Privacy Policy

OVERVIEW

This privacy policy (“Policy”) applies to Sumitomo Rubber North America, Inc., d/b/a Falken Tire Corporation and Dunlop Motorcycle Tires (“SRNA,” “we,” or “us”). 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 Policy to explain our practices regarding the personal information we collect from you or about you on this website or via apps, through written or verbal communications with us, when you purchase our products through partners, or from other sources. While this Policy broadly describes the practices we have adopted across SRNA within North America, local laws vary and some jurisdictions may place restrictions on our collection, use, or disclosure of personal information. Our actual practices in such jurisdictions may be more limited than those described in this Policy to comply with local requirements. If you are a resident of California, please see Appendix A for information regarding SRNA’s use of your personal information.

By accessing or using our websites, mobile applications (“apps”), or submitting information to us, or otherwise agreeing to this Policy, 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 Policy does not apply to our processing of personal information on behalf of and subject to the instructions of third parties.

PERSONAL INFORMATION WE COLLECT

We collect personal information at every touch point or consumer interaction, and in conducting every aspect of our business, we may collect personal information. This personal information may include your name, mailing address, billing address, phone number, information related to your purchase of our products or services, or products or services you purchased or own; participation in a membership or loyalty program, or other programs; participation in a contest, sweepstakes, or marketing program; personal characteristics, nationality, income, driver’s license number or other government identification information; payment information, such as your payment card number and other card information; marketing and communication preferences, information about vehicles you have purchased, registered or own; reviews and opinions about us (if they are identified or associated with you); information provided on membership and account applications; information submitted through forms on our websites; your search queries on our websites; details of your visits to our websites 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.

We collect personal information in certain common cases, such as:

Rebates, Warranties, and Recalls: We offer multiple means of registration and communication with regard to product rebates, warranties, and recalls. We may collect this personal information from you directly, or if you provide the information to one of our service providers to administer such registrations or fulfill related requests. The information we collect in these cases includes account number; address, city, province, state, zip code; age; tire brand, tread, size, type; business name; car make and model; cell phone; contact info; customer comments; date of tire purchase; dealership info; dot serial numbers; email address; first name; last name; gender; a copy of your original invoice; invoice number; last 4 payment card digits from your original invoice; number of household vehicles; odometer reading(s); order date; order number; original receipt; product(s) purchased; return reason; signature; tire service record; trial ending date; vehicle make, model, year; vehicle identification number; purchase preferences; facility visit logs; and other information you choose provide to us. The personal information described in this paragraph is the “Warranty and Recall Data.”

Falken Dealer Programs: For dealers interested in obtaining more information about our Falken dealer opportunities, we may collect information about you in order to assess your suitability to become a Falken dealer. If you are a Falken dealer, we also collect information from you. The information we collect as part of our Falken dealer applications and programs includes dealer status; address, city, state, zip code; bank account number; bank routing number; comments; company; contract date; distributor; distributor center; email address; fax number; first name, last name; location district, fanatic ID, and type; payment method; phone number, mobile phone; tax classification; taxpayer id number; territory; dealer website; and documents or other information that you choose to upload or otherwise provide us.

We also invite certain Falken dealers to participate in on site educational activities, to give our dealers a chance to see the inner workings of our company, intimately learn our products, and truly understand our brand. If you register or attend these events we may collect the following information from you to organize and facilitate your attendance: dealer program status; historical experience attendance; company; work address; work phone; date of birth; dietary needs; a copy of your driver’s license; accessibility requirements; email address; emergency contact name; emergency contact number; emergency contact relationship; flight and airline information, redress number, seating preference, known traveler number, gender; hotel information; job title; mobile phone; name; photographs; shirt size; special requests; transportation; and other information you choose to provide us. The personal information described in this and the preceding paragraph is the “Falken Dealer Data.”

Dunlop Dealer Programs: For dealers interested in obtaining more information about our Dunlop dealer opportunities, we may collect information about you in order to assess your suitability to become a Dunlop dealer. If you are a Dunlop dealer, we also collect information from you. The information we collect as part of our Dunlop dealer applications and programs includes account name; address; age; date of birth; dealership info; email address; IP address; name; payment info; phone number; principle name; purchase history; tax identification number; app information including user audio settings, user network access, user network connections, user photos and videos, user USB storage; customer names, addresses, emails, invoices, and payment information; and other information you choose to provide us. The personal information described in this paragraph is the “Dunlop Dealer Data.”

