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Privacy Policy

KYB Corporation and KYB Group companies in Japan (hereinafter referred to as the "KYB Group"), establishes this Privacy Policy (hereinafter referred to as this "Policy") to ensure the proper handling of personal information as an organization in accordance with the Act on the Protection of Personal Information (Act No. 57 of 2003, hereinafter referred to as the "Personal Information Protection Act").

KYB Corporation：https://www.kyb.co.jp/

KYB Group companies in Japan：https://www.kyb.co.jp/company/global_japan_group.html

Individual privacy policies set forth by each KYB Group and individual privacy policies set forth for each product or service ("Individual Policies") may apply in conjunction with this Policy. In such cases, the Individual Policies shall prevail over this Policy to the extent that the terms of the Individual Policies conflict with the terms of this Policy.

In addition to this Policy, which applies to all of KYB Group's handling of Personal Information, KYB Group has developed the following Privacy Notices that may be applicable to you depending on where you live or where you are located. If the laws and regulations of any of the following jurisdictions apply to you, the applicable following Privacy Notices will also apply in conjunction with this Policy, and the following Privacy Notices will supersede this Policy to the extent that there is any conflict between the terms of the following Privacy Notices and the terms of this Policy.

▶︎ Privacy Notice for EU and UK
▶︎ Privacy Notices for California and Other U.S. States
▶︎ Privacy Notice for Canada

Article 1 (Personal Information)
"Personal Information" refers to "Personal Information" as defined in the Personal Information Protection Law and refers to information about a living individual that can identify the specific individual by name, date of birth, or other description contained in the information, or that contains a personal identification code.
Article 2 (Items of Personal Information to be Obtained)
KYB Group may acquire Personal Information including the following information;
・Name, gender, date of birth, mailing address, telephone number, e-mail address
・Details of the services you have applied for
・Account number and other information necessary for payment of services
Article 3 (Purpose of Use of Personal Information)
KYB Group will use the Personal Information it has acquired (excluding Specified Personal Information, and the same shall apply hereinafter in this Article) to the extent necessary for the following purposes. If KYB Group intends to use the Personal Information beyond the scope of the following purposes, KYB Group shall obtain prior consent from the individual in an appropriate manner.

（1）Personal Information of Customers and business partners ("Customers, etc."). “Customers, etc." also includes individuals belonging to business partners.

・To provide KYB Group products and services

・To bill for KYB Group products and services

・To provide maintenance management and after-sales service for KYB Group products and services

・To provide information, solicit, advertise, or conduct other marketing activities related to the products and services of KYB Group and its partner companies, etc.

・To analyze the attributes of Customers, etc., purchase and usage of KYB Group products and services, browsing history of KYB Group's website, action history, etc.

・For planning, research and development of KYB Group products and services

・To conduct sales promotion activities for KYB Group products and services, such as sending and managing information on campaigns, exhibitions, and events conducted by KYB Group

・To manage access to facilities operated by KYB Group

・To make necessary contact for transactions

・To respond to inquiries, requests, etc.

・To exercise rights and fulfill obligations under contracts, laws and regulations, etc.

・To provide the information to third parties in accordance with Article 5 of this Policy.

・To prevent and respond to fraud, etc.

・To respond to whistleblowing reports

・For the purposes individually specified at the time of acquisition of Personal Information

・For other operations related to the above items


（2）Personal Information of shareholders

・To exercise rights and fulfill obligations under the Companies Act and other laws and regulations

・To manage shareholders and their shares, including preparation of documents, records, and data of shareholders in accordance with prescribed standards under the Companies Act and other laws and regulations.

・To provide services and information to shareholders

・To respond to inquiries and requests from shareholders

・To manage access to facilities operated by KYB Group

・To provide the information to third parties in accordance with Article 5 of this Policy.

・To prevent and respond to fraud, etc.

・For the purposes individually specified at the time of acquisition of Personal Information

・For other operations related to the above items


（3）Personal Information of employees and officers of KYB Group (including former employees and officers of KYB Group, and the same shall apply hereafter)

・To contact and provide information in the event of an emergency and to contact and provide information related to our business.

・For assignment, duties in charge, transfers, evaluations, awards, disciplinary actions, and other personnel management purposes

・To manage equipment and facilities

・To manage working hours, health management, ensuring a proper working environment, and other labor management

・To determine and pay wages, bonuses, retirement benefits, corporate pensions, etc.

