California Consumer Privacy Act Disclosures
In these California Consumer Privacy Act Disclosures ("CCPA Disclosures"), we disclose information about our data processing practices as required by the
California Consumer Privacy Act of 2018 (“CCPA"). These CCPA Disclosures are effective January 1, 2020. You can download a PDF version here

I. Who and what information is subject to these CCPA Disclosures?
California residents are protected as "consumers" by the California Consumer Privacy Act of 2018 (“CCPA”) with respect to personal information.
A number of statutory exceptions apply under the CCPA and to these CCPA Disclosures, including the following:(1) personal information reflecting a written or verbal communication or a transaction between a business and a consumer, where the consumer is anatural person who is acting as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, non-profit, orgovernment agency and whose communications or transaction with the business occur solely within the context of the business conducting due diligence
regarding, or providing or receiving a product or service to or from such company, partnership, sole proprietorship, non-profit, or government agency;(2) personal information that is collected by a business about a natural person in the course of the natural person acting as a job applicant to, an employeeof, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the natural person’s personal informationis collected and used by the business solely within the context of the natural person’s role or former role as a job applicant to, an employee of, ownerof, director of, officer of, medical staff member of, or a contractor of that business;(3) personal information that is collected by a business that is emergency contact information of the natural person acting as a job applicant to, an
employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the personal information iscollected and used solely within the context of having an emergency contact on file;(4) personal information that is necessary for the business to retain to administer benefits for another natural person relating to the natural person acting
as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that thepersonal information is collected and used solely within the context of administering those benefits.

II. How can a consumer with a disability access these CCPA Disclosures?
Consumers who have a visual disability may be able to use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of this notice.

III. CCPA Notice at Collection Online
In this CCPA Notice at Collection Online, we are addressing disclosure requirements under California Civil Code §1798.100(b) at or before the point of online
collection:
We collect the following categories of personal information about consumers:

A. Order Placement and Fulfillment: If you place an order online or contact us online regarding its fulfillment, we collect personal information(such as first and last name, e-mail address, mailing address, billing address, phone number, credit card information, username, password andinformation on your particular order) in order to receive, process, confirm and fulfill your order. For this purpose we may particularly verify youridentity and delivery address and process or collect payments from you.
B. Customer Support: If you request information or support in connection with our products or services, we collect personal information (such as
first and last name, e-mail address, mailing address, billing address, phone number, credit card information, username, password, and information
on your particular request) in order to respond to your customer service request and provide information or support to you.
C. Operation of Our Online Services: We collect personal information (such as the items in your shopping cart and(such as first and last name, email address, mailing address, billing address, phone number, credit card information, username, password and information on your particularorder) in order to operate, and enable you to use, our online services and technologies.
D. Promotions: We collect personal information (such as first and last name and email address and other) in order to communicate with you andsend you information regarding our products and services or our company.
E. Contests and Surveys: If you participate in contests or surveys, we collect personal information (such as first and last name, email address,
mailing address, phone number, user name, password, and your submissions, contributions or responses to the particular contest or survey) in orderto enroll you in the contest or survey, manage your participation and, where applicable, communicate with you on the results.
F. Product Development: We collect personal information (such as first and last name, e-mail address, mailing address, billing address, phone
number, credit card information, username, password and information on your particular order) in order to develop new products and services.
G. Legal Matters: We collect personal information (such as first and last name, e-mail address, mailing address, billing address, phone number,credit card information, username, password and information on your particular order) in order to comply with a law, regulation or legal requests,
facilitate and engage in dispute resolution, enforce our agreements and terms and conditions, and protect our rights and property.
H. Security and Fraud Protection: We collect personal information (such as first and last name, e-mail address, mailing address, billing address,
phone number, credit card information, username, password and information on your particular order) to prevent, detect, mitigate, and investigate
fraud, security breaches and prohibited or illegal activities, protect the security of individuals, and address other security issues.
I. Browsing Activity: We collect personal information that your browser or device sends to us in connection with your access to our website (suchas IP address, MAC address, computer type, domain name, and session length). We also collect personal information about your use of our website(such as the pages you are visiting, products and services you are looking at, clickstream data, and (such as first and last name, e-mail address,
mailing address, billing address, phone number, credit card information, username, password and information on your particular order). We use
this information in order to understand your preferences based on previous or current website activity, enhance and personalize your website
experience, deliver the type of content and product offerings you are most interested in, learn more about shopping preferences and market trends,
and to compile aggregate data about website traffic and website interaction in order to offer better website experiences and tools in the future.
J. Reorganization or Sale: Personal information collected from you (such as first and last name, e-mail address, mailing address, billing address,
phone number, credit card information, username, password and information on your particular order) may be disclosed or otherwise processed asnecessary where we are involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets.
Our online CCPA Privacy Policy can be found here:1IV. CCPA Privacy Policy
Beyond the disclosures in the preceding "Notice At Collection Online" segment, we are providing additional disclosures about consumer rights and our personal
information handling practices in the preceding twelve months, as required by the CCPA.
1.

