PERSONAL INFORMATION WE COLLECT
We collect personal information about you from a variety of sources. We collect information from you directly (e.g., when you contact us), automatically, (e.g., data collected from cookies), from commercial databases, government records, and from our affiliates and subsidiaries.
Information we collect from you
The categories of information that we may collect directly from you include the following:
Identifiers, such as your name, postal address, telephone number, email address, account name, social security number, passport number, national ID number, and other similar identifiers;
Demographics, such as your gender, age, veteran status, and disability status;
Commercial information, such as products or services purchased, or other purchasing or consumption histories or tendencies;
Biometric information, such as your fingerprints;
Financial, medical, or health insurance information, such as bank or credit card numbers, or insurance policy number;
Pictures, audio, and video, such as photographs for identification, voice recordings of business calls, or information collected via video cameras at our facilities;
Professional information, such as employer, salary, job title, experience, skill, or expertise;
Education information; and
Inferences regarding preferences or other characteristics.
Information we automatically collect about you
Identifiers, such as unique device identifiers, cookie numbers, IP addresses, and other persistent identifiers;
Geolocation data, such as precise location;
Commercial information, such as products or services purchased, content downloaded from our sites, or other purchasing or consumption histories or tendencies; and
Internet or other electronic network activity information, such as information regarding your interaction with any websites, applications, or devices associated with our business.
Information we collect from other sources
We may collect information from other sources. For example:
Identifiers. We collect contact information such as email addresses from marketing vendors.
Commercial information. We collect information on your purchasing history and potential interests from data supplementation services.
Public and Government Record Information. We may collect information about you from public sources, including court records and government agencies.
Biometric Information. We collect biometric information from authentication services.
Demographics, such as your gender, age, or veteran status provided by data supplementation services or government sources;
Professional information, such as employer, salary, or job title from references, recruiters, or employment-related services;
Education information from background check providers; and
Internet or other electronic network activity information. We collect information from third-party cookies on our website.
2. HOW AND WHY WE USE YOUR PERSONAL INFORMATION
We may use your personal information for the following purposes:
Identification and authentication: We use your identifiers to verify your identity and to ensure the security of your personal information;
Operating our business: We process your personal information to provide you with our products or services, to assess your ability to provide us with your products or services, or to conduct due diligence including Know Your Customer/Know Your Shareholder diligence for assessment of business relationships;
Communicating with you: We may use your personal information to communicate with you;
Marketing: We may use your personal information to understand your preferences better and to appropriately personalize our marketing.
Exercising our rights: We may use your personal information to exercise our legal rights where it is necessary to do so, for example to detect, prevent and respond to fraud claims, intellectual property infringement claims or violations of law or our terms and conditions;
Complying with our obligations: We may process your personal information to comply with legal or regulatory requirements, where this is explicitly required by law or regulation, such as in response to court orders, to comply with privacy or financial regulations, or to cooperate with law enforcement, other government entities, or lawful investigations;
Protecting against harm: We may use personal information as we deem necessary to protect the rights and safety of us, you, or others.
We may aggregate or de-identify any information collected about you and we may use that aggregated or de-identified information for any purpose.
3. PERSONAL INFORMATION WE SHARE WITH OTHER PARTIES
Information we disclose
In order to achieve our own business purposes, we may disclose the following categories of personal information:
Public and Government Record information;
Internet or other electronic network activity information;
Financial, medical, or health information;
Pictures, audio, and video;
Education information; and
Inferences drawn from any of the above information categories.
We disclose such information to our service providers, business partners, members of the Marubeni group of companies, and others in the following circumstances:
Service providers and business partners: We engage service providers and business partners to assist us with operating and providing you our services. These service providers or business partners may perform marketing services, help us process orders, support email and messaging services, and analyze information. Some of our service providers or business partners may engage their own service providers or business partners to further assist us. Unless otherwise specified, these companies will only use your personal information in the ways described in this Policy.
Marubeni group companies: MAC has affiliates around the world. Our affiliates work closely with each other to provide you access to our services. We may share your personal information among Marubeni group companies for marketing purposes, security, optimization of products and services, and internal reporting. Unless otherwise specified, Marubeni group companies will only use your information in the ways described in this Policy.
To comply with law or cooperate with reasonable requests: We may share your personal information with law enforcement agencies, courts, other government authorities or other third parties where we believe necessary to comply with a legal or regulatory obligation. We may share personal information as we deem reasonably necessary to support lawful investigations or otherwise to protect our rights or the rights of you or any other party.
In the context of a transaction: We may share your personal information with potential transaction partners, service providers, advisors, and other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell or transfer all or a portion of our assets or business.
Information we sell
We do not sell your personal information to third parties.
4. YOUR RIGHTS OVER YOUR PERSONAL INFORMATION
You may have rights in relation to your personal information under local law. Below is a general description of the rights some consumers may hold. In the event you reside in such a jurisdiction and would like to exercise one of your rights, please contact us at http://www.marubeniamerica.com/contact-us.html or at 1-833-272-8715. When submitting a request, please include your name, relationship to Marubeni (e.g. customer, employee, or website visitor), and your contact information. We will use this information to verify your identity (by comparing it to the records we have on file) and identify responsive records. Please note that we may require additional information from you in order to verify your request, that our standard of verification may vary depending on the nature of the request and sensitivity of the information quested, and we may decline your request as permitted under applicable law. If we decline your request, we will provide an explanation of why.
If you are a California resident, you may also submit a request through an agent authorized by the California Secretary of State. Such requests should be submitted in the same manner as individual requests, described above, and must include information about the agent and documentation of the agent's authority. We may, if permitted by law, require the consumer on whose behalf the agent submits the request to demonstrate the agent's authority, verify their own identity, and confirm that they provided the authorized agent permission to submit the request.
Right to know: Users exercising this right may request information about the personal information that we collect, use, disclose, and sell;
Right to deletion: Users exercising this right can ask us to delete their personal information we have collected;
Right to be free from discrimination: Users may freely exercise these rights without fear of being denied goods or services. We may, however, provide a different level of service or charge a different rate reasonably relating to the value of your personal information;
5. DO NOT TRACK SIGNALS
We do not currently respond to web browser "do not track" signals or other mechanisms that provide a method to opt out of the collection of information across websites or other online services. If we do so in the future, we will describe how we do so in this Policy.
6. CONTACT US
If you have questions about this Policy or our use of your personal information, please contact us at http://www.marubeniamerica.com/contact.html.
7. CHANGES TO THE POLICY
We may modify or update this Policy from time to time. We encourage you to visit this Policy at least once per year to learn about any changes to the way we collect, use, or disclose your personal information. If we make a material change to this Policy, we will take reasonable steps to notify you, as required by applicable law.
Effective Date: August 14, 2020