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PRIVACY POLICY

This Privacy Policy applies to the www.twwonline.com and www.twwedge.com websites (collectively, the “Site”), which is owned and operated by Bridgestone Americas Tire Operations, LLC d/b/a Tire Wholesale Warehouse (“BATO” or “we”) and forms part of the Terms and Conditions of Use that govern your use of the Site.

Last Updated: June 19, 2014

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THE SITE. This Privacy Policy tells you about our information gathering, use, and disclosure practices with respect to information collected through the Site. By using our Site, you acknowledge that you have read this Privacy Policy, and agree to be bound by it. If you do not agree to any of the terms contained in this Privacy Policy, your remedy is not to use the Site. This Privacy Policy does not apply to information collected through other means (e.g., via fax, telephone, mail, offline methods of communication) or through other websites.

1. Purpose of Site. The Site is directed primarily to tire dealers and retailers, not to individual consumers of tires. When you visit the Site without registering or logging in, you may learn generally applicable information about our product offerings and marketing programs. When you log in to the TWWOnline portion of the Site, you may access your dealer or retailer account and order tires for resale on behalf of the dealer or retailer you represent. Affiliated retail program members may log in to the TWWEdge portion of the Site to learn about funds they may allocate to different programs, or how they may use funds for different promotions. Although the Site is directed to commercial purposes, in the course of engaging in certain transactions on the Site during your visit to the Site, BATO may collect some personal information from you individually.

2. Information We Collect.

(a)

Information Collected.

(i)

Non-personal Information” is any information that does not identify you individually or does not permit a direct association with an individual. Non-personal Information may include information derived from Personal Information by de-personalizing it to remove unique identifiers and/or combine it with information about other users to form aggregated data.

(ii)

Personal Information” is your personally identifiable information, including first and last name together with email address and/or street address. To the extent we associate Non-personal Information with Personal Information, we treat the combination as Personal Information.

(b)

Not Collected. This website is not directed to children. We do not knowingly collect Personal Information from children under the age of 13 on our Site. If we discover that any registration is made by a child under the age of 13, such registration will be deleted. If you are under the age of 13, do not use this Site or provide information on this Site. If you believe we have received information from or about a child under the age of 13, please contact us here: marketing@twwonline.com.

3. How We Collect Information.

(a)

Information You Provide. In the course of visiting and using the Site, you may provide information to us. For example, you may purchase or order tires or register for participation in an affiliate network (each as representative for a dealer or retailer), report an issue to us, and/or register or create a login account to use certain features of the Site. In the course of doing so, you may be asked for information about yourself (and the dealer and/or retailer). If you voluntarily provide your Personal Information to us, we collect it. When you: (i) place an order; (ii) submit a request or inquiry; and/or (iii) register to use specific parts of the Site or participate in particular programs (each of the foregoing a “Transaction”), you may disclose Personal Information to us that we collect. We may also retain records about your Transactions or correspondence with us or your searches on the Site. You choose whether to disclose Personal Information, but sometimes we may not be able to process your Transaction without it. We may collect information you send us and combine it with information from other users and/or de-personalize it to make it Non-personal Information.

(b)

Technologically Gathered. We may collect some information automatically as you navigate the Site. For example, we may collect usage details, such as traffic data (such as information about how much time visitors spend on the Site or each page, dates and times of visits, etc.), collect and log “clickstream data” (such as internet protocol addresses, pages visited, clicks made, and similar information) and collect information about your computer and internet connection (such as IP address, operating system, and browser type) for all visitors. This sort of information is generally considered Non-personal Information (unless it is combined with Personal Information). We may combine information about your use with information about others’ use to generate aggregated Non-personal Information about visitors as a group. We may collect information through “cookies” and other technology, such as clear GIF technology (also known as a “web beacon”) that is described in more detail below and we may combine this with your Personal Information or with other Non-personal information.

(i)

"Cookies" are small pieces of information that are stored by a user's internet browser on a user's computer's hard drive. Most internet browsers are initially set to accept cookies. You can set your browser to refuse cookies, but then you may not be able to access or use portions of this Site.

(ii)

“Flash Cookies” are local stored objects that allow us to collect and store information about your preferences and navigation to, from and on our Site. Flash cookies are not managed by the same browser settings as are used for browser cookies.

(iii)

“Web beacons” are small bits of code embedded in web pages or emails that assist in delivering cookies. Web beacons help us determine whether a page on this Site has been viewed and, if so, how many times. For example, any electronic image on this Site, such as an ad banner, can function as a web beacon. We may also use web beacons in email messages to determine what the recipient has done with the message.

(iv)

Third Party Advertisements. We do not allow third parties to place advertisements on the Site; however, we may feature links to third party sites relating to benefits or special offers available to our customers.

4. How We Use the Information. Generally, we use information (including Personal Information) collected through the Site to improve our services, to improve, administer, customize, and/or maintain the Site, to speed searching capability, to estimate the size and patterns of the Site’s audience, to manage Transactions, to build relationships with you and other dealers and retailers, to market and provide you with information about tires, to provide the tires themselves, to fulfill other purposes for which you provide the information, to provide you with notices about your dealer or retailer account, to carry out our obligations and enforce our rights, to enable others to enforce their rights, to conduct investigations, to cooperate with law enforcement, to allow you to participate in interactive features of the Site, to conduct market research and analysis, in any other way described when you provide the information, and for any other purpose with your consent. We may contact you to obtain your input, or provide information about our goods, services or events. We may identify you in connection with your use of certain aspects of this Site and may link information about your use of the Site with your Personal Information. We do not place any restrictions on the use of Non-personal Information. More detail about certain uses of Personal Information appears below.

