CTC-America Personal Information Protection Policy

ITOCHU Techno-Solutions America, Inc. (“CTCA”) recognizes the protection of 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 device (“Personal Information”) as part of its corporate activities and realizes that the appropriate handling and safety management of Personal Information are important social responsibilities for CTCA. In order to fulfill such responsibility, CTCA hereby establishes this Personal Information Protection Policy (“Policy”). In line with this Policy, CTCA’s officers and employees strive to handle, manage, and maintain Personal Information in an appropriate manner.

I. Information We Collect 

CTCA has collected the following categories of Personal Information from our consumers within the last twelve (12) months and will collect the following categories of Personal Information:

CTCA obtains your Personal Information listed above directly or indirectly from you in our relationship with you, including, but not limited to, when (i) we receive your business card and (ii) you access our website.

CTCA will not collect additional categories of Personal Information or use the Personal Information CTCA collects for materially different, unrelated, or incompatible purposes without providing you notice thereof.

Ⅱ. Use of Personal Information

In order to perform “CTC’s Business”, CTCA may use your Personal Information for one or more of the following business purposes stated in the “Purposes of Use” below:

CTCA’s Business

1.     Providing services and solutions in relation to computer networks;

2.     Selling hardware, software and ancillary products for computer networks;

3.     Building, developing, maintaining, and managing the operation of hardware, software and ancillary products for computer networks;

4.     Managing the operation of data centers (housing and outsourcing);

5.     Developing, selling, and managing the maintenance and operation of ASP and SaaS systems and various information processing services;

6.     Engaging in consulting, education and publication and holding seminars and events incidental to any of the preceding five (5) items, providing various products and technical information, and providing professional services including the dispatch of technical personnel;

7.     Providing services and solutions in relation to office work related to individual numbers; and

8.     Any and all business incidental to any of the foregoing items.

Purposes of Use

1.     Performing CTCA’s business stated in “CTCA’s Business” above and transactions with business partners

(1)   Sending estimates and delivery statements, and providing other business communications;

(2)   Executing agreements;

(3)   Granting licenses and registering users;

(4)   Developing an entrusted system, accepting the operation and management of a system, and otherwise performing entrusted business;

(5)   Performing maintenance support service under a maintenance agreement;

(6)   Performing claims and debts and contractual obligations;

(7)   Announcing information about new products, providing notification about the expiration of a contractual period, providing information about the release of patches, and otherwise providing after-sales services associated with the performance of transactions;

(8)   Announcing business activities;

(9)   Conducting questionnaire surveys for the purposes of research, development and improvement (communication, implementation, analysis and reporting);

(10)  Understanding clients, delivery destinations, billing addresses, contact addresses for maintenance, etc. and developing a contact network; and

(11)  Providing business communications and sending materials and greeting letters in association with transactions.

2.     Providing information about CTCA’s products, services, solutions, etc. (sending direct mails and announcing seminars and events)

CTCA sends direct mails and issues e-mail newsletters to persons whose Personal Information is to be owned by CTCA as a result of transactions with CTCA and who apply for the provision of information through CTCA’s website, for the purpose of providing information on CTCA’s products, services, solutions, etc., after obtaining prior individual approval.

3.     Contacting applicants for seminars and events which are sponsored, jointly hosted or supported by CTCA, conducting administrative procedures in relation to the participation, analysis and maintenance of statistics on the results of holding seminars and events, and making subsequent improvements;

4.     (In the case where CTCA is entrusted by another business operator with performing business or handling of Personal Information) appropriately performing such entrusted business;

5.     Responding to inquiries and opinions from business partners and sending requested materials;

6.     Sending invitations to lectures and briefings for the media and various stakeholders and providing various communications;

7.     Sending various invitations to and contacting CTCA’s shareholders, and performing administrative procedures;

8.     Considering, investigating, responding and communicating for identification purposes, and performing administrative procedures;

9.     Confirming the identity of unknown persons and visitors and the purposes of their visits, and managing the same to ensure security;

10.  Communicating, responding and sending materials for the purpose of performing smooth procedures with regard to CTCA’s recruitment activities:

1. Performing procedures required under the laws and regulations;

2. Confirming the compliance with CTCA’s recruitment standards;

3. Judging an applicant’s adequacy and competence in recruitment screening;

4. Making emergency contact before joining the company; and

5. Confirming physical conditions for the purpose of personnel allocation plans

11.  Making emergency contact in the course of business;

12.  Preparing various payment records; and

13.  Purchasing goods, being entrusted with and entrusting business, conducting financial transactions in the course of normal company management.

Ⅲ. Disclosure of Personal Information

CTCA may disclose your Personal Information to a third party for business purposes or commercial purposes. When CTCA discloses Personal Information to service providers or contractors for business purposes or commercial purposes, CTCA enters a contract that describes such purposes and requires the service providers or contractors to both keep that Personal Information confidential and not use it for any purpose except for performing the contract.