Social Media: If you choose to participate in SRNA-sponsored social media activities or offerings, we may collect certain information from your social media account consistent with your settings within the social media service, such as location, check-ins, activities, interests, photos, status updates and friend list. We may also allow you to enter into contests to provide photos, such as of tires or products you purchased from one of our brands or partners, which you may share with your connections on social media for votes, shared offers or other promotions. The personal information described in this paragraph is the “Social Data.”

Sponsorship: We collect personal information to consider applications for, and administer, various sponsorship programs. This information includes first name last name; email address; city; state; zip code; questions or comments; photos or files uploaded; vehicle year; vehicle make; vehicle model; vehicle location; current and future vehicle modifications; magazine features; events calendar; podiums or events won; and current sponsors. The personal information described in this paragraph is the “Sponsor Data.”

Event Surveys: We collect personal information at various events through surveys in which you may choose to participate. The information we collect includes age; bike type; agreement to terms of use, date collected; information on tire use, maintenance, purchase history, habits, and preferences; email; first name; last name; miles ridden; opt-in/out of marketing or other communications; phone number; residence; vehicle make, model, and year; and other individual survey responses as indicated at the time of collection. The personal information described in this paragraph is the “Survey Data.”

Automatically Collected Personal Information: By its nature, our websites and apps also automatically collect some personal information about you. In order for you to view or interact with our website or apps, we receive individual identifiers like your IP address and some network information like date and time of pages visited. We may collect this personal information even if you are not logged in. We collect some personal information automatically using cookies or other tracking technologies as described below in Section 7. The personal information automatically collected may be collected by or on behalf of third parties who provide us inferences or aggregate reporting based on analysis of such personal information. The personal information described in this paragraph is the “Use Data.”

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. We also collect geolocation, telematics, speed, breaking, and other vehicular information from our company-owned vehicles driven by employees that we use to track, evaluate, and maintain those vehicles. The personal information described in this paragraph is the “Employee Data.”

In addition to the information we collect from you directly, we may also infer information about you based on the information you provide to us or from other information we collect.

PERSONAL INFORMATION FROM OTHER SOURCES

We may collect personal information about you from a number of sources in addition to those means of collection indicated above including offline or through sources unrelated to your interaction with our websites or apps. For example, from publicly accessible sources (e.g., property records); directly from a third party, (e.g., credit reporting agencies or customer due diligence providers); or from a third party with your consent (e.g., your bank). We may merge or co-mingle that personal information with the personal information we maintain about you and other data collected on or through our website.

PURPOSES FOR WHICH WE COLLECT PERSONAL INFORMATION

In addition to the reasons set forth above, we collect your personal information for the following reasons:

• 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 that, the personal information is not disclosed to a 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 behalf of the business;
• 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.

LIMITED USE

We will only use your personal information for the purposes for which we collected it, unless we reasonably determine we need to use it for another reason and that reason is compatible with the original purpose. For example, we consider de-identification, aggregation, and other forms of anonymization 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.

If you wish to receive an explanation as to how the processing for a particular purpose is compatible with the original purpose, please contact us via the information specified in the Contact section below.

PLEASE NOTE THAT WE MAY PROCESS YOUR PERSONAL INFORMATION WITHOUT YOUR KNOWLEDGE OR CONSENT, IN COMPLIANCE WITH THE ABOVE RULES, WHERE THIS IS REQUIRED OR PERMITTED BY LAW.

HOW WE SHARE PERSONAL INFORMATION

In order to provide you with the best products and services, we share your personal information among our affiliates, service providers, and other third parties as described below.

Sumitomo Rubber Companies. We may share some or all of your personal information with our parent company and entities under shared corporate control (“Sumitomo Rubber

Commercial Customers. We supply services and products to motor vehicle manufacturers, aftermarket parts wholesalers and retailers, motor vehicle dealers, and other customers that offer their own consumer services and products (“Commercial Customers”). We share personal information with our Commercial Customers.

Fulfillment Providers. We share personal information with companies that help us fulfill requests and orders for products and services (“Fulfillment Providers”) including but not limited to warranties and product registrations.