・For procedures related to social insurance, taxation, etc.

・For procedures related to employee benefits, etc.

・To provide training, education and other educational training and capacity building

・To respond to inquiries and requests from employees and officers

・To manage access to facilities operated by KYB Group

・To provide the information to third parties in accordance with Article 5 of this Policy.

・To prevent and respond to fraud, etc.

・To respond to whistleblowing reports

・For the purposes individually specified at the time of acquisition of Personal Information

・For other operations related to the above items


（4）Personal Information of applicants for employment

・To provide information and contact applicants regarding recruitment activities

・To conduct the selection process for applicants

・To confirm the applicant's past applications to KYB Corporation

・To manage information of applicants for employment

・To respond to inquiries and requests from applicants

・To manage access to facilities operated by KYB Group

・To provide the information to third parties in accordance with Article 5 of this Policy.

・To prevent and respond to fraud, etc.

・For the purposes individually specified at the time of acquisition of Personal Information

・For other operations related to the above items

Article 4 (Purpose of Use of Specified Personal Information)
KYB Group will use Specified Personal Information (Personal Numbers and Personal Information that includes Personal Numbers) of employees, officers, etc. to the extent necessary to achieve the following purposes of use and permitted by law.

・To perform administrative work related to employment insurance in accordance with the Employment Insurance Law

・To perform administrative work related to health insurance in accordance with the Health Insurance Law

・To perform administrative work related to pensions in accordance with the Employees' Pension Insurance Law.

・To perform administrative work related to Category 3 insured persons in accordance with the National Pension Law.

・To perform administrative work related to withholding taxes in accordance with the Income Tax Law and Inheritance Tax Law.

・To prepare and provide legal documents related to financial instruments transactions related to the Wealth Formation Savings Program

・To prepare and provide legal documents related to financial instruments transactions related to the Shareholding Association

・To perform administrative work related to human resources and employee benefits programs

・To prepare and submit records of payment of remuneration, fees, contracts, and monetary awards

・To perform administrative work related to the preparation and submission of payment records related to shares and stock

・To prepare and submit payment records for real estate royalties, etc.

・For other Personal Number-related work stipulated by laws and ordinances

Article 5 (Provision to Third Parties)
KYB Group will not provide Personal Information handled by KYB Group to third parties without the prior consent of the individual, except in the following cases

（1）When it is necessary for the protection of the life, body, or property and it is difficult to obtain the consent of the individual.

（2）When it is especially necessary to improve public health or to promote the sound growth of children and it is difficult to obtain the consent of the individual.

（3）When it is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law and obtaining the consent of the individual is likely to impede the execution of such affairs.

（4）When permitted by other laws and regulations.

Article 6 (Entrustment of Handling of Personal Information)
KYB Group may outsource all or part of the handling of Personal Information to third parties to the extent necessary to achieve the purposes of use stipulated in Article 3. In such cases, KYB Group will thoroughly examine the eligibility of the consignee, stipulate confidentiality obligations in the contract, and exercise necessary and appropriate supervision over the consignee.
Article 7 (Joint Use of Personal Information)
KYB Group may share Personal Information to the extent necessary to achieve the purposes of use, as described below.
Items of Personal Information to be Shared
All items of personal information relevant to employees, officers, and job applicants, including but not limited to their names, affiliations, email addresses, mailing addresses, telephone numbers, and other contact details.
Scope of joint use
KYB Group in and outside of Japan
（https://www.kyb.co.jp/company/global.html）
Purpose of Shared Use
Purposes of use described in Articles 3(3) and (4)
Person responsible for management of Personal Information to be shared
KYB Corporation
For the company address and the name of the representative, please refer to Corporate Information.
[Contact]
Head of Internal Control Department
28th Floor, South Tower, World Trade Center Building
2-4-1 Hamamatsu-cho, Minato-ku, Tokyo 105-5128, Japan
Items of Personal Information to be Shared
Information of Customers, etc.
Scope of joint use
KYB Group in and outside of Japan
（https://www.kyb.co.jp/company/global.html）
Purpose of Shared Use
Purposes of use described in Article 3(1)
Person responsible for management of Personal Information to be shared
KYB Corporation
For the company address and the name of the representative, please refer to Corporate Information.
[Contact]
Head of Internal Control Department
28th Floor, South Tower, World Trade Center Building
2-4-1 Hamamatsu-cho, Minato-ku, Tokyo 105-5128, Japan
Article 8 (Request for Disclosure of Personal Information)
1.KYB Group will respond to the following requests in accordance with the Personal Information Protection Law after confirming the identity of the individual in accordance with the prescribed procedures.