Right to Know About Personal Information Collected, Disclosed, or Sold

This CCPA Privacy Policy describes the personal information we generally collect, use, and disclose about California residents. You have the right to requestthat we disclose what personal information we collect, use, disclose and sell about you specifically (“right to know”). To submit a request to exercise the rightto know, please visit https://ninjawifi.com/en/inquiry, call our toll-free phone number +81-50-5533-8264 or submit an email request to info@ninjawifi.com
and include “California Request to Know” in the subject line. Please specify in your request the details you would like to know, including any specific piecesof personal information you would like to access.
We will ask that you provide certain information to verify your identity, such as a code sent to an email address we may have on file for you. If you have apassword-protected account with us, we may verify your identity through our existing authentication practices for your account. The information that we ask
you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. We will respond to
your request in accordance with the CCPA. If we deny requests, we will explain why.
2.

Our Personal Information Handling Practices in 2019

We have set out below the categories of personal information we have collected about California residents in the preceding 12 months and, for each categoryof personal information collected, the categories of sources from which that information was collected, the business or commercial purposes for which theinformation was collected, and the categories of third parties with whom we shared the personal information.
Category of personal information

We collected such personal
information to use for thefollowing business orcommercial purposes:

We have collected such
We shared such personal
personal information from information with thethe following categories of following categories of third
parties:sources:

Identifiers such as a real name, alias,
To receive, process, confirm and From the California resident
postal address, unique personal identifier, fulfill orders; to respond toonline identifier, Internet Protocol
customer service requests andaddress, email address, account name,provide support; to operate andsocial security number, driver’s licenseprovide our online services; tonumber, passport number, or other similar send promotional
communications; to organize
identifiers.
and carry out contests andsurveys; for compliance withlegal obligations; to resolve
disputes and enforce
agreements; for security
purposes; and to understandwebsite usage, provide a morecustomized web experience, andimprove the content of our
website.

Cloud hosting and internet
service providers, government
entities, operating systems andplatforms

Any categories of personal information
To receive, process, confirm and From the California resident
described in subdivision (e) of Section
fulfill orders; to respond to1798.80: “Personal information” means customer service requests andany information that identifies, relates to, provide support; to send
describes, or is capable of being
promotional communications; toassociated with, a particular individual,organize and carry out contests
including, but not limited to, his or her
and surveys; for compliancename, signature, social security number, with legal obligations; and tophysical characteristics or description,
resolve disputes and enforce
address, telephone number, passport
agreements.
number, driver’s license or state
identification card number, insurance
policy number, education, employment,
employment history, bank accountnumber, credit card number, debit card
number, or any other financial
information, medical information, or
health insurance information. “Personal
information” does not include publicly
available information that is lawfully
made available to the general public fromfederal, state, or local government
records."

Cloud hosting and internet
service providers, government
entities, operating systems andplatforms]

Characteristics of protected classifications N/A (subject to statutory
under California or federal law, including exceptions described inage (40 years or older), race, color,
Section I above)
ancestry, national origin, citizenship,
religion or creed, marital status, medical
condition, physical or mental disability,sex (including gender, gender identity,
gender expression, pregnancy orchildbirth and related medical conditions),
sexual orientation, veteran or military
status, genetic information (including

N/A (subject to statutory
exceptions described in
Section I above)

N/A (subject to statutory
exceptions described in
Section I above)2

familial genetic information).
Commercial information, including
records of personal property, products orservices purchased, obtained, orconsidered, or other purchasing or
consuming histories or tendencies.

