Privacy Policy

1. Matters Concerning Disclosure of Purpose of Use of Personal Information

(1)The purpose of use and the basis for processing personal information when obtaining it directly other than in writing and when obtaining it indirectly.

When we obtain your personal information contained in a document directly from you, we specify the purpose of use each time. When we obtain your personal information directly in any other manner, we will process the personal information within the following restricted scope of the purpose of use on the following basis for processing.

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Type	Purpose of Use	Basis for Processing
(1) Personal information of business partners (Name, address, telephone number, email address, company, company address, department, title, etc.)	For sending direct mails such as product information, questionnaires, catalogs, and KITZ VIEW; sending and collecting quotations, order forms, invoices, payment statements, IR materials, etc.; shipping and receiving products, etc.; and communicating and managing training information and other business matters.	Necessary for the performance of a contract to which the data subject is a party. Necessary for the pursuit of legitimate interests of KITZ Group or a third party.
(2) Personal information of shareholders (Name, address, number of shares held, date of acquisition, etc.)	For sending and collecting shareholders meeting convocation notices, reports, resolution notices, IR materials, etc.; and communicating and managing matters necessary in connection with the relationship with shareholders.	Necessary for the pursuit of legitimate interests of KITZ Group or a third party.
(3) Personal information relating to recruitment (Name, address, gender, date of birth, etc.)	For performing internship and recruitment screening affairs; providing corporate information to, and making necessary communication with, job seekers and prospective employees of the KITZ Group; and collecting personnel information necessary for the KITZ Group after the employment.	Necessary for the pursuit of legitimate interests of KITZ Group or a third party.
(4) Personal information of employees (Name, address, telephone number, email address, department, title, etc.)	For making communication and management necessary in connection with the relationship with employees (We separately obtain written consent from employees regarding their personal information upon specifying the purpose of use thereof.)	Based on the consent of the data subject.

(2)Your discretion regarding whether or not to provide your personal information to the KITZ Group, and what happens if you decide not to provide such information.

It is up to you whether or not to provide your personal information, but such information is necessary for the KITZ Group to perform its business.
Accordingly, if you provide insufficient or inaccurate information or refuse to provide such information and it hinders our business performance or causes disadvantages, etc., to you such as communication failure or involvement in a crime or other dangerous situation, you will be responsible for such consequences.

(3)Matters concerning retention period of personal information

The KITZ Group retains your personal information only for the period necessary for the purpose of use described above. Specific retention period shall be determined based on the purpose of acquisition and use of the personal information, nature thereof, and legal or business necessity to retain the personal information.

(4)Matters concerning handling of entrusted personal information

Personal information deposited in connection with the entrustment by the KITZ Group of computer-based data processing service shall be handled within the scope of the purpose of use of the relevant business performance.

(5)Matters concerning acquisition due to merger, company split or business succession

When the KITZ Group (meaning the consolidated subsidiaries stated in the securities report, etc.) acquires personal information from the other company of a transaction such as merger, company split or business succession, such personal information may be handled within the scope of the purpose of use described in (1) above.

(6)Matters concerning joint use

The KITZ Group makes joint use of personal information as follows.

• (a)Persons who jointly use of personal information
  The KITZ Group (including its overseas group companies)
  * For the list of domestic and overseas group companies, please click here.
• (b)Purpose of use of persons who jointly use personal information
  Your personal information
  
  • ・For sending direct emails such as product information, questionnaires, catalogs, and KITZ VIEW; and sending and collecting quotations, order forms, manufacture requests, invoices, payment statement and IR materials, etc.;
  • ・For shipping and receiving products, etc.;
  • ・For communicating training information;
  • ・For making other communications and management necessary for business;
  • ・For performing internship and recruitment screening affairs;
  • ・For providing corporate information to, and making necessary communications with, job seekers and prospective employees of the KITZ Group; and
  • ・For collecting personnel information necessary for the KITZ Group after the employment.

