In this Personal Information Protection Law Disclosure (“PIPL Disclosure”), we, Seiko Group Corporation (“Seiko”), describe our personal information handling practices under the Personal Information Protection Law of the Peoples’ Republic of China (“PIPL”). This PIPL Disclosure is addressed to Chinese residents only and was last updated March 28, 2025. This PIPL Disclosure does not reflect our processing of Chinese residents’ personal information where an exception under the PIPL applies. This PIPL Disclosure supplements our Web Site Privacy Policy (“Policy”) and prevails over any conflicting provisions in the Policy.

1.How We Handle Your Personal Information

We handle your personal information through collection, recording, retention, use, disclosure by transmission, and deletion.

2.Processing of Sensitive Personal Information

In the case of handling sensitive personal information, we implement measures required under the PIPL such as notifying you of the necessity of handling sensitive personal information, and effects on individuals’ rights and interests.

We handle information about your computer or other electronic device which may include your Internet Protocol (IP) address, date and time of your request and information provided by tracking technologies, such as cookies (“Communication Information”) and personal information of the children under 14 years of age (“Minor Information”) as sensitive personal information. The necessity for handling Communication Information and Minor Information, and effects on individual rights and interests, are as follows:

Communication Information

• Necessity for handling
  It is necessary for us to handle Communication Information for the Marketing Purposes described in the Policy.

• Effects on individuals’ rights and interests
  Communication Information is managed under appropriate security control measures, and the possibility of it having effects on individuals’ rights and interests due to leakage, etc. is limited.

Minor Information

• Necessity for handling
  It is necessary for us to handle Minor Information for the purposes described in the Policy.

• Effects on individuals’ rights and interests
  Minor Information is managed under appropriate security control measures, and the possibility of it having effects on individuals’ rights and interests due to leakage, etc. is limited.

3. Provision of Personal Information

In the case we provide your personal information to third parties other than the outsourcees to which the handling of personal information is outsourced by us, we implement measures required under the PIPL, such as notifying you of such third parties’ names, contact methods, handling purposes, handling methods, and categories of personal information.

In the case we provide your personal information to third parties outside China, we implement measures required under the PIPL, such as notifying you of such third parties’ names, contact methods, handling methods, categories of personal information and the methods and procedures in which the rights set forth under the PIPL will be exercised against such third parties.

We may provide your personal information to the following third parties outside China.

A.

Third parties’ names

Seiko group affiliates listed in the Policy.

How to contact third parties

Please contact us using the information indicated in “Contact Information” of the Policy.

Purposes of third party handling

Purposes specified in the section “The Reason Why We Collect, Use and Share Your Personal Data” of the Policy

Third party handling methods

In the manner stated 1. above

Categories of personal information

Personal information specified in the section “Collection of Your Personal Data” of the Policy.

Manner and procedures, etc. to exercise the rights set forth by the Law against third parties

Please contact us using the information indicated in Contact Information of the Policy.

B.

Third party name

Google LLC, Meta Platforms, Inc., X Corp., popIn Inc., Outbrain Inc.

How to contact third parties

Please contact us using the information indicated in Contact Information of the Policy.

Purposes of third party handling

Use of cookie consent management tool

Third party handling methods

In the manner stated 1. above

Categories of personal information

Consent to acquisition or use of cookies, IP address and language information

Manner and procedures, etc. to exercise the rights set forth by the PIPL against a third party

Please contact us using the information indicated in Contact Information of the Policy.

Last Updated: March 28, 2025