（1）Requests for disclosure of Personal Information held by KYB Group or records of provision of Personal Information to third parties, or for notification of the purpose of use of Personal Information

（2）Request for correction, addition or deletion of Personal Information held by KYB Group

（3）Requests to cease use, erase, or cease provision to third parties of Personal Information held by KYB Group


2.To make a request as specified in the preceding paragraph, please contact us to inquire about the procedure via the contact details set forth in Article 13 (Contact for Inquiries).
Article 9 (Procedures for Changing Privacy Policy)
KYB Group may change the contents of this Policy from time to time. The revised Privacy Policy shall become effective when it is notified to you in a manner prescribed by KYB Group or posted on KYB Group website.
Article 10 (Compliance with Laws, Regulations, Guidelines, etc.)
KYB Group complies with all applicable Japanese laws, regulations, guidelines, etc. regarding Personal Information in its possession.
Article 11 (Security Control Measures)
KYB Group shall take necessary safety measures for the management of Personal Information, including thorough employee training and the development of a management system, to prevent unauthorized access, destruction, alteration, loss, or leakage of Personal Information, as described below.

（1）Formulation of basic policy
In order to ensure the proper handling of Personal Information, KYB Group establishes a basic policy (this Policy) regarding "compliance with related laws and guidelines," and "contact for questions and complaints," etc.

（2）Establishment of rules for the handling of Personal Information
KYB Group establishes rules for the handling of Personal Information, including handling methods, responsible persons and persons in charge, and their duties, for each stage of acquisition, use, storage, provision, deletion, and disposal of Personal Information.

（3）Organizational safety control measures
In addition to appointing a person responsible for the handling of Personal Information, KYB Group clarifies the employees who handle Personal Information and the scope of Personal Information handled by such employees and establishes a system for reporting to the person responsible in the event that the fact or indication of a violation of the law or handling rules is detected.
In addition, KYB Group conducts periodic self-inspections of the status of Personal Information handling, as well as audits by other departments and outside parties.

（4）Personal safety control measures
Provide periodic training to employees on matters to keep in mind regarding the handling of Personal Information.
In addition, the employment regulations shall include a confidentiality policy regarding Personal Information.

（5）Physical safety control measures
In areas where Personal Information is handled, KYB Group controls the access of employees, limit the equipment they bring into the office, and implement measures to prevent unauthorized persons from accessing Personal Information.
In addition, KYB Group takes measures to prevent theft or loss of equipment, electronic media, and documents that handle Personal Information, and implements measures to ensure that Personal Information is not easily revealed when such equipment, electronic media, etc. are carried, including within the business site.

（6）Technical safety control measures
Access control is implemented to limit the scope of persons in charge and the Personal Information databases, etc. handled.
In addition, KYB Group implements mechanisms to protect information systems that handle Personal Information from unauthorized external access or unauthorized software.

Article 12 (Address and Name of Representative)
The name, address and name of the representative of each KYB Group company are as follows

KYB Corporation：https://www.kyb.co.jp/company/information.html

KYB Group companies in Japan：https://www.kyb.co.jp/company/global_japan_group.html

Article 13 (Contact for Inquiries)
For inquiries regarding KYB Group's handling of Personal Information, requests for disclosure of Personal Information, or complaints, please contact the following

KYB Corporation：Contact Form

World Trade Center Building South Tower 28F, 2-4-1 Hamamatsu-cho, Minato-ku, Tokyo 105-5128, Japan
TEL: +81-3-6848-0040

Enacted and Effective July 16, 2025

Privacy Notice for EU and UK

A.Your Rights Under the General Data Protection Regulation (GDPR)

This Notice applies if you are a Kayaba Group data subject who resides or is located in the European Economic Area (“EEA”). We adopt this section to comply with European privacy laws, including the General Data Protection Regulation (“GDPR”). Any terms defined in the GDPR have the same meaning when used in this section.

