THIS DOCUMENT SETS FORTH THE PRIVACY AND SECURITY POLICY (“PRIVACY POLICY”) FOR THE WILLIS GROUP (“TWG”) SITE (AS SUCH TERM IS DEFINED IN TWG’S TERMS OF USE), INCLUDING THE WEBSITE WWW.TOKYORODS.COM. TWG VALUES THE PROTECTION OF INDIVIDUAL PRIVACY AND IS COMMITTED TO THE PRIVACY OF ITS VISITORS. THIS PRIVACY POLICY SETS FORTH TWG’S PRIVACY POLICY FOR THE SITE, AND GOVERNS THE MANNER IN WHICH TWG COLLECTS, USES, MAINTAINS AND DISCLOSES INFORMATION COLLECTED FROM USERS OF THE SITE. BY USING THE SITE, YOU AGREE TO BE BOUND BY THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, DO NOT USE THE SITE IN ANY MANNER. THIS PRIVACY POLICY DOES NOT GOVERN PRIVACY PRACTICES ASSOCIATED WITH OFFLINE ACTIVITIES OR ACTIVITIES OCCURRING ON WEBSITES NOT UNDER TWG’S CONTROL.

The Information TWG Collects

Personally Identifiable Information. During your interactions with the Site, such as when you register with the Site, TWG may wish to collect information that personally identifies who you are, such as your name, address, email address and/or telephone number.

Anonymous Information. TWG may collect non-personally-identifiable information during your visit. Examples of non-personally-identifiable information may include your Internet access provider, your computer’s Internet protocol (IP) address, information regarding your user profile, your browser and operating system, the date and time of your visit, the pages you visit, the address of any Site you linked from, and aggregate, statistical data such as usage, traffic patterns and user demographics based on your use of the Site. TWG collects non-personally-identifiable information in order to, among other things, provide you with or assist in the provision of information through the Site, to maintain the performance of the Site, and to make the Site more useful. TWG may also share this non-personally-identifiable information in aggregated form with third parties so that these third parties may provide you with more relevant services and advertisements.

TWG’s Use and Disclosure of Collected Information

Personally Identifiable Information Use. TWG may collect personally identifiable information such as your name, address, e-mail address, or credit card information in order to, among other things, provide you with the information and/or services that you have requested through the Site. TWG retains such personally identifiable information only for as long as is necessary depending on the reason for your submission of such personally identifiable information, and collects no more personally identifiable information than is reasonably necessary to provide you with the services for which such information is collected.

Personally Identifiable Information Disclosure. TWG recognizes your trust and fully respects your privacy. TWG does not sell or otherwise disclose any personally identifiable information to any third parties other than: (1) as required by law; (2) in the event of a sale, merger, public offering, bankruptcy or other change in control of TWG and/or the Site; or (3) with your affirmative consent at the time you provide such information. If you have indicated that you would like to receive information from TWG, we may send you occasional updates via e-mail. If you prefer not to receive these e-mail updates, simply follow the instructions on how to unsubscribe included in the messages you receive

Disclosure to Agents of TWG. From time to time, TWG may share the information you provide to TWG, including personally identifiable information, with outside contractors, auditors, consultants, or others hired by TWG to assist in providing financial or operational activities on TWG’s behalf including technical and processing services and analysis of website performance. TWG informs these parties about safeguarding personally identifiable information, and requires them to use such personally identifiable information only for an authorized purpose on behalf of TWG and consistent with this Privacy Policy.

Electronically Produced Data

Cookies. TWG, like most standard website servers, may use cookies and other tools to collect information about how you use the Site. A cookie is a small, unique text file that a website can send to your computer hard drive when you visit a site. TWG may use “session cookies”, which terminate when a user closes his or her browser, and/or “persistent cookies”, which remain on the user's computer until manually deleted. Most web browsers can either alert you to the use of cookies or refuse to accept cookies entirely. If you do not want TWG to deploy cookies in your browser, you can set your browser to reject cookies or to notify you when a website tries to put a cookie on your computer. Rejecting cookies may affect your ability to use the Site.

