Effective Date: January 1, 2020

1. INTRODUCTION

WDI International, Inc, (“WDI” “we”, “us”, or “our”) values your privacy. In this Privacy Policy (“Policy”), we describe what information we collect from you, why we collect it and use it, and how you can manage, export, and delete your information. “You” or “Your” refers to you, a user of our Site or Services.

• This Policy explains how we collect, use, protect, and disclose personally identifiable information and data (“Personal Information”) when you use the WDI Restaurants website at https://www.wdi.co.jp/en/restaurants and to notify you about marketing and promotional opportunities. For example, we may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you. We also may use the information that we learn about you to assist us in advertising our Site and Services on third-party websites.
  To better understand how users access and use our Site and Services, both on an aggregated and individualized basis, in order to improve our Site and Services and respond to user desires and preferences, and for other research and analytical purposes.

How We Share Your Information
We may share your Personal Information as follows:

• Affiliates. We may disclose the Personal Information we collect from you to our affiliates that own and operate our various restaurants; however, if we do so, their use and disclosure of your Personal Information will be maintained by them in accordance with this Policy.
• Service Providers. We may disclose the Personal Information we collect from you to third-party vendors, service providers, contractors or agents who perform functions on our behalf (“Service Providers”). For example, we may contract with Service Providers to provide certain services, such as hosting and maintenance, data storage and management, property management, and marketing and promotions. We only provide our Service Providers with the information or access to information necessary for them to perform these services on our behalf. Each Service Provider must agree to use commercially reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect your Personal Information from unauthorized acquisition, access, use, or disclosure. Service Providers may only use the Personal Information to provide services to WDI and are prohibited from using Personal Information other than as authorized by WDI under this Privacy Policy.
• Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, or if we are in negotiations with respect to any such transaction, we may transfer the Personal Information we have collected from you to the other company or legal entity.
• In Response to Legal Process. We also may disclose the Personal Information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a subpoena.
• To Protect Us and Others. We also may disclose the Personal Information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of any applicable Terms and Conditions for Services provided through this Site or this Policy, or as evidence in litigation in which we are involved.
• Aggregate and De-Identified Information. We may share aggregate or de-identified Personal Information about users with third parties and publicly for marketing, advertising, research, or similar purposes.

Except as noted in this Section 4, we do not disclose Personal Information to third parties, including for their direct marketing purposes, without your consent, except as explained in this Policy.

Retention of Personal Information
We retain Personal Information about you for the time necessary to accomplish the purpose for which such information was collected, usually for the duration of any contractual relationship or as long as you use or are registered for any of the Services and for any period thereafter as legally required or permitted by applicable law. Our retention policies respect applicable statute of limitation periods and legal requirements.

Our Use of Cookies and Other Tracking Mechanisms
We and our Service Providers use cookies (only when the user is asked to select a location), web beacons, and other tracking mechanisms to track information about your use of our Site and Services. We may combine this information with other Personal Information we collect from you (and our Service Providers may do so on our behalf).

Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies), but such disabling will impair use of the Site and Services.

Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Services. There are two types of cookies: session and persistent cookies.

• Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
• Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. Visitors to our Site who disable cookies will not be able to browse certain areas of the Site or use the Services.
Third-Party Analytics. We may use automated devices and applications, such as Google Analytics, to evaluate usage of our Site and Services. We also may use other analytic means to evaluate our Services. We use these tools to help us improve our Services, performance, and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not share your Personal Information with these third parties unless we have your prior consent to do so. For more information on Google analytics, including how to opt-out, go to https://tools.google.com/dlpage/gaoptout.

Security
We maintain physical, technical, and administrative safeguards to protect the security of information transmitted to us through this Site or Services. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the Site or Services, we cannot and do not guarantee the security of any information you transmit on or through the Site or Services, and you do so at your own risk. You are also responsible for maintaining the security of any password or user login credentials you are provided in connection with the Site or the Services. You should use robust passwords that are not easily guessed.

Links to Other Websites
Our Site and Services may contain links to other websites, including websites that collect data or solicit Personal Information, or allow others to send you such links. A link to a third party’s website does not mean that we endorse it or that we are affiliated with it. We do not exercise control over third-party websites and are not responsible for their privacy and security policies and practices. You access such third-party websites or content at your own risk. We encourage users to be aware when they leave this Site and to read the privacy policy of a third-party website before providing any information to the third-party website.

Children’s Privacy
We do not intend for our websites or other online services to knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow minors under the age of 13 to disclose their Personal Information to us through our Site. Our Site is directed to individuals who are over 18 and are permitted to share their Personal Information without parental consent. If you believe that we might have any information from a child under 13, please contact us as directed below in the “How to Contact Us?” section. You may mark your inquiry “COPPA Information Request.” Parents can learn more about how to protect children’s privacy online here.