Under applicable law, Kayaba Group is considered the “data controller” of the Personal Information we manage under this Notice. In other words, we are responsible for deciding how to collect, use and disclose this information, subject to applicable law.

We want to ensure that the Personal Information we possess is always accurate and therefore we encourage you to update your information in case any changes have occurred. We have listed below the rights that you may be able to exercise with respect to the processing of your Personal Information, subject to applicable law. We take reasonable steps to ensure that the Personal Information we process is limited to the Personal Information that are required in connection with the purposes set out in the Privacy Policy.

If you are a resident of or located within the EEA, you have certain data protection rights. These rights include:

・The right to access, update or delete the information we have collected from you.

・The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

・The right to object. You have the right to object to our processing of your Personal Information.

・The right of restriction. You have the right to request that we restrict the processing of your Personal Information.

・The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.

・The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your Personal Information.

Personal Information Obtained By Us and How We Use It
Please see the Privacy Policy for the categories and sources of Personal Information obtained by us, the purpose for our use and processing of your Personal Information, and how we share that Personal Information.

We retain your Personal Information only for as long as is necessary for the purposes set forth in the Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

We utilize the following criteria to determine the length of time for which we retain Personal Information:

・How long we have had a relationship with you or provided our services to you;

・The business purposes for which the information is used, and the length of time for which the information is required to achieve those purposes;

・Whether we are required to retain the information, or the information is otherwise necessary, in order to: comply with legal obligations or contractual commitments: defend against potential legal claims: detect or prevent potential illegal activity or actions in violation of our policies and procedures; secure our systems and online environment; or protect health and safety;

・The privacy impact on individuals of ongoing retention; and

・The manner in which information is maintained and flows through our systems, and how best to manage the lifecycle of information in light of the volume and complexity of the systems in our infrastructure.

Legal Basis for Processing Personal Information
We rely on the following legal bases for processing your Personal Information:

Contract：To conclude or perform a contract with you; for example:

・To respond to your customer service inquiries and requests for information;

・To manage and fulfill orders, facilitate delivery, and to provide other Services;

・To manage our accounts and records;

・To exercise rights and fulfill contractual, legal, or regulatory obligations;

・To provide information to third parties under the Privacy Policy or other contractual requirements;

・To provide information, solicit, advertise, or other marketing activities related to our products and Services, and its partner companies when you have agreed to such activities;

・To manage shareholders and their shares, including the preparation of documents, records, and data of shareholders in accordance with prescribed standards under the Companies Act and other laws and regulations;

・To provide Services and information to shareholders;

・To respond to inquiries and requests from shareholders

・To provide information and contact applicants regarding recruitment activities;

・To conduct applicant selection process;

・To confirm past applications;

・To manage information of applicants for employment;

・To respond to inquiries and requests from applicants for employment;

・To contact and provide business-related or employment information to employees;

・To manage working hours, health management, and other labor management;

・To respond to inquiries and requests from employees and officers;

・To manage access to our facilities;

・To determine and pay wages, bonuses, retirement benefits, and corporate pensions;

・For other purposes individually specified at the time we acquired your Personal Information; and

・For other operations related to any of the above items.


Legitimate Interests
When we process your Personal Information for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Information for activities where our interests are overridden by the impact on you unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests, as further described below. Examples of legitimate interests include:

・To detect, prevent, or investigate security breaches or fraud;

・To research and develop our products and services;

・To conduct promotional activities, like sending and managing information on our campaigns, exhibitions, and events;

・To maintain, improve, and analyze our site and the services we offer;

・In connection with a sale, transfer, liquidation, purchase, merger, or acquisition of our assets, including Personal Information;

・To analyze customer attributes, purchase and use of our products and Services, our Site’s browsing and action history; and

・To facilitate the functionality of our site.


Legal Compliance：To comply with our legal obligations; for example:

・To maintain appropriate records for internal administrative purposes and as required by applicable law, and

・To provide important product safety information and notice of product recalls or other consumer information.


Consent：We will send you information by email on our services or other promotions only with your consent or if you otherwise opt-in to receiving those communications. If you do not provide us with your consent to the processing of your Personal Information for this purpose, we will not send you this information. You have the right to withdraw your consent at any time by contacting us indicated in our Privacy Policy.
Transfer of Information Outside of the EEA
Our business requires the transfer of your Personal Information to Japan as a Japanese-headquartered company. The European Commission has determined that Japan offers an adequate level of protection. You may review the adequacy decision here.