  Personal information of employees

  • ・For global supervision, employee management and strategy formulation;
  • ・For employee management: report on the number of employees, employee plan (including, but not limited to, appropriate allocation and assessment of employees for specific duties, coordination, advertisement, secondment, transfer within the KITZ Group, cross-border team work, and investment decision making);
  • ・For supporting overseas subsidiaries on staff evaluation, performance management and other matters (development and successor training);
  • ・For career development, talent management, employee education, development on an international level;
  • ・For allocating and planning compensation for damage, profit and financial cost, management of stock-based compensation, and other matters related thereto;
  • ・For the management of health and safety at workplace;
  • ・For communicating through emails, chats, etc., and sharing documents, etc.; and
  • ・For sharing customer information among group companies.
• (c)Personal information to be used jointly
  Your personal information
  
  • ・Name
  • ・Contact information (address, telephone/facsimile numbers, email address, etc.)
  • ・Work-related information (company name, name of representative, department, title, address, telephone/facsimile numbers, email address, etc.)
  • ・School information (school name, address, telephone/facsimile numbers, email address, etc.)
  • ・Contents of inquiries and requests, purchase history of products and services, information on contracts, information on the use of products, etc.; and
  • ・If you are a sole proprietor, your bank account for wages payment (bank, account number, account holder).

  Personal information of employees

  • ・Contact information (e.g.: name, contact details, gender, academic history, date of birth, place of birth, citizenship, marital status, address of workplace, telephone/facsimile numbers, email address and cell phone number for work)
  • ・Employee status and organizational data (e.g.: organizational unit, cost center, place of employment, employment number, business function, title, hiring manager, form of employment (currently at work, on leave, or absent from work), type of employment (full-time worker, part-time worker, or employment with fixed term));
  • ・Data on employee allowance (e.g.: currency, title, qualification for merit-based pay increase, qualification for bonus plan/type, target proportion and amount, grounds for incidental payment, standard working hours and leave per year, various welfare programs plan period, type of leave, and qualification for stock option plan);
  • ・Information on performance and skills (assessment, performance evaluation, appraisal, professional development program, successor development program, rewards);
  • ・Payroll data (wages, deductions, allowances, withholding at source);
  • ・Details of duty assignments;
  • ・Taxpayer identification number/passport number;
  • ・Attendance data (e.g.: paid leave, leave, absence, compensatory leave (not including special information regarding sick leave;))
  • ・Career data (e.g.: job responsibilities, promotions, transfers);
  • ・Education data (e.g.: training requests from employee and employer, attended courses, scores); and
  • ・Business trip details (e.g.: passport number, driver’s license number, preference, emergency contact information, business trip requirements, and booking information).
• (d)Person responsible for the management of personal information
  KITZ Corporation
  Address: Tokyo Shiodome Building, 1-9-1, Higashi-Shimbashi, Minato-ku, Tokyo
  Representative: Makoto Kohno, Director, Representative Executive Officer and President, CEO

2.Matters Concerning Personal Information Subject to Disclosure That Should Be Made Accessible

The purpose of use of personal information retained by the KITZ Group that is subject to disclosure is as follows.

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3.Providing Personal Information to a Third Party

We manage your personal information appropriately and will not provide that to a third party without obtaining your consent in advance, except for the following cases:

• * When required by law or regulation;
• * When there is a need to protect the life, wellbeing, or property of an individual and it is difficult to obtain your consent;
• * When there is a special need to improve public wellbeing or promote healthy child development and it is difficult to obtain your consent;
• * When there is a need to cooperate with a national government organ, local government, or person entrusted thereby with performing the functions prescribed by laws and regulations, and obtaining your consent is likely to interfere with the performance of those functions; or
• * When the third party is an academic research institution or a or the equivalent and such third party needs to handle the personal information for academic research purposes (including cases where only a part of the purpose of handling the personal information is for academic research purposes, and excluding cases where there is a risk of unjustly infringing on individual rights and interests).

4.Procedures for Responding to a Request for Disclosure, Etc.

The KITZ Group responds to a request for disclosure, correction, addition, deletion, suspension of use, erasure and suspension of provision to a third party (collectively, a “Request for Disclosure, Etc.”) made by you or your representative or proxy with respect to the personal information subject to disclosure and a “record of provision to a third party” (as defined in Article 33, paragraph (5) of the Act on the Protection of Personal Information; the “Personal Information Subject to Disclosure, Etc.” in this Section) in the following manners.

(1)Items subject to a Request for Disclosure, Etc.

Regarding the items of the Personal Information Subject to Disclosure, Etc., that are subject to a Request for Disclosure, Etc., please confirm with our Information Security and Personal Information Protection Secretariat (the “Secretariat”) below. After confirmation, please fill out a prescribed application form and state the matters sufficient to identify the relevant Personal Information Subject to Disclosure, Etc. Please also contact the Secretariat if you need information that helps making such identification.

