Privacy Policy

TAMRON USA, INC. (dba TAMRON AMERICAS) PRIVACY NOTICE WITH MEXICO SUPPLEMENT

Requirements set forth by Federal, State and Provincial authorities are designed to protect the privacy of individuals who obtain products or services for personal, family or household use. The regulations apply to all who store any form of Personally Identifiable Information (PII), such as Tamron Americas. We would like to take this opportunity to let you know what Tamron Americas is doing to protect your privacy.

Tamron Americas collects nonpublic information about you from the following sources:

• Information we receive about you on websites, applications or other forms; www.tamron-americas.com and other websites operated by us from which you are accessing the Privacy Notice
• Through our social media pages
• Applications through the software applications made available by us for use on or through computers and mobile devices
• Through HTML-formatted email messages that we send to you that link to this Privacy Notice (collectively, including the Websites, the Apps and our Social Media Pages, the “Services”)
• Information you give us orally

We will obtain your consent before collecting, using, or disclosing your personal information, except where otherwise permitted or required by law. Consent may be expressed, implied, or given through an authorized representative. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. We restrict access to your personal and account information to those employees who need to know that information to provide products and services to you. We also may disclose that information to unaffiliated third parties, only as permitted by law and only as needed for us to provide agreed-upon services to you. We will protect personal information through the use of security safeguards appropriate to the sensitivity of the information. This includes physical, organizational, and technological measures to protect your information from unauthorized access, disclosure, or misuse.

SUPPLEMENTAL PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
CATEGORY	EXAMPLES	COLLECTED
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social media account ID, profile picture, Social Security number, driver’s license number, passport number, or other similar identifiers.	YES
B. Financial information and other personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	A 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. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law	1. 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).	YES
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	NO
G. Geolocation data	Physical location or movements.	YES
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information	Current or past job history or performance evaluations.	NO
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.	NO
K. Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

This Supplemental Privacy Notice for California Residents applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). This supplemental notice is provided to you in order for us to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning used in this notice.

Information We May Collect

We collect personal information for the purposes of providing and improving our services, processing transactions, complying with legal obligations, and other purposes identified at the time of collection or as permitted by law. We have collected the following categories of personal information from consumers within the last twelve (12) months:

“Personal Information” is information that identifies you as an individual, including:
Name
Postal address (including billing and shipping addresses)
Telephone number
Email address
Profile picture
Social media account ID

If you submit any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Notice.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from consumers or their agents, both in writing and orally. For example, from documents that our clients provide to us related to the services for which they hire us.
• Indirectly from consumers or their agents. For example, through information we collect from our clients in the course of providing services to them.
• Directly and indirectly from activity on our website (www.tamron-americas.com) and interactions with our electronic communications. For example, from submissions through our website portal or website usage details collected automatically.
• From third parties that interact with us in connection with the services we perform. For jurisdiction outside of Canada, personal information does not include:

> Publicly available information from government records.
> Information excluded from the CCPA’s scope, like 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 laws, 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

Accuracy
We will take reasonable steps to ensure that personal information is accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. You have the right to request the correction of any inaccuracies in your personal information.

How Information is collected
We and our third-party service providers may collect Other Information in a variety of ways, including:

Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.

Through your use of the App: When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.

Using cookies: Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, browser traffic, time spent on the Services, pages visited, and other anonymous traffic data. We and our service providers use the information for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while using the Services, as well as for online tracking purposes. We can recognize your computer to assist your use of the Services. We also gather statistical information about the usage of the Services in order to continually improve the design and functionality, understand how the Services are used and to assist us with resolving questions regarding the Services. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services. We may also use cookies in online advertising to track responses to our advertisements and we may use cookies or other files to track your use of other websites. See Tamron Americas Cookie Policy here.

