partners, company-operated stores, franchise stores, and service providers, etc.;
3. Technical information: acquired during the use of services; and
4. Information: acquired as a result of merger and other transactions that result in business succession:

Individuals may refuse to provide personal information to us but the decision not to provide certain personal information to us may result in ORIX not being able to provide certain products and services to such individual.

ORIX’s legal basis for processing your personal information will typically be one of the following.

1. Your consent;
2. Necessary for the performance of a contract with you;
3. Necessary for ORIX to fulfill its legal obligations;
4. Necessary to protect vital interests; or
5. Required for our legitimate interests or those of a third party, provided that if such interests are overridden by your interests or fundamental rights and freedoms, we will not process your personal information. Our legitimate interests are specified in more detail in Section 7 “Purpose for Processing of Personal Information” below. More information on the balancing test is available upon request.

ORIX may process your personal information that we collect for the following purposes. If we seek to process your personal information in ways that exceed the scope necessary for achieving these purposes, we will obtain your prior consent to such processing after disclosing information regarding the purpose(s) for which we intend to process it.

1. Appropriately handle business correspondence, such as applications from customers or proposals from us to customers in relation to our business, such as automobile leases, financing, rental and installment sale and purchase, sale of automobile and other insurance, automobile sale, purchase and maintenance and car sharing service (refer to our website for detailed descriptions of our business).
2. Perform credit check in cases of transactions such as automobile leases, financing and installment sale and purchase (Credit Granting Transaction), as well as make appropriate decisions relating to and undertake identity verification of customers.
3. Appropriately manage customer contracts. This includes appropriate management of expired/terminated contracts for reference and as required by laws.
4. Send promotional mails and e-mails regarding company profiles, products and services, of us, ORIX Group companies and other companies.
5. Develop and improve our products and services to provide better products and services for customers.
6. Conduct marketing analysis to improve customer satisfaction.
7. Perform management activities necessary for our operation.
8. Share with ORIX Group companies and franchise companies our car rental business and used car dealing business.
9. Provide to a third party to the necessary extent for the performance of appropriate operations, such as providing Personal Information to participating consumer credit information agencies for credit business (Only with consent for such provision to third parties).

Additionally,　personal　data of customers retained by us may be shared among us, ORIX Group companies, franchise companies of our car rental business and used car dealing business.

Utilization Purpose of ORIX Group companies are as follows.

1. Perform administration that is necessary for management of us or ORIX Group companies, such as identifying claims, asset conditions and risks.
2. Conduct marketing analysis and development of products and services to improve customer satisfaction by providing better products and services for customers.
3. Introduce and offer products and services produced by ORIX Group companies (for details, please refer to "Our Business" (https://www.orix.co.jp/grp/en/business/)).

Utilization Purpose of Franchise companies are as follows.

1. Appropriately handle business conversations with customers, such as applications from customers or proposals from franchise companies to customers within shops of franchise companies.

In the case of personal information of job applicants, the following purposes apply instead of those noted above.

1. To screen for internships and for candidates for interviews, testing and similar activities.
2. To conduct hiring activity on behalf of the ORIX Group (including communications and provision of various information introducing seminars relating to our hiring activity and questionnaires related to improving hiring activity in the future).
3. In the case of personal information of persons that are hired as a result of screening activity, to manage matters within the ORIX Group related to human resources, such as training and employee benefits, following your employment.
4. To conduct statistical and other analyses of data for purpose of hiring activity.

ORIX has established internal rules and regulations on the protection of personal information and pays the utmost attention to managing personal information appropriately and protecting against leakage of such personal information. We have also implemented appropriate and reasonable levels of safety measures to protect against unauthorized access, loss, destruction, or alteration of personal data from outside the company.

Your personal information may be shared with the following third parties under certain circumstances.

1. ORIX Group companies
   In order to meet diverse needs of our stakeholders through the comprehensive strength and consolidated management of the ORIX Group, we may share your personal information within the ORIX Group for the purposes described in this Policy.
2. Contractors and specialists
   In order to support the provision of products and services by ORIX or have others provide services on behalf of ORIX, [we may share your personal information with other companies, agents and contractors that we use].
3. Business partners, directly managed stores, and franchisees
   In order to provide services jointly with other companies or to provide services to you pursuant to a contract, we may share personal information with relevant business partners, directly operated stores and franchised stores.
4. Business successors
   We may sell of certain of our businesses to other companies in connection with reorganizations of our overall business. As a consequence of such sales, we may transfer or sell to third parties your personal information that was held in connection with the business sold.

Our website may from time to time contain links to and from websites of our business partners. Please be aware that each of these websites has its own privacy policy and ORIX has no control over how each business partner uses personal information [that it receives from you]. Prior to providing personal information to any of our business partners, please confirm the privacy policy of the relevant third party’s website.

