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VIASYSYEMS.COM STATEMENT OF USER PRIVACY

Safe Harbor and Online Users Privacy Policy of Viasystems Group, Inc.

1. Purpose. Viasystems Group, Inc. and its subsidiaries (“Viasystems”) have created the following Privacy Policy (a) to comply with the United States Safe Harbor, (b) to facilitate the exchange of information between Viasystems’ offices located in the United States, Mexico, the European Union, Hong Kong, Singapore and China and in other jurisdictions, and (c) to govern information Viasystems generally receives through this Web Site. The scope and terms of this Privacy Policy are set out below.

2. Your Agreement. Your use of this Web Site, or submission of information via this Web Site, constitutes your agreement to the terms of this Privacy Policy. Please review these terms to ensure they are acceptable. In addition, please also review our Terms of Use, located elsewhere on this Web Site to ensure they are similarly acceptable.

3. Safe Harbor Certification. Viasystems has adopted (i) this Safe Harbor and Online Users Privacy Policy and (ii) a separate Viasystems Employee Privacy Policy in order to participate in the US Safe Harbor. Viasystems certifies with the U.S. Department of Commerce that these Privacy Policies comply with the Safe Harbor and provide the adequate protections specified in the Data Protection Directive.

4. Scope of Policy; Application to Viasystems. This Privacy Policy governs the practices of Viasystems in respect of the collection, use and disclosure of data that personally identifies an individual or company or that may be used to personally identify an individual or company “Personal Data”. Personal Data includes data such as an individual's name, address, phone number, email address, user ID and password, personal billing information, and credit card information. This Privacy Policy does not apply to any other data subjects.

4.1. No Application to Viasystems Employees; Employee Personal Data Protection. This Privacy Policy does not set out the Personal Data Protection Practices of Viasystems with respect to employees of Viasystems.

5. Site Visitors. Information which Viasystems may receive concerning visitors using the Viasystems Web Site falls into two broad categories: Aggregate Information (defined below in Section 5.1) and Personal Data (defined in Section 4.1 above). This Section sets out Viasystems’ practices to protect the Personal Data applicable to visitors of this Web Site.

5.1. Aggregate Information from Site Visitors. "Aggregate Information" is information that does not identify a visitor to this Web Site, and may include, for example, statistical information concerning the web pages on the Viasystems Web Site that users most frequent. Aggregate Information may be collected through cookies and similar Internet technologies. "Cookies" are small text files that a web site can use to recognize repeat users, to facilitate the user's ongoing access to and use of the site, and to compile aggregate data to improve the web site and focus advertising. If Viasystems uses cookies or other similar internet technologies on its Web Site, these technologies will not collect or retain the visitor of the Web Site’s name or other Personal Data. In addition, no third parties are permitted to use for their own purposes cookies Viasystems may create at the Viasystems Web Site. With Aggregate Information, Viasystems may undertake or commission statistical and other summary analyses of visitors of this Web Site’s behavior and characteristics when visiting the Viasystems Web Site. Although Viasystems may share this aggregate information with third parties, no aggregate information Viasystems provides to third parties will allow such third parties to identify a visitor to this Web Site, or gather any Personal Data about visitors to this Web Site.

5.2. Personal Data from Site Visitors. Viasystems may receive Personal Data from visitors to this Web Site, where applicable, (i) to submit questions or comments to Viasystems or its staff, (ii) to request information about products or services offered by Viasystems, (iii) request a quote for products or services performed by Viasystems, or (iv) to employ other features that may be available at the Web Site which call for submission of Personal Data. Viasystems uses Personal Data which visitors submit through the Viasystems Web Site (a) to respond to an inquiry or request for quote provided by a visitor to the Web Site (although Viasystems in this Privacy Policy undertakes no obligation to respond to any inquiry or request of quote), and (b) to provide the services or products requested by the visitor, where the requested services or products are, in fact, offered by Viasystems and are in accordance with Viasystems’ standard business procedures.

