Effective Date: 1 April 2023

This Privacy Policy applies to all visitors and users of any website maintained by SG Sagawa USA, Inc. (“Company” or “we” or “us”), and others who reside in the State of California ("consumers" or "you"). We adopt this Policy to comply with the California Consumer Privacy Act of 2018 (CCPA) and the California Privacy Rights Act of 2020 (CPRA), as amended (collectively, “CPRA”) and any terms defined in the CPRA have the same meaning when used in this Policy.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, or device ("personal information"). Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CPRA'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 (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category Examples Collected Retention Period
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or account name. YES Retained until consumer requests deletion or until no longer reasonably necessary to provide products/services to consumer.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, address, or telephone number.
Some personal information included in this category may overlap with other categories.
YES Retained until consumer requests deletion or until no longer reasonably necessary to provide products/services to consumer.
C. Protected classification characteristics under California or federal law. Age (40 years or older), sex/gender. NO Retained until consumer requests deletion or until no longer reasonably necessary to provide products/services to consumer.
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES Retained until consumer requests deletion or until no longer reasonably necessary to provide products/services to consumer.
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 N/A
F. Internet or other similar network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. YES Retained until consumer requests deletion or until no longer reasonably necessary to provide products/services to consumer.
G. Geolocation data. Physical location or movements. YES N/A
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO N/A
I. Professional or employment-related information. Current or past job history or performance evaluations. YES Retained indefinitely until no longer reasonably necessary for employment purposes.
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 N/A
K. Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO N/A
L. Sensitive Personal Information Government identifiers (social security, driver's license, state identification card, or passport number); complete account access credentials (user names, account numbers, or card numbers combined with required access/security code or password); precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; content of postal mail, email, and text messages (unless Company is the intended recipient of the subject communications); genetic data; unique identifying biometric information; health, sex life, or sexual orientation information. YES Retained until consumer requests deletion or until no longer reasonably necessary to provide products/services to consumer.

We obtain 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.

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 CPRA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our Website users is among the assets transferred.

We 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.

Disclosing Personal Information

We 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, carriers and other logistics subcontractors, attorneys, accountants, IT service providers, payroll processors, and benefits providers).

Disclosures of Personal Information for a Business Purpose

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

  • Service providers (including, but not limited to, carriers and other logistics subcontractors, attorneys, accountants, IT service providers, payroll processors, and benefits providers).

Sales or Sharing of Personal Information

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

Your Rights and Choices

The CPRA provides consumers (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 we 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, Deletion Rights and Correction Rights), 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 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 (see Exercising Access, Data Portability, Deletion Rights and Correction Rights), 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, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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.Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  4. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  5. 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.
  6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  7. Comply with a legal obligation.
  8. 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 Company to correct inaccurate personal information collected about you. Company 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 of personal information but do share personal information with service providers. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link:

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by contacting us using any of the methods provided in this Policy.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request. Please note that if we are not able to share some personal information with service providers, we may not be able to complete the services for which you have engaged us.

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 Company 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, except for individuals employed by or seeking employment with us.

Exercising Access, Data Portability, Deletion Rights 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:

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, we must have received a written verifiable request from you designating that agent by name. Such a request may be sent by email.
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. However, we do consider requests made through any password protected account you have with us sufficiently verified when the request relates to personal information associated with that specific account.
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 45 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.
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.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). As stated earlier in this Policy, we do not sell any personal data to third parties, but do share personal information with service providers. If you wish to opt out of sharing of your personal information with third parties, please visit our link here and follow the instructions above.

Non-Discrimination

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

  1. Deny you goods or services.
  2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  3. Provide you a different level or quality of goods or services.
  4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
  5. Retaliate against an employee, applicant for employment, or independent contractor for exercising their CPRA rights.

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. We do not provide such information for third parties for that purpose, however, to make such a request, please send an email to sgusainfo@sgh-global.com or write us at:
SG Sagawa USA, Inc.
Attn: Mr. Shao Ching Yung / Admin Department
18300 S. Wilmington Ave., Unit 100
Rancho Dominguez, California 90220

Our Website currently does not respond to “do-not-track”signals.

Changes to Our Privacy Notice

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

Contact Information

If you have any questions or comments about this Policy, the ways in which we collect and use your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: (800) 697-8923
Website: https://www.sgsagawausa.com
Email: sgusainfo@sgh-global.com
Postal Address:
SG Sagawa USA, Inc.
Attn: Mr. Shao Ching Yung / Admin Department
18300 S.Wilmington Ave, Unit 100,
Rancho Dominguez, California 90220