Processing in the United States
Please be aware that, depending on your location, your Personal Information and communications may be transferred to and maintained on servers or databases located outside your state, province, or country. If you are located outside of the United States, please be advised that we store all Personal Information in the United States. The laws in the United States may not be as protective of your privacy as those in your location. By using the Site or Services, you agree that the collection, use, transfer, and disclosure of your Personal Information and communications will be governed by the applicable laws in the United States.

How to Contact Us?
You may address all communications to our Restaurant Support Center (310) 533-3201, or email to info@wdiusa.com Please include your name, address, and phone number, or email in all communications and state clearly the nature of your request.

Complaints
If you feel that WDI has not complied with the policies outlined in this Privacy Policy, please contact us at (310) 533-3201, or email to info@wdiusa.com. Please include your name, address, and phone number, or email in all communications and state clearly the nature of your request. The Company will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Policy within thirty (30) days of receiving the complaint, unless a shorter period is required by law.

Privacy Policy Changes
We may change this Privacy Policy from time to time. If we decide to change this Policy, we will inform you by posting the revised Policy on the Site. Any changes will go into effect on the “Revised” effective date shown in the revised Policy. By continuing to use the Site or Services, you consent to the revised Policy.

2. YOUR RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT

If you are a California resident who has provided Personal Information to WDI, or a California resident that reasonably believes that WDI collected or stores their Personal Information, you may exercise your rights under the CCPA and submit your requests in one of the following methods: (a) by emailing us at the email listed below; (b) by calling the following number (310) 533-3201.

NOTE: we do not sell your Personal Information as that term is defined in the CCPA.

You have the right to request WDI to:

• (a) Disclose if we have collected Personal Information on you;
• (b) Disclose the categories of Personal Information that we have collected on you (if any);
• (c) Disclose the Personal Information that we have collected on you (if any); and
• (d) Delete Personal Information we have collected on you (if you satisfy the conditions set out in the CCPA).

If you do not have an account with us, and your request concerns “categories” of Personal Information collected, we can request from you two data points of personal information to verify your identity. If you do not have an account with us, and your request concerns specific Personal Information, we can request from you at least three data points of Personal Information as well as a signed declaration with penalty of perjury to verify your identity.

Please note that following your verified request, we will send you your Personal Information from the following email address: info@wdiusa.com (Any response to your request, including any Personal Information may be sent as an encrypted file).Please note that once you have submitted a request, we will send you a receipt, acknowledging your request, within 10 days. If, for some reason, you do not receive such a receipt within 10 days of your submitted request, please send us an email to info@wdiusa.com as an error may have occurred.
We will process and respond to your request within 45 days after it is received (in some cases, as is allowed under the CCPA, this process may be extended by an additional 45-90 days).

Please note, that regarding requests under subsections (a), (b), and (c) above, you may only make two requests in a 12-month period, and the information provided need only cover the 12-month period prior to your request.

We hereby inform you that if you exercise any of your rights under the CCPA we may not deny you goods or services for that reason, or subject you to different prices than those paid by other consumers, unless provided otherwise under the CCPA, Federal, or State law.

Notice of Information We Collect
Pursuant to California Civil Section 1798.100(b), this serves as notice of the categories of Personal Information that we collect through the Site and Services and the commercial purposes for which the information was collected. Please note that all of the categories of Personal Information we collect about you (as detailed below) come from the following categories of sources:

• You, including through your use of our services
• Automatically collected from you
• Our affiliate companies
• Third parties

In particular, the Site and Services have collected the following categories of Personal Information from California consumers within the last twelve (12) months:

/ (“Site”) and associated mobile and other applications and services, any online reservations you make at our Site or any of our restaurants (collectively, the “Services”). This Policy also explains your choices for managing your Personal Information preferences, including your rights under the California Consumer Privacy Act (“CCPA”). Please note that you need to be a U.S. resident to register to our website and be a member in any of our programs. By using and registering to our website and/or any of our loyalty programs, you acknowledge that you are a U.S. resident and that you do not reside in other countries, specifically that you do not reside in a country that is part of the European Union or the European Economic Area.
This Policy is subject to the Terms and Conditions which govern any Services. By accessing or using the Site or Services, you consent to and agree to be bound by this Policy and, depending on the Service, the relevant Terms and Conditions. If you are a resident of California, additional provisions may apply to you as set forth in Appendix A below.

