Kowa American Corporation

Kowa American Corporation Privacy Policy

This Privacy Policy is effective as of  08/31/2023.

California Notice at
Collection
: California residents should see the “Additional
Information for California residents” section below for important information
about their rights.

At Kowa American Corporation, we respect
your privacy. We want to maintain your confidence in our handling of your data
and information that is collected during your visit to our web site at 
https://www.kowa-usa.com/ , https://www.kowachemical.com/ and any other web site that we own
or that posts to this Privacy Policy (“Privacy Policy”). We have developed and
provided this Privacy Policy to inform you of our practices and policies
regarding the collection, use, maintenance, and disclosure of your personal
information.

For the purposes of this Privacy Policy, Kowa American Corporation is referred
to as “KAC”, the “Company” or “we”.

Please review this Privacy Policy and if you have any questions about this
Privacy Policy, please contact by either;
Mailing us at 20001 South Vermont Avenue, Torrance, CA 90502, US;
Emailing us at privacypolicy-kac@kowa.com ; or
Calling us at Toll Free: (800) 966-5692 from US, +1-310-327-1913 from outside
of US.

The information we collect

Information you provide to us. We collect personal data or
information you provide to us when visiting our web site that may include

  • Business and personal contact
    information such as your name, company name, address, e-mail address,
    telephone number;
  • Profile information, such as your
    username and password that you may set to establish an online account with
    us, your photograph, interests, and preferences;
  • Registration information, such as
    information that may be related to a service, an account or an event you
    register for;
  • Feedback or correspondence, such as
    information you provide when you contact us with questions, feedback, or
    otherwise correspond with us online;
  • Demographic Information, such as your
    city, state, country of residence, postal code, and age;
  • Financial information, such as your
    stated income, economic standing, financial account numbers or payment
    card information;
  • Transaction information, such as
    information about payments to and from you and other details of products
    or services you have purchased from us;
  • Usage information, such as information
    about how you use the Service and interact with us, including information
    associated with any content you upload to the websites or otherwise submit
    to us, and information you provide when you use any interactive features
    of the Service;
  • Marketing information, such as your
    preferences for receiving communications about our activities, events, and
    publications, and details about how you engage with our communications;

and;

  • Other information that we may collect
    that is not specifically listed here but that we will use in accordance
    with this Privacy Policy or as otherwise disclosed at the time of
    collection.

Information we obtain from other third
parties.
 We
may also obtain information about you from third parties, such as our
distributors and business partners. For example, a business partner (such as an
independent repair shop) may share your contact information with us if you have
expressed an interest in learning specifically about our products or services
or obtaining a repair for your product. We may obtain your personal information
from other third parties such as marketing partners, publicly-available sources
and data providers.

Information automatically
collected

We, our service providers and our
business partners may automatically log information about you, your computer or
mobile device and activity occurring on or through our web site. The
information that may be collected automatically includes your computer or
mobile device operating system type and version number, manufacturer and model,
device identifier (such as the Google Advertising ID or Apple ID for
Advertising), browser type, screen resolution, general location information
such as city, state or geographic area, information about your activity on a
page or screen (including access times and length of access), the date and time
of each visit to our web site, your IP (internet protocol) address, the
referring IP address or domain (the prior web site visited), and the files
viewed on our web site (including HTML pages, graphics, etc.). We use log file
information to analyze data in the aggregate to determine the trends and usage
of our site.

Cookies and other tracking
technologies

When you use our web site we may gather
information about you through Internet access logs, cookies and other technical
means. ‘Cookies’ are text files placed on your computer to collect Internet log
information and user behavior information. These are used to track website
usage and monitor website activity and for other data processing reasons set
out below.
Some of the cookies we use are essential for parts of the site to operate and
have already been set. You may delete and block all cookies from this site, but
parts of the site will not work.
We may use web beacons which is an often-transparent graphic image that is
placed on a website or in an email used to monitor the behavior of the user
visiting the website or opening the email in order to access cookies and to
count users who visit our site or open email messages.
Our website may contain share buttons. When users wish to share content using
share buttons, users must have provided login credentials to the share site. We
do not gather any login information for third-party share sites that may be in
our website including listed below. We do not have influence with regard to the
scope of data which may be collected with clicking the share button.

