ADDENDUM FOR CALIFORNIA CONSUMERS
Enactment Date: November 21, 2019
Last Updated Date: January 8, 2020
Changes to this California Addendum
We reserve the right to amend this California Addendum at our discretion and at any time. When we make changes to this California Addendum, we will post the updated notice on the website and update the notice’s effective date. Your continued use of our website, products or services following the posting of changes constitutes your acceptance of such changes. If we need to obtain explicit consent from you under the CCPA, we will contact you in a reasonable manner.
California Personal Information We Collect
We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“California Personal Information”). We have collected the following California Personal Information within the last 12 months.
||A real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
||Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
|C. Protected classification characteristics under California or federal law.
||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
|D. Commercial information.
||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
|E. Biometric information.
||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
|F. Internet or other similar network activity.
||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
|G. Geolocation data.
||Physical location or movements.
|H. Sensory data.
||Audio, electronic, visual, thermal, olfactory, or similar information.
|I. Professional or employment-related information.
||Current or past job history or performance evaluations.
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
|K. Inferences drawn from other personal information.
||Profiles reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
For each of these categories, we obtain California Personal Information from the following sources.
- Category A: Identifiers.
- Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
- Category C: Protected classification characteristics under California or federal law.
- Category D: Commercial information.
- Category H: Sensory data.
Source: Yourself; Your browsers and/or devices; Third party service providers
- Category F: Internet or other similar network activity.
- Category K: Inferences drawn from other personal information.
Source: Educational institution
- Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Please note California Personal Information does not include publicly available information from government records, deidentified or aggregate consumer information, and personal information protected by certain other sector-specific federal or California statutes.
Our Use of California Personal Information
- 1.Audits and reporting relating to particular transactions and interactions, including online interactions, you may have with us or others on our behalf;
- 2.Detecting and protecting against security incidents, and malicious, deceptive, fraudulent or illegal activity, and prosecuting the same;
- 3.Debugging to identify and repair errors in our systems;
- 4.Short-term, transient use including contextual customization of ads;
- 5.Providing services on our behalf or on behalf of another, including maintaining or servicing accounts, providing customer service, fulfilling transactions, verifying identity information, processing payments, and other services;
- 6.Conducting internal research to develop and demonstrate technology;
- 7.Conducting activity to verify, enhance, and maintain the quality or safety of services or devices which we may own, control, or provide;
- 8.Administering examinations, performing business operations, and providing notices of results to exam-takers;
- 9.Providing information required for entrance examinations to higher education institutions such as universities;
- 10.Preparing statistics and performing analysis to support our operations;
- 11.Providing examination-takers with information on our educational products and services;
- 12.Conducting marketing and surveys regarding our examinations;
- 13.receiving and responding to inquiries;
- 14.Providing educational materials related to our examinations; and
- 15.Providing information on our business and seminars related to English education.
Sharing of California Personal Information
A. Disclosure of California Personal Information for Business Purposes
Within the last 12 months, we have disclosed California Personal Information identified in the above categories A, B, C, D, F, H, J and K for our business purposes. The categories of third parties with whom we shared information are as follows.
- Educational institutions;
- Educational institutions to which examination takers belong;
- Service providers including third-party data analytics providers; and
- Shipping and processing companies.
When we disclose California Personal Information for a business purpose, we execute a contract that describes the purpose and requires the recipient to keep California Personal Information confidential and not use it for any purpose except performing the contract.
For example, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”), to help us collect information about how you access our online services, which pages you access, and what other sites or services you use. We use the information provided by Google Analytics to improve our services and enhance your experience with us. Although we contractually restrict Google’s use of California Personal Information, you may visit: https://policies.google.com/technologies/partner-sites to learn more about how Google collects, uses and shares your information. We understand that Google provides you with additional choices on how your information is collected by Google Analytics. Please see more information about Google’s “Opt-out Browser Add-on” tool by visiting: https://tools.google.com/dlpage/gaoptout.
B. Sale of California Personal Information
Within the last 12 months, within the meaning of the CCPA, we have not sold any California Personal Information identified in categories A, B, C, D, F, H, J or K above.
California Rights and Choices
You have certain rights related to your California Personal Information. You may exercise these rights free of charge except as otherwise provided by applicable law. We endeavor to respond to your request promptly upon verification and as required by applicable law.
A. Right to Know/Portability
You have the right to request that we disclose to you:
- the categories of California Personal Information we have collected about you;
- the categories of sources from which the California Personal Information is collected;
- our business or commercial purpose for collecting or selling California Personal Information;
- the categories of third parties with whom we share California Personal Information; and
- the specific pieces of information we have collected about you.
- To the extent that we sell your California Personal Information within the meaning of the CCPA or disclose such information for a business purpose, you may request that we disclose to you:
- the categories of California Personal Information that we have collected about you;
- the categories of California Personal Information about you that we have sold within the meaning of the CCPA and the categories of third parties to whom the California Personal Information was sold, by category or categories of personal information for each third party to whom the California Personal Information was sold; and
- the categories of California Personal Information about you that we disclosed for a business purpose.
B. Right to Delete
You have the right to request that we delete California Personal Information about you which we have collected from you. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) 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 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;
- 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 a legal obligation; or
- make other internal and lawful uses of that information that are compatible with the context in which you provided it.
C. How to Submit a Request
You may submit a request to exercise these rights by filling out a form available on the following :
toll free: (833) 345-3652
D. Verifiable Request
As required under applicable law, we take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may require you to provide information sufficient to allow us to reasonably verify you are the person about whom we collected personal information or an authorized representative. We may limit our response to your exercise of the above rights as permitted under applicable law.
E. Agent Authorization and Disability Access
You may designate an authorized agent to make a request on your behalf. As permitted by law, we may require additional verification in response to a request even if you choose to use an agent.
You may also make a verifiable consumer request on behalf of your minor child.
F. Right to Opt Out and Right to Opt In
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt in to personal information sales may opt out of future sales at any time.
Please note we do not sell California Personal Information regardless of your age.
Nondiscrimination and Financial Incentives
We will not discriminate against you because of your exercise of any of the above rights, or any other rights under the CCPA, including by:
- denying you goods or services;
- charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
- providing you a different level or quality of goods or services; or
- suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Other California Privacy Rights
A. Status of “Do Not Track”
At this time, we are not aware of worldwide uniform or consistent industry standard or definition for responding to, processing, or communicating Do Not Track signals. Accordingly, our website is unable to respond to “Do Not Track” requests from browsers.
B. California “Shine the Light” Law (Civil Code Section § 1798.83)
Under the Shine the Light Law, a California resident may ask us to refrain from sharing your personal information with third parties for their marketing purposes. We do not share California Personal Information with third parties for their marketing purposes.
Contact Information Regarding this California Addendum and CCPA
You may contact us with questions or concerns about our privacy policies or practices and your choices and rights under California law at:
Administration Committee for the Protection of Personal Information
c/o Public & Legal Affairs Section
Eiken Foundation of Japan
55 Yokotera-machi Shinjuku
Tokyo, Japan 162-8055