Effective Date: 7 / 1 / 2021
1. Information Collected by the Company
The personal information of the Consumers collected by the Company and the status of disclosure of such personal information to third parties and other relevant matters in the past 12 months are as follows. The Company does not sell the collected personal information to any third party. In addition, when a Consumer uses the Company's websites or services, it is not possible for other businesses to collect personally identifiable information on the Consumer's online activities in chronological order and across different websites.
※ Categories A to I listed in the table below correspond to categories listed in CCPA §1798.140 (o) (1) (A) to (K).
|Category||Collected personal information||Collection source||Business and commercial purposes of the collection||Disclosure to third parties||Categories of third parties to whom personal information is disclosed|
|A. Identifiers||Real name, postal address, online identifier, email address||Website, LinkedIn, YouTube, events, business deals (business cards, etc.)||Communication and marketing of products and services||Yes||Sales partners, suppliers|
|B. Personal information listed in California Customer Records statute (California Civil Code Title 1.81. CUSTOMER RECORDS) § 1798.80 (e)||Name, address, telephone number, employment, credit card number||Websites, LinkedIn, E-commerce websites, events, business deals (business cards, etc.)||Communication and marketing of products and services, settlement of purchase of products||Yes||Sales partners, suppliers|
|D. Commercial information||Records of products purchased||E-commerce websites||For procedures such as return of goods||Yes||Sales partners|
|F. Internet or other similar electronic network activity||Browsing history||Websites, analytics||Measurement of marketing effectiveness||Yes||Our contractors that assist us in analyzing web traffic data|
|I. Professional or employment-related information||Current job title||Websites, webinars, LinkedIn, events, business deals (business cards, etc.)||Communication and marketing of products and services||Yes
||Sales partners, suppliers|
2. Personal Information of Consumers Under the Age of 16
The Company does not sell any personal information of any Consumers we know to be under the age of 16.
3. Consumer's Rights under the CCPA
The CCPA grants specific rights regarding personal information to the Consumers.
3.1 Right to access
Consumers may request the Company to disclose certain information related to the collection and use of their personal information in the last 12 months. The Company will disclose the following information concerning the last 12 months after we receive your request and verify the method of exercise and your identity:
(i) Category of any personal information acquired by the Company concerning such Consumer within the past 12 months;
(ii) Categories of the source of collection from which the personal information under (i) above was collected;
(iii) Business or commercial purposes of acquiring or selling personal information under (i) above;
(iv) Categories of third parties with whom the Company shares the personal information under (i) above;
(v) Specific content of the personal information under (i) above;
(vi) Categories of the personal information of the relevant Consumer sold by the Company in the past 12 months, and categories of third parties to whom the Company sold per each category of the relevant personal information; and
(vii) Categories of the personal information of the relevant Consumer disclosed by the Company for business purposes in the past 12 months, and categories of third parties to whom it was disclosed per each category of the relevant personal information.
However, we will not disclose if we are unable to verify your identity or in the case of the following information:
(i) government-issued personal identification number such as a social security number or driver's license card number;
(ii) account number;
(iii) health insurance or medical identification number;
(iv) account password;
(v) security-related questions and answers; and
(vi) unique biometric data obtained by measurement or technical analysis of human characteristics.
3.2 Right to request deletion
With certain exceptions, Consumers may request the Company to delete their personal information that the Company collects and maintains. Upon receipt of the request, the Company will verify the exercise method and the identity of the requesting Consumer, and will delete, or will instruct the service provider (if any) to delete, the relevant Consumer's personal information from the Company's records unless an exception applies.
The Company may not be able to accept deletion requests if the Company or the service provider needs to maintain the information for the following purposes:
- To complete transactions for which the Company has collected personal information, to provide goods or services requested by the Consumer, to take actions reasonably expected within the context of a continuous commercial relationship with the Consumer, or to perform any contract with the Consumer;
- To detect security incidents, to protect against malicious, fraudulent, unauthorized or illegal activities, or to hold responsible any persons liable for such activities;
- To debug to identify and repair errors that prevent existing intended functionality;
- To exclusively allow internal use reasonably tailored to the Consumer's expectations pursuant to the relationship between the Consumer and the Company;
- To comply with legal obligations;
- To engage in public or peer-reviewed scientific, historical or statistical surveys of the public interest in compliance with all other applicable ethics and privacy-related acts when the deletion of information could render the outcome of the study impossible or materially prejudicial if the Consumer has previously given informed consent;
- To use the Consumer's personal information internally within a business operator in a lawful manner that conforms to the context in which the Consumer provided the information; or
- To exercise free speech, to secure the right of other Consumers to exercise free speech or to exercise other rights granted by law.