  • Facebook: operated by Facebook, Inc.
    https://www.facebook.com/policy.php
  • Twitter: operated by Twitter, Inc.
    https://twitter.com/en/privacy
  • Instagram: operated by Facebook, Inc. https://help.instagram.com/519522125107875
  • LinkedIn: operated by LinkedIn
    Corporation www.linkedin.com/legal/privacy-policy

Cookie
List

A cookie is a
small piece of data (text file) that a website – when visited by a user – asks
your browser to store on your device in order to remember information about
you, such as your language preference or login information. Those cookies are
set by us and called first-party cookies. We also use third-party cookies –
which are cookies from a domain different than the domain of the website you
are visiting – for our advertising and marketing efforts. More specifically, we
use cookies and other tracking technologies for the following purposes:

Strictly
Necessary Cookies

These
cookies are necessary for the website to function and cannot be switched off in
our systems. They are usually only set in response to actions made by you which
amount to a request for services, such as setting your privacy preferences,
logging in or filling in forms. You can set your browser to block or alert you
about these cookies, but some parts of the site will not then work. These
cookies do not store any personally identifiable information.

Strictly
Necessary Cookies

Cookie
Subgroup

Cookies

Cookies
used

sportingoptics.kowa-usa.com

PHPSESSID

First Party

kowa-usa.com

OptanonAlertBoxClosed OptanonConsent eupubconsent

First Party

lenses.kowa-usa.com

ee71a5687e53d260a86f630d713c16c7

First Party

www.kowaoptic.com

x-cache-context-hash,
session-1, nocache

Third Party

onetrust.com

__cfduid

Third Party

Kowachemical.com

OptanonAlertBoxClosed

 First Party

Kowachemical.com

OptanonConsent

 First Party

www.sigmaaldrich.com

akaalb_origin-alb

 Theird Party

Performance Cookies

These
cookies allow us to count visits and traffic sources so we can measure and
improve the performance of our website. They help us to know which pages are
the most and least popular and see how visitors move around the website. If you
do not allow these cookies we will not know when you have visited our website
and will not be able to monitor its performance.

Performance
Cookies

Cookie
Subgroup

Cookies

Cookies
used

lenses.kowa-usa.com

ln_or

First Party

kowa-usa.com

_gat _gid _ga

First Party

snap.licdn.com

ln_or

Third Party

kowachemical.com

_tccl_visit

Third Party

kowachemical.com

_tccl_visitor

Third Party

kowachemical.com

_ga_xxxxxxxxxx

Third Party

kowachemical.com

_ga

Third Party

Targeting
Cookies

These
cookies may be set through our website by our advertising partners. They may be
used by those companies to build a profile of your interests and show you
relevant advertisements on other websites. They do not store any information
that directly identifies you, but store the information that uniquely
identifies your browser and internet device. If you do not allow these cookies,
you will experience less targeted advertising.

Targeting
Cookies

Cookie
Subgroup

Cookies

Cookies
used

analytics.yahoo.com

IDSYNC

Third Party

youtube.com

VISITOR_INFO1_LIVE, YSC, GPS

Third Party

dpm.demdex.net

dpm

Third Party

doubleclick.net

IDE, test_cookie

Third Party

turn.com

uid

Third Party

owneriq.net

lc, p2, tapq, apndmp, cwc, oath, epq, bk, rc, nsc, tpq, stc, kc,
oxc, ttd, yo, si, cc, gguuid, lrc, apnxs, pmc, adpq

Third Party

bluekai.com

bkpa, bkdc, bku

Third Party

syndication.twitter.com

metrics_token

Third Party

openx.net

i

Third Party

facebook.com

sb, fr

Third Party

google.com

NID

Third Party

tapad.com

TapAd_DID, TapAd_TS

Third Party

ads.linkedin.com

lang

Third Party

bh.contextweb.com

INGRESSCOOKIE

Third Party

adnxs.com

uuid2, anj

Third Party

adsymptotic.com

U, __cfduid

Third Party

linkedin.com

AnalyticsSyncHistory, bcookie, lissc, lidc, UserMatchHistory,
lang, li_sugr

Third Party

demdex.net

demdex

Third Party

www.linkedin.com

bscookie

Third Party

rlcdn.com

rlas3, pxrc

Third Party

adsrvr.org

TDCPM, TDID

Third Party

krxd.net

_kuid_

Third Party

rubiconproject.com

audit, khaos

Third Party

sharethis.com

__stidv, __stid

Third Party

contextweb.com

V, pb_rtb_ev

Third Party

cdn.syndication.twimg.com

lang

Third Party

agkn.com

ab

Third Party

yahoo.com

APID, APIDTS, A3, B

Third Party

pubmatic.com

PUBMDCID, PugT, KRTBCOOKIE_xxxx

Third Party

twitter.com

tfw_exp

Third Party

crwdcntrl.net

_cc_aud, _cc_dc, _cc_cc, _cc_id

Third Party

casalemedia.com

CMPRO, CMPS, CMRUM3, CMST, CMID

Third Party

exelator.com

EE, ud, udo

Third Party

advertising.com

APID

Third Party

Information about third
parties

Information we process as described in
this Privacy Policy may also include information about third parties whose
details you supply to us. If you provide us with information about a third
party, you may only do so if you have permission from the third party.

