Effective (last updated) Date: March 10, 2025

This Kowa U.S. Online Privacy Notice (“Online Privacy Notice”) provides notices regarding the online data practices of the following Kowa entities: Kowa Company, Ltd. (“KCL”), Kowa Holdings America, Inc. (“KHD-AM”), Kowa American Corp. LA Branch (“KAC-LA”), Kowa American Corp. – Chemical (“KAC-Chem”), Kowa American Corp. – Lifestyle (“KAC-Lifestyle”), Kowa Research Institute, Inc. (“KRI”), Kowa Pharmaceuticals America, Inc. (“KPA”), and Kowa Health Care US Company, Ltd. (“KHC”) (collectively referred to in this Online Privacy Notice as “Kowa,” “we,” “us,” and “our””), and applies to our U.S. online services (including websites, and emails) that post a link to this Online Privacy Notice (“Online Services”). Other of our online properties may post different privacy notices that will apply to those services (e.g., our non-U.S. websites).

Do not use our Online Services if you do not accept our data practices as described in this Online Privacy Notice and agree to our Terms of Use.

Section B includes information regarding changes to this Online Privacy Notice and Section C lists our contact information.

Collectively, Sections A-C are our Online Privacy Notice, and supplement our U.S. Privacy Policy, which provides detail on our broader personal data practices and how to exercise additional consumer rights of residents of certain states not explained in this more limited Online Privacy Notice. As more fully explained in our U.S. Privacy Policy, the Kowa entities offer different products and services through which they may collect Online Services PD (defined below) and the entities operate their personal data practices independently.

Additional notices may be made at the point of collection, in which case those will supplement this Online Privacy Notice and govern that collection in the event of a conflict with this Online Privacy Notice. In the event of a conflict between any other Kowa policy, statement, or notice and this Online Privacy Notice, this notice will prevail as to Online Services PD collected via our Online Services, except where additional notices are posted at collection that are said to modify or supplement this Online Privacy Notice. Capitalized terms used but not defined herein will have the meanings given to them, as applicable, in our U.S. Privacy Policy or in applicable U.S. laws where we are subject to such laws, which may differ from one applicable jurisdiction to another.

To see and print our full Online Privacy Notice, click here. You can also request disability access assistance by contacting us as set forth in Section C.

1. NOTICE OF ONLINE PD PRACTICES

   This Online Privacy Notice applies to all users of our Online Services, regardless of if you are a resident of a state with State Privacy Laws. Section A.6 applies only to users from outside of the U.S.

   This Online Privacy Notice applies to “Online Services PD,” which is Personal Information or Personal Data (collectively “PD”)(as those terms are defined under State Privacy Laws, see U.S. Privacy Policy) that is collected through the Online Services. To the extent we combine your Online Services PD with data we receive outside of the Online Services or with deidentified data, we will treat the combined data as Online Services PD and apply this Online Privacy Notice to such combined data, unless we have disclosed otherwise. As permitted by applicable law, we do not treat Online Services PD that has been deidentified or aggregated as PD and we reserve the right to convert, permit others to convert, your Online Services PD into deidentified or aggregate data. We will not attempt to reidentify data that we maintain as deidentified.

   1. Data We Collect

      Kowa and the third parties we have retained to perform or provide certain services or functions to us (“Vendors”) collect Online Services PD in a number of ways:

      1. Data That You Provide

         The Online Services are publicly available. We may collect Online Services PD from you when you interact with, or submit your data through, the Online Services, such as when you fill out forms (e.g., Contact Us form); correspond with us by phone, e-mail or otherwise; subscribe to notifications (e.g., email alerts); search for content; interact with our social media functions on the Online Services; participate in contests, sweepstakes and other promotions; and when you report a problem with our Online Services. The Online Services PD you give us may include, but is not limited to, your name, address, email address, phone number, the content of your communication, and any other data you choose to provide to us. You are responsible for ensuring the accuracy of the data you submit to Kowa. Inaccurate data may affect your ability to use the Online Services, the data you receive when using the Online Services, and our ability to contact you. For example, your email address should be kept current.