In addition, since it is difficult to recover the personal information once it is deleted, for the sake of certainty, if a request for deletion is made, the Company will contact you again for confirmation. Furthermore, please note that, in the event of deletion in response to a request, we will retain records of such requests in accordance with laws and regulations.
3.3 Opt-out rights
Consumers may at any time direct the Company not to sell their personal information (opt-out rights).
Any Consumers who wish to opt-out (or an agent of the Consumer) should email us to our email address listed in "Contact Information."
With regard to cookies and web beacons that are not strictly necessary for the functioning of the website, Consumers may also choose to allow or deny them to the extent legally required from the settings screen that can be displayed from the cookie banner provided on the website of each domain.
We will pay due respect to the Consumers who have exercised their opt-out rights for a period of 12 months following the request.
The procedures for allowing sales again after opting out are as follows:
(i) Please contact the above address.
(ii) The Company will re-confirm with the Consumer of his/her intention to opt-in.
(iii) After confirmation of (ii) above, the Company will resume sales.
3.4 Exercise of Your Rights
In order to exercise your rights to access and to request deletion, please email us to our email address listed in "Contact Information."
Only you or your agent may make requests related to your personal information.
The Company will verify your identity upon receipt of any such request for access or deletion. Your request is unacceptable if we are unable to verify your identity.
- If you have an account with a password that the Company provides:
- We will verify your identity through the existing authentication method.
- You will be required to recertify before disclosure or deletion.
- If we suspect fraud or a malicious claim, we will verify your identity in accordance with "If you do not have an account with a password provided by the Company" below.
- If you do not have an account with a password provided by the Company:
- The Company will ask you two or more questions about any request to disclose "Category" of your personal information in order to verify with reasonable certainty that you are the one requesting this information.
- With respect to a request for disclosure of "Details" of personal information, the Company requests that you separately submit a written request in order to verify with reasonably high level of certainty that you are the one requesting this information. We will provide you with more details when you actually made the inquiry.
※ In relation to a request for deletion, in order to confirm that the request is from the Consumer with reasonable or reasonably high level of certainty in accordance with the sensitivity of the personal information and the risk of adverse effects due to inappropriate deletion, we will confirm the requesting person's identity by one of the methods described above according to the subject information.
※ If requested by an agent, we will require and confirm the agent authorization form (power of attorney).
No fees or other commissions will be charged by the Company to process or respond to legitimate requests unless they are clearly groundless, repetitive or otherwise manifestly excessive. If the Company determines that a request from a Consumer is clearly groundless, repetitive or otherwise manifestly excessive, we will either reject the request after notifying the reason thereof to the Consumer or will accept the request by charging reasonable fees after considering the costs required to provide the information. In such case, we will provide you with an estimate of the fees before we respond to your request.
The Company will not discriminate against any Consumer in exercising his or her rights under the CCPA. Unless permitted by the CCPA, the Company will not discriminate against any such Consumer by:
- refusing to offer goods or services;
- charging different prices or interest rates for goods or services (through granting discounts or other benefits, or imposing penalties);
- offering goods or services of a different level or quality; or
- suggesting that you will receive goods or services at different prices or interest rates, or at a different level or quality for the goods or services.
However, the Company may offer certain financial incentives or different pricing or services (hereinafter referred to as "financial incentives") as permitted by the CCPA in connection with the acquisition, retention or sale of personal information, that may result in different level of pricing and quality of the products or services offered. In proposing financial incentives, important conditions will be clearly presented in advance and the prior consent of the Consumers will be obtained. The Consumers may revoke this consent at any time.
4. Do Not Track Feature
5. "Shine the Light" Law
California Shine the Light law gives Consumers the right to request annually the content of personal information that businesses share with third parties for direct marketing purposes. To request additional information under this Law, please email us to our email address listed in "Contact Information."
※ When you make this request, please write "Claims under the California Shine the Light Law" to enable us to properly specify your inquiry.
Macnica Americas, Inc.
380 Stevens Ave., Solana Beach CA 92075