Information you provide to us

You can make an informed decision whether
to visit our web site and whether you wish to voluntarily provide any personal
data or information. If you register for or enroll in a promotion or service
through our web site, make purchases from our on-line offerings, respond to a
request for information or make any other on- line request of us, you will be
voluntarily providing personally identifiable information. If you do not agree
with this Privacy Policy, we ask that you please do not provide the requested information.
You may nevertheless continue to use most of our web site subject, however, to
the collection of information through cookies or other tracking technologies.
Where we are required by law to collect your personal information or where we
need your personal information in order to provide you with a service, if you
do not provide this information when requested (or you later ask to delete it),
we may not be able to provide you with our services. We will tell you what
information you must provide to receive the service by designating it as
required at the time of collection or through other appropriate means.

Collection of information
from children

As a general rule, children are not
allowed to use the web site. We do not deliberately collect personal
information from children. We define “children” as follows:

  • residents outside of Europe: anyone
    under 16 years old; and
  • residents of Europe and the United
    Kingdom: anyone under 16 years old or the age needed to consent to the
    processing of personal information in your country.

If we learn that a child has provided us
with personal information without the consent of the child’s parent or
guardian, we will delete it or otherwise comply with applicable law.

How we may use your
information

To operate the services provided by the
web site and our business, we may use your personal information for the
following reasons, to:

  • develop and manage our relationship
    with you and our business partners which may include providing our
    services, works and information about our products, services and
    transactions;
  • have communications with you or your
    company which may include informing you of products, services, updates,
    transactions and, responding to questions, inquiries or requests and,
    marketing our business and those of our group;
  • provide our customer services and
    works or products;
  • comply with legal, regulatory and
    corporate governance obligations and good practice;
  • gather information as part of
    investigations by regulatory bodies or in connection with legal
    proceedings or requests;
  • adhere to our business policies;
  • operate our business, such as
    recording transactions, training and quality control;
  • protect the confidentiality of
    commercially sensitive information;
  • vet security concerns, investigate
    claims, complaints and allegations of criminal offences;
  • complete statistical analysis;
  • prevent unauthorized access and
    modifications to systems;
  • prevent fraudulent, harmful,
    unauthorized, unlawful, or unethical activity
  • analyze purchasing preferences and
    improving services; and
  • enforce the terms and conditions that
    govern the web site.

We also use your personal information for
the following purposes:

  • for research and development, we
    analyze web site visitors’ use of the web site to improve our business and
    develop new products and services;
  • to send you marketing and promotional
    communications, we may send you KAC-related marketing communications as
    permitted by law. You will have the ability to opt-out of our marketing
    and promotional communications as described in the opt-out of marketing section;
  • to display advertisements, we may work
    with advertising partners to display advertisements on our web site or
    elsewhere online. These advertisements are delivered by our advertising
    partners and may be targeted based on your use of the web site or your activity
    elsewhere online. To learn more about your choices in connection with
    advertisements, please see the section titled “Targeted online
    advertising”;
  • with your consent, we may use your
    information as your direct us to;
  • to create anonymous, aggregated or
    de-identified data, we may create anonymous, aggregated or de-identified
    data from your personal information and other individuals whose personal
    information we collect. We may use this anonymous, aggregated or de-identified
    data and share it with third parties for our lawful business purposes,
    including to analyze and improve our web site or business.