Your personal information may be transferred to and processed in a country or region other than the one where you are located by ORIX or a third party described in Section 9 “Provision of Personal Information to Third Parties” of this Policy for the purposes set forth in Section 7 “Purpose for Processing of Personal Information” of this Policy. Such countries and regions include countries that have different standards of data protection than those of the country where you are located. ORIX will take all reasonable steps required by applicable law, including the execution of appropriate contracts, to ensure that your personal information is handled in a safe and secure manner and in accordance with this Policy and applicable data-protection laws and regulations.

You can exercise the following rights to the extent permitted by laws and regulations of the country or region in which you reside.

1. Notice of intended use of personal information
   You can request we inform you of our intended use for your personal information that we possess. In the event you make such a request, we will respond to the request promptly and appropriately in accordance with applicable laws and regulations.
2. Access to personal information
   You have the right to verify whether or not we process personal information about you and, if we process such personal information, you have the right to request access to it. You also have the right to obtain a copy of your personal information that we process. In the event you request we disclosure your personal information to you, we will respond to the request promptly and appropriately in accordance with applicable laws and regulations.
3. Correction of personal information
   If your personal information is inaccurate or incomplete, you have the right to request that we correct, supplement or otherwise complete such personal information ("Rectify"). In the event you request we Rectify your personal information, we will respond to such request promptly and appropriately in accordance with applicable laws and regulations.
4. Deletion of personal information
   You have the right to require us to delete any of your personal information that we process. Provided, however, that we are not obligated to take such action if our retention of such personal information is necessary to comply with our legal obligations or to assert, enforce or defend our legal rights.
5. Restrictions on the processing of personal information
   If your personal information processed by ORIX is inaccurate, the processing by ORIX is illegal or it is no longer necessary for ORIX to process the personal information for a particular purpose, you have the right to restrict the processing of your personal information. However, if ORIX is unable to delete your personal information due to the need to comply with legal or other obligations or you do not request deletion of your personal information by ORIX, we are not obligated to take such action.
6. Data portability
   If your personal information is (1) personal information provided to us by you, and (2) we processes such personal information based on your consent or in order to perform a contract with you, you have the right to obtain the personal information held by us with respect to you in a structured, commonly used and machine-readable format and the right to transmit such personal information to another controller. You also have the right to have us directly transmit such personal information to another controller, where technically feasible.
7. Withdrawal of consent
   If you consent to processing of your personal information, you have the right to withdraw your consent at any time without charge. This includes cases where you wish to stop receiving marketing communications.
8. Complaints
   You have the right to file a complaint about the processing of your personal information by us.

If you wish to exercise the right described above, please contact us through the e-mail address listed in Section 15 “Contact Information for Inquiries about Personal Information” of this Policy. In order to respond to your request and protect your privacy and security, we may request you provide information necessary for us to confirm your identity. In cases where we are unable to confirm your identity based on the information that we receive from you and information in our possession, we may request you provide additional information. We are committed to responding to your request to exercise your rights in accordance with applicable laws and regulations.

If you believe that ORIX is not in compliance with applicable laws and regulations on the protection of personal information, you have the right to file a complaint with the competent supervisory authority with oversight over data protection in accordance with applicable laws and regulations.

ORIX will generally only retain personal information we collect for a period of time reasonably necessary to achieve the particular business purposes for which we collected the personal information. In some cases, we may need to retain personal information for longer periods of time pursuant to laws or regulations applicable to our business. Personal information that is no longer needed will be promptly deleted.

In the event the Act on the Protection of Personal Information of Japan is applicable to the processing of your personal information, the following terms apply:

1. Shared users of personal information
   ORIX will share the personal information described in “4. Types of Personal Information” for the purpose described in “7. Purpose for Processing of Personal Information”. The scope of shared use of personal information will be limited to ORIX Group companies as described in “1. ORIX Group companies” and “3. Business partners, directly managed stores, and franchisees” in Section 9 “Provision of Personal Information to Third Parties” of this Policy.
   1. Please note that this category of “1. ORIX Group companies” includes companies that do not contain “ORIX” in their name. For details regarding such companies, please see our “List of Shared Users.”
   2. Category of “3. Business partners, directly managed stores, and franchisees” includes companies which have franchise contract for Car Rentals and Used Car Sales with ORIX. For detail of such companies, please see "Car Rental Franchise Companies List" and "ORIX U-car Franchise Companies List".
      ※Listed companies subject to change.

ORIX will not disclose or provide your personal information to third parties without your consent, except for cases of shared use, disclosure to contractors, or where otherwise permitted by applicable law and regulations.

ORIX Auto corporation is responsible for the management of shared personal data.

ORIX Auto corporation
ORIX INUI Bldg., 3-22-8 Siba,
Minato-ku, Tokyo, 105-8589, Japan

ORIX Auto Corporation
Email address: data_security_oac@orix.jp

Representative in EU ORIX Corporation Europe N.V. Attn. Secretariat/Privacy matters
Address: Weena 850, 3014 DA Rotterdam, The Netherlands
Email Address: privacy @orixnv.com

Pursuant to the California Consumer Privacy Act of 2018, and California Privacy Rights Act (collectively, the “CCPA”), we are providing the following additional details regarding the categories of Personal Information that we collect, use, and disclose about California residents.