Advertising Networks. We share personal information with third parties who help us market to you through advertising online and otherwise (“Advertising Networks”) as described in Sections 7 and 9 of this Privacy Policy.

Service Providers. We may from time to time use business partners, suppliers, and sub-contractors (“Service Providers”) to assist us with the provision of services to you (for example, without limitation, website hosting, app design, maintenance services, database management, web analytics, app analytics, billing, payment processing, fraud protection, credit risk reduction, marketing, or improvement of services). These Service Providers 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.

Third Parties. In addition to third parties in the foregoing categories, we may share personal information with the following categories of third parties: Data Analytics Providers as defined in Section 7, 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.

Compliance with Laws. 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).

Sale or Transfer of Business or Assets. 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 Policy.

Other Legitimate Business Purposes. We may also disclose your personal information when it may be necessary for other legitimate purposes as reasonably determined by us, in which case we will notify you of such use via telephone, email, and/or a prominent notice on our website.

COOKIES AND OTHER TRACKING TECHNOLOGIES

Third parties, including Google and Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on the internet and use that information to provide measurement services and target ads. You can opt-out of the collection and use of information for ad targeting using the options provided in the Opting Out section below. The tracking technologies we utilize include the following:

Cookies. We may use different types of cookies when providing different types of web-related services. If you do not know what cookies are, or how to control or delete them, then we recommend you visit www.aboutcookies.org for detailed guidance. Cookies allow us to identify and authenticate visitors, track aggregate behavior, and enable important service features. We use both session ID cookies and persistent cookies. Session ID cookies are used to maintain your browser state as you browse through services, and they expire when you close your browser. A persistent Cookie remains on your hard drive for an extended period, and we use that to identify you should you return to services and want to find information you had previously entered or accessed.

We also contract with analytics services, third-party affiliate services, and third-party advertising companies to collect similar information. These cookies allow the ad servers to recognize your computer each time they send you an online advertisement and compile information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you.

You may disable cookies through your web browser. For information about opting out of these collection services, please see the Your Choices section below.

Web Beacons/Tags. We automatically collect aggregate anonymous information through files embedded in our services and emails known as “web beacons.” We may deliver a web beacon to you through our services from an advertising network with which we have contracted. Web beacons allow third parties to provide anonymized and aggregated auditing, research, and reporting for us. Web beacons also allow us to tell whether email recipients are able to properly view messages or have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to users. We do not tie the information gathered by web beacons to personal information.

Flash LSOs. When we post videos, third parties may use local shared objects, known as “Flash cookies,” to store your preferences for volume control or to personalize certain video features. Flash cookies are different from browser cookies because of the amount and type of data and how the data is stored. The cookie management tools provided by many popular browsers will not remove Flash cookies. To learn how to manage Flash cookie privacy and storage settings, click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html.

Analytics. We may use analytics tools or similar tools provided by third parties (“Data Analytics Providers”) to help analyze how you and other users utilize our services. Analytics tools use cookies and other tracking technologies to collect information such as how often users visit services, what pages they visit, and what other websites they used prior to visiting our services. We use the information we get from analytics tools only to improve services. Analytics tools collect the IP address or other unique identifier assigned to you on the date you visited services. We do not combine the information generated through the use of analytics tools with your other personal information. Analytics tools provided by third parties plant a persistent cookie on your web browser to identify you as a unique user the next time you visit our website, and the treatment of that information is governed by the third party’s terms of use and/or privacy policy. To learn about how Google uses data related to website analytics when you use our site or apps, click here: https://policies.google.com/technologies/partner-sites. For information about how Facebook uses cookies and other storage technologies, click here: https://www.facebook.com/policies/cookies/.

BY USING ANY OF OUR WEBSITES, YOU GIVE CONSENT FOR US TO SHARE YOUR DATA WITH THESE PROCESSORS, AND FOR THEM TO TRANSFER THIS INFORMATION ONWARD TO THEIR PARTNERS IN CONNECTION WITH PROVIDING YOU SERVICES.

YOUR CHOICES

You have the following choices with respect to the personal information we hold about you. To protect your privacy and security, we may take reasonable steps to verify your identity before granting requests to access, alter, or delete your personal information.