Contact Information	KITZ Corporation (Makoto Kohno, Director, Representative Executive Officer and President, CEO) Information Security and Personal Information Protection Secretariat Tokyo Shiodome Building, 1-9-1, Higashi-Shimbashi, Minato-ku, Tokyo 105-7305, Japan
Contact Us	https://www.kitz.com/en/contact/

(2)How to make a Request for Disclosure, Etc.

For making a Request for Disclosure, Etc., please fill in a prescribed application form, attach necessary documents, and send them by post to the Secretariat. On the envelope, please state “Enc. request for disclosure, etc.”

(3)Documents (forms), etc., to be submitted upon making a Request for Disclosure, Etc.

When making a Request for Disclosure, Etc., please contact the Secretariat by telephone or email first for an application form (“A” below) which will be mailed to you from us. Please fill out the application form with all the necessary matters stated, attach an identification document (“B” below), and send them by post.

• A: Application form prescribed by the Secretariat
  • * A “request for disclosure/correction of personal information”

• B: Identification document (a copy of one of the following)
  • * Passport;
  • * Driver’s license;
  • * Insurance certificate (such as health insurance card);
  • * Nursing care insurance certificate;
  • * Pension handbook;
  • * A copy of resident record; or
  • * Any other document that has been determined to be acceptable to us as equivalent to the above by contacting the Secretariat in advance.
    (If there has been change in your address, please attach a copy of the resident record showing the history of such change of address; also, please exclude the “registered domicile,” etc., when making a copy of the passport or a certificate containing the registered domicile, etc. A resident record, extract of family register, certificate of registered information, registered seal certificate, etc., must have been issued within three months at the time of receipt by us.)

(4)A Request for Disclosure, Etc., by representative or agent

If the person making a Request for Disclosure, Etc., is your legal representative because you are a minor or an adult ward, or your agent commissioned to make a Request for Disclosure, Etc., please enclose the following documents in addition to the above.

• A: Legal representative
  • * A copy of a document evidencing his/her right of legal representation (such as a family register; in the case of a legal representative of adult ward, a certificate of registered information is acceptable; in the case of person who has parental authority, a copy of insurance card containing the names of the dependents is acceptable); and
  • * A copy of a document identifying the legal representative himself/herself (a copy of an official document, such as driver’s license or passport, of the legal representative)

• B: Privately appointed agent
  • * A copy of the letter of proxy;
  • * A copy of a registered seal certificate of the agent; and
  • * A copy of a document identifying the agent himself/herself (a copy of an official document, such as driver’s license or passport, of the agent)

(5)Fee for a Request for Disclosure, Etc., and manner of collection

1,000 yen per request
Please enclose a fixed amount postal money order or postage stamps worth 1,000 yen. If the amount of fee is insufficient or the fee is not enclosed, we will notify you about that. If you fail to pay the fee within a certain period, we will regard that no Request for Disclosure, Etc., has been made.

(6)How we respond to a Request for Disclosure, Etc.

We will answer in writing, which will be sent to the address stated on the application form.

(7)Purpose of use of personal information obtained in connection with a Request for Disclosure, Etc.

We will handle personal information obtained in connection with a Request for Disclosure, Etc., within the scope necessary for the Request for Disclosure, Etc. We will discard the documents submitted after keeping them for two years from our dispatch of a written answer to the Request for Disclosure, Etc. (The said documents will be kept and discarded strictly in accordance with our in-house rules.)

[Grounds for non-disclosure of personal information subject to disclosure]

The KITZ Group will not respond to a Request for Disclosure, Etc., in any of the following cases. If we determine not to respond, we will send you a notice stating such decision and the reason therefor to the address stated on the application form. Even in such case, the fee described above is payable.

• * When your identity cannot be verified due to, for example, inconsistency among the address stated on the application form, the address on the identification document, and the address on our records;
• * When the right of representation cannot be verified in the case of application by a representative;
• * When the application documents are insufficient;
• * When the subject of the Request for Disclosure, Etc., is not included in the personal information subject to disclosure;
• * When your life, body, property or other right or interest or that of a third party is threatened to be damaged;
• * When the due performance of our services is threatened to be significantly hindered; or
• * When such disclosure would result in a violation of other laws and regulations.