In the preceding twelve (12) months, CTCA has disclosed the Personal Information to the following categories of third parties for business purposes or commercial purposes:

• Affiliated Companies (including those listed at: https://www.ctc-g.co.jp/en/company/about/group/);

• Cloud service providers; and

• Security Monitoring vendors.

Ⅳ. Sale or Sharing of Personal Information

CTCA has not sold or shared your Personal Information that CTCA has collected from you in the preceding twelve (12) months.

Ⅴ. Retention Period

CTCA retains your Personal Information to the extent necessary for the purposes described in the Section II (Use of Personal Information). The criteria used to determine our retention period include, but are not limited to: (i) the duration of the contractual relationship with you; (ii) whether there is any legal obligation to which CTCA is subject; and (iii) whether there is a need to perform a contract to which you are a party.

Ⅵ. Your Rights and Choices under the Applicable Law

Depending on your jurisdiction, in accordance with applicable law, you may have several rights on our processing of your Personal Information, which may include, to request access to, correction, or deletion of your Personal Information. They may also include the ability to opt-out of receiving notifications, promotions, offers or other advertising from CTCA.

If you are a California resident, the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, (the “CCPA”) provides consumers who are residents of California with specific rights regarding Personal Information. The following of this Section describes your CCPA rights and explains how to exercise those rights.

（1）Right to Access Specific Information

You have the right to request that CTCA discloses certain information to you about CTCA’s collection, sharing, disclosure or use of your Personal Information over the past twelve (12) months from the time of your request. Once CTCA receives and confirms your verifiable consumer request, CTCA will disclose to you any or all of the following information:

• The categories of Personal Information CTCA collected about you;

• The categories of sources for Personal Information CTCA collected about you;

• CTCA’s business or commercial purpose for collecting, selling or sharing Personal Information;

• The categories of third parties to whom CTCA discloses, shares or sells Personal Information;

• The categories of Personal Information that CTCA sold or shared about you and the categories of third parties to whom Personal Information was sold or shared, by category or categories of Personal Information for each category of third parties to whom Personal Information was sold or shared;

• The categories of Personal Information that CTCA disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose; and

• The specific pieces of Personal Information CTCA collected about you.

Please note that CTCA has not sold or shared any Personal Information in the preceding twelve (12) months.

（2）Right to Request Deletion

You have the right to request that CTCA deletes any of your Personal Information that CTCA collected from you and retained, subject to certain exceptions. Once CTCA receives and confirms your verifiable consumer request, CTCA will delete (and notify our service providers or contractors and third parties to whom CTCA has sold or shared such Personal Information to delete) your Personal Information from our records, unless an exception applies.

CTCA may deny your deletion request if retaining Personal Information is necessary for us or our service providers 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 CTCA’s ongoing business relationship with you, or otherwise perform CTCA’s 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 that conforms or adheres to all other applicable ethics and privacy laws, when CTCA’s deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if you have provided informed consent;

• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with CTCA and compatible with the context in which you provided the information; or

• Comply with legal obligations.

（3）Right to Request Correction

You have the right to request that CTCA corrects any of your inaccurate Personal Information that CTCA collected from you and retained, subject to certain exceptions. Once CTCA receives and confirms your verifiable consumer request, CTCA will correct (and notify our service providers or contractors and third parties to whom CTCA has sold or shared such Personal Information to correct) your inaccurate Personal Information. CTCA may deny your correction request if we determine that the contested Personal Information is more likely than not accurate based on the totality of the circumstances.

（4）Right to Opt-Out of Sale or Sharing

CTCA has not sold or shared and will not sell or share your Personal Information that CTCA has collected from you.

（5）Non-Discrimination

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

• Deny you goods or services;

• 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.

（6）Exercising Access, Deletion and Correction Rights

To exercise the access, deletion and collection rights described above, please submit a verifiable consumer request to us by contacting us in the manner set forth in Section VIII (Contact Us).

Only you, or 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 power of attorney or is acting as a conservator for you, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom CTCA collected Personal Information or an authorized representative (e.g. Passport or ID); and

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

Ⅶ. Review

CTCA will review and improve the contents of the above items regarding the handling of your Personal Information as appropriate. When changes are made to this Policy, an update notice will be posted on the website and will be effective as of the date posted.

Ⅷ. Contact Us

If you have any questions or comments about this Policy, the ways in which CTCA collects and uses your information described above, or wish to exercise your rights described in the Section VI (Your Rights and Choices under the Applicable Law), please do not hesitate to contact us at:

• compliance@ctc-america.com

Privacy Policy Last Updated and Effective: March 22, 2023