5.3. Further Uses. Viasystems may wish to use Personal Data for purposes which are in addition to those specified in Section 5.2. (Personal Data from Site Visitors) and which do not involve disclosures beyond those permitted in Section 11 (Onward Disclosures). If Viasystems uses Personal Data for these additional purposes, such as for contacting the visitor to the Viasystems Web Site independent of an inquiry from such visitor, such visitor shall be entitled to opt-out of such additional uses in accordance with Section 10 (Choice and Opt-Out Rights).

5.4. Disclosure. Viasystems will not disclose Personal Data received from visitors to the site except in accordance with Section 11 (Onward Disclosures).

6. Employment Applicants. The Viasystems Web Site allows individuals to submit an application for employment with Viasystems through the Viasystems Web Site (an “Employment Applicant”). Applications submitted by Employment Applicants will include Personal Data. This Section provides Viasystems’ protection practices with respect to the Personal Data submitted through this Web Site.

6.1. Use of Employment Applicants' Personal Data. Viasystems uses Personal Data it receives from Employment Applicants (i) to process the Applicants' applications, (ii) to contact references which may be identified in such applications, (iii) to collect and compile additional information concerning the Applicant from available sources, consistent with applicable law, and (iv) to evaluate the Employment Applicant's candidacy for employment.

6.2. Further Uses. Viasystems may wish to use an Employment Applicant's Personal Data for purposes which are in addition to those specified in Section 6.1 (Use of Employment Applicant's Personal Data) and which do not involve disclosures beyond those permitted in Section 11 (Onward Disclosures). If Viasystems uses an Employment Applicant's Personal Data for these additional purposes, such as for contacting the Employment Applicant independent of the employment application process, the Employment Applicant shall be entitled to opt-out of such additional uses in accordance with Section 10 (Choice and Opt-Out Rights).

6.3 Disclosure. Except as otherwise set forth herein, Viasystems will not disclose Personal Data received from an Employment Applicant except in accordance with Section 11 (Onward Disclosures).

6.4. Sensitive Data. Viasystems does not request Personal Data that discloses the medical or health condition; race or ethnicity; political, religious or philosophical affiliations or opinions; sexual orientation; or trade union membership (“Sensitive Data”) of an Employment Applicant or any other user of this Web Site, except as expressly permitted under the local laws and regulations of the applicable jurisdiction. In the event an Employment Applicant submits Sensitive Data, Viasystems will handle such Sensitive Data in accordance with Section 8 (Sensitive Data).

7.1. Viasystems Has No Obligation to Consider Application. Due to the nature of the Internet and the structure of the Viasystems Web Site, Viasystems may receive (i) substantially more applications through this Web Site than Viasystems wishes to review, (ii) applications which do not meet the requirements for positions that are available, and (iii) applications at points where no positions are currently available. Accordingly, there is no assurance that Viasystems will process or review materials which Employment Applicants submit seeking employment with Viasystems. Viasystems expressly disclaims any obligation to engage in such processing or review, and disclaims any obligation to respond to any Employment Applicant submissions.

8. Sensitive Data. This Section provides Viasystems’ practices to protect the Sensitive Data of visitors of the Web Site.

8.1. Compliance with Law. Viasystems complies with the laws and regulations applicable to Sensitive Data in their respective jurisdictions, and does not collect or request Sensitive Data except in accordance with such laws and regulations.

8.2. Additional Protections for Sensitive Data. If Viasystems receives Sensitive Data, Viasystems will not disclose such Sensitive Data to any third party and will not use the Sensitive Data for any purpose other than (i) for the purpose for which it was originally provided by the sender of the Sensitive Data or (ii) for a later purpose expressly authorized or consented to by the sender of the Sensitive Data, except as provided below in Section 8.3 (Exception from Consent Requirement for Certain Disclosures).

8.3. Exception from Consent Requirement for Certain Disclosures. Notwithstanding the requirements of Section 8.2 (Additional Protections for Sensitive Data), Viasystems shall be entitled to use or disclose Sensitive Data (as well as Personal Data) where such disclosure or use: (i) is in the vital interests of the sender of the data or another person, (ii) is necessary for the establishment of legal claims or defenses, (iii) is required to provide medical care or diagnosis, (iv) is necessary to carry out Viasystems’ obligations in the field of employment law, or (v) is related to data manifestly made public by the sender of such Sensitive Data.