3. WHO IS COLLECTING YOUR INFORMATION

The Site is operated by vendors of WDI International, Inc., which is the controller for all Personal Information collected through the Site and Services and at our restaurants. This Policy applies only to the Site, Services, and our restaurants.

4. MANAGING YOUR INFORMATION PREFERENCES

You can request to review, correct, update, change, or delete the Personal Information you provided to us by contacting us at either the number or email address listed herein. We will respond to your requests within the time period specified by applicable law, or if no time period is specified, we will use reasonable efforts to respond within thirty (30) days of receipt of the request, subject to any limitations in applicable law.
If you wish to exercise your rights under the CCPA, please review Appendix A below. If you wish to opt-out of receiving email marketing communications, you can click the unsubscribe mechanism at the bottom of the email.

5. INFORMATION WE COLLECT

Personal Information We Collect Directly From You
We collect Personal Information that you choose to provide us, such as when you make a reservation at one of our restaurants, register for email communications.
We also collect Personal Information when you sign up, use, or make an online order of food, swag, memorabilia, and gift cards through our Site, App, or Services.

We also collect information regarding your transactions at our restaurants (“Transaction Information”) for marketing and promotions, and to develop and improve our products and services.
If you apply for a job at one of our locations or online at the Site, we may collect certain information to process that information, including your name and contact information and your resume (“Job Applicant Information”).

Information We Collect Automatically
We may automatically collect the following Personal Information about your use of our Site or Services through cookies and other technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; your mobile device ID; the length of time you visit our Site or Services; and the referring URL, or the web page that led you to our Site (collectively, “Usage Data”). We may combine this Usage Data with other information that we have collected about you, including, where applicable, your Personal Information. Please see the section “Our Use of Cookies and Other Tracking Mechanisms” below for more information. We use Usage Data to help us understand how people use the Site and Services, and to enhance our Site and the Services we offer.
Geolocation. If you have provided permission through your mobile device to allow us to collect location information through the App, we may obtain your physical location information in terms of latitude and longitude from technologies like GPS, Wi-Fi, or cell tower proximity. You are able to withdraw your permission for us to acquire such physical location information from your mobile device through your mobile device settings, although we do not control this process. If you have questions about how to disable your mobile device’s location services, we recommend you contact your mobile device service provider or the mobile device manufacturer.

How We Use Your Information
We use your Personal Information for the following business purposes:

• To provide our Site and Services to you, including reservations and services you request at our restaurants, to optimize and fulfill your online orders through our Site, to communicate with you about your use of our Site and Services, to respond to your inquiries, to process job applications, to fulfill your orders, and for other customer service purposes.
• To tailor the content and information that we may send or display to you, to offer location customization, personalized help and instructions, and to otherwise personalize your experiences while using our Site or Services.
• To notify you about marketing and promotional opportunities. For example, we may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you. We also may use the information that we learn about you to assist us in advertising our Site and Services on third-party websites.
• To conduct promotions, such as sweepstakes, contests and giveaways.
• To better understand how users access and use our Site and Services, both on an aggregated and individualized basis, in order to improve our Site and Services and respond to user desires and preferences, and for other research and analytical purposes.

How We Share Your Information
We may share your Personal Information as follows:

• Affiliates. We may disclose the Personal Information we collect from you to our affiliates that own and operate our various restaurants; however, if we do so, their use and disclosure of your Personal Information will be maintained by them in accordance with this Policy.
• Service Providers. We may disclose the Personal Information we collect from you to third-party vendors, service providers, contractors or agents who perform functions on our behalf (“Service Providers”). For example, we may contract with Service Providers to provide certain services, such as hosting and maintenance, data storage and management, property management, and marketing and promotions. Each Service Provider must agree to use commercially reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect your Personal Information from unauthorized acquisition, access, use, or disclosure. Service Providers may only use the Personal Information to provide services to WDI and are prohibited from using Personal Information other than as authorized by WDI under this Privacy Policy.
• Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, or if we are in negotiations with respect to any such transaction, we may transfer the Personal Information we have collected from you to the other company or legal entity.
• In Response to Legal Process. We also may disclose the Personal Information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a subpoena.
• To Protect Us and Others. We also may disclose the Personal Information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of any applicable Terms and Conditions for Services provided through this Site or this Policy, or as evidence in litigation in which we are involved.
• Aggregate and De-Identified Information. We may share aggregate or de-identified Personal Information about users with third parties and publicly for marketing, advertising, research, or similar purposes.

Except as noted in this Section 5, we do not disclose Personal Information to third parties, including for their direct marketing purposes, without your consent, except as explained in this Policy.