California Privacy Notice

Date last revised: November 1, 2026

This California Privacy Notice (this “Notice”) explains, for California residents to whom the California Consumer Privacy Act (as amended by the California Privacy Rights Act, the “CCPA”) applies (“California Consumers”), how TIER IV, Inc. and Tier IV North America Inc. process personal information, and the rights of California Consumers under the CCPA and other California law.

Covered Companies and Scope.

The companies covered by this Notice are TIER IV, Inc. and Tier IV North America Inc. (collectively, the “Covered Companies”). In this Notice, “we”, “us” and “our” refer to the Covered Company or Companies subject to obligations as a Business under the CCPA with respect to a particular processing of personal information. This Notice does not apply to officers, employees, former employees, seconded personnel or job applicants of the Covered Companies or other individuals in an employment or recruitment relationship with them (“Workforce Members”). The processing of personal information relating to Workforce Members is governed by the notice separately provided by the Covered Companies to those individuals. In addition, where a Covered Company processes personal information as a service provider or contractor of a customer or other third party solely on that third party’s instructions, that third party’s privacy notice will, in principle, apply.
In this Notice, “personal information”, “sensitive personal information”, “sell”, “share”, “business purpose”, “service provider” and other terms defined in the CCPA have the meanings given to them in the CCPA, unless otherwise specified. In the event of any inconsistency or conflict between this Notice and the “TIER IV Privacy Policy” or “Local Deviations - US”, this Notice prevails with respect to personal information within the scope of this Notice that is subject to the CCPA.

1. Our Processing of Personal Information

a) Collection and Disclosure of Personal Information

Our collection, use and disclosure of personal information vary depending on your relationship with us, the Covered Company concerned and the specific processing context. The table below shows the categories of personal information we have collected about California Consumers in the past 12 months or currently collect, examples of such personal information, and the categories of recipients to whom we disclose such personal information for a business or commercial purpose. The same personal information may fall within more than one category. Not every Covered Company collects all of the personal information listed in each field.

Categories of Personal Information Collected	Personal Information Collected	Recipients of Disclosures for a Business or Commercial Purpose
Identifiers	TIER IV, Inc.: name, email address, telephone number, company name, department, job title, account name, account ID, subject ID, IP address, cookie ID, device identifiers and other identifiers linked to you or your account or device. Tier IV North America Inc.: names, telephone numbers and email addresses of partners, prospective customers and other business contacts.	Service providers and contractors (providers of cloud, hosting, software, security, CRM, email delivery, analytics and other business support services). Other Covered Companies (to the extent necessary for products and services, customer support or business development).
Personal information described in Cal. Civ. Code §1798.80(e)	Name, telephone number and other information described in that section that we actually collect in connection with business negotiations, contracts, provision of services, inquiries or other business relationships.	Service providers and contractors, other Covered Companies, professional advisers and other recipients, to the extent necessary for each processing activity.
Commercial information	TIER IV, Inc.: business negotiations, proposals, quotations, contracts, orders, invoices, payments, licenses, subscription plans, maintenance and support, inquiries, downloads of materials, event participation, newsletter subscriptions, leads and other transaction and sales-related information. Tier IV North America Inc.: information relating to building partnerships, customer acquisition, business negotiations, and related communications and coordination.	Service providers and contractors, other Covered Companies, customers, partners and other transaction or project stakeholders (to the extent necessary for the purpose).
Internet or other electronic network activity information	Principally with respect to TIER IV, Inc., IP addresses, URLs accessed, User-Agent, Referer, cookies, browsing, search and access dates and times, login and authentication, operations, API usage, uploads and downloads, communications, monitoring, error and security logs, and other information relating to the use of websites, Web.Auto and other products and services.	Providers of cloud, hosting, system operation, security, analytics and other services acting as service providers and contractors.
Geolocation data	TIER IV, Inc.: approximate location information estimated from IP addresses, collected in connection with the use of websites, Web.Auto and other products and services. In addition, location information (latitude and longitude), driving routes and times, where linked to drivers, operators, passengers, vehicle occupants or others, collected for research and development of autonomous driving systems, vehicle and operation management and other purposes.	Providers of cloud, hosting, system operation, security, data analysis and other services acting as service providers and contractors. Customers, local governments, universities and research institutions, joint research partners and other project stakeholders (to the extent necessary for the purpose).
Audio, electronic, visual or similar information	TIER IV, Inc.: video information, such as the appearance, behavior and clothing of pedestrians, drivers, cyclists and others, and vehicle license plates, recorded by exterior vehicle cameras and other devices during driving for the research, development, demonstration, evaluation and safety improvement of autonomous driving systems.	Providers of cloud, hosting, data analysis, annotation, blurring and masking and other services acting as service providers and contractors. Customers, local governments, universities and research institutions, joint research partners and other project stakeholders (to the extent necessary for the purpose).
Professional or employment-related information	Excluding information relating to Workforce Members, company name, department, job title, business contact details, history of business card exchanges and event participation, and other information relating to professional relationships of customers, business partners, alliance partners, media and other business contacts.	Providers of CRM, email delivery, event management and other services acting as service providers and contractors, and other Covered Companies (to the extent necessary for sales, business development, public relations and other operations).
Sensitive personal information	Principally with respect to users of TIER IV, Inc.’s products and services, passwords, access tokens and other credentials allowing access to an account.	Limited to service providers and contractors that require access to such information for authentication, security, system operation or other purposes.

