CA Privacy Policy
SeAH Group’s Privacy Policy for California Residents
Effective Date: January 1, 2023
This Privacy Policy for California Residents ("California Policy") supplements the information contained in our Policy above and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this California Policy to comply with the California Consumer Privacy Act, as amended by the California Consumer Privacy Rights and Enforcement Act of 2020, ("CCPA") and any terms defined in the CCPA have the same meaning when used in this California Policy.
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This Privacy Policy ("Policy") lets you know what information we collect about you or what information you may provide to us, including when you visit our website at www.seah.co.kr and related webpages (our "Website"), and our practices for using, disclosing, protecting and sharing that information.
This Policy was last updated on January 1, 2023.
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This Policy applies to information that we collect on our Website, in emails or other electronic messages between you and SeAH Holdings Corp. or SeAH Steel Holdings Corp., information you may provide us, including when you visit us, and information you provide to us when you contact us, subscribe to receive updates, or create an account with us.
Please read this Policy carefully to understand our practices regarding your information and how we will treat it. If you do not agree to the terms of this Policy, you should not use our Website. We reserve the right to update or modify this Policy from time to time. Where applicable data protection laws require us, we will provide appropriate notice, and take any necessary action, should we make any material changes to our practices. We encourage you to review this page periodically for the latest information on our privacy practices.
Children under the Age of 16. Our Website is not intended for use by children under the age of 16. We expect that any use of our Blog, including Storytelling posts, will be accessed and chaperoned by a parent. We do not knowingly collect, sell, or share personally identifiable information from children under 16. If you are under the age of 16, do not use or provide any information on our Website. If we learn we have collected or received personal information from a child under the age of 16 without proper consent, we will delete that information.
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We collect personal information from you in a variety of ways including, for example, when you visit our site, place an order, fill out forms, become a subscriber, or request to receive updates. The CCPA defines personal information by the categories in the table below, including the categories for sensitive personal information. This information may include personal information that can be used to identify you. Personal information does not include publicly available information from government records, or either deidentified or aggregated consumer information. We do not sell the personal information of California residents.
In particular, we have collected the following categories of personal information within the past twelve months:
Category Collected?
(Y/N)Sources Business or Commercial Purpose RetentionPeriod Sold/Shared/Disclosed to 3rd parties (if yes, include the categories of 3rd parties and the business purpose for selling/sharing/ or disclosing)A IdentifiersSuch as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name SSN, driver’s license number, passport number or other similar identifiers.YES data analytics provider YES 14months NO B Personal Information (Categories Listed in the Customer Records statute)Such as a name, signature, social security number, physical characteristics or description, postal address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit or debit card number, or any other financial information, medical information, or health insurance information. Note: Some information in this category may overlap with other categoriesNO C Protected ClassificationSuch as a name, signature, social security number, physical characteristics or description, postal address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit or debit card number, or any other financial information, medical information, or health insurance information. Note: Some information in this category may overlap with other categories.YES directly from the customers YES 14months NO D Commercial InformationSuch as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.NO E Biometric InformationSuch as 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 and health or exercise data.NO F Internet or other similar activitySuch as your browsing history, search history, and information regarding your interaction with our Website, advertisement, application and social media.YES data analytics provider YES 14months NO G Geolocation Data
YES data analytics provider YES 14months NO H Sensory DataSuch as audio, electronic, visual, thermal, olfactory, or similar information.NO I Professional or employment-related information
NO J Non-public education informationSuch as information that is not publicly available personally identifiable information as defined in the Family Education Rights and Privacy Act.NO K Inferences drawn from other PISuch as any inferences drawn from any information identified in the above categories to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.YES data analytics provider YES 14months NO SENSITIVE PERSONAL INFORMATION (1) (A) Your social security, driver’s license, state identification card, or passport number. NO (B) Your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. NO (C) Your precise geolocation (e.g., derived from a device to locate a consumer within a 1,850 foot radius). YES data analytics provider YES 14months NO (D) Your racial or ethnic origin, religious or philosophical beliefs, or union membership. NO (E) The contents of your mail, email, and text messages, unless the business is the intended recipient of the communication. NO (F) Your genetic data. NO (2) (A) The processing of biometric information for the purpose of uniquely identifying you. NO (B) Personal information collected and analyzed concerning your health. NO (C) Personal information collected analyzed concerning your sex life or sexual orientation. NO -
We may disclose your personal information to a third party for a business purpose or share your personal information with a third party subject to your right not to provide your information in those circumstances (see Sales Opt-Out and Opt-In Rights below). 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 share your personal information with the following categories of parties:
- •Our service providers;
- •Data marketing and analytical suppliers;
- •In Corporate Transactions. We may share your data with a potential buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of all or some of our assets. This may occur prior to the closing of such transaction.
- •Other Reasons. We may share your data to: (a) satisfy applicable law, regulations, legal process or valid governmental request; (b) enforce the terms of use applicable to our services, (c) detect, prevent or mitigate fraud or security or technical issues; or (d) protect against imminent harm to the rights, property or safety of our company, our customers or the public as required or permitted by law.
- Disclosures of Information
- •Personal Information
- In the preceding twelve (12) months, we have disclosed the following categories of personal information:
- Category A, Identifiers; Category F, Internet or other similar activity; Category G, Geolocation Data; and Category K, Inferences drawn from other PI.
- We disclose your personal information to the following categories of third parties:
- •Google Analytics 4
- Reselling Personal Information
The CCPA prohibits a third party from reselling personal information unless you have received explicit notice and an opportunity to opt-out of further sales. No businesses purchase personal information from us.
