California Privacy Statement

Effective Date: April 1, 2024

1. YOUR CALIFORNIA PRIVACY RIGHTS UNDER THE CCPA

Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), if you are a resident of California, you have the following rights with respect to your personal information.

1.1 Right to Know About Our Collection, Disclosure, Sharing and Sale of Personal Information about You.

Personal information as defined in the CCPA as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you, including the following categories of information: (a) personal identifiers; (b) categories described in California Civil Code §1798.80(e); (c) characteristics of protected classes; (d) commercial information; (e) biometric information; (f) internet or other electronic network activity; (g) geolocation data; (h) audio, electronic, visual, thermal, olfactory or similar information; (i) professional or employment related information; (j) education information; and (k) inferences drawn from such information to create a consumer profile.

You have the right to know the categories of personal information we have collected about you; the categories of sources from which we collect personal information; our business or commercial purpose for collecting, disclosing, sharing or selling personal information; the categories of third parties to whom we disclose, share or sell personal information, if any; and the specific pieces of personal information we have collected about you. Personal information includes “sensitive” personal as described below.

1.2 Right to Know About Our Collection, Disclosure, Sharing and Sale of “Sensitive” Personal Information about You.

“Sensitive” personal information as defined in the CCPA is personal information that reveals: (a) your social security, driver’s license, state identification card, or passport number; (b) your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) your precise geolocation; (d) your racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of your mail, email, and text messages unless we are the intended recipient of the communication; and (f) your genetic data. “Sensitive” personal information also includes biometric information that is processed for the purpose of identifying you, information that is collected and analyzed concerning your health; or your sex life or sexual orientation.

You have the right to know the categories of “sensitive” personal information we have collected about you, the categories of sources from which we collect personal information, our business or commercial purpose for collecting, selling or sharing “sensitive” personal information, the categories of third parties with whom we sell or share “sensitive” personal information, if any, and the specific pieces of “sensitive” personal information we have collected about you.

1.3 Right to Delete Your Personal Information

Subject to the exceptions set out below, and upon your submission of a verifiable request, you have the right to request the deletion of your personal information from our records, and to have us direct our service providers, contractors and third parties to delete your personal information from their records.

We are not required to, and reserve our right to not delete your personal information if it is necessary to: (i) complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; (ii) help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes; (iii) debug to identify and repair errors that impair existing intended functionality; (iv) 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; (v) comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code; (vi) 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; (vii) enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information; and (viii) comply with a legal obligation.

1.4 Right to Correct Inaccurate Personal Information.

Subject to the exceptions set out below, and upon your submission of a verifiable request, you have the right to correct any inaccurate personal information in our records, and to have us direct our service providers, contractors and third parties to correct any inaccurate personal information from their records.

If we cannot verify your identity pursuant to the CCPA and its regulations, we may deny a request to correct. In such event, we shall inform you that your identity cannot be verified.

In determining the accuracy of the personal information that is the subject of your request to correct, we shall consider the totality of the circumstances relating to the contested personal information. We may deny your request to correct if we determine that the contested personal information is more likely than not accurate based on the totality of the circumstances.

1.5 Right to Be Free from Discrimination

You have the right to not be discriminated against by us because you have exercised any of your rights under the CCPA. This means we cannot, on the basis of the exercise of your rights thereunder, among other things, deny goods or services to you, charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to you; or suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services or retaliate against you as an employee, applicant for employment or independent contractor.

1.6 Right to Opt-Out of the Sharing of Personal Information

We may disclose your personal information to third parties for cross-context behavioral advertising purposes (“Share” or “Sharing”). This means the targeting of advertising to you based on your personal information that we obtain from your activity across businesses, distinctly-branded websites, applications, or services, other than our business, distinctly-branded website, application, or service. We may Share personal information with advertising networks so that they may help us to deliver advertisements to you based on your activity on our website or apps and/or your activity on other websites or apps.

You have the right to opt-out of the Sharing of your personal information and you may exercise your right by clicking the following link:  Do Not Sell or Share My Personal Information. If you exercise your right to opt-out of the Sharing of your personal information, we will refrain from Sharing your personal information, unless you subsequently provide express authorization for the sharing of your personal information.

1.7 Right to Opt-Out of the Sale of Personal Information

We may disclose your personal information to third parties in exchange for monetary or other consideration. Such disclosures are considered to be “Sale(s)” under the CCPA. We may sell personal information to advertising networks so that they may help us to deliver advertisements to you based on your activity on our website or apps and/or to recommend our products and services to you based on your activity on other websites or apps. You have the right to opt-out of the Sale of your personal information and you may exercise your right by clicking on the following link: Do Not Sell or Share My Personal Information. If you exercise your right to opt-out of the Sale of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the Sale of your personal information.

