CALIFORNIA PRIVACY STATEMENT

1. OVERVIEW

This California privacy statement (“Statement”) applies to Denso International America, Inc. (“DENSO,” “we,” “us,” or “our”) and is effective as of the date last updated, above. We strive to deliver outstanding products and services, and value our customers’ business and loyalty. We recognize that privacy is an important issue. We developed this Statement to explain our practices regarding the personal information we collect on this website, through written or verbal communications with us, when purchasing our products through partners, or from other sources.

For California consumers, this Statement supplements and supersedes the practices we have adopted across North America as described in our Privacy Policy, to describe our collection, use, and disclosure of personal information. All defined terms within the California Consumer Privacy Act, including those defined in Cal. Civ. Code § 1798.140, apply for the purposes of interpreting this Statement.

By accessing or using our websites, submitting information to us, or otherwise agreeing to this Statement, e.g. in the context of registering for any of our products or services, you understand and consent to our collection and use of your personal information as described herein.

Please note that this Statement does not apply to our processing of personal information on behalf of and subject to the instructions of third parties [such as] [examples of third parties that would give Company PI for specific and limited purposes, e.g., information processed for RideCell].

2.  YOUR CALIFORNIA PRIVACY RIGHTS

As a California consumer, you have the right to request that we disclose what personal information about you we collect, use, disclose, and sell. More specifically, you have rights to the following without charge:

Disclosure of Personal Information We Collect About You

You have the right to know the categories of personal information we have collected about you, the categories of sources from which we collect personal information, our business or commercial purpose for collecting or selling personal information, the categories of third parties with whom we share personal information, if any, and the specific pieces of personal information we have collected about you.

We will not retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; not reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; and reserve our right not to provide personal information to you more than twice in a 12-month period.

Disclosure of Personal Information Sold or Disclosed for a Business Purpose

In connection with personal information we may sell or disclose for a business purpose, if any, you have the right to know the categories of personal information about you that we sold and the categories of third parties to whom we sold the personal information, and the categories of personal information that we disclosed about you for a business purpose, and the categories of third parties to whom we disclosed personal information.

Deletion of Personal Information

Subject to the exceptions set out below, and upon your submission of a verifiable request, you have the right to deletion of your personal information from our records, and to have us direct our service providers delete your personal information from their records.

We are not required to, and reserve our right not to, delete your personal information it if is necessary to complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; debug to identify and repair errors that impair existing intended functionality; exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; enable solely internal uses that are reasonably aligned with your expectations based on the your relationship with us; comply with an existing legal obligation; and otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Your Right to Opt-Out of the Sale of Personal Information

Under the definition of “sale” provided by California law, we sell personal information that identifies, relates to, describes, is capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household to third parties.

You have the right to opt-out of the sale of your personal information. If you exercise your right to opt-out of the sale of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of you personal information.

To opt-out of the sale of your personal information, click [here].

Children’s Personal Information

We do not sell the personal information of minors under 16 years of age without affirmative authorization.  We do not knowingly collect personal information from individuals under 18 years of age.  Our website is available only to individuals and entities that can form legally binding contracts under applicable law. Without limiting the foregoing, our website and the services offered by our website are not available to minors. If you do not qualify, you may not use v. You warrant that you are eighteen (18) years of age or older to use our website. As a parent or legal guardian, please do not to allow your children to submit personal information without your permission. 

Freedom from Discrimination

You have the right to not be discriminated against by us because you exercised any  of your rights under the California Consumer Privacy Act. This means we cannot on the basis of the exercise of your rights thereunder, among other things, deny goods or services to you, charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to you; or suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

3. PURPOSES FOR WHICH WE COLLECT PERSONAL INFORMATION

We collect your personal information for the following business purposes:

  • Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • Debugging to identify and repair errors that impair existing intended functionality;
  • Short-term, transient use, provided the personal information that is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
  • Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on our behalf;
  • Undertaking internal research for technological development and demonstration; and
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

4. SOURCES FROM WHICH WE COLLECT PERSONAL INFORMATION

We collect personal information from the following categories of sources:

  • You, the consumer.
  • Commercial Customers.
  • Service Providers.
  • DENSO Companies
  • Data analytics providers.
  • Government entities.
  • Consumer data resellers.