Access or correct your personal information. You can access a variety of your personal information that we collect by accessing your respective account, by phone, email, or in writing using the information provided in the Contact section below.

Deleting your personal information. You may ask us to delete your personal information at any time by phone, email, or in writing using the information provided in the Contact section below. Please note we may maintain some portions of your personal information as needed to comply with our legal obligations, resolve disputes, and/or enforce any of our agreements. We will delete or de-identify all your personal information as described in this subsection 8.2 within 30 days of your request for deletion.

OPTING OUT

You can make the following choices regarding your personal information:

Promotional and Other Emails. You may choose during the account registration processes on one of our websites, or otherwise, to provide us with your email address for the purpose of allowing us to send newsletters, surveys, offers, and other materials related to our services. You can stop receiving these emails by sending a request to the email address in the Contacting Us section below. If you decide not to receive these emails, we may still send you communications related to your current or former membership.

Behavioral Advertising. Our services may use behavioral advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our websites so that they can provide advertising about products and services tailored to your interests. That advertising may appear either on our website, or on other websites not operated by us. If you do not want third parties who collect information about your use of our services, you can opt-out of such at the Digital Advertising Alliance in the US, the Digital Advertising Alliance of Canada in Canada, or the European Digital Advertising Alliance in Europe.

PLEASE NOTE THAT OPTING-OUT OF BEHAVIORAL ADVERTISING DOES NOT MEAN THAT YOU WILL NOT RECEIVE ADVERTISING WHILE USING SERVICES. IT WILL, HOWEVER, EXCLUDE YOU FROM INTEREST-BASED ADVERTISING CONDUCTED THROUGH PARTICIPATING NETWORKS, AS PROVIDED BY THEIR POLICIES AND CHOICE MECHANISMS.

Analytics. Many analytics providers allow end-users to opt out of the retention of their information, including our third-party analytics providers. Please note that typically, unless you create an account with the analytics provider, your choice to opt out applies only to the device from which you make the request, because the providers use cookies on that device to recognize your choice. If you get a new device, install a new web browser, update your browser, or otherwise erase/alter your browser cookie files you may clear the opt-out cookie.

You may learn more about the use of information by and opting-out of analytics from our third-party provider by visiting its opt-out page at the following links:

www.google.com/policies/privacy/partners/

https://tools.google.com/dlpage/gaoptout

Cookies. You may disable, or delete cookies in your Web browser, but doing so may impact the usability of the website. To block cookies, you can also browse our service using your browser’s anonymous usage setting (called “Incognito” in Chrome, “In Private” for Internet Explorer, “Private Browsing” in Firefox and Safari etc.).

Do Not Track. Our website recognizes and responds to “Do Not Track” requests available through many popular web browsers. If we recognize that you have enabled one of these “Do Not Track” signals, we will not track or sell cookie information about your online activities.

INTERNATIONAL TRANSFERS OF INFORMATION

Your personal information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding personal information may be less stringent than the laws in your country. Therefore, in some circumstances, you might be left without a legal remedy in the event of a privacy breach or other use that is prohibited in your country. By submitting your personal information, you agree to this transfer, storage and/or processing, including all associated risks.

EXERCISING YOUR PRIVACY RIGHTS

When exercising the rights or options described in this Policy, the following guidelines apply:

No fee usually required. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.

11.2 What we may need from you. When exercising your rights or otherwise assisting you, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. When exercising your rights or otherwise assisting you, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

INFORMATION SECURITY

No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. We make efforts to protect your personal information from improper or unauthorized loss, misuse, access, disclosure, alteration, or destruction. If you have questions about the security of your personal information, contact us at the email or regular mail address specified in the Contact section below.

DATA RETENTION

We will retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, whether we can achieve those purposes through other means, and the applicable legal requirements.

THIRD-PARTY LINKS

Our websites or apps may contain links to other websites or apps. We are not responsible for the privacy practices or the content of these other websites or apps. You should read the policy statement of these others websites or apps to understand their policies. When you access a linked websites or apps, you may be disclosing private information. It is your responsibility to keep such information private and confidential.

CHANGES TO THIS PRIVACY POLICY

We may update this Policy from time to time, in our sole discretion. When we do so, we will post the new Policy on our website. You should consult this Policy 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.

