California Consumer Privacy Act Disclosures

In these California Consumer Privacy Act Disclosures (“CCPA Disclosures”), we, Seiko Watch 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:

1. 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
2. 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
3. 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.
4. 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 Online

In this CCPA Notice at Collection Online, 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 online collection:
We collect the following categories of personal information about consumers:

We collect personal information about consumers for the following purposes:

• to (i) sell SEIKO’s products and services to consumers, (ii) bill consumers for SEIKO’s products and services they have requested, (iii) deliver SEIKO’s products and services to consumers, (iv) implement online membership services, and (v) perform SEIKO’s obligations under a contract to which consumers are a party.to (i) provide consumers with promotional information on SEIKO’s products and services, (ii) carry out promotional activities to consumers, (iii) send consumers invitations to promotional events, (iv) invite consumers to participate in surveys and market research activities, and (v) analyze consumers’ interests to improve SEIKO’s products and services.
• to personalize consumers' website experience and to deliver content and product and service offerings relevant to the consumers' interests, including targeted offers and ads through our website.
• 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 arrange consumers' visit to our manufacturing sites.
• to comply with and enforce our rights and perform our obligations under applicable laws.

III. CCPA Privacy Policy

Beyond the disclosures in the preceding “Notice At Collection Online” segment and any other Notice at Collection, we are providing additional disclosures about consumer rights and our personal information handling practices in the preceding twelve months, as required by the CCPA and regulations of the California Attorney General, including § 999.308 (Privacy Policy).

1.Right to Know About Personal Information Collected, Disclosed, or Sold

This CCPA Privacy Policy describes personal information we generally collect, use, disclose and sell about California residents. You have the right to request that we disclose what personal information we collect, use, disclose and sell about you specifically (“right to know”). To submit a request to exercise the right to know, please call our toll-free phone number 888-348-3111 or submit an email request to privacy@seiko-watch.co.jp and include “California Request to Know” in the subject line. Please specify in your request the details you would like to know, including any specific pieces of personal information you would like to access.

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.

We have also set out below the categories of personal information that we have disclosed for a business purpose to third parties in the preceding 12 months and the categories of third parties to whom the information was disclosed.

3.Disclosures of Personal Information, No Sale

Over the preceding 12 months, we disclosed certain categories of California residents’ personal information to the categories of third parties as shown in the table above. In the preceding 12 months, we did not sell 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 privacy@seiko-watch.co.jp 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 the Postal address below; 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

If you have questions or concerns regarding our privacy policy or practices, you may contact us using the following details. As we will collect your personal information including your email address, name, and address and use such information to respond to your inquiry, please send us an email after reading our Website Privacy Policy and this CCPA Disclosure and agreeing to provide your personal information.

Email address: privacy@seiko-watch.co.jp
Postal address: 26-1, Ginza 1-chome, Chuo-ku, Tokyo 104-8118, Japan Seiko Watch Corporation
Last Updated: March 2021