PRIVACY POLICY

Effective May 25, 2018

KDDI America, Inc. has implemented the following Online Privacy Policy. This Privacy Policy (the "Policy") outlines the information KDDI America will collect and how we will use that information. KDDI America has a long-standing tradition of recognizing and protecting the privacy of customers who use its telecommunications networks. KDDI America maintains strict customer information privacy policies and uses the most recent industry standard technologies to safeguard customer information and communications from unauthorized intrusions.

KDDI America is aware that the growth of online services, including Internet services, has created additional privacy concerns, particularly for consumers. Online privacy concerns focus primarily on the protection of "customer identifiable" information which an individual reasonably expects to be kept private. As the term suggests, "customer identifiable" information is information that, when referenced to an individual identifies that individual, such as, a customer's name, address, and e-mail address.

Some Internet users also want to know who can learn about what they do on the Internet, even though their online behavior is not directly linked to any information that identifies an individual. For example, advertisers may observe whether visitors to a website take any kind of action in reply to online advertising without knowing who those visitors are.

Today it is common practice and often a necessity for companies, governments, and other organizations to collect customer identifiable information in order to conduct their business and offer services. For example, a telecommunications provider may collect customer identifiable information, such as name, address, telephone number, and a variety of other information in the course of billing and providing telephone and/or internet services to a customer. Consumers signing up for an Internet access service, for example, are usually asked to provide name, address, telephone number and credit card and other information that is typical when the consumer orders a product or service. Similarly, business web sites may ask visitors to supply information about themselves, particularly when information, services and/or merchandise are requested, but often simply to be able to better target the company's services to the customer's interests and requirements.

How KDDI America Protects Your Privacy Online

Collection and Use: KDDI America does not directly track any visitors who interact with our website(s), via cookies, KDDI America therefore does not respond to Do Not Track (DNT) signals.

Nevertheless, KDDI America’s website(s) may indirectly collect cookies (“session identifiers”), through third-party webmasters, such as Google Analytics, none of which are personal identifiable information. The collection of cookies by such third-party webmasters shall be governed by their respective privacy policies.

KDDI America will collect and use customer identifiable information, only if provided by a customer, for the subscription to a KDDI America online service, for billing purposes, to provide and change services, to anticipate and resolve problems with your services, and/or to create and inform you of products and services that better meet your personal and/or business needs. This means that KDDI America may use your customer identifiable information, in conjunction with information available from other sources, to market new services to you that we think will be of interest to you, but we will not disclose your customer identifiable information to third parties who want to market products to you.

When you revisit our website(s), the cookies allow the site to recognize your browser. Cookies may store user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However some websites features or services may not function properly without cookies.

A detailed explanation regarding Google Analytics’s cookies may be found at:

https://policies.google.com/technologies/cookies

Furthermore, Google Analytics’s collection of cookies is covered by Google’s privacy policy, which may be found at

https://policies.google.com/privacy?hl=en

Disclosure: KDDI America will not use and/or share any cookie related information with any third parties without first obtaining your consent. Furthermore, KDDI America will not sell, trade, or disclose to third parties any customer identifiable information derived from the registration for a KDDI America online service -- including customer names and addresses -- without the consent of the customer.

Notwithstanding anything contained herein to the contrary, KDDI America may at times be requested to disclose your customer identifiable information, without obtaining your consent and/or without informing you of the disclosure, pursuant to court orders, laws, statutes, subpoenas, and other related reasons.

Marketing Practice: From time to time a customer may receive direct marketing communications from KDDI America in connection with KDDI America services. KDDI America(a) may contact the customer directly with marketing messages about KDDI America services, and (b) may use customer identifiable information obtained from that customer's registration for or use of an online and/or any other services to contact that customer with marketing messages about any other KDDI America products or services. A customer may receive such messages by e-mail, by mail, or by telephone. Customer-identifiable information which a visitor volunteers at one of the KDDI America Websites to order any KDDI America services will be protected just as if the information had been provided under more traditional ways of ordering that service.

