This privacy policy (“Policy”) describes how Citizen Watch Co., Ltd. and its affiliates and subsidiaries (collectively, “Citizen”, “we”, “our” or “us”) collect, use, and disclose personal information about you through the Riiiver services (“Riiiver”), including through Riiiver-connected applications and devices and the Riiiver website, located at https://riiiver.com/en; how we use and protect this information; and your rights in relation to this information.

This Policy applies to all personal information we collect, use, and disclose about you. “Personal information” is information that identifies, relates to, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household.

We collect personal information about you from a variety of sources. We collect information from you directly (e.g., when you contact us or create a Riiiver account), automatically (e.g., data collected from cookies), and from other sources, including commercially available sources, such as public databases (where permitted by law).

We may be required by law to collect certain personal information about you or as a consequence of any contractual relationship we have with you. Failure to provide this information may prevent or delay the fulfilment of these obligations.

Information we collect directly from you

When necessary in order to provide our services, we may directly collect the following categories of information from you:
•Identifiers, such as your name, postal address, telephone number, email address, account username and password, for third-party services you choose to connect to your account or other similar identifiers;
•Protected characteristics, such as your gender, age, date of birth, nationality, or other protected classifications under applicable law;
•Commercial information, such as purchase and browsing histories, information about your usage of our products and services (e.g., teams joined on Riiiver, language used on Riiiver), or other purchasing or consumption histories or tendencies;
•Financial, medical, or health information, such as methods of payment, bank or credit card numbers, and historical heart rate or other biometric or health-related data;
•Audio, electronic, visual, thermal, olfactory, or similar information, such as photographs or voice recordings;
•Professional information, such as employer, job title, job location, or business contact information; and
•Communications, such as when you participate in message boards or forums, respond to polls or surveys, write a review, or contact us with a question, comment, or request. (e.g. when you participate in message boards or forums, participate in polls or surveys, write a review or contact us with a question, comment or request).

Information we may automatically collect about you

We may collect information about you automatically through the use of cookies and similar technologies. You may limit our ability to automatically collect certain types of information by adjusting the cookie settings on your web browsers or by adjusting your preferences within the Riiiver app or your mobile device settings. If you choose to reject cookies or the collection of certain personal information (including biometric information or geolocation data), you may still use our service though your access to some functionality may be restricted. The categories of information collected through cookies and similar technologies include:
•Identifiers, such as unique device identifiers, online identifiers, IP address, or other persistent identifiers;
•Biometric information, such as your likeness, step counts, temperature, heart rate, sleep patterns, speed, blood pressure, or behavioral tendencies that may identify you;
•Geolocation data, such as precise location; and
•Internet or other electronic network activity information, such as browsing history, search history, SMS and call history, device status and sensor data, or information regarding your interaction with any websites, applications, or devices associated with Riiiver.
Additionally, we may draw inferences from any of your personal information to create a profile about you, which may reflect your preferences, characteristics, psychological trends, predispositions, behavior, abilities, and aptitudes.

Information we may collect from other sources

We may collect information from other sources in order to more seamlessly provide you access to Riiiver and related services. In addition to the specific sources listed below, all of these types of information may also be collected from our affiliates or subsidiaries within the Citizen group of companies: https://riiiver.com/en/privacy/group/.
•Identifiers, such as online identifiers, IP address, other persistent identifiers, name, username, email address, may be collected from third-party cookie providers, social media platforms, or other companies that you choose to link to your Riiiver account;
•Financial information, such as methods of payment, bank or credit card numbers;
•Biometric information, such as your likeness, step counts, temperature, heart rate, sleep patterns, speed, blood pressure, or behavioral tendencies that may identify you, from our partners; and
•Geolocation data, such as precise location, may be collected from location providers.