(a)

Transactional Purposes. If you provide Personal Information to us in connection with a Transaction, we will use your information to process the Transaction and communicate with you about it. Processing the Transaction may require communication of your Personal Information with third parties, including affiliates. We may send you electronic communications if you subscribe to any of our services.

(b)

Marketing. If you provide your email address or mailing address to us, we may use your Personal Information to offer, market and advertise to you via the Site and/or through email or U.S. mail. We may communicate with you about our goods or services or third party products or services (including network programs) that may interest you. We may use Personal Information to conduct market research and analysis for ourselves.

5. Data Security.

(a)

Security Measures. We take steps to protect your Personal Information. Access to your Personal Information is restricted in the following ways: We encrypt information transmitted through the Site. We restrict access to your Personal Information and password through encryption. Only BATO employees and contractors are granted access to your Personal Information, and then only for use helping us provide the services to you and the dealer or retailer you represent. The servers on which your information is stored are kept in a secure environment protected by a firewall.

(b)

Steps you can Take. Where you have selected or received a password for use in connection with login information or accessing certain features of the Site, you are responsible for maintaining the confidentiality of the password and for not sharing it with anyone.

(c)

Caution. While we will endeavor to safeguard your Personal Information, we cannot guarantee absolute security. You acknowledge agree that we shall not be liable for any security breach that results from causes or events that are beyond our control (such as acts of God, hacking, terrorism, power outages, defects in third party security products and services, your own acts and omissions, and other similar events). Please be aware that no security measures are perfect or impenetrable, so security is not guaranteed. Additionally, we cannot control the actions of other users of the Site.

6. Disclosure Practices.

(a)

Non-personal Information. We do not place any restrictions on the use or disclosure of Non-personal Information (included aggregated information). We may share it with anyone for any purpose.

(b)

Personal Information. We may share your Personal Information with affiliates. In addition, we may share your Personal Information with other third parties as follows:

(i)

ENABLING SERVICES. We may disclose your Personal Information to contractors, service providers, and other third parties to enable them to provide services to us, process orders for us, provide research or analysis for us, provide data storage for us, help us in managing the Site or the programs, assist us in providing the services available through the Site, to effect, administer, or enforce a Transaction requested or authorized by you, or otherwise. Such disclosure is subject to confidentiality restrictions prohibiting such third parties from using your Personal Information for other purposes, and requiring such third parties to protect the confidentiality of such information. We may also disclose your Personal Information to fulfill the purpose for which you provided such information or for any other purpose we disclose when you provide the information. We may disclose your Personal Information with your consent or at your direction.

(ii)

LEGAL REASONS. We may disclose your Personal Information in response to a subpoena or other court order, if otherwise required by law, in an effort to cooperate with law enforcement, to enable someone to enforce their rights, or to allow us to enforce our rights. We may disclose your Personal information when we believe that doing so is necessary or desirable (a) to protect our records, enforce our rights, or defend against legal claims, (b) to investigate, prevent, or take action regarding illegal activities, actual, potential, or suspected fraud or other liability, situations involving personal threats to physical safety, allegations of intellectual property infringement or violations of privacy rights, (c) to exercise institutional risk control or resolve customer disputes, (d) to attorneys, accountants, auditors, others who assess our compliance with industry standards and regulations and applicable rating agencies, (e) to consumer reporting agencies, (f) to comply with laws, rules, legal requirements, civil, criminal, and regulatory investigations, or subpoenas or summons, and/or (g) as otherwise required or permitted by law.

(iii)

ASSIGNMENTS. We may disclose your Personal Information to a buyer or other successor in interest in the event of a sale of substantially all of our assets, the merger, dissolution, divestiture, restructuring, reorganization, sale, exchange, or transfer of BATO, or some or all of its assets, whether as a going concern or as part of bankruptcy, liquidation, or a similar proceeding. If that happens, the buyer, assignee, or other successor in interest’s privacy policy may govern the further protection, use, and disclosure of your Personal Information.

7. Managing Information. The mechanisms below provide you with certain options about how to exercise control over certain information:

(a)

Information Access. Upon your request, we will remove Personal Information that you provided to us through the Site from our records related to this Site. This may cancel your ability to use some or all of the services we offer via this Site or otherwise. If you wish to update/correct Personal Information you have already provided to us, or if you wish to remove your Personal Information from our records, please send your request to us via email at marketing@twwonline.com or via postal mail to this address: Bridgestone Americas Tire Operations, LLC, 535 Marriott Drive, Nashville, TN 37214, Attn: TWW Marketing. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

(b)

Email Marketing. You may choose to opt out of receiving marketing emails from us at any time by sending your request to us via email at marketing@twwonline.com or via postal mail at Bridgestone Americas Tire Operations, LLC, 535 Marriott Drive, Nashville, TN 37214, Attn: TWW Marketing, or by using the means (such as clicking “unsubscribe”) provided in our marketing emails. Please note, however, that your opt-out will apply only to marketing emails, not email communications about your Transaction or other non-marketing correspondence.

(c)

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of the Site may then be inaccessible or not function properly.

(d) Do Not Track Disclosure. We take no action in response to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.
(e)

Targeted Advertising. We do not engage in targeted advertising using the Personal Information you provide to us through the Site.

8. Modifications to Privacy Policy.

We may modify this Privacy Policy from time to time in our sole discretion. If we make a material change to this Privacy Policy, we will post such changes on the Site. By continuing to use our Site after such notice, you are prospectively bound by this Privacy Policy as modified.

9. Contact Information.

If you have questions about this Privacy Policy, you may contact us at: marketing@twwonline.com or via postal mail at Bridgestone Americas Tire Operations, LLC, 535 Marriott Drive, Nashville, TN 37214, Attn: TWW Marketing. We will use reasonable efforts to respond promptly to reasonable requests or questions you may have regarding our use of your Personal Information.