      2. Other Data Collected About You

         When you access or use the Online Services, Kowa, our Vendors, and/or third-party websites, apps, locations, platforms, code (e.g., plug-ins and application programming interfaces (“API”), and software development kits (“SDKs”)), or other services (“Third-Party Services”), may automatically collect the following data (note, however, that the privacy policy of that Vendor and/or Third-Party Service also apply to your interaction):

         • Usage data, including the URL from which you linked to the Online Service, how you use and interact with the Online Service, what pages you visit, and which hyperlinks you click. For instance, we and others may collect usage data to analyze usage trends to understand how individuals use the Online Service to help us improve the user experience, better serve you more relevant content and ads, and to provide customer assistance and technical support.
         • Technical data, including data regarding your Internet Protocol (“IP”) address, device type, device operating system, browser type you use to access the Services, the unique device identifier (“UDID”) or mobile equipment identifier (“MEID”) for your mobile device, and other data (“Device Identifiers”). For instance, we and others may use such Device Identifiers to associate data collected via different devices, or during separate interactions with us on the Online Services on the same device.
         • Data about you from cookies and other similar “Tracking Technologies” (e.g., pixels, embedded scripts, etc.), which may be considered PD under applicable laws. For instance, we and others may use such Tracking Technologies, to distinguish you from other users of the Online Service, to improve your experience on and off of the Online Service, including to serve you more relevant content and ads, to improve the Online Service, and our other products and services, and for other functions.

         Kowa, and our Vendors and Third-Party Services, may use Tracking Technologies to, for instance, help us collect data about interactions with the Online Service, other online services, and/or our emails, including data about your browsing and information or service request behaviors. These methods enable Kowa to serve you better and more efficiently, and to personalize your experience. These methods may include:

         • Cookies. A cookie is a small text file that is stored on a user’s device, which may be session ID cookies or tracking cookies. Session cookies make it easier for you to navigate the Online Services and expire when you close your browser. Tracking and other persistent cookies remain longer and help in understanding how you use the Online Services, enhance your user experience, and perform other functions such as facilitating analytics and Targeted Advertising and remembering you and your preferences when you return. Persistent cookies may remain on your device for an extended time. The Online Services may associate some or all types of these cookies with your devices. If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked, which may cause some Online Services features and functionalities to not work.
         • Web Beacons/Tracking Pixels (“Pixels”). Pixels are small graphic images, also known as “Internet tags” or “clear gifs”, embedded in webpages and e-mail messages. Pixels may be used, without limitation, to count the number of visitors to the Online Services, to monitor how users navigate the Online Service, to determine if our emails are opened, and to count content views.
         • Embedded Scripts. An embedded script is programming code designed to collect information about your interactions with the Online Services. It is temporarily downloaded onto your device from Kowa’s web server, or from a third party with which Kowa works, and is active only while you are connected to the Online Services and deleted or deactivated thereafter.
         • Location-Identifying Technologies. Our Online Services may provide you the ability to enable location-identifying technologies, for example, to help you find the closest location that sells our products in-person. To stop utilizing, or to change the settings with respect to location-identifying technologies, you can change your device or browser preference settings.
         • Device Recognition Technologies. Technologies, including application of statistical probability to data sets, as well as linking a common unique identifier to different device use (e.g., Facebook ID) that attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user or household) (“Cross-device Data”).
         • Device and Activity Monitoring and Session Replay. Technologies that monitor, and may record, certain of your interactions with the Online Services including, without limitation, keystrokes, and/or collect and analyze information from your device, such as, without limitation, your operating system, plug-ins, system fonts, and other data, for purposes such as identification, security, fraud prevention, troubleshooting, tracking and/or improving the Online Services and customizing or optimizing your experience on the Online Services. This may also include technologies that monitor and record usage sessions to help us better understand, track, and improve the usage of our Online Services.

         We are giving you detailed notice of the tracking technologies and your choices regarding them so that your consent is meaningfully informed. For information on how to exercise preferences as to our features, functionality, and communications, see the Choices: Tracking and Communications Options section below. For more information on Third-Party Services’ data collection and practices, and the choices they may offer you, please refer to the Third-Party Services section below.