If we share your Personal Information within the Company or with third parties located outside the European Economic Area to a country where an adequacy decision has not been made, we take steps to ensure that appropriate safeguards are in place to guarantee to the continued protection of your Personal Information, such as by entering into the European Commission’s Standard Contractual Clauses, binding corporate rules, applicable privacy framework, or explicit consent, as needed.
How to Exercise Your Rights Under the GDPR
If applicable, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us by contacting us indicated in our Privacy Policy. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of the EEA by including your country of citizenship or residence in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in the EEA to obtain the information. We will respond to your request within 30 days or let you know if we need additional time.

Please note that we will ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.

Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us indicated in our Privacy Policy.

B.Your Rights Under the United Kingdom GDPR (UK GDPR)

If you are based in the United Kingdom, the following provisions also apply:

Our business requires the transfer of your Personal Information to Japan as a Japanese-headquartered company. The UK Information Commissioner’s Office has recognized the adequacy of Japan for personal data transferred to private sector organizations falling within the scope of Japan’s Act on the Protection of Personal Information (“APPI”) and acknowledges the European Commission’s adequacy decision referenced above. You may review additional information relating to the ICO adequacy decision here. If we share your Personal Information within the company or with third parties located outside the United Kingdom where an adequacy decision has not been made, we take steps to ensure that appropriate safeguards are in place to guarantee to the continued protection of your Personal Information, such as by entering into the UK International Data Transfer Agreement or the International Data Transfer Addendum to the European Commission’s Standard Contractual Clauses, adopted by the UK Government under section 119A of the Data Protection Act 2018.

You have the same data subject rights as those for the EU listed above, except that references to the “GDPR” should be read as references to the “UK GDPR” and complaints should be filed with the UK supervisory authority, the Information Commissioner’s Office (https://ico.org.uk/).

Privacy Notices for California and Other U.S. States

A.California

This section of the Privacy Notice applies solely to California residents. We adopt this Section to comply with the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”). Any terms defined in the CCPA or CPRA have the same meaning when used in this Section.

California residents have the following rights:

・To know the categories of Personal Information being collected about you, and the purposes for which the categories of Personal Information are collected or used;

・To know the length of time we intend to retain each category of Personal Information;

・To know whether your Personal Information is sold, shared or disclosed, and to whom;

・To access your Personal Information;

・To delete the Personal Information you have provided to us, with certain exceptions;

・To correct your Personal Information;

・To opt out of the sale of Personal Information;

・To know if Sensitive Personal Information (“SPI”) is being collected about you, the categories of SPI being collected, the purposes for which the categories of SPI are collected or used, and whether the SPI is sold or shared;

・To limit the use of your SPI if it is used for cross-contextual behavioral advertising or for the purposes of inferring characteristics about you; and

・Not to be discriminated against, even if you exercise your privacy rights.

Request for Information, Correction, or Deletion
California residents have the right to request, under certain circumstances, that a business that collects Personal Information about them disclose the information listed below for the preceding 12 months:

・The categories of Personal Information collected about you;

・The categories of sources from which the Personal Information is collected;

・The business or commercial purpose for collecting, selling or sharing Personal Information;

・The categories of third parties to whom the business discloses Personal Information; and

・The specific pieces of Personal Information collected about you


Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.