1.8 Right to Opt-Out by Using Opt-Out Preference Signals.

We will process any opt-out preference signal that (a) is in a format commonly used and recognized by businesses (for example, in an HTTP header field) and (b) is sent from a platform, technology, or mechanism that makes it clear to the consumer, whether in its configuration or in disclosures to the public, that the use of the signal is meant to have the effect of opting the consumer out of the sale and sharing of their personal information (“Opt-Out Preference Signal”). We shall treat the Opt-Out Preference Signal as a valid request to opt-out of the Sale or Sharing of personal information for your browser or device, and, if known, for you.

If the opt-out preference signal conflicts with other privacy settings that you have submitted to us, we will process the opt-out preference signal but may notify you of the conflict and provide you with the opportunity to consent to the Sale or Sharing of your personal information.

If the Opt-Out Preference Signal conflicts with your participation in a financial incentive program, we may notify you of the conflict and request your affirmation that you intend to withdraw from the financial incentive program. If you affirm your intent to withdraw we shall process the Opt-Out Preference Signal. If you do not affirm your intent to withdraw, we will not process the Opt-Out Preference Signal.

1.9 Right to Limit the Use of “Sensitive” Personal Information

We use your “sensitive” personal information only to the extent that it is necessary to provide our goods and perform our services as reasonably expected by you. If we were to use your “sensitive” personal information other than is necessary to provide our goods and perform our services, you would have the right to limit our use of your “sensitive” personal information to that which is necessary to provide our goods and services to you.

1.10 Right of Children to Opt-In to the Sale of Personal Information

We do not knowingly collect or sell the personal information of minors under 16 years of age without affirmative authorization. For minors who wish to opt-in to the sale of their personal information, we have established the following processes:

Minors between 13 and 16 years of age:

In the case of consumers between 13 and 16 years of age, we require the consumer to affirmatively authorize the sale of the consumer’s personal information. In order to opt-in minors in this age range, as part of the account registration process for our products which may be targeted toward minors, we require the consumer or consumer’s parent or guardian to verify the consumer’s identity by providing at least two data points with data points maintained by the business, which we have determined to be reliable for the purpose of verifying the consumer.

Minors under 13 years of age:

In the case of consumers who are less than 13 years of age, we require the consumer’s parent to affirmatively authorize the sale of the consumer’s personal information. In order to opt-in minors in this age range, as part of the account registration process for our products which may be targeted toward minors, we require that the consumer’s parent or guardian verify the consumer’s identity, which we have determined to be reliable for the purpose of verifying the consumer.

We reserve the right to require additional information or not complete your request if we cannot verify your identity. If you are a parent or guardian seeking to opt-out on behalf of their child, please contact us at 1-833-957-2199 or email us at [email protected] with the subject “Minor Opt-Out.”

2. HOW TO EXERCISE YOUR CCPA RIGHTS

Unless otherwise specified, to exercise any of your rights described in this statement, please submit your request to us at 1-833-957-2199 or at [email protected] with the subject “CCPA Consumer Request.”

In order to verify your request, we will need you to provide us with enough information to identify you (e.g., your full name, address, and customer or matter reference number), proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill), and a description of what right you wish to exercise along with any information to which your requests relates. If feasible, we will match the identifying information provided by you with the personal information that we already maintain about you.

You may designate an authorized agent to make a request under the CCPA on your behalf. In order to fulfill your request to know or delete submitted by an authorized agent, you must provide the authorized agent written permission to do so, and we may require that you verify your own identity with us directly.

We reserve our right not to grant a consumer request if we cannot verify that the person making the request is the person about whom we have collected information, or someone authorized to act on such person’s behalf. You may only make a request to access or receive copies of personal information twice within a 12-month period, free of charge. Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

3. OUR PERSONAL INFORMATION COLLECTION, USE AND DISCLOSURE PRACTICES

A description of the personal information that we collect online and off-line is provided in Section 2 of the main Policy. The purposes for which we collect and use personal information are described in Sections 2 and 4 of the main Policy. Sources from which we receive personal information are described in Section 3 of the main Policy. Our personal information disclosure practices are described in Sections 6 and 7 of the main Policy. Our personal information retention practices are described in Section 11 of the main Policy.

3.1 Categories of Personal Information Collected; Sold or Shared for Cross-Context Behavioral Advertising; and Disclosed for a Business Purpose within the past 12 months.

3.2  Categories of “Sensitive” Personal Information Collected; Sold or Shared for Cross-Context Behavioral Advertising; and Disclosed for a Business Purpose within the past 12 months.

4. OTHER CALIFORNIA PRIVACY RIGHTS

4.1 Shine the Light Request.

Individual consumers who reside in California and have provided us with their personal information may request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such requests must include your name, street address, city, state, and zip code, and be submitted to us at one of the following addresses: [email protected] with the subject “California Shine The Light Request” or DENSO International America, Inc., 24777 Denso Drive, Southfield, Michigan 48086-5047, Attention: Privacy Officer. Within thirty days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. We are not obligated to respond to a request from the same customer more than once per calendar year. Additionally, we reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.

4.2 Minor’s Right to Remove Posted Content.

If you are a California resident under the age of 18, and a registered user of any website where this Policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information that you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to [email protected] with the subject “Privacy Rights for Minors.” Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.