5.Personal Information Safety Control Measures

The KITZ Group endeavors to maintain collected personal information to be accurate and up to date, to implement safety measures to prevent unauthorized access to or loss, destruction, falsification, leakage, etc., of such personal information, and to appropriately manage the same.

6.Filing a Grievance

(1)How to file a grievance concerning the handling of personal information

If you have any grievance concerning our handling of your personal information, please contact us, as follows. Please note that we do not accept any in-person inquiry at our offices.

By telephone	KITZ Corporation Information Security and Personal Information Protection Secretariat
By letter	KITZ Corporation Information Security and Personal Information Protection Secretariat Tokyo Shiodome Building, 1-9-1, Higashi-Shimbashi, Minato-ku, Tokyo 105-7305, Japan
By email	KITZ Corporation Information Security and Personal Information Protection Secretariat https://www.kitz.com/en/contact/

(2)Name of the certified personal information protection organization to which we belong and the contact information for filing a complaint

Currently, we do not belong to any certified personal information protection organization.

1.Personal Information to Be Collected and Handled

The purpose of use, legal basis and retention period of personal information KITZ Group collect are, as follows:

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Items of Personal Information	Purpose of Processing	Legal Basis	Retention Period
Name, address, telephone number, email address, company, company address, department, title, etc.	To response to inquiries from customers	Necessary for the pursuit of KITZ Group’s legitimate interests or those of third parties (to develop KITZ Group’s products/services and grow KITZ Group’s business)	For the duration of transactions
Name, address, telephone number, email address, company, company address, department, title, etc.	To provide information to customers, such as information about products and services (maintenance and support, exhibitions, seminars, and other items)	Necessary for the pursuit of KITZ Group’s legitimate interests or those of third parties (to develop KITZ Group’s products/services and grow KITZ Group’s business)	For the duration of transactions
Name, address, telephone number, email address, company, company address, department, title, etc.	To comply with applicable laws, regulations, court orders, government and law enforcement agencies’ requests, to operate our systems properly and to protect ourselves, our users and customers and to solve any customer disputes.	Necessary for compliance with legal obligations	For the duration of transactions
Name, address, gender, date of birth telephone number, email address, educational background, personal history, employment history, qualifications, academic credentials, information on previous employment, etc.	To perform recruitment screening, provide corporate information to, and make necessary communication with, job seekers and prospective employees	Necessary for the pursuit of KITZ Group’s legitimate interests or those of third parties	For a period necessary to attain the purpose of processing

When the provision of personal information is required under law or contract or is a requirement necessary to enter into a contract, you are obliged to provide the relevant personal information. However, your provision of personal information on KITZ Group’s website is not a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as you are not obligated to provide the personal information. Please note that the failure to provide such personal information may cause difficulty in providing products/services you may request.

Unless required by law or your consent is obtained, KITZ Group will not obtain or use any sensitive information (such as information on racial or ethnic origin, political belief, religion, thought or admission to a labor union, genetic information, biological information, or information on physical status, sex life or sexual orientation).

KITZ Group will not use personal information for any monitoring or profiling activity or process, and will not adopt any automated decision-making process.

2.Disclosure of Personal Information to a Third Party

KITZ Group may disclose your personal information to one of KITZ Group and/or audit corporations within the extent of the purposes of processing.

3.Your Rights

You have the following rights with respect to personal information held by KITZ Group:

• ・Right to request access to your personal information;
• ・Right to request rectification of your personal information;
• ・Right to request erasure of your personal information.
• ・Right to request the restriction of processing of your personal information;
• ・Right to request data portability of your personal information;
• ・Right to object to processing your personal information (including for marketing purposes);
• ・Right to withdraw your consent at any time with respect to the personal information collected based on your consent; and
• ・Right to lodge a complaint to a competent data protection authority of a country in which your personal information is processed (You can find the list provided by the European Data Protection Board here.)

4.Transfer of Personal Information to a Third Party Outside the EEA or the UK

KITZ Group may transfer your personal information to third parties located in countries outside the EEA or the UK within the extent of the purpose of use. The European Commission and the UK Government recognized Japan as having an adequate level of data protection in 2019.
Some of overseas group companies of KITZ Group are located in third countries that are not recognized by the European Commission as having the same level of personal information protection law as the EEA or the UK; however, a sufficient level of personal information protection is secured by entering into data transfer agreements with one of KITZ Group. In such case, KITZ Group take appropriate protection measures necessary for international data transfer such as the EU Standard Contractual Clauses.