   2. How We Use Your Online Services PD

      Kowa may use data about you, including Online Services PD, for any purposes not inconsistent with Kowa’s statements under this Online Privacy Notice and our U.S. Privacy Policy, or otherwise made by us in writing at the point of collection, to the extent permitted by applicable law including, without limitation, the following:

      • To operate and improve our Online Services;
      • To provide you with information, products and services you request, view, or engage with;
      • To communicate with you regarding information, products and services you request, view, or engage with;
      • To send you offers and promotions for our products and services or third-party products and services;
      • To facilitate, manage, personalize and improve your online experience;
      • To market our products and services, including by providing you with advertising based on your activity on the Online Services and on third-party websites and applications and to operate contests, sweepstakes and other promotions;
      • To send you notices to inform you about important changes and updates to the Online Services;
      • To operate, optimize, analyze the use of, improve and enhance the Online Services, including by using survey, research and analytics tools;
      • For auditing, compliance and legal purposes, to protect the rights and property of Kowa, its partners and customers and other users of the Online Services and to investigate potential violations of and to enforce our Terms of Use;
      • To detect, investigate and prevent activities that may violate our policies, pose safety issues or be fraudulent and illegal;
      • To respond to requests from legal and regulatory enforcement authorities, as appropriate and to the extent permitted or required by law; and/or
      • For all other purposes related to our business that are reasonably proportional to the forgoing purposes, or otherwise subject to your consent.
   3. How We Disclose Your Online Services PD

      We may disclose your Online Services PD for any purpose not inconsistent with our statements under this Online Privacy Notice and our U.S. Privacy Policy, or statements otherwise made by us in writing at the point of collection, and not prohibited by applicable law. We disclose Online Services PD to Vendors. Other instances when we may disclose any Online Services PD to outside parties include:

      • When we reasonably believe that such disclosure is permitted or required by law or pursuant to legal process or is necessary in connection with actual or threatened litigation or to protect Kowa or third parties.
      • We may disclose your Online Services PD to third parties in connection with a Corporate Transaction, such as the sale, purchase, merger, reorganization, liquidation, or dissolution of Kowa, or under similar circumstances.
      • In connection with the purposes set forth in the How We Use Your Online Services PD section above.
   4. Choices: Tracking and Communications Options
      1. Tracking Technologies Generally

         Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. Please be aware that if you disable or remove these technologies, some parts of the Online Services may not work and that when you revisit the Online Services. Your ability to limit browser-based tracking technologies is subject to your browser settings and limitations. Accordingly, you may want to consider the more limited opt-out choices noted in the next section.

         Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, Kowa currently does not alter Kowa’s practices when Kowa receives a “Do Not Track” signal from a visitor’s browser. However, we do honor browser signals known as “Global Privacy Controls” and provide cookie preference tools on our Online Services as more fully explained in the Do Not Sell/Share/Target Opt-out subsection of the U.S. Privacy Policy.

         Some third parties, however, may offer you choices regarding their tracking technologies. For specific information on some of the choice options offered by third party analytics and advertising providers, see the next section. We do not represent that these third-party tools, programs or statements are complete or accurate.

         You will need to set preferences on each device and browser that you use to access our Online Services and clearing cookies on your browser(s) may disable some preference settings.

      2. Analytics and Advertising Tracking Technologies

         Kowa may engage and work with Vendors and other third parties to serve advertisements on the Online Services and/or on other online services. Some of these ads may be tailored to your interest based on your browsing of the Online Services and elsewhere on the Internet, which may include use of precise location and/or Cross-device Data, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Targeted Advertising”). This may include sending you an ad on another online service after you have left our Online Services (i.e., retargeting).