How we may share your
information

We do not disclose or share your personal
information without your consent except as described below;

  • Affiliates. We may disclose and
    exchange your personal information with our group companies including
    those in different countries.
  • Service Providers. We may disclose and
    exchange your personal information with third party service providers,
    sales representatives, agents, and distributors to perform their service
    or works for us including those in different countries. Moreover, we rely
    on various third-party service companies to provide certain services
    (e.g., shipping, credit card billing) for which it may be necessary to
    provide your personal information.
  • Business Partners. We may sometimes
    share your personal information with partners or enable partners to
    collect information via our web site. For example, if we receive an order
    for repair service, we may share your information with an agent, retailer
    or external repair company. These entities may have their own privacy
    practices. Please review these entities’ privacy notices for a description
    of how they may use your personal information.
  • Professional Advisors. We may disclose
    your personal information to professional advisors such as lawyers,
    bankers, auditors and insurers, where necessary in the course of the
    professional services that they render to us.
  • Law Enforcement and Other Regulatory
    Bodies. We may also disclose and exchange your personal information with
    law enforcement agencies, regulatory bodies and governmental agencies
    including law enforcement and other public authorities, which may include such
    authorities outside your country of residence when we are legally required
    with or without prior notice to you.
  • For Compliance, Fraud Prevention and
    Safety. We may disclose your personal information to public and private
    bodies for compliance, fraud prevention and safety purposes as described
    in the How we use your information section above.
  • With Consent. We may make disclosures
    of your personal information with your affirmative consent.
  • Business Transfers. We may sell,
    transfer or otherwise share some or all of our business or assets,
    including your personal information, in connection with a business
    transaction (or a potential business transaction) such as a corporate
    divestiture, merger, consolidation, acquisition, reorganization or sale of
    assets, or in the event of bankruptcy or dissolution.

We may share anonymized or aggregated
information which will not identify you internally, with our group companies
and with third parties for any purpose.

How we store and secure
personal information

We maintain reasonable safeguards
designed to prevent personal information from being accidentally lost or used
or accessed in an unauthorized way and, designed to protect the security and
confidentiality of your personal information against unauthorized disclosure,
misuse, or alteration. However, we cannot guarantee the security of information
provided over the Internet and will not be responsible for breaches of
security.

Other sites, mobile
applications and services

Please note that although we may seek to
require that third party service providers, sales representatives, agents,
distributors and business partners use information regarding our users only in
the ways permitted by this Privacy Policy, we do not control and are not
responsible for their privacy practices, or those of any other party.

Through our web pages, you may connect to third parties’ web sites or other
online services via hyperlinks, and the connections may or may not be obvious.
These links are not an endorsement of, or representation that we are affiliated
with, any third party. We are not responsible for the collection, use,
maintenance, sharing, or disclosure of data and information by such third
parties.

In addition, our content may be included on web pages or in mobile applications
or online services that are not associated with us. We do not control third
party websites, mobile applications or online services, and we are not
responsible for their actions. Other web sites and services follow different
rules regarding the collection, use and sharing of your personal information.
We encourage our users to be aware of the varied privacy policies of web sites
that they visit.

Retention periods

Your personal information will be held in
accordance with the Company’s retention policy or policies. There could be a
wide range of retention periods that may be relevant to you. We retain personal
information for as long as necessary to fulfill the purposes for which we
collected it, including for the purposes of satisfying any business, legal,
accounting or reporting requirements to establish or defend legal claims, or
for fraud prevention purposes. To determine the appropriate retention period
for personal information, we consider the amount, nature, and sensitivity of
the personal information, the potential risk of harm from unauthorized use or
disclosure of your personal information, the purposes for which we process your
personal information and whether we can achieve those purposes through other
means, and the applicable legal requirements.

Your choices

In this section, we describe the rights
and choices available to all web site visitors. Web site visitors who are
located within California can find additional information about their rights
below.

Access or Update Your Information. You have the right, at any time, to review
and/or modify any of your personally identifiable information that you provide
during registration, or any other voluntarily provided information. If you have
registered for an account with us, you may review and modify this information
by emailing us at privacypolicy-kac@kowa.com.

Opt Out of Marketing Communications. You may also remove yourself from our
active databases of e-mail lists. To do so, you should send an e-mail to
“unsubscribe@kowa.com” requesting that you be removed from our databases of
active e-mail lists. We will endeavor to comply with your request as soon as
reasonably possible.

Cookies. Most browsers let you remove or reject cookies. To do this, follow the
instructions in your browser settings. Many browsers accept cookies by default
until you change your settings. Please note that if you set your browser to
disable cookies, the web site may not work properly. Similarly, your browser
settings may allow you to clear your browser web storage.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track”
signals to the online services that you visit. We currently do not honor the
“Do Not Track” or similar signals. To find out more about “Do Not Track”,
please visit http://www.allaboutdnt.com.

Targeted Online Advertising. Some of the business partners that collect
information about web site visitors’ activities on or through the web site may
be members of organizations or programs that provide choices to individuals
regarding the use of their browsing behavior or mobile application usage for
purposes of targeted advertising.

Web site visitors may opt out of receiving targeted advertising on websites
through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance
by clicking 
here.