9. Confidentiality and Security Of Personal Data. Viasystems maintains physical, electronic and procedural safeguards designed to secure the Personal Data of the users and visitors of this Web Site, and to prevent unauthorized access. These technical security systems are structured to deter and prevent hackers and others from accessing the Personal Data of the users and visitors of this Web Site.

9.1. Limitations on Technical Protections. Due to evolving technologies, Viasystems cannot provide assurance that Personal Data provided will remain free from loss, misuse, or alteration through third parties who, despite Viasystems’ efforts, obtain unauthorized access.

9.2. Employee Education. Employees of Viasystems with access to Personal Data concerning users and visitors of this Web Site are educated concerning Viasystems’ applicable Personal Data protection practices, and employees who violate these practices are subject to disciplinary process.

10. Choice and Opt-Out Rights. Viasystems will use the Personal Data of users and visitors of this Web Site for the purposes specified in Section 5 (Site Visitors), Section 6 (Employment Applicants), above (collectively, "Original Purposes"). Viasystems may wish periodically to use such Personal Data for purposes other than the Original Purposes, including for purposes of providing the users and visitors of this Web Site with direct marketing and other information. Information provided to a visitor of this Web Site for such purposes is referred to collectively as "Direct Marketing Information."

10.1. Opt-Out Notice. If a user or visitor of this Web Site does not want to receive Direct Marketing Information from Viasystems, such visitor shall send a letter to Viasystems in accordance with Section 18 hereof and mail it to Viasystems.

10.2. Response. If Viasystems receives an Opt Out Notice for Direct Marketing from a user or visitor of this Web Site, Viasystems will restrict their uses of such person’s Personal Data to the Original Purposes, or such other purposes as such person may authorize, subject to the Data Subject's rights under Section 12 (Rights to Access, Change, or Delete Personal Data). Viasystems shall be entitled to a reasonable period of time to process a request under this Section 11 (Choice and Opt-Out Rights).

11. Choose and Opt-out Rights; Onward Disclosures. Viasystems discloses Personal Data of users of this Web Site only to its employees who have a reasonable "need to know" such Personal Data, and such employees are under obligations of confidentiality to Viasystems. Viasystems will not disclose the Personal Data of users of this Web Site to anyone other than such reasonable "need to know" employees, except as provided below in this Section 1 (Onward Disclosures) and in Section 16 (Assignment).

11.2. Viasystems Agents. Viasystems may disclose Personal Data of users or visitors of this Web Site (i) to a third party that is acting as Viasystems’ agent to perform tasks on Viasystems’ behalf and under Viasystems’ supervision, provided the third party either (a) subscribes to the Safe Harbor principles or (b) agrees (1) to provide auditable protections for such person’s privacy interests that are no less protective than those set out in this Privacy Policy, and (2) to use the Personal Data only for the purposes for which the third party has been engaged by Viasystems.

11.3. Other Third Parties. Except as provided for herein, Viasystems will not disclose Personal Data of users or visitors to this Web Site to any third party other than one identified in this Section 11 (Onward Disclosures) without such person’s express consent.

12. Right To Access, Change, or Delete Personal Data. Upon reasonable request, and to the extent the request does not compromise Viasystems practices to protect Personal Data, Viasystems allows users and visitors of this Web Site access to their Personal Data to correct, amend or delete such Data.

12.1. Requests. All requests under this Section 12 (Right to Access, Change, or Delete Personal Data) must be sent in writing to the address specified below in Section 18 (Complaints, Questions, and Requests).

12.2. Timing of Response. Viasystems will endeavor to timely respond to proper requests for access and changes or deletions under this under this Section 12 (Right to Access, Change, or Delete Personal Data). Any questions or inquiries concerning the timing of Viasystems’ response should be directed to the address specified below in Section 18 (Complaints, Questions, and Requests).