Security: KDDI America has implemented technology and security features and strict policy guidelines to safeguard the privacy of your customer identifiable information from unauthorized access or improper use, and we will continue to enhance our security procedures as new technology becomes available.

E-mail Contents: KDDI America will not read or disclose to third parties private e-mail communications that are transmitted using KDDI America services except as required to operate the service or as otherwise authorized by law.

Improper Conduct: KDDI America may also use customer identifiable information to investigate and help prevent potentially unlawful activity or activity that threatens KDDI America's network or otherwise violates the customer agreement for that service.

Account Information: KDDI America shall honor requests from customers to review all customer identifiable information maintained, which currently consists of your name, address, e-mail address, telephone number and/or billing information, and will pursuant to the customer's request correct any such information which may be inaccurate.

Customer Concerns: If you have submitted personally identifiable information through a KDDI America Website or via other means, and would like that information updated and/or deleted from our records or require additional assistance, please contact us at our email address privacy@kddia.com. We will use reasonable efforts to update and/or delete this information from our existing files and to assist you in any other manner.

Changes to the Policy

We may change this Policy from time to time. The most recent version of the Policy will always be posted on the KDDI America Website, with the "Effective Date" posted at the top of the Policy. We may revise and update this Policy if our practices change, as technology changes, or as we add new services or change existing ones. If we make any material changes to our Policy or how we handle your personal information, or we are going to use any personal information in a manner that is materially different from that stated in our Policy at the time we collected such information, we will give you a reasonable opportunity to consent to the change. If you do not consent, your personal information will be used as agreed to under the terms of the privacy policy in effect at the time we obtained that information. By using our website or services after the Effective Date, you are deemed to consent to our then-current privacy policy. We will use information previously obtained in accordance with the Policy in effect when the information was obtained from you.

Additional Privacy Protections for Children Using the Internet

KDDI America recognizes that children, including young teens, may not be able to make informed choices about personal information requested online. Accordingly, KDDI America does not target children or teenagers (younger than eighteen years of age) for collection of information online. KDDI America does not solicit or collect customer identifiable information targeted at children and teenagers under eighteen and does not allow anyone else to do so on a KDDI America Website.

If a child has provided us with personally-identifiable information without the consent of a parent or guardian, a parent or guardian of that child should contact us immediately. We will use reasonable efforts to delete the child's information from our existing files.

Finally, KDDI America complies with all federal laws and regulations, including the Children's Online Privacy Protection Act ("COPPA"), which requires the consent of a parent or guardian for the collection of personally identifiable information from children under 13. You may learn more about COPPA by visiting http://www.ftc.gov/ogc/coppa1.htm

Additional Privacy Protections for European Economic Area Residents

If you reside in a country in the European Economic Area (EEA) and/or you are a citizen of the EEA (residing in the U.S.), then under the General Data Protection Regulation (the “GDPR”) and applicable data protection laws and regulations you have the rights, among other things, to access your personal data, have us erase it, and/or restrict its further processing. If you wish to access or delete your personal data (if any) maintained by KDDI America related to advertising on the KDDI America Website, you can contact us at our email address privacy@kddia.com

You also have the rights under GDPR, among others, to:

(i)access your personal data
(ii)ensure the accuracy of your personal data
(iii)the right to have us delete your personal data
(iv)the right to restrict further processing of your personal data, and
(v)the right to complain to a supervisory authority in your country of residence in the event that data is misused. If you believe that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your residence, your place of work or the place of the alleged infringement.

Privacy Policy for California Residents

This Privacy Policy for California Residents conforms to the California Consumer Privacy Act of 2018 (the “CCPA”) and forms part of our Privacy Policy. It applies to the handling of personal information of our consumers who are residents of California (“consumers” or “you”).