We may use your personal information for the following purposes:
•Identification and authentication: We use your identifiers to verify your identity when you access your Riiiver account and to ensure the security of your personal information;
•Operating Riiiver: We process your personal information to provide you with access to Riiiver, as you have requested;
•Improving Riiiver: We analyze information about how you use Riiiver to provide an improved experience all Riiiver users, including product testing and site analytics;
•Communicating with you: We may use your personal information to communicate with you, for example if we are providing information about changes to the terms and conditions or if you contact us with questions;
•Marketing: We may use your personal information to build a profile about you and place you into particular marketing segments in order to understand your preferences better and to appropriately personalize the marketing messages we send to you. We may also use your identifiers to send you marketing communications about Riiiver and other products or services that may be of interest to you;
•Exercising our rights: We may use your personal information to exercise our legal rights where it is necessary to do so, for example to detect, prevent and respond to fraud claims, intellectual property infringement claims or violations of law or our terms and conditions;
•Complying with our obligations: We may process your personal information to, for example, carry out fraud prevention checks or comply with other legal or regulatory requirements, where this is explicitly required by law;
•Customizing your experience: When you use Riiiver, we may use your personal information to improve your Riiiver experience, such as by providing interactive or personalized elements to your Riiiver apps or devices, providing you with content based on your interests, and allowing you to communicate with other Riiiver users; and
•Partnering with service providers. Citizen will partner with Google, LLC and Adobe Inc. (“Receivers”) in order to process personal information collected through, and to otherwise operate, Riiiver. For example, we use Google Analytics to track and report our web traffic to improve your experience on our websites, and Adobe Fonts to maintain Riiiver’s brand image on the website and display text in a manner that is easy to see. In turn certain personal information may be accessible to Google and Adobe through this service. Please visit https://policies.google.com/technologies/partner-sites learn how Google collects and uses your personal information through its Google Analytics and Google Tag Manager services, and https://www.adobe.com/privacy/policies/adobe-fonts.html to learn how Adobe collects information about you through our use of Adobe Fonts.
•Protecting against harm: We may use personal information as necessary to protect our systems or other individuals from potential harm.
•Aggregation or Anonymization. We may aggregate or de-identify any information collected about you through your use of Riiiver or otherwise, and we may use and/or disclose that aggregated or de-identified information for any purpose.

We may disclose certain categories of your personal information by sharing it with our service providers, business partners or affiliates, or by selling it to third parties. As used in this Policy, the “sale” of personal information refers to selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating your personal information to a third party for monetary or other valuable consideration, subject to certain exceptions under applicable law. As used in this Policy, when we “share” your personal information, we do only to achieve our own purposes and do not do so in exchange for monetary or other consideration. When transferring personal information to service providers, business partners and affiliates, we will ensure that such parties maintain a comparable level of protection of the personal information as set out in this Policy by using contractual or other means. To the fullest extent permitted by applicable law, Citizen excludes all liability arising from the use of your personal information by third parties. We can, on request, confirm the name and location of each third party that personal information is, or will be, transferred to.

Information we share

We may share your personal information with the following parties:
•Service providers and business partners: We engage service providers, such as VELDT Inc., and business partners to assist us with operating and providing you access to Riiiver. These service providers or business partners may perform marketing services, process secure payments, fulfill orders, optimize services, serve online behavioral advertising, send newsletters and marketing messages, support email and messaging services, and analyze information. Some of our service providers or business partners may engage their own service providers or business partners to further assist us. Unless otherwise specified, these companies will only use your personal information in the ways described in this Policy.
•Citizen group companies: Citizen has affiliates around the world, including Citizen Watch Company of America, Inc. Our affiliates work closely with each other to provide you access to Riiiver and other Citizen products and services from country to country. We may share your personal information among Citizen group companies for marketing purposes, security, optimization of products and services, and internal reporting. Unless otherwise specified, the Citizen group companies will only use your information in the ways described in this Policy.
•Where required by law: We may share your personal information with law enforcement agencies, courts, regulatory entities, other government or quasi-governmental authorities or other third parties where we believe necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party. Where it is reasonable to do so, we may also share your identifiers with any third party who makes a bona fide claim that material you have posted to our website violates their rights.
•In the context of a transaction: We may share your personal information with potential transaction partners, service providers, advisors, and other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell or transfer all or a portion of our assets or business.
The following categories of your personal information may be shared with these parties:
•Identifiers;
•Protected characteristics;
•Commercial information;
•Biometric information;
•Geolocation data;
•Internet or other electronic network activity information;
•Financial, medical, or health information;
•Audio, electronic, visual, thermal, olfactory, or similar information;
•Professional information; and
•Communications.

