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, process and disclose about you. Personal information is information, or a combination of pieces of information that could reasonably allow you to be identified.

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:

•Personal details, such as your name, gender, age, date of birth, nationality, postal address, telephone number, email address, account username and password, log in details for third-party services you choose to connect to your account or other similar information;
•Riiiver usage 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 information, such as methods of payment, bank or credit card numbers;
•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.

Special categories of personal data

In some jurisdictions, some of the categories of information that we collect are special categories of personal data (also known as sensitive personal information), such as medical and health information, including your likeness, step counts, temperature, historical heart rate, sleep patterns, blood pressure, or other health-related data that may identify you.

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, you may still use our service though your access to some functionality may be restricted. Detailed information on the Cookies and Tracking Technologies we use and the purposes for which we use them are provided set out in our Cookies policy.

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; and
•Internet or other electronic network activity information, such as browsing history, search history, device status and sensor data, or information regarding your interaction with any websites, applications, or devices associated with Riiiver.

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 listed at 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; and
Health data, such as your likeness, step counts, temperature, heart rate, sleep patterns, speed, blood pressure, and other personal data relating to the physical or mental health of an individual, from our partners..

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;
•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, and in turn certain personal information may be accessible to Google 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 Typekit.; and
•Protecting against harm: We may use personal information as necessary to protect our systems or other individuals from potential harm.

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 must have a legal basis to process your personal information. In most cases the legal basis will be one of the following:

•to fulfil our contractual obligations to you, for example to provide a services that you have requested;
•to meet our legitimate interests, for example to understand how you use our services and to enable us to derive knowledge from that enable us to develop new services. When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.

We may obtain your explicit consent to collect and use certain types of personal information when we are required to do so by law (for example, in relation to our direct marketing activities, or when we process sensitive personal information). If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this privacy notice.

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 https://riiiver.com/en/privacy/group/, 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;
•Health 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.

Information we sell

If you otherwise agree to your personal data being processed by a third-party service provider or business partner that provides you with its services through Riiiver in connection with our products or services (“Other Receiver”), Citizen may sell your personal information to such Other Receivers.

While much of Receivers’ and Other Receivers’ involvement in Riiiver will be based on information shared with Receivers and Other Receivers as a service provider or business partner, you should review each Receiver’s and Other Receiver’s privacy policy in order to understand how the Receiver and Other Receiver will use and disclose your personal information beyond the Riiiver platform. The following categories of your personal information may be sold to any of our Receivers and Other Receivers:

•Identifiers;
•Protected characteristics;
•Commercial information;
•Health 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.

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: 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 provide you to access to personal information where an exemption to this right applies under the local law. 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 erasure: Users exercising this right may request erasure of their personal information;

•Right to rectify: Users exercising this right may request rectification of inaccurate or incomplete personal information;

•Right to restrict: Users exercising this right may request that we restrict our use of their 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.

You also have the right to lodge a complaint with your local data protection authority.

We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate.

We implement technical and organisational measures to ensure a level of security appropriate to the risk to the personal information we process through Riiiver. These measures are aimed at providing on-going integrity and confidentiality for your personal information. We evaluate these measures on a regular basis to ensure the security of the processing however, no information system can be 100% secure, so we cannot guarantee the absolute security of your information.

We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to:

•Maintain business records for analysis and/or audit purposes
•Comply with record retention requirements under the law
•Defend or bring any existing or potential legal claims
•Deal with any complaints regarding the services

We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.

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. 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 (or under the age of 16, where local law requires) without first obtaining the consent of their parent or guardian. If a child under the relevant age has provided us with their personal information, we ask that a parent or guardian please contact us.

Citizen Watch Co., Ltd is the controller responsible for the personal information we collect and process.

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.

Our Data Protection Officer of UK can be contacted at:
Contact Title is : GDPR Officer
Enquiry Desk is: GDPR Data Protection
Email Address is : privacy@citizenwatch.co.uk

Our Data Protection Officer of the Republic of Ireland can be contacted at:
Contact Title is : Data Protection Officer
Enquiry Desk : Data Protection Office
Email Address is : dataprotection@solatrex.com

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to your local data protection authority.

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: December 16th, 2022