5.Update of this Policy

When this Policy is updated, the previous version of this Policy will be archived and become available for reference.

6.Contact Information

The data controllers of the personal information collected from individuals in the EEA or the UK are the following group companies located in the EEA or the UK.

• ・KITZ Corporation of Europe, S.A.
  Address: Ramón Viñas, 8, 08930 Sant Adrià de Besòs, Bar celona, Spain
  Phone: +34 -93-462 -1408
• ・Perrin GmbH
  Address: Seimensstraße 1, 61130 Nidderau, Germany
  Phone: +49 -6187-928 -0

For inquiries or comments about this Policy, please contact:
KITZ Corporation
Information Security and Personal Information Protection Secretariat
Tokyo Shiodome Building, 1-9-1, Higashi-Shimbashi, Minato-ku, Tokyo 105-7305, Japan
https://www.kitz.com/en/contact/

Last updated on: April 1, 2024

1.Personal Information KITZ Group Collect About You

KITZ Group may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with particular consumer or household.

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Categories of Personal Information	Specific Types of Personal Information Collected
Identifiers (e.g., name, alias, account name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, social security number, driver’s license number, passport number, or other similar identifiers)	・Full name; ・Telephone number; ・Email address ・Company name; ・Company address; ・Company website; ・Internet Protocol address;
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual (including, but not limited to his or her 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)	・Full name; ・Telephone number; ・Email address ・Company name; ・Company address; ・Company website; ・Company department;
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)	・Product purchase history with us; ・Requests for quotations;
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement)	・Browsing history on website; ・Download history on website; ・Cookies;
Geolocation data	Approximate location via Google Analytics;
Professional or employment-related information	・Company name; ・Company department.

2.How Your Personal Information is Collected

KITZ Group collect most of this personal information directly from you – in person, by telephone, text or email, and via KITZ Group’s website. However, KITZ Group may also collect your personal information from following sources:

• ・From publicly accessible sources (e.g., public corporate records);
• ・Directly from a third party (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers);
• ・From a third party with your consent (e.g., your bank);
• ・From cookies on KITZ Group’s website; and
• ・Via KITZ Group’s IT systems, including without limitation:
  • ・Automated monitoring of KITZ Group’s websites and other technical systems, such as KITZ Group’s computer networks and connections, access control systems, communications systems, email and instant messaging systems; and
  • ・Any other relevant systems.

The Purpose Why KITZ Group Collect and Use Your Personal Information

KITZ Group collect and use your personal information only for the following purposes:

• ・Providing products and services to you;
• ・Preventing and detecting fraud against you or the KITZ Group;
• ・Conducting checks to identify KITZ Group’s customers and verify their identity:
  • ・Screening for financial and other export controls, sanctions or embargoes;
  • ・Other processing necessary to comply with professional, legal, and regulatory obligations that apply to KITZ Group’s business;
• ・Gathering and providing information required by or relating to audits, inquiries, or investigations by regulatory agencies or bodies;
• ・Ensuring business policies are adhered to (e.g., policies covering security and Internet use);
• ・Operational reasons, such as improving efficiency, training and quality control;
• ・Statistical analysis to help KITZ Group manage KITZ Group’s business and services (e.g., in relation to KITZ Group’s financial performance, customer base, efficiency measures, and product range);
• ・Preventing unauthorized access and modifications to systems;
• ・Updating and enhancing customer records;
• ・Marketing KITZ Group’s services to:
  • ・Existing and former customers;
  • ・Third parties who have previously expressed an interest in KITZ Group’s services; and
  • ・Third parties with whom KITZ Group have had no previous dealings.

Sensitive Personal Information

KITZ Group may collect personal information that is defined as “sensitive personal information” under the CCPA/CPRA. KITZ Group do not use or disclose sensitive personal information for any purpose other than the following purposes:

• ・To perform services or provide products reasonably expected by average consumers who request such products or services;
• ・To prevent, detect, or investigate security incidents;
• ・To act against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activity;
• ・To secure physical safety;
• ・For brief or temporary use for such purposes as non-personalized advertisement displayed as part of the current cross-interaction between consumers and businesses;
• ・To provide services as a business;
• ・To check or maintain safety, improve, enhance or upgrade functions of products, services and devices owned, manufactured or managed by us; and
• ・To collect or process sensitive personal information without the intention to speculate on the characteristics of the consumer.

