CALIFORNIA PRIVACY RIGHTS
The California Consumer Privacy Act or “CCPA”, the California Privacy Rights Act of 2020 or “CPRA” (Cal. Civ. Code § 1798.100 et seq.), and the Shine the Light law (Cal. Civ. Code § 1798.83) afford consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you. This section of the Privacy Statement applies to information collected online and offline through or in connection with our Site, mobile applications, or other Services.
California Consumer Privacy Act
In the preceding 12 months, we have collected the categories of personal information set forth in the table below. For details about the precise data points we collect and the categories of sources of such collection, please see the Collection of Information section above. We collect personal information for the business and commercial purposes described in the Use of Information section above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:
| Category of Personal Information | Examples | Collected | Disclosed for a business purpose within the past 12 months? | Sold or Shared with Third Parties within the past 12 months? | Categories of Recipients |
|---|---|---|---|---|---|
| Identifiers | Name, alias, address, email address, IP address, account name, unique device ID, etc. | Yes | Yes | Yes | Affiliates. Vendors and service providers such as web hosting, information technology, customer service, cloud service, social networks, marketing and advertising. Third parties, such as payment processor, and analytics and advertising providers. Other companies, applications, individual at you request. |
| Personal Information listed in California Customer Records Statute (Cal. Civ. Code §1798.80(e))
Note: Some personal information included in this category may overlap with other categories |
Name, signature, physical characteristics or description, address, telephone number, state ID number, financial information, medical information, and health insurance information. etc. | Yes | Yes | Yes | Affiliates. Vendors and service providers such as web hosting, information technology, customer service, cloud service, social networks, marketing and advertising. Third parties, such as payment processor, and analytics and advertising providers. Other companies, applications, individual at you request. |
| Protected classifications characteristics | Gender, age, marital status, etc. | Yes | Yes | Yes | Affiliates. Vendors and service providers such as web hosting, information technology, customer service, cloud service, and marketing and advertising. Third parties, such as payment processor. |
| Commercial information | Information about Services purchased, obtained, or considered | Yes | Yes | Yes | Affiliates. Vendors and service providers such as web hosting, information technology, customer service, cloud service. Third parties, such as payment processor. |
| Biometric information | Medication, Blood pressure, electrocardiogram information, and weight from our mobile application | Yes | Yes | No | Affiliates. Vendors and service providers such as web hosting, information technology, customer service, cloud service. Other companies, applications, individual at you request. |
| Internet or other similar network, browsing, or search activity | Domain information, browsing activity, session information, cookie information | Yes | Yes | Yes | Affiliates. Vendors and service providers such as web hosting, information technology, customer service, cloud service, social networks, marketing and advertising. Third parties, such as payment processor, and analytics and advertising providers. Other companies, applications, individual at you request. |
| Geolocation information | Physical location or movements | Yes | Yes | Yes | Affiliates. Vendors and service providers such as web hosting, information technology, customer service, cloud service, social networks, marketing and advertising. Third parties, such as payment processor, and analytics and advertising providers. Other companies, applications, individual at you request. |
| Sensory information | Audio, electronic, visual, thermal, olfactory, photo or images of an individual, or similar information | Yes | Yes | No | Affiliates. Vendors and service providers such as web hosting, information technology, customer service, cloud service. |
| Professional or employment-related information | Current or past job history or performance evaluations | No | No | No | Not applicable |
| Non-publicly available educational information under the Family Educational Rights and Privacy act (FERPA) and related regulations | Education records directly related to a student maintained by an educational intuition or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records | No | No | No | Not applicable |
| Inferences drawn from other personal information to create consumer profiles | Characteristics, interests, and trends | Yes | Yes | Yes | Affiliates. Vendors and service providers such as web hosting, information technology, customer service, cloud service, social networks, marketing and advertising. Third parties, such as payment processor, and analytics and advertising providers. |
California Privacy Rights Act
CPRA has required us to disclose the collection of your sensitive personal information. In the preceding 12 months, we have collected the following categories of sensitive personal information set forth below and we have disclosed the following categories of sensitive personal information for business purposes to the following categories of recipients.
| Category of Sensitive Personal Information | Examples | Collected | Disclosed for a business purpose within the past 12 months? | Sold or Shared with Third Parties within the past 12 months? | Categories of Recipients |
|---|---|---|---|---|---|
| Government Identifiers | Social security, driver’s license, state identification card, or passport number | No | No | No | N/A |
| Complete account access credentials | User names, account numbers, or card numbers combined with required access/security code or password | No | No | No | N/A |
| Precise geolocation | Physical location or movements | Yes | Yes | Yes | Affiliates. Vendors and service providers such as web hosting, information technology, customer service, cloud service, social networks, marketing and advertising. Third parties, such as payment processor, and analytics and advertising providers. |
| Racial or ethnic origin | – | Yes | Yes | No | N/A |
| Religious or philosophical beliefs | – | No | No | No | N/A |
| Union membership | – | No | No | No | N/A |
| Genetic data | – | No | No | No | N/A |
| Mail, email, or text message contents | The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication | No | No | No | N/A |
| Unique identifying biometric information | – | No | No | No | N/A |
| Medical information | Health information (such as EKG readings, medication data, sleep data, health related information, sex lift, or sexual orientation information) | Yes | Yes | No | Affiliates. Vendors and service providers such as web hosting, information technology, customer service, cloud service. |
Under CCPA and CPRA, personal information does not include:
- Publicly available information from government records
- De-identified or aggregated consumer information
- Information excluded from the CCPA’s scope, such as:
- 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
- Personal information covered by certain sector-specific privacy law, 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
Do Not Sell or Share My Personal Information
We do not sell or share your personal information or sensitive personal information for money but we engage third parties to provide the payment processing and advertising and analytics services to us. In the case of payment processing, we share your personal information and your sensitive personal information with our payment processor to complete payment processing for any orders placed on our website, such sharing is considered as a “sale” or “sharing” of personal information under the CCPA and CPRA.