         You may choose whether to receive some Interest-based Advertising by submitting opt-outs through the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, including use of Cross-device Data for serving ads, visit http://www.aboutads.info/choices/. Please be aware that, even if you opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads, including Targeted Advertising. Opting out only means that those selected DAA members should no longer deliver certain Interest-based Advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks) or have your PD Sold, Shared or Processed for Targeted Advertising. Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your DAA browser-based opt-out may not, or may no longer, be effective. Kowa supports the DAA’s Self-Regulatory Principles for Online Behavioral Advertising which are available for download at https://digitaladvertisingalliance.org/principles and expects that ad networks Kowa directly engages to serve you Interest-based Advertising will do so as well, though Kowa cannot guaranty their compliance. Also note that the DAA program is national and not the same as Do Not Sale/Share/Target Opt-out Rights under State Privacy Laws. Residents of states with State Privacy Laws have broader opt-out rights that will more effectively limit Targeted Advertising, as more fully explained in the Do Not Sell/Share/Target Opt-out subsection of the U.S. Privacy Policy.

         We may also use Google Ad Services. To learn more about the data Google collects and how your data is used by it and to optout of certain Google browser Interest-Based Advertising, please visit: http://www.google.com/settings/ads.

         In addition, we may serve ads on other online services that are targeted to reach people on those services that are also identified on one of more of our data bases (“Matched List Ads”). This is done by using tracking technologies or by matching common factors between our data bases and the data bases of the other online services. For instance, we may use such ad services offered by Meta (Facebook and Instagram) or X (f/k/a Twitter) and other Third-Party Services, which may offer user controls that you can use to limit Matched List Ads. We are not responsible for these Third-Party Services, including without limitation their security of the data or their failure to comply with your or our opt-out instructions, they may not give us notice of opt-outs to our ads that you give to them, and they may change their options without notice to us or you.

         Kowa may use Google Analytics or other Vendors for analytics services. These analytics services may use cookies and other tracking technologies to help Kowa analyze users and how they use the Online Services. Data generated by these analytics services (e.g., your IP address and usage data) may be transmitted to and stored by these Vendors on servers in the U.S. (or elsewhere) and these Vendors may use the data for purposes such as evaluating your use of the Online Services, compiling statistic reports on the Online Services’ activity, and providing other services relating to Online Services activity and other Internet usage. Kowa is not responsible for, and makes no representations regarding, the policies or business practices of any third parties, including, without limitation, analytics Vendors and Third-Party Services associated with the Online Services, and encourages you to familiarize yourself with and consult their privacy policies and terms of use.

         You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.

         Kowa is not responsible for effectiveness of, or compliance with, any third parties’ opt-out options or programs or the accuracy of their statements regarding their programs.

         Residents of certain U.S. states have additional, more comprehensive, rights more fully explained in the Do Not Sell/Share/Target Opt-out subsection of the U.S. Privacy Policy.

      3. Communications

         We may send certain promotional communications (emails or text messaging) and you can opt-out of receiving such communications from us at any time, as applicable. However, because each Kowa entity manages its own marketing, communications and information governance programs, you must opt-out separately to each entity for email, and separately for each text program and mobile app as follows:

         • Promotional Emails. To opt out of promotional emails, follow the instructions provided in emails or by clicking on the “Unsubscribe” link, or if available by changing your communication preferences by logging into your account.
         • Text Messages. To opt out of receiving our text messages, text the word “STOP” in response to a text we send you, and follow any other opt-out instructions provided in the text messages we send you.

         Please note that your opt-out is limited to the email address or phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt-out of receiving promotional communications, we may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or our ongoing business relations.

      4. Third-Party Services

         This Online Privacy Notice only applies to the processing activities of Kowa through the Online Services. As described above, the Online Services may include or link to Third-Party Services, such as, for example, third-party websites, apps, locations, platforms, code (e.g., plug-ins, APIs, or other services. These Third-Party Services may use their own cookies, web beacons, and other tracking technologies to independently collect data about you and may solicit PD from you.

         Certain functionalities on the Online Services may permit interactions that you initiate between the Online Services and certain Third-Party Services, such as third-party social networks (“Social Features”). Examples of Social Features include: enabling you to send content such as contacts and photos between the Online Services and a Third-Party Service; “liking” or “sharing” Kowa’s content; logging in to the Online Services using your Third-Party Service account (e.g., using Facebook Connect to sign-in to the Online Services); and to otherwise connect the Online Services to a Third-Party Service (e.g., to pull or push information to or from our Online Service). If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Online Services or by the Third-Party Service that you use. Similarly, if you post information on a Third-Party Service that references the Online Services (e.g., by using a hashtag associated with Kowa in a post or status update), your post may be used on or in connection with the Online Services or otherwise by Kowa. Also, both Kowa and the third party may have access to certain data about you and your use of the Online Services and any Third-Party Service.