3.Promotional Communications

KITZ Group may use your personal information to send you updates (via email, text message, telephone, or mail) about KITZ Group’s products and services, including exclusive offers, promotions or new products and services.

KITZ Group have a legitimate interest in processing your personal information for promotional purposes. This means that KITZ Group do not usually need your consent to send you promotional communications. However, where consent is needed, KITZ Group will first seek your consent separately and clearly.

Your personal information will be processed with the utmost respect, and KITZ Group will never sell your personal information to other organizations outside of the KITZ Group for marketing purposes.

You have the right to opt-out of receiving promotional communications from KITZ Group at any time by:

• ・Contacting us at info@kitzsctamerica.com; or
• ・Using the “unsubscribe” link in emails or “STOP” message in texts.

4.Disclosure of Personal Information

KITZ Group routinely disclose personal information to the following third parties:

• ・KITZ Group’s parents or affiliates, including companies within the KITZ Group;
• ・Service providers KITZ Group use to help deliver KITZ Group’s products and/or services to you, such as payment service providers, warehouses, and delivery companies;
• ・Other third parties KITZ Group use to help KITZ Group run KITZ Group’s business, such as marketing agencies or website hosts;
• ・Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
• ・Credit reporting agencies;
• ・KITZ Group’s insurers and brokers; and
• ・KITZ Group’s banks.

In the preceding twelve (12) months, KITZ Group have disclosed for a business purpose to one or more third parties listed above the following categories of personal information:

• ・Identifiers (e.g., name, alias, account name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, social security number, driver’s license number, passport number, or other similar identifiers);
• ・Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification 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 information;
• ・Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
• ・Internet or other electronic network activity (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement);
• ・Geolocation data; and
• ・Professional or employment-related information.

KITZ Group only allow service providers to handle your personal information if KITZ Group are satisfied that they take appropriate measures to protect your personal information. KITZ Group also impose contractual obligations upon service providers to ensure they can only use your personal information to provide services to KITZ Group and to you. KITZ Group may also disclose personal information to external auditors as it may relate to accreditation or the audit of KITZ Group’s accounts.
KITZ Group may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with KITZ Group’s legal and regulatory obligations.

KITZ Group may also need to disclose some personal information to other parties, such as potential buyers of a portion or all of KITZ Group’s business, or while in the process of a company re-structuring. KITZ Group will typically anonymize personal information, but this may not always be possible. The recipient of the personal information will be bound by confidentiality obligations.

5.Personal Information KITZ Group Sold or Shared for a Business Purpose

KITZ Group have not sold, in the preceding twelve (12) months, and do not sell, consumers’ personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

KITZ Group use cookies and similar technologies on KITZ Group’s websites and have shared your personal information with service providers in the preceding twelve (12) months.
For information on cookies and similar technologies KITZ Group use, please see “15. Cookies” below.

Except for the above, KITZ Group do not share your personal information. Also, KITZ Group do not knowingly share personal information of minors under 16 years old.
To send a request to opt-out of sharing your personal information, you can choose to validate online a universal tool that automatically communicates the opt-out setting such as the Global Privacy Control (“GPC”), if available.

6.Where Your Personal Information Is Held.

Personal information may be held at KITZ Group’s offices and those of KITZ Group’s parents, affiliates, third party agencies, service providers, representatives, and agents as described above (see “4. Disclosure of Personal Information”).

7.How Long Your Personal Information Will Be Kept.

KITZ Group will keep your personal information while you have an account with KITZ Group or while KITZ Group are providing either KITZ Group’s products and/or services to you. Thereafter, KITZ Group will keep your personal information for as long as is necessary to:

• ・Respond to any questions, complaints, or claims made by you or on your behalf;
• ・Show that KITZ Group treated you fairly; or
• ・Keep records as may be required by law.

KITZ Group will not retain your personal information for longer than necessary for the purposes set forth in this Policy. Different retention periods apply for different types of personal information.

8.Protection of Personal Information

KITZ Group have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. KITZ Group limit access to your personal information to those who have a genuine business need to access it. Those processing your personal information will do so only in an authorized manner and are subject to a duty of confidentiality. In addition to KITZ Group’s own internal storage of your personal information, KITZ Group also utilize WordPress for the collection of your personal information as part of your use of KITZ Group’s website. KITZ Group encourage you to visit WordPress’s privacy policy page at (https://automattic.com/privacy/) for more information, and how you may contact WordPress to exercise your rights under the CCPA/CPRA.