Use of Personal Information

Your Personal Information may be disclosed:

• To fulfill or meet the reason you provided the information to us.
• To our third-party service providers who provide services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services.
• To provide you with other information, products, or services that you request from us.
• To create, maintain, customize, and secure your account with us.
• To process your requests, transactions, and payments and prevent fraud.
• Subject to our obligations under applicable anti-spam laws, to provide you with notifications, reports, statements, invitations and other notices concerning products, services, events, or news that you may request or that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts between you and us, including for billing and collections.
• To improve our website and electronic communications, present their contents to you, and maintain their security.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• To respond to law enforcement and regulatory agency requests, as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise permitted under applicable law.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of your personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for the purposes contemplated in this Privacy Notice. When doing so, we enter into a contract with the third party describing the purpose of such disclosure and requiring that such personal information be kept confidential and not used for any purpose except to perform the services contracted or respond to bona fide regulatory or law enforcement requests.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for the purposes contemplated in this Privacy Notice:

Category A: Identifiers
Category B: California Customer Records personal information categories
Category D: Records of personal property or services purchased or obtained
Category G: Location
…to the following categories of third parties:

• Our affiliates
• Our vendors and service providers
• Third parties to whom you or your agents authorize us to disclose personal information in connection with products or services we (or they) provide to you

In the preceding twelve (12) months we have not sold any personal information and furthermore we have no intention to sell such information in the future.

Openness
Tamron Americas will make readily available to individuals specific information about our policies and practices relating to the management of personal information. This includes contact information for our Privacy Officer and details on how to access your personal information.

Your Rights and Choices

Certain privacy laws provide individuals with specific rights regarding their personal information. This section describes your rights and explains how to exercise those rights. You also have any other rights available to you under applicable law.

Access to Specific Information and Data Portability Rights

You have the right to access your personal information held by Tamron Americas. Upon request, we will inform you of the existence, use, and disclosure of your personal information over the past 12 months and provide access to that information, subject to any applicable legal restrictions. You may also request the correction of any inaccuracies in your information. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

To the extent permitted by applicable law, we may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. 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.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech and ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. 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.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Email: webmaster@tamron.com
• Phone: 1-631-858-8409
• Mail your request to:

Tamron Americas
10 Austin Blvd.
Commack, NY 11725
Attn: Webmaster

For California residents: Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

USE OF THE SERVICES BY MINORS

The Services are not directed to individuals under the age of fourteen (14), and we do not knowingly collect personal information from children under this age without verifiable parental consent.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information (or their authorized representative).
• Describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request as promptly as possible and always in accordance with applicable laws. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, based on your preference. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request.

Non-Discrimination

We will not discriminate against you for exercising any of your rights. Unless permitted by applicable law, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Transfers outside your jurisdiction of residence

Some of our service providers may be located outside of your jurisdiction, including in the United States. When transferring personal information to service providers in other jurisdictions, we will ensure that appropriate safeguards are in place, in accordance with all relevant laws covering our operating locations. As a result, your personal information will be used, stored and/or accessed in countries outside of your jurisdiction of residence, including the United States. However, all such information will be protected in accordance with this Privacy Notice. Please note that when your personal information is located outside of your jurisdiction of residence. it will be subject to the laws of the country in which it is situated.

Retaining Your Personal Information

We will use, disclose, and retain personal information only for the purposes for which it was collected, except with your consent or as required by law. We will retain personal information only as long as necessary to fulfill those purposes.. Your personal information is securely stored until such time as it is no longer required, after which it is destroyed or rendered such that it is unable to identify you.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, our use of service providers outside your jurisdiction of residence ,your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact our Privacy Officer at:

Phone: 1-631-858-8409
Website: www.tamron-americas.com
Email: webmaster@tamron.com

10 Austin Boulevard
Commack, NY 11725
Attn: Webmaster

Rev 08/2024

Mexico-specific supplement

These terms supplement our Privacy Policy with additional or specific information applicable solely to visitors, users, and others who are Mexican residents, which data controller is Tamron USA, Inc. (DBA Tamron Americas) (“Tamron”), with legal address located at 10 Austin Boulevard Commack, NY 11725. (“Mexico-specific Supplement”). Tamron’s Privacy Team may be contacted at the means described on the “Contact Information” section. 

This Privacy Policy refers to personal information and personal data indistinctively. In the event of a conflict between the provisions of this Privacy Policy and the Mexico-specific Supplement, the terms of the Mexico-specific Supplement in Spanish shall prevail and control.

