Effective date: January 1, 2020
Date last updated:May 20th, 2021
The protection of personal data is of great concern to us. This Statement for persons who are California residents (collectively, “you” or “your”) explains below how we collect and use your Personal Information (as defined below) under the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”) and what your rights and our obligations are in relation to the processing of your Personal Information in accordance with the CCPA. This Statement will be updated from time to time as needed.
For the purpose of this Statement, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.
Categories of Personal Information Collected
The following is a list of categories of Personal Information as listed in the CCPA which we may have collected or disclosed for its operational business purposes during the 12-month period prior to the effective date of this Statement.
| Category of Personal Information Collected |
Collect? |
Disclose for
business purpose? |
Identifiers, such as Name, alias, postal address, email
address, account name, social insurance number, driver's
license number, passport number, bank account number,
social security number, insurance enrollment, telephone
number, face images, state identification card number,
medical information, unique personal identifier, online
identifier Internet Protocol Address, or any other similar
identifier. |
Yes |
Yes |
Additional data subject to the California customer records
law (any categories of personal information described in
subdivision (e) of Cal. Civ. Code Sec. 1798.80), such as
Signature, physical characteristics or description, phone
number, insurance policy number, education, work
history, credit card number, debit card number or other
financial information, medical information or health
insurance information. |
Yes |
Yes |
Characteristics of protected classifications under California
or federal law, such as age (40 years and over), race,
nationality, citizenship, religion or beliefs, marital status,
medical conditions, physical or mental disorders, gender
(gender, gender identity, gender expression, pregnancy
or birth and related medical conditions) |
Yes |
Yes |
Commercial information, such as records of property,
records of products or services purchased, acquired or
considered, or records of other purchases or consumption
history or trends. |
Yes |
Yes |
Biometric information, such as genetic, physiological,
behavioral, and biological properties used to extract
templates or other identifiers or identifying information, or
activity patterns, fingerprints, facial recognition,
voiceprints, irises, retinal scans, keystrokes, walking and
other physical patterns, sleep, health, exercise data. |
Yes |
Yes |
Internet or network activity information such as browsing
history, search history, and consumer interaction with
internet websites, applications or advertisements. |
Yes |
Yes |
Professional or employment-related information, such as
current or past work history or performance evaluations. |
Yes |
Yes |
Education information subject to the federal Family
Educational Rights and Privacy Act, such as educational
records, such as grades, grade certificates. |
Yes |
Yes |
Inferences drawn from any of the Personal Information
listed above to create profile / summary about, for
example, an individual’s preferences and characteristics,
such as consumer preferences, personality, psychological
tendencies, nature, behaviors, attitudes, intelligence,
estimated information derived from identification
information to create a profile that reflects abilities and
qualities. |
Yes |
Yes |
Sources of Personal Information
For each of these categories, we have collected such categories of Personal Information from the following sources:
- Directly or indirectly from you or your agents.
- Directly or indirectly from activity at our facilities or on our website or intranet.
- Our group companies (affiliates and subsidiaries)
Business or Commercial Purposes
We may use or disclose the Personal Information described above for one or more of the following purposes:
- Communication with you or your company
- To facilitate business transactions. For example, for shipping, delivery, or distribution, or to make or receive payments.
- As part of ordinary business processes. For example, as part of human resources processes, payrolls, health check-up or trainings and educations.
- As necessary or appropriate to protect the rights, property or safety of our employees, customers, or others.
- In cooperation with law enforcement or as required or permitted by applicable law, court order, or regulation.
- As described to you when collecting your personal information.
Sharing of Your Personal Information
1. Sale of Your Personal Information
We do not sell Personal Information and have not sold Personal Information during the 12-month period prior to the effective date of this Statement, including the Personal Information of minors.
2. Disclosure of Personal Information for a Business Purpose
We may disclose the Personal Information described above to various third parties. Such disclosures may be made to service providers who use the information in compliance with our instructions, to companies and individuals as necessary to facilitate the operation of our business, and to other entities, such as our parent company or government authorities, as required or permitted by
law. We will limit disclosures to only the information necessary to fulfil the legal or business purpose for which the information is being disclosed.
Your Rights and Requests
Under the CCPA, you may:
1. Request that we disclose to you the following information that we have collected, used or disclosed over the past 12 months:
- The categories of Personal Information we have collected about you;
- The categories of sources from which we have collected such Personal Information;
- The business or commercial purpose(s) for collecting such Personal Information;
- The categories of third parties with whom we shared such Personal Information; and
- The specific pieces of Personal Information we have collected about you; and
2. Request that we delete Personal Information we have collected from or about you.
We will not discriminate against you for exercising any of your rights under the CCPA.
To make a request for the disclosure or deletion described above, please contact Administration department, our affiliate located in the United States, by using the following means:
Upon receiving a request from you, we will first verify your identity by requiring you to submit your name, email address, phone number and any other
information we may need to verify your identity and by matching the information you provide with the information we already have on file.
If you wish to use an authorized agent to submit a request to know or a request to delete, you may do so by providing Administration department with a written document that is signed by both you and the agent that authorizes the agent to submit a request on your behalf (including a power of attorney).
Contact US
If you have any questions or concerns regarding this Statement or our privacy practices, please contact us at: