CCPA Privacy Notice

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS UNDER THE CALIFORNIA
CONSUMER PRIVACY ACT OF 2018 (“CCPA”)
Effective Date: July 1, 2020

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in our General Privacy Policy and applies to individual visitors, users, and others who are residents of the State of California (as defined in the CCPA) who are not affiliated with our business customers or suppliers nor are our employees, contractors, or job applicants. As used herein “you” refers to an individual consumer (and not a legal entity such as a corporation or LLC) residing in California.

We adopt this notice to comply with the California Consumer Privacy Act of 2018 and any terms defined in the CCPA have the same meaning when used in this notice.

You have the right to (1) request we disclose to you your Personal Information we hold, (2) source(s) from which your Personal Information is collected, (3) categories of your Personal Information that we sold or disclosed for a business purpose, (4) request that we do not sell your Personal Information (“opt out”) and (5) request that we delete your Personal Information. You can opt out by clicking on “Do not sell my information” on our homepage.

Please also read our General Privacy Policy and Terms of Use. In the event of a conflict, the provisions of our CCPA Privacy Policy shall control.

Categories of Personal Information” under the CCPA includes:

  1. Any information that identifies, relates to, describes, or is capable of being associated with, you, including but not limited to, your name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information; YES, WE COLLECT THIS
  2. Any characteristics of classifications that are protected under California or federal law such as citizenship, age, gender identity, pregnancy; YES, WE COLLECT THIS
  3. Any commercial information obtained, purchased or considered, such as records of personal property, records of products or services purchased or other purchasing or use histories or tendencies; YES, WE COLLECT THIS.
  4. Biometric information, if applicable such as fingerprints, faceprints, voice prints; NO, WE DO NOT COLLECT THIS
  5. Activity information relating to internet or other electronic networks such as browsing or searching history, or interaction with a website, ad or app (if any); YES, WE COLLECT THIS
  6. Geolocation information that identify, relate to, or reasonably link, directly or indirectly, with you or your household; YES, WE COLLECT THIS
  7. Audio, visual, thermal, electronic, olfactory or other similar information; NO, WE DO NOT COLLECT THIS
  8. Information related to employment or other professional standings and information related to education; YES, WE COLLECT THIS
  9. Any inferences drawn using any of the above information to profile a consumer and reflect the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes. YES, WE COLLECT THIS
    We have disclosed Personal Information to the following categories of Personal Information in the last 12 months: Categories 1, 3, and 5.

Personal information does not include:

  1. Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records.
  2. Deidentified or aggregated consumer information.
  3. Information excluded from the CCPA’ s scope, like:
    1. health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    2. personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

What are our sources of Personal Information?
For all categories of Personal Information which we collect, we obtain Personal Information from the following categories of sources:

  1. Our affiliates
  2. Direct interactions by you giving us your Personal Information, by filling in forms or by corresponding with us by mail, phone, fax, email or in-person. This includes, but may not be limited to, personal data you provide when you:
    1. Purchase our products or services or to request samples;
    2. Request marketing be sent to you;
    3. Subscribe to our publications;
    4. Enter a contest or promotion
  3. Indirectly from your activity on our websites. For example, from participation in our forums, promotions, from orders or other submissions through our website or website usage details.
  4. Publicly available information on the internet, social media and/or any other platform.

How do we use your Personal Information that we collect?
We may use or disclose the Personal Information we collect for the following business purposes:

  1. To perform the service for which the Personal Information is provided. For example, if you provide us with Personal Information for us to complete an order, we will use that information to complete that order. We may also save your Personal Information to facilitate new product orders or process returns.
  2. To provide you with information, products, or services that you buy from us.
  3. To create, maintain, customize, and secure your account with us.
  4. To provide you with email alerts, event registrations, and other notices concerning our products or services, or events or news that may be of interest to you.
  5. To enable you to partake in a prize drawing, promotion, competition or complete a survey.
  6. To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
  7. To deliver you relevant website content and advertisements and measure or understand the effectiveness of the advertising we send to you.
  8. To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
  9. To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
  10. To make suggestions and recommendations to you about goods or services that may be of interest to you.
  11. To enforce our rights arising from any contracts entered between us, including for billing and collections.
  12. To improve our website and present its contents to you.
  13. For testing, research, analysis and product development.
  14. To protect our rights, property or safety and those of our customers or others.
  15. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  16. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information we hold about our website users is among the assets transferred.
  17. As may otherwise be disclosed to you when collecting your Personal Information or as otherwise set forth in the CCPA.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Do we share your Personal Information?
We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to keep Personal Information confidential and not use it for any purpose except performing the contract. We may share your Personal Information with the following categories of third parties:

  1. Service providers
  2. Data aggregators
  3. Our affiliates and subsidiaries
  4. Third parties with which we partner to handle logistics in delivering products and services to you.

