NIKON PRIVACY MANAGEMENT
CALIFORNIA-SPECIFIC ADDENDUM

Effective Date: January 1^st, 2020
Last Reviewed On: December 26^th, 2019

If you are a California consumer within the meaning of the California Consumer Privacy Act of 2018 (“CCPA”), this California-Specific Addendum (“California-Specific Addendum”) applies to you. This California-Specific Addendum supplements, and prevails over any conflicting provisions with, the Privacy Management and the Nikon Group Privacy Protection Statement. Our Privacy Management, the Nikon Group Privacy Protection Statement and this California-Specific Addendum together constitute our “Privacy Policy.”

California Personal Information We Collect

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“California Personal Information”). We obtain California Personal Information from a variety of sources. In particular, we have collected the following categories of California Personal Information from the following data sources within the last 12 months.

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Categories (A) through (I) are collected from: (1) yourself, with respect to both online and offline interactions you may have with us or our service providers.

Category (A) information is also collected from: (2) other entities with whom you transact, and (3) others with whom you maintain relationships who may deal with us on your behalf.

Category (A) and (I) information are also collected from: (4) the devices you use to access our websites, mobile applications, and online services.

Categories (A) and (B) are collected from: (5) marketing and analytics providers.

In addition, some information in Category (A) is collected from: (6) social media platforms.

Please note California Personal Information does not include publicly available information from government records, deidentified or aggregate consumer information, and personal information protected by certain other sector-specific federal or California statutes.

Our Use of California Personal Information

We use the California Personal Information we collect for business purposes as defined by the CCPA. For example, we use California Personal Information primarily for the following purposes:

• (1)To provide products or services requested by the customer, including product sales, repair and inspection, after-sales service, and catalogue distribution (California Personal Information includes such information as necessary to understand the requirements of the customer, including customers' purchase history and repair history);
• (2)To enable response to customer requests such as customer inquiry history, including through the collection of customer inquiries for the purpose of improving our responsiveness;
• (3)As a reference to determine customer requirements for products, planning, development, advertisement, sales, and service activities of the Nikon Group. This personal information will include answers to questionnaires given at the time of purchase, the customer satisfaction survey, and the customer's inquiry history);
• (4)To offer product information, company information, service information, and other related information of the Nikon Group, e.g. the sending of a catalogue, new product information, books, magazines or a mail magazine;
• (5)To notify a prizewinner or send a prize, or for the purpose of other communications with the person in question;
• (6)To verify participants in exhibitions and seminars and to correspond with them after the event;
• (7)To develop and maintain relationships with business partners and related entities;
• (8)As a reference in the recruitment of an individual where the personal information is provided by an inquirer or an applicant to the Nikon Group;
• (9)To send necessary documentation to shareholders including notification of the general shareholders' meeting, and to administer dividend payments or other actions as required by the laws and regulations;
• (10)To comply with applicable laws and regulations.

The primary business purposes for which we use California Personal Information are as follows:

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Sharing of California Personal Information

A. Disclosure of California Personal Information for Business Purposes

Within the last 12 months, we have disclosed California Personal Information identified in the above categories to our subcontractors, the Nikon Group, and, with consent or at your direction, other third party entities for our business purposes. To learn more about the categories of third parties with whom we share such information, please see our Privacy Management.

B. Sale of California Personal Information

Within the last 12 months, within the meaning of the CCPA, we have sold California Personal Information identified in the above categories: (A), (D), (E), (F), (G), and (I), to the data analytics and advertising vendors. However, as of January 1, 2020, we do not sell or otherwise disclose California Personal Information to business or third parties for monetary or other valuable consideration.

California Rights and Choices

You have certain rights related to your California Personal Information. You may exercise these rights free of charge except as otherwise provided by applicable law. We endeavor to respond to your request promptly upon verification and as required by applicable law.

A. Right to Know/Portability.

You have the right to request that we disclose to you:

• The categories of California Personal Information we have collected about you;
• The categories of sources from which the California Personal Information is collected;
• Our business or commercial purpose for collecting or selling California Personal Information;
• The categories of third parties with whom we share California Personal Information; and
• The specific pieces of information we have collected about you.

B. Right to Delete.

You have the right to request that we delete California Personal Information about you which we have collected from you. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• 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;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• 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;
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
• 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;
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
• Comply with a legal obligation; or
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

C. How to Submit a Request.

You may request to exercise these rights by:

• By completing our rights request form available here.

D. Verifiable Request.

As required under applicable law, we take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may require you to provide information sufficient to allow us to reasonably verify you are the person about whom we collected personal information or an authorized representative and to describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

E. Agent Authorization and Disability Access.

You may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. As permitted by law, we may require additional verification in response to a request even if you choose to use an agent. You may also make a verifiable consumer request on behalf of your minor child.

Nondiscrimination and Financial Incentives

We will not discriminate against you because of your exercise of any of the above rights, or any other rights under the CCPA, including by:

• denying you goods or services;
• charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• providing you a different level or quality of goods or services; or
• suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. We currently provide the following financial incentives.

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Other California Privacy Rights

A. California Do Not Track Disclosure.

Our websites, apps and other online services are not designed to respond to “Do Not Track” requests from browsers.

B. Other California Privacy Rights.

Under California's “Shine the Light” law (Civil Code Section § 1798.83), you, as a California resident, may ask us to refrain from sharing your personal information with third parties for their marketing purposes. To make such a request, please contact us using the contact information below.

Changes to this California-Specific Addendum

We reserve the right to amend this California-Specific Addendum at our discretion and at any time. When we make changes to this California-Specific Addendum, 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.

Contact Information

You may contact us with questions or concerns about our privacy policies or practices and your choices and rights under California law at here.