CONTACT US

If you have questions regarding this Policy, its appendices, or our treatment of your personal information, you may contact us at:

Sumitomo Rubber North America, LLC
Attn: Privacy Officer
8656 Haven Ave
Rancho Cucamonga, CA 91730
privacy@falkentire.com

APPENDIX A: CALIFORNIA PRIVACY RIGHTS

Date Last Updated: January 1, 2020

Your California Privacy Rights:

Under the California Consumer Privacy Act of 2018 and certain other privacy and data protection laws, as applicable, residents of California have the right to request that we disclose what personal information we collect, use, disclose, and sell. More specifically, if you are a resident of California 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 reserve our rights to (i) 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 consumers is not retained; (ii) 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 (iii) not provide personal information to you more than twice in a 12-month period.

Disclosure of Personal Information Sold or Used 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.

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 to not delete your personal information if it is necessary to: (i) 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; (ii) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity or prosecute those responsible for that activity; (iii) debug to identify and repair errors that impair existing intended functionality; (iv) 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; (v) comply with the California Electronic Communications Privacy Act; (vi) 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; (vii) enable solely internal uses that are reasonably aligned with your expectations based on the your relationship with us; (viii) comply with an existing legal obligation; and (ix) otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

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.

How to Exercise Your Rights

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 1-800-723-2553 or submit your request to us at the following address: Sumitomo Rubber North America, Inc., 8656 Haven Ave., Attn: CA Privacy, Rancho Cucamonga, CA, 91730

In order to verify your request, you will need to provide us with enough information to identify you (e.g., your full name, address, and customer or matter reference number), proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill), 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 may require you verify your own identity with us directly.

We reserve our right not to grant a consumer request 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. You may only make a request to access or receive copies of personal information twice within a 12-month period. 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.

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

We sell to third parties 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.

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 your personal information.

To opt-out of the sale of your personal information, visit our homepage and click on the Do Not Sell My Personal Information .

Children’s Right to Opt-In to the Sale of Personal Information

We do not sell the personal information of minors under 16 years of age without affirmative authorization. For minors who wish to opt-in to the sale of their personal information, we have established the following processes:

Minors between 13 and 16 years of age:

In the case of consumers between 13 and 16 years of age, we require the consumer to affirmatively authorize the sale of the consumer’s personal information. In order to opt-in minors in this age range, as part of the account registration process for our products which may be targeted toward minors we require the consumer or consumer’s parent or guardian verify their identity by providing at least two data points with data points maintained by the business, which we have determined to be reliable for the purpose of verifying the consumer.

Minors under 13 years of age:

In the case of consumers who are less than 13 years of age, we require the consumer’s parent to affirmatively authorize the sale of the consumer’s personal information. In order to opt-in minors in this age range, as part of the account registration process for our products which may be targeted toward minors we require the consumer’s parent or guardian verify their identity, which we have determined to be reliable for the purpose of verifying the consumer.

We reserve the right to require additional information or not complete your request if we cannot verify your identity. If you are a parent or guardian seeking to opt-out on behalf of their child, please email us at privacy@srna.com.

Our Collection and Disclosure of Personal Information

Sources from Which We Receive Personal Information

We receive personal information from the following categories of sources:

• You, the consumer.
• Commercial Customers.
• Fulfillment Providers.
• Communication Platforms.
• Data Analytics Providers.
• Service Providers.
• Government entities.

Third Parties with Whom We Share Personal Information

We routinely share personal information with the following categories of third parties:

• Sumitomo Rubber Companies
• Commercial Customers.
• Fulfillment Providers.
• Communication Platforms.
• Data Analytics Providers.
• Advertising Networks.
• Service Providers
• Government entities.

Categories of Personal Information Collected, Disclosed, and Sold.

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; geolocation data; professional or employment-related information; and education information.

Individual customers who reside in California and have provided us their personal information 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: privacy@falkentire.com with the subject “California Shine The Light Request” or Sumitomo Rubber North America, Inc., 8656 Haven Ave., Attn: CA Privacy, Rancho Cucamonga, CA, 91730. 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.

If you are a California resident under the age of 18, and a registered user of any website where this Policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to privacy@falkentire.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

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