1. Information We Collect

We collect 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”). In particular, we have collected the following categories of personal information from our consumers within the last twelve (12) months and will continue to collect the following categories of personal information:

Category	Examples
A. Identifiers.	Real name, postal code, unique personal identifier, Internet Protocol address, email address, and other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Name, address, and telephone number.
C. Internet or other similar network activity.	Browsing history, search history, and any other information on a consumer’s interaction with a website, application, or advertisement.

We obtain the categories of personal information listed above from the sources indicated below:

Directly from you: Categories A through C
Indirectly from you. For example, from our affiliated companies, partners, or organizations to which our consumers belong: Categories A and B

2. Use of Personal Information

We may use the categories of personal information listed above for one or more of the following business purposes indicated below:

For communicating with business partners and customers in business negotiations, contract negotiations, etc.: Categories A and B
For communicating with business partners and customers for direct advertising or other forms of marketing or advertising: Categories A and B
For providing various services to customers: Categories A and B
For improving the convenience of our website: Category C
- * For more information, please refer to the following link to our cookie policy.

We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you prior notice thereof.

3. Sharing or Disclosure of Personal Information

We may share or disclose your personal information to a third party for business purposes or commercial purposes. When we disclose personal information to service providers for business purposes or commercial purposes, we enter into a contract that describes such purposes and requires the service providers 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, we have shared or disclosed the following categories of personal information listed above to the following categories of third parties for business purposes or commercial purposes:

Affiliates, business partners, and service providers including a company involved in the telecommunications business and a company providing digital marketing service: Categories A and B
Adverting distributors, and service providers including a company operating our website: Category C

4. Sales of Personal Information

We have not sold any personal information in the preceding twelve (12) months, and we will not sell any personal information without first obtaining your prior written consent thereto.

5. Your Rights and Choices under the CCPA

The CCPA provides consumers (California residents) with specific rights regarding personal information. This Section 5 describes your CCPA rights and explains how to exercise those rights.

(1) Access Right to Specific 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 over the past twelve (12) months from the time of your request. Once we receive and confirm your verifiable consumer request, we will disclose to you within 45 days of receipt of a verifiable consumer request, the following information:

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 purpose for collecting or selling that personal information;
The categories of third parties with whom we share or sell that personal information;
The categories of personal information sold to us, by each third party who sold us personal information;
The categories of personal information disclosed for business purposes or commercial purposes; and
The specific pieces of personal information we collected about you.

Please note that we have not sold any personal information in the preceding twelve (12) months, and we will not sell any personal information without first obtaining your prior written consent thereto.

(2) Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, within 45 days of receipt of a verifiable consumer request, unless an exception applies.

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

Complete the transaction for which we collected the 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;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
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;
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
Comply with legal obligations; or
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

(3) Opt-Out Rights

We have not sold and will not sell any personal information collected from consumers, and we will not sell any personal information without first obtaining your prior written consent thereto.

(4) 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 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; or
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

(5) Exercising Access and Deletion Rights

To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by contacting us in the manner set forth in Section 6 (Contact Us).

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, 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 we collected personal information or an authorized representative (e.g. a copy of your passport, residence certificate, etc.); and
Describe your request with sufficient detail that allows us to properly and accurately understand, evaluate, and respond thereto.

Contact Us

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your information described above, or wish to exercise your CCPA rights, please do not hesitate to contact us at:

KDDI America, Inc. Personal Data Disclosure Consultation Office

Postal Address:: KDDI America, Inc., 7 Teleport Drive, Staten Island, NY 10311
Email:: privacy@kddia.com
Phone:: 1-866-348-3370
(9:00 to 17:00 (EST), except Saturdays, Sundays, public holidays, and New Year holidays)

If you would like to request us to disclose/delete personal information, please download a request form from the below link and fill in necessary information, and send it to the above e-mail address.

Request Form to Disclose/Delete Personal Information based on California Consumer Privacy Act