9.Your Rights Under the CCPA/CPRA

Under the CCPA/CPRA, you may exercise the following rights, free of charge:

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Related Activity	Your Rights
Disclosure of Personal Information KITZ Group Collect About You	The Right to Know: You have the right to know the following matters. ・The categories of personal information KITZ Group have collected about you; ・The categories of sources from which the personal information is collected; ・The business or commercial purposes to collect, sell or share personal information; ・The categories of third parties with whom KITZ Group disclose personal information; and ・The specific pieces of personal information KITZ Group have collected about you. Please note that KITZ Group are not required to: ・Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; ・Re-identify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or ・Provide the personal information to you more than twice in a twelve (12)-month period.
Right to Opt-Out of the Sale/Sharing of Personal Information	You have the right under the CCPA/CPRA to opt-out of the sale or sharing of your personal information. Under the CCPA/CPRA, the “selling” or “sale” of personal information means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating (in oral, written, or electronic form) a consumer’s personal information by the business to another business or third party for monetary or other valuable consideration. KITZ Group do not sell any personal information to any third parties.
Right to Deletion	Subject to exceptions set forth under “How to Exercise Your Rights,” on receipt of a verifiable request from you, KITZ Group will: ・Delete your personal information from KITZ Group’s records; and ・Direct any service providers to delete your personal information from their records. Please note that KITZ Group may not delete your personal information if it is necessary to: ・Complete the transaction for which the personal information was collected, provide products or services requested by you, perform an act reasonably anticipated within the context of KITZ Group’s ongoing business relationship with you, or otherwise perform a contract between you and us; ・Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; ・Debug to identify and repair errors that impair existing intended functionality; ・Exercise free speech, ensure that right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; ・Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §1546 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 KITZ Group’s deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided KITZ Group have obtained your informed consent; ・Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with KITZ Group; ・Comply with legal obligations; or ・Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Right to Correction	You have the right to request correction of your personal information held by KITZ Group inaccurately.
Right to limit the Use or Disclosure of Sensitive Personal Information	You have the right to limit the use and disclosure of your sensitive personal information held by KITZ Group to specific business purposes permitted under the CCPA/CPRA.
Protection Against Discrimination	Unless otherwise permitted by law, you will not be discriminated against because you exercised any of your privacy rights under the CCPA/CPRA or any other applicable law, including, without limitation, in the following manners: ・Denial of products or services to you; ・Charge different prices or rates for products or services, including through the use of discounts and other benefits or through the imposition of penalties; ・Provide a different level or quality of products or services to you; or ・Suggest that you will receive a different price or rate for products or services or a different level or quality of such products or services. Please note that KITZ Group may charge a different price or rate or provide different level or quality of products and/or services to you, if that difference is reasonably related to the value provided to KITZ Group’s business by your personal information.

California Civil Code §1798.83 permits users of KITZ Group’s website that are California residents to request certain information regarding KITZ Group’s disclosure of personal information to third parties for direct marketing purposes. To make such a request, please contact KITZ Group using the information contained in “14. How to Contact Us” section below.

(1)How to Exercise Your Rights

If you would like to exercise any of your rights as describe in this Policy, you may call, write, or email us, using the contact information contained in “14. How to Contact Us” section below. Please note that you may only make a data access or data portability disclosure request related to CCPA/CPRA twice within a twelve (12)-month period. When contacting us, you will need to provide us with:

• ・Sufficient identifying information (e.g., your full name, address, and any customer or matter reference number);
• ・Proof of your identity and address (e.g., copy of your driver’s license, passport, or a recent utility bill); and
• ・A description or statement identifying what right you wish to exercise and the information to which your request relates.

KITZ Group are not obligated to make a data access or data portability disclosure if KITZ Group are unable to verify that the person making the request is the person about whom KITZ Group collected information or is someone authorized to act on such person’s behalf.

Any personal information KITZ Group collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

(2)How to Authorize a Person to Act on Your Behalf

Unless a power of attorney is submitted to the relevant person acting on your behalf pursuant to California Probate Code Sections 4000-4465, you need to (1) submit to the person acting on your behalf a signed authorization that clearly states his or her authority to make a request on your behalf, (2) prove your own identity, and (3) directly confirm that you submitted a written authorization to the person authorized to make a request on your behalf. If KITZ Group do not receive a signed authorization proving the authority of the person making a request on your behalf, KITZ Group may reject a request by such person.

