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In order to operate the WBC service and to reduce the risk of fraud, WBC, ("WBC" or "we") must ask you to provide us information about yourself and your company information. This Privacy Policy describes the information we collect and how we use that information.

WBC takes the privacy of your personal information very seriously and will use your information only in accordance with the terms of this Privacy Policy. We will not sell or rent your personally identifiable information or a list of our customers to third parties. However, as described in more detail in Part C below, there are limited circumstances in which some of your information will be shared with third parties, under strict restrictions, so it is important for you to review this Privacy Policy. This Privacy Policy applies to all services that are hosted on the WBC.vc Web site, whether the services are offered by WBC, by its subsidiaries.

Required Information

Web Site Traffic Information

Because of the way that World Wide Web communication standards work, when you arrive at or leave the WBC Web site, we automatically receive the Web address of the site that you came from or are going to. We also collect information on which pages of our Web site you visit while you are on the WBC site, the type of browser you use and the times you access our Web site. We use this information to try to understand our customers' preferences better and to manage the load on our servers, so as to improve our service and your experience with WBC. We do not track the Web sites that you visit before or after you leave the WBC site.

Our Use of "Cookies"

"Cookies" are small files of data that reside on your computer and allow us to recognize you as a WBC customer if you return to the WBC site using the same computer and browser. We send a "session cookie" to your computer if and when you log in to your WBC account by entering your e-mail address and password. These cookies allow us to recognize you if you visit multiple pages in our site during the same session, so that you don't need to re-enter your password multiple times. Once you log out or close your browser, these session cookies expire and no longer have any effect.

We also use longer-lasting cookies to display your e-mail address on our sign-in form, so that you don't have to retype the e-mail address each time when you log in to your WBC account. In addition, we use cookies to process our referral program, described in Section C below. Our cookie files are encoded so that your e-mail address and other information can only be interpreted by WBC. We may, however, share cookie information regarding whether or not a certain user is already registered with WBC with certain merchants with whom we have an official co-marketing relationship.

Customer Service Correspondence

If you send us correspondence, including e-mails and faxes, we retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from WBC to you. We retain these records in order to measure and improve our customer service, and to investigate potential fraud and violations of our User Agreement. We may, over time, delete these records if permitted by law.

Questionnaires, Surveys and Profile Data

From time to time, we offer optional questionnaires and surveys to our users for such purposes as collecting demographic information or assessing users' interests and needs. The use of the information collected will be explained in detail in the survey itself. If we collect personally identifiable information from our users in these questionnaires and surveys, the users will be given notice of how the information will be used prior to their participation in the survey or questionnaire.

Internal Uses

We collect, store and process your personal information on servers located in Japan. We use the information we collect about you in order 1) to provide our services and process your transactions, 2) to provide customer service, 3) to determine your eligibility to receive offers for special features or products, and 4) to improve our products and services. At your option (as indicated in your WBC Profile settings), we use the information you provide to access specific third party services on your behalf and perform the actions that you request us to perform.

We authorize access to individually identifiable information about our users only to those employees who require it to fulfill their job responsibilities.

Disclosure to Other WBC Customers

If you are a registered WBC user, your name, e-mail address, phone number (if applicable), date of sign-up, and are displayed to other WBC customers whom you have registered on WBC site. and also the Web site address (URL) and customer service contact information that you provide us.

Disclosure to Third Parties Other Than WBC Customers

WBC will not sell or rent any of your personally identifiable information to third parties. WBC will not share any of your personally identifiable information with third parties except in the limited circumstances described below, or with your express permission (and with other WBC customers as described above). These third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information is shared.

1. We share information with companies that help us process the transactions you request and protect our customers' transactions from fraud. We may disclose the information we collect from you to companies that market WBC-related products and services on our behalf.
2. We may disclose the information we collect to other institutions with whom we have joint marketing agreements, in order to determine whether you are pre-approved for the products that WBC is jointly marketing with these institutions. These institutions are subject to confidentiality agreements with us and other legal restrictions that prohibit using the information except to market the specified WBC-related products or services, unless you have affirmatively agreed or given your prior permission for other uses.
3. If you do not want WBC to share any of your information with these institutions who are our joint marketing partners, please log in to your account to set your Notification preferences in the Profile page of the My Account tab to indicate that you do not want to receive Partner/Third-Party Promotions or the WBC Periodical Monthly Newsletter and Product Updates. Use the following URL to see your Notification preferences: http://www.WBC.vc/
4. We disclose information that we in good faith believe is appropriate to cooperate in investigations of fraud or other illegal activity, or to conduct investigations of violations of our User Agreement. For example, this means that if we conduct a fraud investigation and conclude that one side has engaged in deceptive practices, we can give that person or entity's contact information to victims who request it.
5. We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action.
6. When a user signs up for a co-branded version of WBC through links to WBC from our co-branded partner's web site, WBC will share with the co-branded partner that user's name, e-mail address and physical address in order to provide enhanced integration between WBC's services and the services of our co-branded partner. If you do not want your information shared with WBC's co-branded partner, you should sign up with WBC directly and not through a link from our partner's web site.
7. We disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
8. As with any other business, it is possible that WBC in the future could merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the information maintained by WBC, including customer information, but would continue to be bound by this Privacy Policy unless and until it is amended as described in Section A above.
9. We share your information with our parent, subsidiaries, affiliates and joint ventures to help coordinate the services we provide to you, enforce our terms and conditions, and promote trust and safety.