5.  PERSONAL INFORMATION WE COLLECT

In conducting every aspect of our business, we may collect personal information. This personal information may include your name; address; email; telephone number; vehicle identification number; license plate number; field test video; GPS data; products or services you purchased or own; other government identification information; marketing and communication preferences; reviews and opinions about us (if they are identified or associated with you); information submitted through forms on our website; your search queries on our website; details of your visits to our website including traffic data, location data, logs, IP address, operating system, browser type; and other types of information that you choose to provide us or that we may obtain about you.

We may also collect information related to conversations, including records or copies of your correspondence with us or customer service calls for quality assurance and training purposes, and other communications such as website chat support, in-app messages, or SMS.

Some of the common ways in which we collect personal information include the following:

Warranty Program

We may collect personal information in the course of our administration of warranties, and recalls. We typically receive this personal information from our Commercial Customers to administer such requests. The personal information we may receive in these cases includes name and address and may include other personal information.

Vehicle Systems Testing

We regularly test technologies to improve vehicle safety, reliability, efficiency, and convenience. These technologies include but are not limited to systems designed to facilitate automated, connected, and eco-friendly driving. The personal information we collect in these cases includes field test video from onboard cameras. For more information about these onboard cameras [click here].

Employee Data

We collect information in the context of your role as an applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of our business.  The personal information we collect in these cases includes name, social security number, address, date of birth, bank account and routing number, tax filing status, emergency contact info, telephone number, and family member names.  We only use this information for purposes of evaluating qualifications related to your job application; or providing employee, owner, director, officer, staff, contractor, or other compensation, benefits, and services in the context of the employment relationship.

Automatically Collected Personal Information

By its nature, our website also automatically collects some personal information about you. In order for you to view or interact with our website, we receive individual identifiers like your IP address and some network information like date and time of pages visited. We collect some personal information automatically using cookies or other tracking technologies. The personal information automatically collected may be collected by or on behalf of third parties who provide us inferences or reporting based on analysis of such personal information.

6.  HOW WE LIMIT COLLECTION AND USE OF PERSONAL INFORMATION

We will not collect additional categories of personal information or use personal information collected for additional purposes without providing you with notice consistent with California law. We consider de-identification and aggregation of personal information to be compatible with the purposes listed above and in your interest, because the anonymization of such information reduces the likelihood of improper disclosure of that information.

PLEASE NOTE THAT WE MAY PROCESS YOUR PERSONAL INFORMATION WITHOUT YOUR KNOWLEDGE OR CONSENT, AS REQUIRED OR PERMITTED BY LAW.

7. HOW WE SHARE PERSONAL INFORMATION

In order to provide you with the best products and services, we share your personal information among our parent, subsidiary, and affiliated entities; service providers; and other third parties as described in this section.

DENSO Companies

We may share some or all of your personal information with parent and subsidiary entities as well as entities under shared corporate control for the purposes described in [Section 3] above. For the purposes of this Statement, these are the “DENSO Companies.”

Commercial Customers

DENSO supplies services and products to major automakers and other customers. We may share your personal information with automakers and customers that offer their own consumer services and products.  For the purposes of this Statement, these are our “Commercial Customers.”

Service Providers

We may from time to time use business partners, suppliers, and sub-contractors to assist us with the provision of services to you (for example, without limitation, website hosting, web analytics, maintenance services, database management, billing, payment processing, fraud protection, credit risk reduction, marketing, product research, or improvement of services). These entities have access to your personal information only to perform the respective tasks assigned to them on our behalf, and are obligated not to disclose or use it for any other purpose. For the purposes of this Statement, these are our “Service Providers.”

Third Parties

We may share personal information with the following categories of third parties: DENSO Companies, Commercial Customers, Advertising Networks, Data Analytics Providers, Government Entities, Internet Service Providers, Operating Systems and Platforms, and Social Networks. For the purposes of this Statement, “third party” or “third parties” means third party as defined by the California Consumer Privacy Act, and includes parties that may sell, retain, use, or disclose personal information for certain purposes beyond the limited scope of our contract or direct business relationship with such entities.

We do not share personal information with third parties for their direct marketing purposes without your permission.

Other Reasons for Which We Will Share Personal Information

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose your personal information to government or law enforcement officials or private parties in response to lawful requests when we believe disclosure or sharing is necessary to comply with any legal obligation, enforce or apply our terms and conditions, respond to claims and legal process, protect our services, members, dealers, our rights and/or the safety of the public or any person, or prevent or stop any illegal, unethical or legally actionable activity (including for the purposes of fraud protection).