(3)Exceptions to Exercise of Rights

Your rights described above are not absolute rights, and there are certain exceptions. For example, if your request causes a certain level of risk to the security of your personal information in question or a website, KITZ Group cannot disclose or give access to specific personal information.

Also, if KITZ Group or any service providers and/or contractors need to retain information for any of the following purposes, KITZ Group may reject your request for deletion:

• ・Complete the transaction for which the personal information was collected, provide products or services requested by you, perform an act reasonably anticipated within the context of KITZ Group’s ongoing business relationship with you, or otherwise perform a contract between you and us;
• ・Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for such activity;
• ・Debug to identify and repair errors that impair existing intended functionality;
• ・Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
• ・Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §1546 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 KITZ Group’s deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided KITZ Group have obtained your informed consent;
• ・Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with KITZ Group;
• ・Comply with legal obligations; or
• ・Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

(4)When and How KITZ Group Respond to Your Request

KITZ Group make efforts to respond to all verifiable requests within 45 days of the receipt thereof. If a longer period (not exceeding 90 days) is necessary, KITZ Group will inform you of the reason therefor and the required period in writing. Unless your request is excessive, repetitive or obviously groundless, KITZ Group do not charge you any fee for processing and responding to your verifiable requests. If KITZ Group decide that your request is chargeable, KITZ Group will inform you of the reason for such decision and provide a fee quotation before responding to your request.

10.Third Party Analytics

KITZ Group work with third party analytics companies and advertisers as part of the operation of KITZ Group’s website. Specifically, KITZ Group work with Google Analytics, who may provide similar opt-out mechanisms at https://policies.google.com/privacy?hl=en_US.

11.Minors and Users Under 18 Years Old

KITZ Group’s website is not intended for minors. No one under the age of majority may provide any personal information to or on KITZ Group’s website on their own behalf or on behalf of a company or business. KITZ Group do not knowingly collect personal information from minors. If you are under the age of majority, do not use or provide any information on KITZ Group’s website on or through any of its features or links. If KITZ Group believe KITZ Group have collected or received the personal information of a minor, KITZ Group will promptly delete that information. If you believe KITZ Group may have any information from or about a minor, please contact KITZ Group pursuant to “9.(1) How to Exercise Your Rights” section above and “14. How to Contact Us” section below.

12.Redress of Grievances

If you feel that KITZ Group are not abiding by this Policy, you should contact KITZ Group immediately via KITZ Group’s contact information under “14. How to Contact Us” section below.

13.Changes to This Policy

From time to time, KITZ Group may change this Policy. Any amendments, changes, or revisions to this Policy shall be posted to this page, and the changes are effective at the time of posting. By continuing to access or use the Services after such changes become effective, you agree to be bound by such revised Policy.

14.How to Contact KITZ Group

Please do not hesitate to contact us by mail, email, or telephone if you have any questions about this Policy or the information KITZ Group hold about you. KITZ Group may be contacted, as follows:

• KITZ SCT America Corporation
  Address:5201 Great America Pkwy, Suite 238
  Santa Clara, CA 95054, U.S.A.
  Email:info@kitzsctamerica.com

15.Cookies

A cookie is a small piece of data (normally a 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. KITZ Group also use third-party cookies, which are cookies from a domain different from the domain of the website you are visiting, for other business purposes (e.g., advertising and marketing). More specifically, KITZ Group 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 KITZ Group’s 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 may not properly function. These cookies do not store any personally identifiable information.

Performance Cookies

These cookies allow us to count visits and traffic sources so KITZ Group can measure and improve the performance of KITZ Group’s site. They help us know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our site, and will not be able to monitor its performance.

Targeting Cookies

These cookies may be set through KITZ Group’s site by any third-party partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites. They do not directly store personal information, but are based on uniquely identifying your browser and internal device. If you do not allow these cookies, you will experience less targeted advertising.

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Under the CCPA/CPRA, you have the right to opt-out of the sale of your personal information to third parties. KITZ Group do not currently sell any personal information you provide to us either directly (e.g., voluntary submission through KITZ Group’s website or by providing your personal information by email, mail, or telephone) or indirectly (e.g., cookies). You may contact KITZ Group for further clarification about your rights as a California consumer.

Last updated on: April 1, 2024