Action Tags. Like most standard website servers, TWG may employ a software technology called action tags (also known as “web beacons”, “single pixel gifs”, “clear gifs” or “web bugs”), which collect information and help to manage cookies, in order to gather information about Site usage. Action tags help TWG identify and track the performance of web pages on the Site, therefore allowing TWG to measure the performance and quality of the Site and to manage Site content. In addition, TWG may use action tags in emails. This allows TWG to gauge the effectiveness of certain communications by showing, for example, how many emails have been opened.

IP Addresses. An IP address is a number that is assigned to your computer when you use the Internet. Like most standard website servers, TWG collects IP addresses and other technical information about your machine through your web browser such as your operating system, browser type and referring URL for the purposes of, among other things, system administration and to ensure the validity of user requests.

Log Files. Like most standard website servers, TWG gathers certain information automatically and store it in log files, which contain information such as, among other things, IP addresses, browser type, operating system, ISP, date/time stamps and referring pages. Among other things, this information allows TWG to track statistics and trends on an aggregate basis.

Maintenance of Information and Security

Secure Transactions. TWG has contracted with Paymerica ® to securely process all credit card transactions conducted on its’ site. Paymerica uses the latest encryption technology and other methods to protect your credit card information.

Other Protections. TWG maintains physical, electronic and procedural safeguards to protect the confidentiality and security of any personally identifiable information that you disclose to TWG. TWG utilizes what TWG believes to be industry standard security measures to protect the loss, misuse and alteration of personally identifiable information under TWG’s control, and TWG limits access to your personally identifiable information within TWG to those employees who need to know the personally identifiable information to provide information, services and/or products to you. However, due to the nature of the Internet, computer networks, systems and other factors, no transmission of data over the Internet is guaranteed to be completely secure. It may be possible for third parties not under the control of TWG to intercept or access transmissions or private communications unlawfully, regardless of TWG’s best intentions. As such, TWG cannot ensure or warrant the security of any information you transmit to TWG, including without limitation personally identifiable information.

Review or Correction of Person Information

You may review, request corrections, ask that we delete, or refuse further collection or use of the personally identifiable information TWG collects from you. You may do this by contacting TWG using the contact information provided at the end of this document. In the event TWG changes this Privacy Policy to allow disclosure of personally identifiable information to third parties, you will have the option to agree to the collection and use of such information.

Other Information

Consent to Receive Notices Via the Site. By submitting any personally identifiable information to the Site, you are agreeing that TWG may deliver all privacy and opt out notices to you electronically, including via email to the most recent email address you have provided to TWG, or via posting on the Site.

Links. The Site may contain links to third party sites at which your personally identifiable information is collected and used. Your visit to any third party website is governed by the privacy and other policies applicable to that site. TWG cannot control nor is it responsible for any such third party collection or use of your personally identifiable information or the content or policies of such sites, and TWG expressly disclaims any liability related to such sites.
Web Logs and Other Forums. The Site may offer web logs, web postings, bulletin boards, chat rooms, newsgroups or other forums which permit users to interact online. Any information you transmit or post online in such forums will be made public and TWG cannot control nor is it responsible for the use any third party may make of such information.

Changes to Our Privacy Policy. Our Privacy & Security Policy is intended to provide you with the safest and most secure experience possible. Since offerings and technologies change, we reserve the right to change, modify, add or remove portions of our Policy at any time without prior notice at our sole discretion. All Privacy Policy changes will be posted on the Site and are effective immediately upon posting. Consequently, you are advised to visit and review this Privacy Policy frequently for changes. last date on which this Privacy Policy has been updated is noted below.

Limitation of Liability. YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND TWG’S TERMS OF USE (INCLUDING ANY LIMITATIONS ON DAMAGES CONTAINED THEREIN).

TWG Contact Information

If you have any questions or comments regarding this Privacy Policy, or wish to review or revise any personally identifiable information as provided herein, please email TWG at info@tokyorods.com

THIS PRIVACY POLICY WAS LAST UPDATED ON April 22, 2009