• Data Categories

Tamron collects and processes the following personal data: Identity, contact information (including address), age, gender, location and inferences drawn from personal data we collect which include language, product use, market research data. Tamron does not collect or process sensitive data. Additionally, we use cookies, for more information regarding our use of cookies, please see our Cookie Policy at: https://tamron-americas.com/cookie-policy/

• Information collected indirectly

In the event that we have obtained your personal data through indirect means, you have a period of 5 (five) business days, as from our first contact with you, to send an email at webmaster@tamron.com to refuse the processing of your personal data.

• Purposes of the data processing

The personal data we collect from you will be used for any of the purposes described in the section “Use of Personal Information”, which are necessary, as applicable, to: (i) comply with our obligations arising from a legal or contractual relationship (between the Controller and the Data Subject), (ii) comply with legal requirements, (iii) to exercise our rights, or (iv)  to protect an individual in the event of an emergency situation that could potentially harm an individual or their property, and therefore your consent would not be required.

Unless you indicate otherwise, we can collect and process your personal data for the following secondary purpose: (i) to provide you with notifications, reports, statements, invitations and other notices concerning products, services, events, or news that you may request or that may be of interest to you. You may, at any time, request your right to object or consent withdrawal, by following the ARCO Rights procedure described below.

• Data transfers

Your personal data will be transferred for the following necessary purposes, as applicable, which do not require your consent:

• to maintain or fulfill a legal relationship between the controller and the Data Subject,
• performing contractual obligations with third parties in the interest of the Data Subject (including, when necessary, to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred),
• to share with our professional advisors, such as our accounting and legal advisors,
• to the extent required to comply with a law or treaty to which Mexico is a party,
• for the safeguard of a public interest or for the procurement or justice administration
• for the recognition, exercise or defense of a right in a judicial process,
• for emergency reasons, and
• when the transfer is made to holding companies, subsidiaries or affiliates under common control of the Controller, or to a parent company or any company in the same group of the Controller that operates under the same internal processes and policies (“Group Companies”).

The “Third-Parties” to whom we transfer your personal data may be located in Mexico or abroad, and include our Group Companies, relevant authorities, professional advisors, and service providers which services allow us to comply with our legal or contractual obligations.

• ARCO rights

You have the right to access, rectify, cancel or object to the use of your personal data to the extent permitted by law (hereinafter, the “ARCO Rights”).

You may, at any time, request the exercise of the ARCO Rights, as well as to withdraw your consent and limit the use or disclosure with respect to the personal data provided, through our email at  webmaster@tamron.com. The request referred to in the previous paragraph must include:

1. Name of the Data Subject and the means through which we will communicate the response to your request (e.g., by email).
2. Documents proving your identity or that of your legal representative.
3. A clear and precise description of the personal data and/or sensitive personal data for which you intend to exercise any of the ARCO Rights, as well as the ARCO Rights to be exercised, and
4. Any other element that may facilitate the location of the personal data with respect to which you intend to exercise the ARCO Rights.

Once the ARCO Rights request has been received:

1. The Controller will have a period of 20 (twenty) business days to provide a response regarding the validity or invalidity of your request.
2. If the request is valid, the Controller will have an additional period of 15 (fifteen) business days to grant the request.
3. The aforementioned term may be extended for an equal period of time when justified and the Controller informs you accordingly.
4. In case the exercise of the requested right is deemed as invalid, the Controller must respond to your request, explaining the reasons for such denial, within the previously stated period of 20 business days.

All ARCO Rights requests, as well as any doubts or questions related to the protection of your personal data must be requested through the email address indicated in this Mexico-specific Supplement.

• Use of the services by minors

This Privacy Policy is acknowledged and accepted, by accepting our Terms, the data subject declares that they are of legal age under the laws of Mexico (at least 18 years old) and have full legal capacity to enter into and be bound by these Terms. If the data subject is not of legal age, their parent or legal guardian hereby represents and warrants that they have reviewed and expressly consent to these Privacy Policy and Terms on behalf of the minor.

• Spanish version

The Spanish version of this Privacy Policy is available at https://tamron-americas.com/es/politica-de-privacidad/