Privacy Notice for California Residents
Effective Date: May 1st, 2020
Last updated: May 1st, 2022

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information containedin the Privacy Statement of Septeni America, Inc. (“we,” “us,” or “our”) and applies solely to visitors,
users, and others who reside in the State of California (“consumers” or “you”). We adopt thisnotice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California
privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
1. Information We Collect
We collect information that identifies, relates to, describes, references, 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 consumers within the last twelve (12) months:
Category

ExamplesCollected
A real name, alias, postal address, unique personal
identifier, online identifier, Internet Protocol address,
A. Identifiers.
email address, account name, Social Security number, YES
driver's license number, passport number, or othersimilar identifiers.
A name, signature, Social Security number, physicalcharacteristics or description, address, telephone
number, passport number, driver’s license or state
B. Personal information
identification card number, insurance policy number,categories listed in theeducation, employment, employment history, bank
California Customer
YES
account number, credit card number, debit card number,
Records statute (Cal. Civ.
or any other financial information, medical information,
Code § 1798.80(e)).
or health insurance information. Some personal
information included in this category may overlap withother categories.
Age (40 years or older), race, color, ancestry, national
origin, citizenship, religion or creed, marital status,
C. Protected classification medical condition, physical or mental disability, sex
characteristics under(including gender, gender identity, gender expression, NO
California or federal law. pregnancy or childbirth and related medical conditions),
sexual orientation, veteran or military status, genetic
information (including familial genetic information).
Records of personal property, products or services
D. Commercial
purchased, obtained, or considered, or other purchasing NO
information.
or consuming histories or tendencies.
Genetic, physiological, behavioral, and biologicalcharacteristics, or activity patterns used to extract atemplate or other identifier or identifying information,
E. Biometric information.
NOsuch as, fingerprints, faceprints, and voiceprints, iris orretina scans, keystroke, gait, or other physical patterns,
and sleep, health, or exercise data.
Browsing history, search history, information on aF. Internet or other similar
consumer's interaction with a website, application, orYES
network activity.
advertisement.
G. Geolocation data.
Physical location or movements.
YES
Audio, electronic, visual, thermal, olfactory, or similar
H. Sensory data.
NOinformation.

I. Professional oremployment-relatedinformation.

YES(jobapplicants,Current or past job history or performance evaluations.
officers andemployees
only)

J. Non-public education
Education records directly related to a student
information (per themaintained by an educational institution or party acting
Family Educational Rights
on its behalf, such as grades, transcripts, class lists,
NOand Privacy Act (20student schedules, student identification codes, student
U.S.C. Section 1232g, 34
financial information, or student disciplinary records.
C.F.R. Part 99)).
K. Inferences drawn from Profile reflecting a person's preferences, characteristics,
other personal
psychological trends, predispositions, behavior,YESinformation.
attitudes, intelligence, abilities, and aptitudes.
Personal information does not include:(a) Publicly available information from government records.
(b) De-identified or aggregated consumer information.
(c) Information excluded from the CCPA's scope, like:(i) 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;(ii) 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.
We obtain the categories of personal information listed above from the following categories ofsources:(a) Directly from our clients or their agents. For example, from documents that our clients provide
to us related to the services for which they engage us.
(b) Indirectly from our clients or their agents. For example, through information we collect fromour clients in the course of providing services to them.
(c) Directly and indirectly from activity on our website (https://www.septeni.co.jp/sf/).
For example, from website usage details collected automatically.
(d) From third-parties that interact with us in connection with the services we perform. For example,
from data management platform or social media services.
2. Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following
business purposes:(a) To fulfill or meet the reason for which the information is provided. For example, to provide
targeted advertising, process employment application, respond to an inquiry, process yourorder or take and carry out statutory procedures and welfare and other necessary
operations concerning the Company’s officers, employees and job applicants(b) To provide you with information, products or services that you request from us.
(c) 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.
(d) To carry out our obligations and enforce our rights arising from any contracts entered into
between you and us, including for billing and collections.
(e) To improve our website and present its contents to you.
(f) For testing, research, analysis and product development.
(g) As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
(h) To respond to law enforcement requests and as required by applicable law, court order, orgovernmental regulations.
(i) As described to you when collecting your personal information or as otherwise set forth in theCCPA.

(j) To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or othersale 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 held by us is among the assets
transferred.
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 younotice.
3. Sharing 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 into a contract that describes thepurpose and requires the recipient to both keep that personal information confidential and not use
it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal
information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category I: Professional or employment-related information.
In the preceding twelve (12) months, we have disclosed your personal information for a businesspurpose to the following categories of third parties:(a) Our affiliates (only employees and business to business personal information).
(b) Service providers.
In the preceding twelve (12) months, we have not sold any personal information.
4. Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personalinformation. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection anduse of your personal information over the past 12 months. Once we receive and confirm yourverifiable consumer request, we will disclose 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 purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability
request).
If we sold or disclosed your personal information for a business purpose, two separate lists
disclosing:sales, identifying the personal information categories that each category of recipient purchased;
anddisclosures for a business purpose, identifying the personal information categories that eachcategory of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collectedfrom you and retained, subject to certain exceptions. Once we receive and confirm your verifiableconsumer 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 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 orservice 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, orprosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights,
or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 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 onyour relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context inwhich you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit averifiable consumer request to us by either:Calling us at (800) 677-9691
Email: privacy@septeniamerica.com
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.
You may only make a verifiable consumer request for access or data portability twice within a 12month period.
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.
Describe your request with sufficient detail that allows us to properly understand, evaluate, andrespond 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 toyou. Making a verifiable consumer request does not require you to create an account withus. We will only use personal information provided in a verifiable consumer request to verify therequestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If werequire more time (up to 90 days), we will inform you of the reason and extension period inwriting. 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, atyour option. Any disclosures we provide will only cover the 12-month period preceding theverifiable consumer request's receipt. The response we provide will also explain the reasons wecannot comply with a request, if applicable. For data portability requests, we will select a format
to provide your personal information that is readily useable and should allow you to transmit theinformation from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it isexcessive, 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 completingyour request.
5. Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. 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.
Suggest that you may receive a different price or rate for goods or services or a different level orquality of goods or services.
6. Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we
make changes to this privacy notice, we will notify you by email or through a notice on our website
homepage.
7. Contact Information
If you have any questions or comments about this notice, our Privacy Statement, the ways inwhich 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:Phone: (800) 677-9691
Website: https://www.septeni.co.jp/sf/
Email: privacy@septeniamerica.com
Postal Address: 5 Lusk Street, San Francisco, CA 94107