PRIVACY POLICY

Spring Co., Ltd. (hereinafter referred to as "VINESPA", "we", "us", "our") will collect personal information of customers (i.e. information that identifies you, hereinafter referred to as "personal information", "customer information", "your personal information") that you provided to VINESPA at the time of registration and purchasing from VINESPA. Please acknowledge the handling of personal information in accordance with the following provisions.

In addition, if you cannot provide customer information, various services may not be available.

1. Purpose of use of customer information

We will not use anything other than the below purpose without prior consent of the customer. We will use customer information for the following purposes.

1. Providing information on VINESPA's products, services and event information (including advertisements)
2. Requesting your opinions and comments
3. Providing other benefit services
4. As part of statistical data

2. Storing / erasing of customer information

We take appropriate measures to keep your personal information secure, so that third parties will not unfairly access your personal information. In addition, VINESPA may erase the customer information upon judging that it is no longer necessary to further retain.

3. Disclosure of customer information

Except for the cases below, we will not disclose your information to third parties without your consent. However, this does not apply to statistical information that cannot identify you individually.

1. In cases where disclosure and access to personal information held by us is required to third parties appointed by VINESPA for purpose of use in which customers are notified (in which case we require these third parties to keep that personal information confidential and not to use or disclose it for any purpose other than the purpose of use)
2. In cases where we are required or authorized by law to do so, for example to law enforcement agencies

4. About providing information on others

When you register personal information other than yourself, please be sure to obtain consent to provide personal information to VINESPA from that person.

5. Inquiries on your personal information

If you wish to correct, delete, or restrict processing and distribution of your personal information from VINESPA, please contact us by phone or fax.

6. About this document

VINESPA can change, modify, add, and delete the contents of this document as necessary.

April 1, 2009
Spring Co., Ltd.