Third Party Services

Other than above, Citizen provides the option for you to connect your use of Riiiver to third party apps or services, or to other users of Riiiver. Where you agree that Citizen may provide your personal data to a third-party service provider or business partner in this manner, you should review each third party’s privacy policy in order to understand how the third party will use and disclose your personal information beyond the Riiiver platform.

Some consumers may have rights in relation to their personal information as conferred by local law. Below is a general description of the rights some consumers may hold. In the event you reside in such a jurisdiction and would like to exercise one of your rights, please contact us at [https://riiiver.com/en/contact/]. Please note that we may require additional information from you in order to honor your request.

•Right to access personal information: Users exercising this right may request access to the categories and specific pieces of their personal information we hold. When you ask to access your personal information, we will use reasonable efforts to comply with your request; however, we may not be able to allow you to access certain personal information in certain circumstances, for example, for legal, security or commercial proprietary reasons. Further, we may not be able to provide you with your personal information if collecting the information would prove burdensome (for example, it would be prohibitively costly to provide such personal information). In such cases, we will provide you with a reasonable explanation of why it is not possible to grant access to your personal data;

•Right to data portability: Users exercising this right may receive their personal information, when provided electronically, in a readily-useable format;

•Right to deletion: Users exercising this right can ask us to delete personal information of theirs from our servers. We may decline the request as permitted under applicable law;

•Right to disclosure: Users exercising this right can receive additional information regarding the sources from which we collected information, the purposes we collect and share personal information, the information of theirs we hold, and the categories of parties with whom we share their information;

•Sale or lease of personal information: As permitted by applicable law, we may sell your personal information, as that term is defined in this Policy;

•Right to be free from discrimination: Users may freely exercise these rights without fear of being denied goods or services. We may, however, provide a different level of service or charge a different rate reasonably relating to the value of your data; and

•Right to erasure: Users under the age of 18 may ask us to remove content or personal information about them that have been posted to any Riiiver website or applications by emailing us at support@riiiver.com. Please note that your request does not ensure complete or comprehensive remove of the content or information as, for example, some of your content may have been reposted by another user;

•Right to accuracy, completeness and currency: Users exercising this right may request rectification of inaccurate or incomplete personal information; and

•Right to withdraw consent: Users have the right to change their mind about consenting to the use, disclosure and transfer of their personal information in accordance with this Policy. If you withdraw your consent, we may not be able to provide you with our entire service.

We implement reasonable technological, organizational and administrative security measures designed to safeguard the personal information we process through Riiiver. These measures are aimed at providing on-going integrity and confidentiality for your personal information. However, no information system can be 100% secure, so we cannot guarantee the absolute security of your information.

We retain personal information we collect from you where we have an ongoing legitimate business need to do so for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements.

Your personal information may be transferred to, stored and/or processed outside your jurisdiction of residence and such jurisdiction’s data protection laws may differ from the jurisdiction in which you live. When we collect your personal information, it is collected on servers located in Japan. Your personal information may be transferred to servers located in the United States. We may also disclose your personal information to our affiliates located in the European Union, the United Kingdom, Japan and other Asian countries.
When your personal information is transferred outside your jurisdiction of residence, it may be accessible to law enforcement and government agencies of that jurisdiction.
We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Policy when transferred, processed or stored outside of your jurisdiction of residence, including by using appropriate safeguards (such as contractual commitments). Where we have engaged international third parties to perform services in respect of any personal information collected from you, we will use contractual or other means to ensure such third parties offer a comparable level of protection in respect of the personal information. For more information on the appropriate safeguards in place, please contact us at the details below.

We are committed to protecting the privacy of children. We do not knowingly collect information from people under the age of 13 without first obtaining the consent of their parent or guardian. If a child under the age of 13 has provided us with their personal information, we ask that a parent or guardian please contact us.

If you have questions about this Policy or our use of your personal information in relation to Riiiver, please contact us at support@riiiver.com.

We may modify or update this Policy from time to time. We encourage you to visit this Policy at least once per year to learn about any changes to the way we collect, use, or disclose your personal information. Where changes to the Policy will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights, including your right to withdraw your consent.

Last Updated: October 27, 2021