We may share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If another company or individual acquires our business, or assets, that company or individual will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Statement.

Categories of Personal Information Collected, Disclosed, and Sold.

Category of Personal Information

Information  Collected

Sold in the Past 12 Months Categories of Third Parties to Whom Sold Disclosed for a Business Purpose in Past 12 Months Categories of Third Parties to Whom Disclosed for a Business Purpose
Identifiers  Address;
Date of Birth;
Email Address;
IP Address;
License Plate;
Name;
Telephone number;
Vehicle Identification Number
Yes Data Analytics Providers Yes Commercial Customers;
DENSO Companies
Information that identifies,
relates to, describes, or is capable of being associated with, a particular individual.
Address;
Date of Birth;
Email Address;
GPS data;
IP Address;
License Plate;
Location;
Name
Yes Data Analytics Providers Yes Commercial Customers;
DENSO Companies
 
Characteristics of protected classifications under California or federal law None No None No None
Commercial information. None No None No None
Biometric information. None No None No None
Internet or other electronic network activity.         Website data; Yes Data Analytics Providers No None
Geolocation data GPS data No None Yes DENSO Companies
Audio, electronic, visual, thermal, olfactory, or similar information. Field test video No None Yes DENSO Companies
Professional or employment-related information. None No None No None
Education information. None No None No None
Inferences drawn from any of the information identified above. Website analytics data No None No None

The above chart does not include information collected for employment related purposes or where your communications or transactions with us occur solely in the context of due diligence regarding, or providing or receiving a product or service to or from a company, partnership, sole proprietorship, nonprofit, or government agency on whose behalf you are acting. 

The categories of information we collect for employment related purposes are: identifiers; information that identifies, relates to, describes, or is capable of being associated with, a particular individual; characteristics of protected classifications under California or federal law; internet or other electronic network activity; professional or employment-related information; and education information.

8.  HOW TO EXERCISE YOUR RIGHTS

Unless otherwise specified, to exercise any of your rights described in this Appendix A, please refer to the link below.

For California State resident

Unless otherwise specified, to exercise any of your rights described in this Appendix A, please complete a data subject request form available [here]; call us toll-free at [1-833-957-2199]; or submit your request to us at one of the following addresses: na_privacy@denso-diam.com or DENSO International America, Inc., 24777 Denso Drive, Attn: Privacy Officer, Southfield, Michigan, 48086-5047.

For non California State resident

In order to verify your request, you will need to provide us with enough information to identify you, verify your identity and address, and a description of what right you wish to exercise along with any information to which your requests relates.

You may also designate an authorized agent to make a request under the California Consumer Privacy Act on your behalf. In order to fulfill your request to know or delete submitted by an authorized agent, you must provide the authorized agent written permission to do so, and we may require you verify your own identity with us directly.

User-enabled privacy controls, such as a browser plugin or privacy setting or other mechanism, that communicate or signal your choice to opt-out of the sale of personal information are considered a request directly from you, not through an authorized agent.

We reserve our right not to make a data access or portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or someone authorized to act on such person’s behalf. Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification. You will not have to pay a fee to exercise your rights described herein. However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive. You may only make a request to know or receive personal information twice within a 12-month period.

To opt-out of the sale of your personal information, visit our homepage and click on the Do Not Sell My Information link, or click [here].

9.  CHANGES TO THIS PRIVACY STATEMENT

We may update this Statement from time to time, in our sole discretion. When we do so, we will post the new Statement on our website. You should consult this Statement regularly for any changes. Continued use of services following posting of such changes constitutes your acknowledgement of such changes and agreement to be bound by the changes. If you do not agree, you should immediately discontinue your use of our website and services.

10.  CONTACT US

If you have questions regarding this Statement or our treatment of your personal information, you may contact us at the following:

DENSO International America, Inc.
Attn: Privacy officer
24777 Denso Drive
Southfield, Michigan, 48086-5047
na_privacy@denso-diam.com

Individual customers who reside in California and have provided their personal information to us may request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such requests must include your name, street address, city, state, and zip code, and be submitted to us at one of the following addresses: na_privacy@denso-diam.com or DENSO International America, Inc., Attn: Privacy Officer, 24777 Denso Drive, Southfield, Michigan, 48086-5047. Within thirty days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.