12.3. Conditions. Viasystems reserves (i) the right, where permitted by law or other legal authority, to charge a reasonable fee to cover the costs incurred in responding to an appropriate request, and (ii) reserves the right to delete such information, rather than correct or update this information where the information retains limited utility.

12.4. Extent of Data Deletions. Upon fulfilling a requested deletion of Personal Data under this Section 12 (Right to Access, Change, or Delete Personal Data), Viasystems will cease to use such Personal Data and will use commercially reasonable efforts to remove all record of such Personal Data; however, it may be impossible to delete the information completely from applicable Viasystems databases, due to backups and records of deletions.

13. Privacy Protection For Children. The Viasystems Web Site is not directed at children, and Viasystems will not accept or request Personal Data from individuals Viasystems knows to be under 13. In accordance with the Children's Online Privacy Protection Act of 1998, if Viasystems learns that a child under 13 has provided Personal Data, Viasystems will delete this information from its databases, in accordance with its deletion policy, set out in Section 12 (Right to Access, Change, or Delete Personal Data).

14. Exceptions. As further provided herein, Viasystems may disclose Personal Data as may be required in legal proceedings, or in response to a subpoena, court order, or administrative order compelling disclosure. In addition, in cases involving a threat of imminent harm to a Data Subject or to others, Viasystems may release such Personal Data to prevent or mitigate the threat. In any such case, Viasystems will seek to limit the scope of disclosure, and will disclose only such Personal Data as is reasonably required to fulfill the purpose of the disclosure.

15. Changes to This Privacy Policy. The practices of Viasystems to protect Personal Data defined in this Privacy Policy are current as of January 1, 2007. Viasystems reserves the right to change this Privacy Policy from time to time consistent with applicable privacy laws and principles. Unless such changes afford greater protections to the privacy interests of users and visitors of this Web Site, such changes will apply only to Personal Data received after the effective date of such change. Users and visitors of this website should refer to this Privacy Policy for information concerning such changes. Where Viasystems deems appropriate, other forms of notice will be given concerning such changes.

16. Assignment. Viasystems shall be entitled to assign or transfer to a third party Personal Data that Viasystems receives under this Privacy Policy, in connection with the sale or transfer of all or an applicable portion of its business or assets; provided such third party agrees before receipt of such data to comply with restrictions on the use of such data that are no less protective of the privacy interests of users and visitors of this Web Site than those set out in this Privacy Policy.

17. Choice Of Law And Jurisdiction. This Privacy Policy shall be construed in accordance with the laws of the State of Missouri, without regard to any conflict of law provisions. Any dispute arising under this Privacy Policy shall be resolved exclusively by the state sitting in St. Louis County, Missouri, or in the case of Federal Jurisdiction is proper, the Eastern District of Missouri.

18. Complaints, Questions, and Requests. Safe Harbor and Online Privacy Policy Data Subjects may contact Viasystems (i) with complaints concerning this Privacy Policy or its implementation, (ii) with questions concerning this Policy, and (iii) with requests under Section 12 (Right to Access, Change, or Delete Personal Data), at the following address:

Viasystems Group, Inc.
Office of the General Counsel
101 South Hanley Road
Clayton, MO 63105

Opt-Out Notice For Direct Marketing
Capitalized terms in this Notice are defined in Viasystems’ Privacy Policy for Safe Harbor and Online Users. This Policy is located at www.viasystems.com

Viasystems periodically may wish to use Personal Data to send Direct Marketing Information to users and visitors to its Web Site located at www.viasystems.com (the “Viasystems Web Site”). Such users and visitors of the Viasystems Web Site have the right to opt-out of receiving such Direct Marketing Information, in accordance with Section 10 of Viasystems’ Privacy Policy for Safe Harbor and Online Users. If you are a user or visitor to the Viasystems Web Site, and you choose to exercise this opt-out right, please send a letter to the address below informing Viasystems of your desire to exercise your right to opt-out.

Viasystems Group, Inc.
Office of the General Counsel
101 South Hanley Road
St. Louis, MO 63105