         If you follow a link to any Third-Party Services (including the “Opportunities” website that is linked on the Online Services, which is hosted by a third party), please note that those websites have their own privacy statements and that we do not accept any responsibility or liability for those practices. Please check the privacy statements, terms of use and other notices posted by those other third parties before visiting the third party’s website or submitting any personal data via Third-Party Services.

      5. Additional Notices for Users Outside of the U.S.

         The Online Services PD we and our Vendors collect via the Online Services is governed by U.S. law. We have other online services operated outside of the U.S., which have their own terms and privacy policies and notices and are governed by the law of the applicable jurisdiction(s). If you are accessing our U.S. Online Services from outside of the U.S., please be aware that information collected through the Online Services may be transferred to, processed, stored, and used in the U.S. Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Online Services, or provision of any information therefore, constitutes your acknowledgement of the transfer to and from, processing, usage, sharing, and storage of your information, including PD, in the U.S. (and potentially other territories worldwide) as set forth in this Online Privacy Notice.

      6. Data Retention, Security and Monitoring

         Kowa will retain the Online Services PD that is subject to this Online Privacy Notice for as long as reasonably necessary to achieve the purpose for which you provided it, or to the extent necessary for Kowa to protect its rights, or as otherwise permitted or required by applicable laws.

         Kowa maintains reasonable administrative, technical and physical safeguards to protect your PD against loss, misuse, unauthorized access, disclosure, alteration or destruction. Nevertheless, transmission via the Internet and online digital storage are not completely secure and Kowa does not guarantee the security of your PD or of the Online Service.

         To help protect you and others, Kowa and its Vendors may (but make no commitment to) monitor use of the Online Service, and may collect and use related information for all purposes not prohibited by applicable law or inconsistent with this Online Privacy Notice, including, without limitation, to identify fraudulent activities and transactions; prevent abuse of, and investigate and/or seek prosecution for, any potential threats to or misuse of the Online Service; ensure compliance with the Terms of Use; investigate violations of or enforce these policies; improve the Online Services and your user experiences, and to protect the rights and property of Kowa, third parties, and other users. Monitoring may result in the collection, recording, and analysis of online activity or communications through our Online Services. If you do not accept these conditions, you must discontinue your use of the Online Services.

      7. Children and Teens

         Our Online Services are intended for individuals who are of the age of majority in the jurisdiction in which they reside, and are not directed at, marketed to, nor intended for children or other minors. Kowa does not knowingly collect any data, including Online Services PD, from children or other minors. If you believe that we have inadvertently collected data from a child under 13 years of age, please contact us, and we will take immediate steps to delete or otherwise treat the data as required by applicable law. Some State Privacy Laws provide additional consideration for children and teens. More information on the privacy of the PD of / from children and, where regulated by State Privacy Laws, teens (collectively “Child-Aged”) Consumers is included in the Child-Aged Consumers of Certain States subsection of the U.S. Privacy Policy.

2. CHANGES TO THIS NOTICE

   We reserve the right to change this Online Privacy Notice prospectively effective upon the posting of the revised Privacy Policy. We also reserve the right to update and modify this Online Privacy Notice at any time without other form of notice, but from time to time, we may also notify you by email, or otherwise, when appropriate. Additional or different practices may be disclosed at the point of collection without changing the Online Privacy Notice. Any modifications will apply only to Online Services PD we may collect after posting the updated Online Privacy Notice unless we obtain your consent. Please check frequently to see any updates or changes to this Online Privacy Notice. To the extent any provision of this Online Privacy Notice is found by a court of competent jurisdiction, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

3. CONTACT US

   If you have any questions or comments about this Online Privacy Notice or the Service, please email us at contact@kowa.com or call us at (888) 710-6525.