Mitsubishi Materials U.S.A. Corporation Privacy Policy

Effective Date: June 1, 2023
Last Reviewed on: December 18, 2023

This Privacy Policy applies to all visitors and users of any website operated by Mitsubishi Materials U.S.A. Corporation (“MMUS,” “we,” “our,” “us”), including www.mmus.com (the “Website”), as well as to individuals with whom we do business both online and offline, and MMUS employees located in the State of California. In addition to the policies and disclosures stated in this Policy, certain rights are provided to residents of various states where local law provides for such rights.

1. INFORMATION WE COLLECT

MMUS, both through its Website and offline, collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, MMUS has collected, either through its Website or offline, the following categories of personal information from its consumers within the last twelve (12) months, to be retained for the following retention periods: 

Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the scope of otherwise applicable state laws, 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.

MMUS obtains the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Website.

2. USE OF PERSONAL INFORMATION

We may use or disclose the personal information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our Website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• For employment-related matters including, but not limited to, employee onboarding, payroll, and employee benefits.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the California Consumer Privacy Act and other applicable law.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of MMUS's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by MMUS about our Website users is among the assets transferred.

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

3. DISCLOSING PERSONAL INFORMATION

MMUS may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We disclose your personal information to the following categories of third parties:

• Service providers (including, but not limited to, attorneys, accountants, IT service providers, payroll processors and benefits providers).
• Data aggregators.
• MMUS-authorized dealers.
• Government entities (for employment-related matters such as work authorizations, I-9 forms, payroll and tax withholding).

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, MMUS has disclosed the following categories of personal information for a business purpose:

1. Category A: Identifiers.
2. Category B: California Customer Records personal information categories.
3. Category C: Protected classification characteristics under California or federal law.
4. Category D: Commercial information.
5. Category I: Professional or employment-related information.
6. Category L: Sensitive Personal Information

We disclose your personal information for a business purpose to the following categories of third parties:

• Service providers (including, but not limited to, attorneys, accountants, IT service providers, payroll processors and benefits providers).
• Data aggregators.
• MMUS-authorized dealers.
• Government entities (for employment-related matters such as work authorizations, I-9 forms, payroll and tax withholding).

Sales or Sharing of Personal Information

In the preceding twelve (12) months, MMUS has not sold personal information nor has MMUS shared personal information for cross-context behavioral advertising purposes.

4. RIGHTS OF CALIFORNIA RESIDENTS

The California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020, provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that MMUS disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion 0), 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 or selling 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 MMUS 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 (see Exercising Access, Data Portability, and Deletion 0), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, provide product warranty service, fulfill the terms of a product recall conducted in accordance with federal law, 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, 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 et. 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.

Right to Correct

You have the right to request MMUS to correct inaccurate personal information collected about you. MMUS will make commercially reasonable efforts to correct any inaccurate personal information we hold about a consumer within 45 days of receiving a verifiable consumer request. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

Right to Opt-Out of Personal Information Sales and Sharing

If you are age 16 or older, you have the right to direct us to not sell or share your personal information for cross-context behavioral advertising purposes at any time (the "right to opt-out"). Please note that we do not currently engage in sales or sharing of personal information triggering such opt-out requirements.

Right to Limit Disclosure or Use of Sensitive Personal Information

You have the right to limit the disclosure or use of your sensitive personal information to only those actions necessary for MMUS to provide goods and services to you or as otherwise specifically directed by you. Please note that we do not currently collect sensitive personal information triggering such limitation rights.

Exercising Access, Data Portability, Deletion and Correction Rights

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

• Visiting www.mmus.com.
• Emailing us at [ecomsales@mmus.com].

​​​​​Only you, or someone legally authorized 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. To designate an authorized agent, you must first verify your identity directly with us and provide written authorization to your agent to make requests on your behalf.

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 an authorized representative, which may include:
• Your name, address, and any other information we may require to verify your identity.
• Describe your request with sufficient detail that allows 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 within forty-five (45) days of its receipt. 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, at your option.

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, specifically .csv format.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

5. NON-DISCRIMINATION

We will not discriminate against you for exercising any of your rights provided under applicable state laws. 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.
• Retaliate against an employee, applicant for employment, or independent contractor for exercising their rights under applicable law.

6. PRIVACY RIGHTS FOR RESIDENTS OF COLORADO, CONNECTICUT, UTAH AND VIRGINIA

For residents of the States of Colorado, Connecticut, Utah, and Virginia, MMUS provides the same rights as for residents of the State of California, namely, the right to obtain a disclosure from us of personal information we have collected from you, the right to correct personal information, the right to delete personal information, and the right to not be discriminated against because of your exercise of these rights. Please follow the same directions provided above to contact us to exercise these rights. These rights do not apply to MMUS employees resident in Colorado, Connecticut, Utah, or Virginia.

7. RESIDENTS OF CANADA

For residents of Canada, MMUS provides the same rights to access, correct, and delete your personal information as provided above. In addition, Canadian residents may contact MMUS’s data protection officer at [PRIVACY CONTACT EMAIL] to bring any challenge concerning MMUS’s handling of their personal information under the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and similar Canadian provincial laws.

8. NEVADA RESIDENTS

For residents of the State of Nevada, MMUS currently does not sell any personal information such that there is no need for you to opt out of such sales.

9. PRIVACY OPTIONS FOR RESIDENTS OF OTHER STATES

For residents of other states, including Nevada, we will provide the same ability to access your personal information collected by us, and to seek the correction or deletion of your personal information held by us, by contacting us using the instructions above. We will continue to provide you with these options unless and until applicable state law requires otherwise. These options do not apply to employees of MMUS who are resident in states other than California.

10. OTHER CALIFORNIA PRIVACY RIGHTS

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [ecomsales@mmus.com] or write us at: Mitsubishi Materials U.S.A. Corporation, Attn: Privacy Policy Team, 3535 Hyland Avenue, Suite 200, Costa Mesa, California 92626.

11. DO NOT TRACK DISCLOSURE

MMUS does not track its customers over time and across third-party websites for targeted advertising purposes. Accordingly, MMUS and its websites do not respond to Do Not Track signals.

12. CHANGES TO OUR PRIVACY POLICY

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

13. CONTACT INFORMATION

If you have any questions or comments about this privacy policy, the ways in which MMUS collects and uses your information described below and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Website: www.mmus.com
Email: ecomsales@mmus.com
Postal Address:
Mitsubishi Materials U.S.A. Corporation
Attn: Privacy Policy Team
3535 Hyland Avenue, Suite 200, Costa Mesa, California 92626

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