What Personal Information do we sell?
We have not sold any Personal Information of any consumers in the preceding 12 months.

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer who is between 13 and 16 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

We do not sell, as defined in the CCPA, your Personal Information (except for cookies). The cookie itself is anonymous and does not contain any personal data, except when such information has been supplied by you, such as when you provide your name and email address when completing a registration form. However, under the CCPA, if any cookie can uniquely identify you or the device you, or any other person is using, via an IP address or other online identifier, this is personal data. To the extent that the collection or sharing of any cookies, as applicable, constitutes a sale under the CCPA, you can exercise your right to have us delete your Personal Information.

California Privacy Choices
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the 12 months prior to receiving your request or to delete your Personal Information. Once we receive and confirm your verifiable request, we will disclose to you the categories of Personal Information we collected about you.

  1. The specific pieces of Personal Information we collected about you (also called a data portability request).
  2. The categories of sources for the Personal Information we collected about you.
  3. The categories of third parties with whom we shared Personal Information we collected about you.
  4. Our business or commercial purpose for collecting or sharing your Personal Information with third parties.
  5. If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
    1. sales, identifying the Personal Information categories that each category of recipient purchased; and
    2. disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights
You have the right to request that we delete some or all your Personal Information. Once we receive and confirm your request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. We may deny your deletion request if we are unable to verify your identity or if we are not required to delete your Personal Information under the CCPA.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  1. Complete the transaction for which we collected your Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  7. Comply with a legal obligation.
  8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
  9. If we cannot verify your identity or the disclosure creates a substantial, articulable, and unreasonable risk to the security of your Personal Information, your account with us, or the security of our business’s systems or networks.
  10. In no event will we disclose your Social Security number, driver’s license number or other government-issued identification number, account password, or security questions and answers.

Making your privacy choices
You may make your privacy choice(s) at any time. Your choice(s) will remain unless you state otherwise. If we do not hear from you we may share some or all your Personal Information as described above.

Only you or an authorized agent may make a verifiable request. You may also make a verifiable request on behalf of your minor child under age 16.

We are only required to respond to a verifiable consumer request twice within a 12-month period.

You can submit requests by either:

  1. Calling: 800-733-6270 and ask for Customer Service
  2. Online: privacy@zojirushi.com. In the subject line please insert “CCPA Request” for better handling.
  3. Mail: Zojirushi America Corporation, Attn: CCPA Requests, 19310 Pacific Gateway Drive #101, Torrance, CA 90502-1031

The verifiable request must:

  1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or your authorized representative.
  2. 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 request does not require you to create an account with us. We will only use Personal Information provided in a verifiable request to verify the requestor's identity or authority to make the request.

You may change your choice at any time by notifying us.

Response Timing and Format
We will confirm receipt of your request within 10 business days following our receipt. We endeavor to respond to a verifiable request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

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.

We do not charge a fee to process or respond to your verifiable 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.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your verified request.

The response we provide will also explain the reasons we cannot comply with a request, if applicable.

Non-Discrimination
We will not discriminate against you for exercising your rights under CCPA. We will not:

  1. Deny you access to our consumer goods or services
  2. Charge you different prices for goods or services, whether through denying benefits or imposing penalties
  3. Provide you with a different level or quality of goods or services than we provide to other consumers
  4. Threaten you with any of the above

Amending this Policy
We may change these policies at any time. When we make changes to this policy, we will post the updated policy on our website and update its effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.

Please review our policy from time to time. We have no duty to notify you of any changes.

If you have any questions or comments about this notice, the ways in which we collect and use your Personal Information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at the addresses described above.

You can contact us for general information by:

  1. Calling: 800-733-6270 and ask for Customer Service
  2. Online: privacy@zojirushi.com. In the subject line please insert “CCPA Request” for better handling.
  3. Mail: Zojirushi America Corporation, Attn: CCPA Requests, 19310 Pacific Gateway Drive #101, Torrance, CA 90502-1031