For advertising and analytics, we and our business partners use tracking technologies to help us to understand our customers and visitors to the Services, to enhance your online experience, and to customize our offerings in ways that may be deemed a “sale” or “sharing” of personal information and sensitive personal information under the CCPA and CPRA. This includes working with third parties such as ad networks that collect personal information via tracking technologies to personalize advertisements on and off our Services and to provide us with data collection, reporting, and ad response measurement. To the extent we or our partners use such technologies on the Services, we offer a “Do Not Sell or Share My Personal Information” button (“Cookie Settings”), as discussed in the Sharing of Information and Advertising and Analytics section above. If you elect to opt out of the sale and sharing of your personal information, then we will notify third parties of your request.
We do not knowingly sell personal information about consumers under the age of 16.
Data Retention
We keep your personal information and communication records for as long as your account is in existence and for so long as necessary to fulfill the purposes for which it was collected and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.
Your Rights under the CCPA and CPRA.
Subject to certain limitations, you have the right to:
- request to know more about the categories and specific pieces of personal information we collect, use, disclose, and sell,
- request deletion of your personal information,
- request to correct inaccuracies of your personal information
- opt out of any “sales” or “sharing” of your personal information that may be occurring,
- limit the use and sharing of sensitive personal information
- opt out of automated decision-making
- request to have your personal information transmitted to another entities (“Data portability”), and
- not be discriminated against for exercising these rights.
The privacy rights request is subject to our being able to reasonably verify your identity and authority to make these requests. In order to verify your identity when you submit a request, we will ask you to provide two (2) or three (3) pieces of personal information to confirm in our records. For example, if you purchased an OMRON product or Service through our Site, you will be asked to provide at least your name and details of your recent interactions with us.
How to Submit a Request Under the CCPA or CPRA
If your Personal Information is subject to the CCPA or CPRA, you may make these requests by calling +1 (888) 557 1189 or completing this Form. You may also authorize someone to exercise these rights on your behalf. In order to do so, we require signed permission. If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with power of attorney or equivalent document that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. We will not discriminate against you if you exercise your rights under the CCPA or CPRA.
If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. Once we have a copy of the valid signed authorization, your designated representative/authorized agent will be able to exercise these rights with respect to the account(s) listed on such authorization for the life of the account, unless there is a specified term or expiration date on the authorization form. Any information gathered as part of the verification process will be used for verification purposes only. Responses to verifiable consumer requests will be delivered through secure email or postal mail, depending on your election when you submit such requests.
Authorized Agents. You may use an authorized agent to submit a rights request. If you do so, the authorized agent must present signed written authorization to act on your behalf, and you will also be required to independently verify your own identity directly with us and confirm with us that you provided the authorized agent permission to submit the rights request. This verification process is not necessary if your authorized agent provides documentation reflecting that the authorized agent has power of attorney to act on your behalf under Cal. Prob. Code §§ 4121 to 413. If you are an authorized agent seeking to make a request, please contact us by phone at +1 (888) 557 1189 or online by completing this Form.
California Shine the Light
California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at +1 (888) 557 1189 or online by completing this Form.
Financial Incentives
We provide price discounts, rewards, services, and other perks for members of our loyalty programs related to certain OMRON Services (collectively “rewards programs”) and members of our emailing list. Through these offerings, consumers like you provide us with some personal information (e.g., names, emails, phone numbers, health and medication information, and information about your daily routine) when you opt in and participate in our rewards programs. There is no obligation to opt in and you, as well as other consumers, may opt out at any time. The details of each rewards program are contained in the applicable offering. Our rewards programs can be found in the “Rewards” section of our mobile applications. We offer these rewards programs, among other things, to enhance our relationship with you so you can enjoy more of our products/services at a lower price. We invest heavily in our marketing and brands, in part, so we can provide rewards programs to our customers. Consumer data is valuable to our business only when it is combined with a sufficient number of other consumer data and after it is enhanced by our efforts described below. The value to our business of any individual consumer’s personal information is dependent on a number of factors, including, for example, whether and to what extent you take advantage of any offerings, whether and to what extent you opt out of any offerings, and whether we are able to enhance the data through our efforts described below. Our ability to create any value from the rewards programs is heavily based on our ability to leverage said intellectual properties. We do not calculate the value of consumer data in our accounting statements. We make this good faith estimate for California residents. To the extent we create overall value from our rewards programs to our business that could be directly or reasonably related to the value of customer data, the method for calculating the same would include: (1) the expenses associated with the offer, provision or imposition of any financial incentive or price or service differences, such as our intellectual property, data analytics, and marketing operations, (2) the expenses related to the collection, retention and enhancement of customer’s personal information, and (3) all other expenses reasonably related to the rewards programs.
You can opt-in to, or opt-out of, our rewards programs at any time through the same means they are offered, or by phone at +1 (888) 557 1189 or online by completing this Form.
Metrics
California law requires us to compile metrics for the previous calendar year regarding consumer requests and responses. Below are certain metrics for requests we received from all individual from California between January 1, 2022 and December 31, 2022.
| Request Type | Number of requests received | Number of requests fulfilled | Number of requests denied (data subject failed to verify his/her identity) | Median number of days to fulfil requests |
|---|---|---|---|---|
| Access request | 86 | 16 | 70 | 34 |
| Deletion request | 33 | 26 | 7 | 29 |
| Do not sell request | 243 | 103 | 140 | 5 |