You can also request that we correct or delete your Personal Information. There may be certain exceptions to our obligation to correct or delete your information such as if you have an existing account or transaction with us or if we have a legitimate business reason to keep your information.
Personal Information Collected
We have collected the following categories of Personal Information from consumers within the last twelve (12) months:
Category of Personal Information Collected by KYB Corporation
Category of Third Parties Personal Information is Disclosed to for a Business Purpose
Category of Third Parties to Whom Personal Information is Sold And/or Shared
A.Identifiers.
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
Service providers, Our corporate family, Advertising partners (online identifiers only), Data analytics providers
Advertising partners (online identifiers only), Data analytics providers (online identifiers only)
B.Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, address, telephone number, education, employment, employment history, credit card number, debit card number, or any other financial information. Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Note: Some personal information included in this category may overlap with other categories.
Service providers, Our corporate family, Data analytics providers
N/A
C.Protected classification characteristics under California or federal law.
Age (40 years or older), national origin, citizenship, marital status, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status.
Service providers, our corporate family, Data analytics providers
N/A
D.Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Service providers, Our corporate family, Data analytics providers, Advertising partners
Data analytics providers, Advertising partners
E.Biometric information.
Not collected
N/A
F.Internet or other electronic network activity.
Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.
Service providers, Our corporate family, Data analytics providers, Advertising partners
Data analytics providers, Advertising partners
G. Geolocation data
Service providers, Our corporate family, Data analytics providers, Advertising partners
Data analytics providers, Advertising partners
H.Sensory data.
Audio, electronic, visual, or similar information.
Service providers, Data analytics providers
N/A
I.Professional or employment-related information.
Current or past job history.
Collected only for employees or job applicants
N/A
J.Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as class lists or student identification codes.
Not collected
N/A
K.Inferences drawn from other personal information to create a profile about a consumer.
Profile reflecting a consumer's preferences.
Service providers, Data analytics providers, Advertising partners
Data analytics providers (online identifiers only), Advertising partners (online identifiers only)
L.Sensitive Personal Information (other than publicly available SPI)
Not collected
N/A

We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age.
Data Retention Policies
We retain your Personal Information only for as long as is necessary for the purposes set forth in the Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies. We utilize the following criteria to determine the length of time for which we retain Personal Information:

・How long we have had a relationship with you or provided our Services to you;

・The business purposes for which the information is used, and the length of time for which the information is required to achieve those purposes;

・Whether we are required to retain the information, or the information is otherwise necessary, in order to: comply with legal obligations or contractual commitments: defend against potential legal claims: detect or prevent potential illegal activity or actions in violation of our policies and procedures; secure our systems and online environment; or protect health and safety;

・The privacy impact on individuals of ongoing retention; and

・The manner in which information is maintained and flows through our systems, and how best to manage the lifecycle of information in light of the volume and complexity of the systems in our infrastructure.

Do Not Sell My Personal Information
As a California resident, you also have the right, at any time, to tell us not to sell Personal Information – this is called the “right to opt-out” of the sale of Personal Information. We do not sell Personal Information, but we recognize that some privacy laws define “Personal Information” in such a way that making available identifiers linked to you for a benefit may be considered a “sale.” To opt out of this, please use the options in our footer, or contact us using the information in the “Contact for Inquiries” section in the Privacy Policy. Please include that you are a California resident when you make your request.
Right to Limit Use of Sensitive Personal Information
California residents have the right to limit the use of each type of Sensitive Personal Information for each purpose with each type of third-party partner. Currently, we do not provide any Sensitive Personal Information to third parties other than those services providers that are necessary to provide our Services to you.
Right Not to Be Discriminated Against
We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by California law, we will not:

・Deny you goods or services.

・Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

・Provide you a different level or quality of goods or services.

・Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Third Party Marketing (“Shine The Light Act”)
California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us a list of what Personal Information (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties.
Exercising Your California Privacy Rights
You or your authorized agent may make a request to access, correct, delete, opt-out of the sale of your Personal Information, or limit the use of your Sensitive Personal Information by contacting us using the information in the “Contact for Inquiries” section of the Privacy Policy

If you use an authorized agent to submit your request, we may require proof of the written authorization you have given. We also may require you to confirm your identity and your residency to obtain the information, and you are only entitled to make this request twice in a 12-month period. For emails, please include “California Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a California resident. We will acknowledge your request within 10 days and respond to your request within 45 days or let you know if we need additional time. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.

B.Other US State Laws

If you live in certain other U.S. states, such as Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have rights under applicable privacy laws once those laws have become effective.

Based on the applicable law in the state where you live, you may have the following rights with respect to your Personal Information:

・To confirm whether or not a controller is processing your personal data and to access such personal data;

・To know the categories of Personal Information we collect about you, the purposes for the collection, how long we retain your Personal Information, and whether that information is sold or shared or disclosed and to whom;

・To correct inaccuracies in your personal data;

・To delete your personal data;

・To obtain a copy of your personal data that you previously provided to us in a portable, and if technically feasible, readily usable format, if processing is carried out by automated means;

・To opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.


