In these California Consumer Privacy Act Disclosures (“CCPA Disclosures”), we, Seiko Holdings Corporation (“Seiko”), disclose information about our data processing practices in the format and with the terminology contemplated by the California Consumer Privacy Act of 2018 (“CCPA”). Given the fact that these disclosures are crafted to address specific disclosure requirements in CCPA with specific terminology prescribed by the statute, these disclosures must not be read out of context of CCPA and its scope limitations.
I. Who and what information is subject to these CCPA Disclosures?
California residents are protected as “consumers” by the CCPA with respect to personal information.
A number of statutory exceptions apply under the CCPA and to these CCPA Disclosures, including the following:
- personal information reflecting a written or verbal communication or a transaction between the business and the consumer, where the consumer is a natural person who is acting as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, non-profit, or government agency and whose communications or transaction with the business occur solely within the context of the business conducting due diligence regarding, or providing or receiving a product or service to or from such company, partnership, sole proprietorship, non-profit, or government agency
- personal information that is collected by a business about a natural person in the course of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the natural person’s personal information is collected and used by the business solely within the context of the natural person’s role or former role as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or a contractor of that business
- personal information that is collected by a business that is emergency contact information of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the personal information is collected and used solely within the context of having an emergency contact on file
- personal information that is necessary for the business to retain to administer benefits for another natural person relating to the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the personal information is collected and used solely within the context of administering those benefits.
II. CCPA Notice at Collection
In this CCPA Notice at Collection, we are addressing disclosure requirements under California Civil Code §1798.100(b) and California Attorney General Regulations § 999.305 at or before the point of collection:
We collect the following categories of personal information about consumers:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||NO|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||NO|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||NO|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 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 grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
We collect personal information about consumers for the following purposes:
- to (i) offer benefits to SEIKO’s shareholders, (ii) implement measures to improve a relationship between the shareholders and us, and (iii) create and provide materials regarding shareholders’ data in accordance with applicable laws.
- to provide consumers with support and to respond to consumers’ inquiries.
- to improve our website and services.
- to help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
- to comply with and enforce our rights and perform our obligations under applicable laws.
1. Right to Know About Personal Information Collected, Disclosed, or Sold
We will ask that you provide certain information to verify your identity, such as a code sent to an email address we may have on file for you. If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. We will respond to your request in accordance with the CCPA. If we deny requests, we will explain why.
2. Our Personal Information Handling Practices in the Preceding 12 months
We have set out below the categories of personal information we have collected about California residents in the preceding 12 months and the categories of sources from which the personal information was collected. We collected the personal information outlined in the table for the business and commercial purposes listed in Section II above.
|A. Categories of personal information as referenced in Cal. Civ. Code 1798.130 (c)||B. Categories of personal information that Seiko collected about the consumer||C. Categories of sources from which the personal information is collected|
|Identifiers||Real name, alias, unique personal identifier, postal address, email address, IP address, Cookie and other online identifier||
Administrator of shareholder registry.
|Any categories of personal information described in subdivision (e) of Section 1798.80:||Name, postal address, telephone number||
Administrator of shareholder registry.
|Commercial information.||Products or services purchased, obtained, or considered||Our affiliate.|
|Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with our website||
3. Disclosures of Personal Information, No Sale
In the preceding 12 months, we did not sell or disclose California residents’ personal information. We do not sell personal information. We do not have actual knowledge that we sell the personal information of minors under 16 years of age.
4. Right to Request Deletion of Personal Information
You have a right to request the deletion of personal information that we collect or maintain about you. To submit a request to delete personal information, please call our toll-free phone number 888-348-3111 or submit an email request to firstname.lastname@example.org and include “California Request to Delete” in the subject line. Please specify in your request the personal information about you that you would like to have deleted, which can be all of your personal information as required by the CCPA.
We will ask that you provide certain information to verify your identity, such as a code sent to an email address we may have on file for you. If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. Once confirmed, we will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.
5. Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
You may not be discriminated against because you exercise any of your rights under the CCPA in violation of Cal. Civ. Code §1798.125.
6. Authorized Agent
You can designate an authorized agent to make a request under the CCPA on your behalf if:
- The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
- You sign a written declaration that you authorize the authorized agent to act on your behalf.
If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please have the authorized agent take the following steps in addition to the steps described in Sections 1 and 4 above:
- Mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf to 26-1, Ginza 1-chome, Chuo-ku, Tokyo 104-8110, Japan and
- Provide any information we request in our response to your email to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue.
If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.
7. Contact for More Information
Last updated on December 10, 2020.