To receive, process, confirm and From the California resident Cloud hosting and internet
fulfill orders; to respond toservice providers, government
customer service requests andentities, operating systems andprovide support; to send
platforms]
promotional communications; toorganize and carry out contests
and surveys; to resolve disputes
and enforce agreements; forsecurity purposes; and tounderstand website usage,
provide a more customized web
experience, and improve thecontent of our website.

Biometric information.

N/AInternet or other electronic network
activity information, including, but notlimited to, browsing history, searchhistory, and information regarding a
consumer’s interaction with an Internet
Web site, application, or advertisement.

To operate and provide our
From the California resident
online services; for security
purposes; and to understandwebsite usage, provide a morecustomized web experience, andimprove the content of our
website.

Cloud hosting and internet
service providers, government
entities, operating systems andplatforms]

Geolocation data.

N/A

N/A

N/A

Audio, electronic, visual, thermal,
olfactory, or similar information.

N/A

N/A

N/A

Professional or employment-related
information.

N/A (subject to statutory
exceptions described in
Section I above)

N/A (subject to statutory
exceptions described in
Section I above)

N/A (subject to statutory
exceptions described in
Section I above)

Education information, defined as
N/A (subject to statutory
information that is not publicly available exceptions described inpersonally identifiable information as
Section I above)
defined in the Family Educational Rights
and Privacy Act (20 U.S.C. section
1232g, 34 C.F.R. Part 99).

N/A (subject to statutory
exceptions described in
Section I above)

N/A (subject to statutory
exceptions described in
Section I above)

Inferences drawn from any of theinformation identified above to create aprofile about a consumer reflecting theconsumer’s preferences, characteristics,
psychological trends, predispositions,behavior, attitudes, intelligence, abilities,
and aptitudes.

3.

N/A

To send promotional
Based on personalcommunications; to organize
information collected fromand carry out contests andthe categories of sources
surveys; and to understanddescribed above.
website usage, provide a morecustomized web experience, andimprove the content and of thewebsite.

N/A

Cloud hosting and internet
service providers, government
entities, operating systems andplatforms]

Disclosures of Personal Information, No Sale

Over the preceding 12 months, we disclosed certain categories of California residents’ personal information to the categories of third parties as shown in thetable above.
We have not sold California residents’ personal information over the preceding 12 months and will not do so. We have not and will not sell the personal
information of minors under 16 years of age without affirmative authorization.
4.

Right to Request Deletion of Personal Information

You have a right to request the deletion of personal information that we collect or maintain about you. To submit a request to delete personal information, please
visit https://ninjawifi.com/en/inquiry or submit an email request to info@ninjawifi.com and include “California Request to Delete” in the subject line. Please
specify in your request the personal information about you that you would like to have deleted, which can be all of your personal information as required by theCCPA.
We will ask that you provide certain information to verify your identity, such as a code sent to an email address we may have on file for you. If you have apassword-protected account with us, we may verify your identity through our existing authentication practices for your account. The information that we ask
you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. Once we haveverified your identity, we will ask you to confirm that you wish to have your personal information deleted. Once confirmed, we will respond to your request inaccordance with the CCPA. If we deny your request, we will explain why.
5.

Right to Opt-Out of the Sale of Personal Information

You have the right to opt-out of the sale of your personal information by a business. We do not and will not sell your personal information.
6.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

You may not be discriminated against because you exercise any of your rights under the CCPA in violation of Cal. Civ. Code §1798.125.
7.

Authorized AgentYou can designate an authorized agent to make a request under the CCPA on your behalf if:••

The authorized agent is a natural person or a business entity registered with the Secretary of State of California; andYou sign a written declaration that you authorize the authorized agent to act on your behalf.

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If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please have the authorized agent take thefollowing steps in addition to the steps described in Sections 2 and 3 above:••

Mail your written declaration authorizing the authorized agent to act on your behalf, certified by a California notary public, to info@ninjawifi.com andProvide any information we request in our response to your email to verify your identity. The information that we ask you to provide to verify youridentity will depend on your prior interactions with us and the sensitivity of the personal information at issue.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps andwe will respond to any request from such authorized agent in accordance with the CCPA.
8.

Contact for More Information

If you have questions or concerns regarding our privacy policy or practices, you may contact us using the following details:
Email address: info@ninjawifi.com
Postal address: 8F SHINJUKU EASTSIDE SQUARE, 6-27-30 Shinjuku, Shinjuku-ku, Tokyo 160-0022, Japan
Date this CCPA Privacy Policy was last updated: December 19, 2022.

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