Our Contacts with WBC Customers

We communicate with users on a regular basis via e-mail to provide requested services, and we also communicate by phone to resolve customer complaints or investigate suspicious transactions. We use your e-mail address to confirm your opening of a WBC account, to send information about important changes to our products and services, and to send notices and other disclosures required by law. Generally, users cannot opt out of these communications, but they will be primarily informational in nature rather than promotional.

We also use your e-mail address to send you other types of communications that you can control, including the WBC Periodical newsletter, customer surveys and notice of special third-party promotions. You can choose whether to receive some, all or none of these communications when you complete the registration process, or at any time thereafter, by logging in to your account on the WBC Web site and changing your preferences in the Profile page of the My Account tab. You can also change your choices at any time through the same procedure.

In connection with independent audits of our statements and operations, the auditors may seek to contact a sample of our customers to confirm that our records are accurate. However, these auditors cannot use personally identifiable information for any secondary purposes.

Internet Address Information

We use IP addresses, browser types and access times to analyze trends, administer the site, improve site performance and gather broad demographic information for aggregate use.

Your Use of Information and Our Services

In order to facilitate the transactions between WBC members, our service allows you limited access other users' contact or shipping information. As a seller you may have access to the User ID, email address and other contact or shipping information of the purchaser, and as a purchaser you may have access to the User ID, email address and other contact information of the seller.

By entering into our User Agreement, you agree that, with respect to other users' personally identifiable information that you obtain through the site or through an WBC-related communication or WBC-facilitated transaction, you will only use this information for: (a) WBC-related communications that are not unsolicited commercial messages, (b) using services offered through WBC (e.g. insurance, shipping and fraud complaints), and (c) any other purpose that such user expressly agrees to after adequate disclosure of the purpose(s).

In all cases, you must provide users with the opportunity to remove themselves from your database and review any information you have collected about them. In addition, under no circumstances, except as defined in this Section, can you disclose personally identifiable information about another WBC user to any third party without our consent and the consent of such other user after adequate disclosure. Note that law enforcement personnel and other rights holders are given different rights with respect to information they access.

WBC does not tolerate spam. Therefore, without limiting the foregoing, you may not add a WBC user to your mail list (email or physical mail) without their express consent after adequate disclosure, even if said user has previously made a purchase from you. We strictly enforce our Anti-Spam Policy! To report WBC-related spam to WBC, please contact us.

Please use our referral program responsibly. We strictly enforce our Anti-Spam Policy!

Information Security

WBC is committed to handling your customer information with high standards of information security. Your information are stored only in encrypted form on computers that are not connected to the Internet. We maintain physical, electronic and procedural safeguards that comply with federal regulations to guard your nonpublic personal information. We test our security systems regularly and also contract with outside companies to audit our security systems and processes.

The security of your WBC account also relies on your protection of your WBC password. You may not share your WBC password with anyone. If you do share your WBC password with a third party for any reason, including because the third party has promised to provide you additional services such as account aggregation, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your password. If you believe someone else has obtained access to your password, please change it immediately by logging in to your account at http://www.WBC.vc and changing your Profile settings, and also contact us right away.

WBC will never ask you to send your password or other sensitive information to us in an e-mail, though we may ask you to enter this type of information on the WBC website, which will always have a URL beginning with http://www.WBC.vc/.

Any e-mail or other communication requesting your password, asking you to provide sensitive account information via email, or linking to a website with a URL that does not begin with http's://www.WBC.vc/ should be treated as unauthorized and suspicious and should be reported to WBC immediately by forwarding the email to us.

You can review the personal information you provided us and make any desired changes to such information, or to the settings for your WBC account, at any time by logging in to your account on the WBC Web site and changing your preferences in the Profile page of the "My Account" tab. You can also close your account through the WBC Web site. If you close your WBC account, we will mark your account in our database as "Closed," but will keep your account information in our database. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, or as required by law.

Our site uses Google's access analysis tool "Google analytics" to improve the service. Cookies are used to collect access information. This access information is collected anonymously and is not personally identifiable. By using this site, you are deemed to have given permission to use cookies. This function can be rejecte by disabling cookies. The setting method depends on the browser, so please refer to the help of your browser. Please note that some content may not be available if you deny the access information to be collected. Please check the following sites for information on Google Analytics Terms of Service and how Google Analytics collects and processes data.

• Google Analytics Terms of service https://www.google.com/analytics/terms/us.html
• Google Privacy Policy https://www.google.com/intl/en/policies/privacy/