To exercise any of these rights, you may make a request to confirm, access, correct, delete, obtain a copy, or opt-out of the processing of your personal data for targeting advertising, sale, or profiling by using the information in the “Contact for Inquiries” section of the Privacy Policy. You must include your full name, email address, and attest to the state in which you are a resident. We may require you to confirm your identity and your residency in order to obtain the information, and you are only entitled to make this request up to twice annually.

We will process your request within 45 days or let you know if we need additional time or cannot process your request. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.
Right to Opt Out
You may have the right to opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. To exercise your right, please click on the links provided in our footer on any webpage where your information is being collected, or in any communication you receive from us.
Opt-Out Preference Signals
Some browsers and browser extensions support opt-out preference signals such as the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales. GPC is a web browser-level setting, maintained by either a browser or a browser extension, that a user or privacy-focused technology can set. In certain regions, when we detect such a signal, we will make reasonable efforts to respect your choices as required by applicable law.
Appeals of Our Decisions
In some jurisdictions, you may appeal to us if we refuse to take action on your exercise of certain choices described above. In order to appeal such a refusal, please contact us using the methods indicated in the Privacy Policy and provide the relevant information.

If we decline to take action on any request you make, we will provide you with the information required by the applicable law where you live. This may include an explanation of why we declined your request, information on how to appeal our decision, and/or how to make a complaint to your state Attorney General.

Privacy Notice for Canada

Canadian laws provide specific privacy rights to our Canadian customers or purchasers of our products in Canada. If you are a resident of Canada, this Notice is applied. Where applicable, we follow applicable Canadian federal and provincial privacy laws (“Canadian Privacy Law”), including:

・The Personal Information Protection and Electronic Documents Act (PIPEDA)

・Alberta’s Personal Information Protection Act (Alberta PIPA)

・British Columbia’s Personal Information Protection Act (BC PIPA)

・Québec's Act respecting the protection of Personal Information in the private sector (Québec Act)

Consent
In most cases, we rely on implied consent to collect, use, or disclose your Personal Information. In some circumstances, including those involving sensitive Personal Information, we obtain express consent. Where you have provided your consent to the collection, use, and transfer of your Personal Information (whether orally, in writing, or electronically), you may have the legal right to withdraw your consent under certain circumstances. In addition to the methods described above with respect to your privacy choices, you may withdraw your consent by submitting a request using the information in the “Contact for Inquiries” section of the Privacy Policy. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time of your request to help you with your decision.
Use of Your Personal Information
We will not collect, use, or disclose Personal Information except for the identified purposes identified in the Privacy Policy (See Purpose and use of Personal Information), unless we have received additional consent or the processing is authorized without consent. Where we engage service providers who utilize the Personal Information we provide to them, those relationships are governed by a written agreement regarding the confidentiality of your information.
Canadian Access and Challenge Rights
Canadian Privacy Law provides the right to receive information about the existence, use, and disclosure of your Personal Information and be provided access to that information. You may also challenge the accuracy and completeness of your Personal Information and have it amended as appropriate. Depending on the nature of the challenged information, amendment may involve correction, deletion, or addition of information.
Exercising Your Canadian Privacy Rights
If you have an account with us, you may view and update your account information directly by logging into your account. To submit a request for access to information not contained within your account, or to challenge the accuracy or completeness of your Personal Information, you may also submit a request using the information in the “Contact for Inquiries” section of the Privacy Policy. When submitting a request, we also may require you to confirm your identity and your residency to obtain the information. We will begin processing your request once you have completed the verification process and will respond within the timeframe required by law.

If we cannot substantively respond to your request in a timely manner, we will notify you and state the reason for the delay. Under certain circumstances, we may not be able to fulfill your request, such as when doing so would interfere with our regulatory or legal obligations, where we cannot verify your identity, or if your request involves disproportionate cost or effort. However, we will respond to your request within a reasonable time, as required by law, and provide an explanation.

Additional information about how to exercise your rights under Canadian Privacy Law can be found here:

Office of the Privacy Commissioner of Canada
Website
Phone: 1-800-282-1376


Office of the Information and Privacy Commissioner of Alberta
Website
Phone: 1-888-878-4044


Edmonton office: (780) 422-6860


Calgary office: (403) 297-2728


Office of the Information and Privacy Commissioner of British Columbia
Website


Vancouver: (604) 660-2421


Elsewhere in BC: (800) 663-7867


Commission d'acces a' l' information du Quebec
Website
Phone: 1-888-528-7741

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