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If you are a California resident, the CCPA provides you with specific rights regarding your personal information. This section describes your CCPA rights and explains how to exercise those rights.
- Accessing Your 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 since January 1, 2022, including beyond the 12 month period preceding your request, unless doing so would involve disproportionate effort or is not possible. Once we receive and confirm your verifiable consumer request, 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, selling, or sharing that personal information;
- •The categories of third parties to whom we disclose that personal information;
- •The specific pieces of personal information we collected about you (also called a data portability request);
- •If we sold, shared, or disclosed your personal information for a business purpose:
- •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.
- Requesting Deletion of Information
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, we will delete (and notify our service providers and contractors to delete, [and to the extent possible and within reasonable efforts, notify any third parties to whom we have sold or shared your personal information 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:
- •Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service that you requested, take actions reasonably anticipated by you within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- •Help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes.
- •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 that conforms or adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the ability to complete such research, if you previously provided informed consent.
- •Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and compatible with the context in which you provided the information.
- •Comply with a legal obligation.
- Right to Correct Information
You have the right to request that we correct any inaccurate personal information that we have about you. Once we receive and confirm your verifiable consumer request, we will use commercially reasonable efforts to correct any inaccurate information and we will instruct our service providers or any contractors to correct such information. We will also inform you whether or not we have complied with your request, including any basis for denial of the request.
- Exercising Access, Data Portability, Correction and Deletion Rights
To exercise the access, data portability, correction, and deletion rights described above, please submit a verifiable consumer request to us by:
- •Emailing us at seahpr@seah.co.kr
- •Submitting such a request by mail to SeAH Tower 30F, 45 Yanghwa-ro, Mapo-gu, Seoul 04036, Republic of Korea
Only you, or a person registered with the California Secretary of State that you authorize 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. If you submit a request on behalf of another person, we may require proof of authorization and verification of identity directly from the person for whom you are submitting a request.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable 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: a name, telephone number and email address.
- •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 your password protected account 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
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact seahpr@seah.co.kr
We endeavor to respond to a verifiable consumer within 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, which may include either a screen shot of the information or a pdf.
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
Under the CCPA, if you are 16 years of age or older, you have the right to direct us not to sell your personal information at any time (the "right to opt-out"). To exercise the right to opt-out, you, or your authorized representative, may submit a request by:
- •Emailing us at seahpr@seah.co.kr
- •Submitting such a request by mail to SeAH Tower 30F, 45 Yanghwa-ro, Mapo-gu, Seoul 04036, Republic of Korea
You will need to provide your First Name, Last Name, Email Address and confirmation that you are a resident of California.
Once you make an opt-out request, we will wait at least 12 months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to sharing personal information by emailing.
You do not need to create an account with us to exercise your opt-out rights. We will only use your personal information provided in an opt-out request to review and comply with the request.
- Sensitive Personal Information Use and Disclosure Limitation Rights
Under the CCPA, if you are 16 years of age or older, you have the right to direct us to limit the use and disclosure of your sensitive personal information for [INSERT ADDITIONAL PURPOSE FOR USE OF SENSITIVE PERSONAL INFORMATION IDENTIFIED ABOVE (I.E. BEYOND THE BULLET-POINT LIST)] at any time (the "right to limit "). To exercise the right to limit, you, or your authorized representative, may submit a request by:
- •Emailing us at seahpr@seah.co.kr
- •Submitting such a request by mail to SeAH Tower 30F, 45 Yanghwa-ro, Mapo-gu, Seoul 04036, Republic of Korea
You will need to provide your First Name, Last Name, Email Address and confirmation that you are a resident of California.
Once you make a limitation request, we will wait at least 12 months before asking you to reauthorize use and disclosure of your sensitive personal information. However, you may change your mind and opt back in to the use and disclosure of your sensitive personal information by emailing.
You do not need to create an account with us to exercise your limitation rights. We will only use your personal information provided in a limitation request to review and comply with the request.
- Non-Discrimination
We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by the CCPA, we will not:
- •Deny you goods or services.
- •Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- •Provide you with a different level or quality of goods or services.
- •Suggest that you may 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 under the CCPA. For example, [include succinct summary of financial incentive; link to the material terms of the financial incentive, including the categories of personal information that are implicated and the value of the data; how the consumer can opt-in to the financial incentive; a statement of the consumer’s right to withdraw from the financial incentive at any time and how the consumer can exercise that right; and an explanation of how the price or service difference is reasonable related to the value of the consumer’s data, including (a) a good faith estimate of the value of the consumer’s data that forms the basis for offering the price or service difference, and (b) a description of the method (s) the business used to calculate the value of the consumer’s data.]
- Changes to the Privacy Policy
We reserve the right to change this California Policy. If we decide to make changes, we will post the updated policy on our Website so you are always aware of what information we collect, how we use it, and the circumstances, if any, we disclose it. The date this California Policy was last revised is identified at the top of the page. You are responsible for ensuring that we have an up-to-date active and deliverable email address for you and for periodically visiting our website and the Policy to check for any changes. Your continued use of our Website following the posting of changes constitutes acceptance of such changes. Where required by applicable data protection laws, we will also seek your consent to any material changes that affect how we use your information.
- Help
If you need help with unsubscribing, or have questions regarding this California Policy, the ways in which we collect, share, and use your information as described in this Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at seahpr@seah.co.kr.