If you choose to opt-out of targeted advertisements, you will still see
advertisements online but they may not be relevant to you. Even if you do
choose to opt out, not all companies that serve online behavioral advertising
are included in this list, so you may still receive some cookies and tailored
advertisements from companies that are not listed.

International Data Transfers

We are headquartered in the United States
and may have service providers in other countries, and your personal
information may be transferred to the United States or other locations outside
of your state, province, or country where privacy laws may not be as protective
as those in your state, province, or country.

Changes to the Privacy Policy

We reserve the right to change our
policies regarding the privacy of your personally identifiable information in
the future. If that happens, we will endeavor to promptly update this Privacy
Policy. We may also attempt to provide a message to our customers whose e-mail
addresses we have, in conformity with this Privacy Policy, advising of any such
change(s). Any modifications to this Privacy Policy will be effective upon our
posting the new terms and/or upon implementation of the new changes on the web site
(or as otherwise indicated at the time of posting). Your continued use of the
web site following changes to this policy will indicate that you accept the
changes. For ease of your review of any changes, the following is a list of the
date of all revisions to this Privacy Policy:

We hope that this Privacy Policy helps you to make an informed decision whether
to visit our web site and/or to provide us with certain information.

Additional Information for
California residents

The California Consumer Privacy Act of
2018, as amended by the California Privacy Rights Act  (the “CCPA”) requires KAC to disclose certain
additional information to California residents. This Section provides such
additional information applicable to visitors, users and others who reside in
the State of California, which do not apply to users in other geographies.

Information We Collect.

Our web site collects information that
identifies, relates to, describes, references, is capable of being associated
with, or could reasonably be linked, directly or indirectly, with a particular
consumer or household (“Personal Information” as defined in the CCPA). In
particular, our web site has collected the following categories of personal
information from its consumers within the last twelve (12) months. Information
you voluntarily provide to us, such as in free-form webforms, may contain other
categories of personal information not described below.

Statutory Category of Personal Information

Personal Information Collected

Categories of third parties to whom we “disclosed” Personal
Information for a business [or commercial] purpose

A. Identifiers.

A real name, alias, postal address, unique personal
identifier, online identifier, Internet Protocol address, email address, and
account name

 

B. Personal information categories listed in the California
Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, address, telephone number, bank account
number, credit card number, debit card number, or any other financial
information. Some personal information included in this category may overlap
with other categories.

 

D. Commercial information.

Records of personal property, products or services purchased,
obtained, or considered, or other purchasing or consuming histories or
tendencies.

 

F. Internet or other similar network activity.

Browsing history, search history, or information on a
consumer’s interaction with a website.

 

How We Collect Information About You.

We obtain the categories of Personal
Information listed above either directly from you (e.g., from forms you
complete or products and services you purchase), indirectly from you (e.g., from
observing your actions on our web site). We may also obtain
information about you from third parties, such as our distributors and business
partners. For example, a business partner (such as an independent repair shop)
may share your contact information with us if you have expressed an interest in
learning specifically about our products or services or obtaining a repair for
your product. We may obtain your personal information from other third parties
such as marketing partners, publicly-available sources and data providers.

 

Use of Personal Information.

We may use the Personal Information we
collect for any legitimate and lawful business purpose, including those listed
in the Section below titled “How we may use your information.”

Disclosures of Personal Information for a
Business Purpose.

In the preceding twelve (12) months, KAC
has disclosed the following categories of Personal Information for a business
purpose:

  • Category A: Identifiers.
  • Category B: California Customer
    Records personal information categories.
  • Category D: Commercial Information.
  • Category F: Internet or other similar
    network activity.

Sale or Sharing  of Personal Information.

In the preceding twelve (12) months, KAC
has not “sold” or “shared” (as such terms are defined by the CCPA) any
Personal Information.

Sensitive personal information.

We do not use or disclose sensitive
personal information for purposes that California residents have a right to
limit under the CCPA.

Your Rights and Choices.

The CCPA provides California residents
with specific rights regarding their personal information. The following
describes your CCPA rights and explains how to exercise those rights.

Right to Know and Access to Specific
Information.

You have the right to request that we
disclose certain information to you about our collection and use of your
Personal Information over the past twelve (12) months; in other words, the
“right to know.” Once we receive and confirm your verifiable consumer request
(see Exercising Knowledge, Access, and Deletion Rights), subject to certain
permitted exceptions, we will disclose to you:
The categories of personal information we collected about you.

