PRIVACY POLICY

We collect the following information that identifies, relates to, describes, references, and is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”).

• Customer data, including name, address, phone number, email address, online identifier (cookie, IP address), device information (language, location data, etc.), usage status of the website, various questionnaire information, purchase history, etc.
• Business partner data, including name, address, company name, department name, job title, phone number, email address, etc.
• Recruitment data, including name, date of birth, gender, address, telephone number, email address, nationality, educational background, employment history, qualifications, information on awards and punishments, etc.
• Employment management data, including name, date of birth, gender, address, telephone number, email address, nationality, social security number, bank account number, employment insurance information, salary, personnel evaluation, etc
• Shareholder data, including name, address, number of held shares, date of purchase, contact information, shareholder number, etc.

In particular, we have collected the following categories of personal information as defined in the CCPA from you within the preceding twelve (12) months:

Category

• Customer data, including name, address, phone number, email address, online identifier (cookie, IP address), device information (language, location data, etc.), usage status of the website, various questionnaire information, purchase history, etc.
• Business partner data, including name, address, company name, department name, job title, phone number, email address, etc.
• Protected classification characteristics under California or federal law.
• Commercial information
• Internet or other electronic network activity information
• Professional or employment-related information.
• Education information
• Sensitive personal information

We may collect your personal information directly from you or through third parties, including our group companies. In addition, when you visit our websites, we may automatically collect, store, and use a usage environment to access our website and your interaction with our website. This information will be sent to us from your computer or other devices using a variety of cookies.

We may use your personal information to achieve the following business purposes indicated below:

• To send products and other prizes to survey respondents and winners of various campaigns and events;
• To respond to requests for opinions, inquiries, etc.;
• To manage store reservations;
• To develop products and services by analyzing customer usage patterns through surveys, etc.;
• To handle shareholder-related matters in accordance with laws and regulations;
• To communicate with, respond to, and manage business transactions with our business partners and customers;
• To handle various matters, including communicating with and managing applicants for employment with our group or its franchisees (whether a legal entity or an individual; the same applies hereinafter) who have entered into a franchise agreement with us;
• To handle various matters related to the employment and human resource management of our group’s employees (including retired employees); and
• For other purposes of use, published or notified when the personal information is provided.

We may disclose your personal information to the following recipients for business purposes or commercial purposes.

• Our group companies (https://eternal-hospitality.co.jp/company/group/); and
• Service providers providing cloud services, marketing services, security services, etc.

When we disclose personal information to service providers or contractors for business purposes or commercial purposes, we enter a contract that describes such purposes and requires the service providers or contractor to both keep that personal information confidential and not use it for any purpose except for performing the contract.

We have not sold or shared any personal information collected from consumers in the preceding twelve (12) months.

“Sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a consumer’s personal information by the business to a third party for monetary or other valuable consideration.

“Share” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a consumer’s personal information by the business to a third party for cross-context behavioral advertising.

We will not retain your personal information for as long as necessary to fulfill the purposes for which we collected your personal information and comply with the Applicable Laws. To determine the appropriate retention period for the personal information, we will consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which we collect the personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Depending on your jurisdiction, you may have several rights in relation to our processing of your personal information in accordance with Applicable Laws, which may include the right to request access to, correct, or delete your personal information. They may also include the ability to opt-out of receiving notifications, promotions, offers, or other advertising from us.

If you are a California resident, the CCPA provides specific rights in relation to our processing of your Personal Information. The following parts of this Section describe your rights under the CCPA and explain how to exercise those rights.

（1）Right to access personal information

You have the right to request that we disclose certain information to you about our collection, sharing, disclosure or use of your personal information. Once we receive and confirm your verifiable request, we will disclose the following information to you:

• The categories of personal information we collected about you;
• The categories of sources for the personal information we collected about you;
• Our business or commercial purposes for collecting, selling, or sharing such personal information;
• The categories of third parties with whom we share such personal information;
• The categories of personal information that we sold, and for each category identified, the categories of third parties to whom we sold such personal information;
• The categories of personal information that we disclosed for a business purpose, and for each category identified, the categories of third parties to whom we disclosed such personal information; and
• The specific pieces of personal information we collected about you.

（2）Right to request deletion

You have the right to request that we delete any of your personal information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete, and notify our service providers or contractors and third parties to whom we have sold or shared such personal information to delete, your personal information from our records, unless an exception applies.

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

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

（3）Right to request correction

You have the right to request that we correct any of your inaccurate personal information that we have collected from you and retained. Once we receive and confirm your verifiable request, we will correct, and notify our service providers or contractors and third parties to whom we have sold or shared such personal information to correct, your inaccurate personal information.

We may deny your request for correction if we determine that the contested personal information is more likely than not to be accurate based on the totality of the circumstances.

（4）Right to opt-out of sale or sharing

We have not sold or shared any personal information collected from consumers.

（5）Right to limit the use of sensitive personal information

We have not used and disclosed and will not use or disclose sensitive personal information collected from you for any purpose other than the following:

• To perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services;
• To help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes;
• For short-term, transient use (except those involving profiling or changes to the future consumer experience);
• To perform services on our behalf; and
• To undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us.

（6）Non-discrimination

We will not discriminate against California residents for exercising any of their rights under the CCPA. Moreover, unless permitted by the CCPA, we will not:

• Deny the goods or services to you;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods or services;
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services; or
• Retaliate against an employee, applicant for employment, or independent contractor.

（7）Exercising rights for disclosure request,
deletion request and correction request

To exercise your rights for disclosure request, deletion request and correction request described above, please submit a verifiable request to us by contacting us in the manner set forth in Section 8 (CONTACT US).

Only you, a natural person or a person registered with the California Secretary of State that you authorize to act on your behalf, or a person who has a power of attorney or is acting as a conservator for you, may make a verifiable request related to your personal information. You may also make a verifiable request on behalf of your minor child.

Your verifiable request must:

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond thereto.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond thereto.

We cannot respond to your request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

（8）Contact Us

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your personal information described above, or wish to exercise your rights provided in Section 7 (Your Rights and Choices under the Applicable Laws), please do not hesitate to contact us at:
・info@zokuyakitori.com

Privacy Policy Last Updated and Effective: September 5th, 2024