  • The categories of sources for the
    personal information we collected about you.
  • Our business or commercial purpose for
    collecting or selling that personal information.
  • The categories of third parties with
    whom we share that personal information.
  • The specific pieces of personal
    information we collected about you (also called a data portability
    request).
  • If we sold or disclosed your personal
    information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal
    information categories that each category of recipient purchased; and
  • disclosures for a business purpose,
    identifying the personal information categories that each category of
    recipient obtained.

You have a right to request a copy of the
Personal Information that we have collected about you during the past 12
months.

Right to Request Correction.

You can ask us to correct inaccurate Personal
Information that we have collected about you.

Deletion Request Rights.

You have the right to request that KAC
delete any of your personal information that we collected from you and
retained, subject to certain exceptions. Once we receive and confirm your
verifiable consumer request (see Exercising Knowledge, Access, and Deletion
Rights), we will delete (and direct our service providers to delete) your
personal information from our records, unless an exception applies.
Without limitation, we may deny your deletion request if retaining the
information is necessary for us or our service provider(s) to:

  • Complete the transaction for which the
    personal information was collected, fulfill the terms of a written
    warranty or product recall conducted in accordance with federal law,
    provide a good or service requested by you, or reasonably anticipated by you
    within the context of our ongoing business relationship with you, or
    otherwise perform a contract with you.
  • Help to ensure security and integrity
    to the extent the use of the consumer’s personal information is reasonably
    necessary and proportionate for those purposes.
  • Debug products to identify and repair
    errors that impair existing intended functionality.
  • Exercise free speech, ensure the right
    of another consumer to exercise their free speech rights, or exercise
    another right provided for by law.
  • Comply with the California Electronic
    Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed
    scientific, historical, or statistical research in the public interest
    that adheres to all other applicable ethics and privacy laws, when the
    information’s deletion may likely render impossible or seriously impair
    the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are
    reasonably aligned with consumer expectations based on your relationship
    with us and compatible with the context in which you provided the
    information.
  • Comply with a legal obligation.

Automated
Decision Making and Profiling
.

We do not engage in automated decision
making or profiling performed on personal information.

 

Exercising Knowledge, Access, and
Deletion Rights.

To exercise the knowledge, access, and
deletion rights described above, please submit a verifiable consumer request to
us by either:
Emailing us at 
privacypolicy-kac@kowa.com ; or
Calling us at Toll Free: (800) 966-5692 from US, +1-310-327-1913 from outside
of US.
Only you or a person registered with the California Secretary of State that you
authorize to act on your behalf, may make a verifiable consumer request related
to your personal information.  However,
we may need to verify your authorized agent’s identity and authority to act on
your behalf.  We may require a copy of a
valid power of attorney given to your authorized agent pursuant to applicable
law. If you have not provided your agent with such a power of attorney, we may
ask you to take additional steps permitted by law to verify that your request
is authorized, such as by providing your agent with written and signed
permission to exercise your California privacy rights on your behalf, the information
we request to verify your identity, and confirmation that you have given the
authorized agent permission to submit the request. You may also make a
verifiable consumer request on behalf of your minor child. You may only make a
verifiable consumer request for knowledge or access twice within a twelve (12)
month period. The verifiable consumer request must:

  • Provide sufficient information that
    allows us to reasonably verify you are the person about whom we collected
    personal information or an authorized representative.
  • Describe your request with sufficient
    detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or
provide you with personal information if we cannot verify your identity or
authority to make the request and confirm the personal information relates to
you. Making a verifiable consumer request does not require you to create an
account with us. We will only use personal information provided in a verifiable
consumer request to verify the requestor’s identity or authority to make the
request.

Response Timing and Format.

We endeavor to respond to a consumer
request within applicable time limits. If you have an account with us, we will
deliver our written response to that account. If you do not have an account
with us, we will deliver our written response by mail or electronically, at
your option. Any disclosures we provide will only cover the twelve (12) month
period preceding the verifiable consumer request’s receipt. The response we
provide will also explain the reasons we cannot comply with a request, if
applicable. For data access requests, we will select a format to provide your
personal information that is readily useable and should allow you to transmit
the information from one entity to another entity without hindrance. We do not
charge a fee to process or respond to your verifiable consumer request unless
it is excessive, repetitive, or manifestly unfounded. If we determine that the
request warrants a fee, we will tell you why we made that decision and provide
you with a cost estimate before completing your request.

Non-Discrimination.

We will not discriminate against you for
exercising any of your CCPA rights. Unless permitted by the CCPA, 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.