b) Sale and Sharing of Personal Information

In the past 12 months, we have not sold personal information in a manner constituting a “sale” under the CCPA, or shared personal information in a manner constituting “sharing” for cross-context behavioral advertising. If we engage in any such processing in the future, we will provide the necessary notices and choices in accordance with the CCPA. We do not have actual knowledge that we sell or share the personal information of California Consumers under 16 years of age.
Where we create or use deidentified information within the meaning of the CCPA, we maintain such information in deidentified form in accordance with applicable law and do not attempt to reidentify the California Consumers to whom such information relates, except as permitted by the CCPA.

i) Sources of Personal Information

We collect the personal information described above principally (1) directly from you (for example, through web forms, account registration, email, business cards, business negotiations, inquiries, events and other business communications), (2) automatically from websites, apps, Web.Auto and other products and services and from the devices you use, (3) from customers, business partners, alliance partners, event organizers, other Covered Companies and other business contacts, and (4) from publicly available information and other lawful sources.

ii) Purposes of Collecting, Using and Disclosing Personal Information

We collect, use and disclose the personal information described above principally for the following purposes: (1) providing products and services, account management, authentication, maintenance, support and responding to inquiries; (2) contracts, business negotiations, building partnerships, customer acquisition, managing relationships with customers and business partners, and related communications and coordination; (3) newsletters, seminars, trade shows, webinars and other sales, public relations and marketing activities; (4) improving products, services and the user experience, research and development, usage analysis and compiling statistics; (5) information security, preventing unauthorized access and misuse, and responding to failures and incidents; and (6) legal compliance, audits and responding to legal claims.
We use or disclose sensitive personal information to the extent necessary for account authentication, access control, security, prevention of unauthorized access and other purposes permitted by the CCPA. We do not use or disclose sensitive personal information for purposes that would require us to offer a right to limit the use or disclosure of sensitive personal information under the CCPA.

iii) Disclosure of Personal Information

To the extent necessary for the purposes described above, we may disclose personal information to providers of cloud, hosting, software, security, system operation, data analysis, CRM, email delivery, event management and other services acting as service providers and contractors. We may also provide personal information to other Covered Companies to the extent necessary for the provision of products and services, customer support, research and development or business development. For example, Tier IV North America Inc. may provide business contact information obtained from partners or prospective customers to TIER IV, Inc. for customer acquisition by TIER IV, Inc. In addition, where necessary for contracts, projects, legal compliance or legal claims, we may disclose personal information to customers, partners, professional advisers, public authorities and others.

2. Retention Periods

We do not retain personal information for longer than is reasonably necessary to achieve the purposes of collection and use or than is required by applicable law. The retention periods for each category of personal information, or the criteria used to determine them, are set out below. Where more than one retention period may apply, we determine the retention period taking into account our relationship with you, the status of contracts and transactions, the nature and sensitivity of the information, security needs, statutory retention obligations, and the need to respond to audits, disputes and legal claims. Personal information that is no longer needed for its purposes is deleted, deidentified or rendered unusable in accordance with applicable law and our procedures.

Category of Personal Information	Retention Period or Criteria Used to Determine It
Identifiers	Account identifiers are retained for the life of the account and for the period reasonably necessary for the provision of services and security; business contact information is retained for the period necessary for customer and business partner relationships, building partnerships, customer acquisition and other purposes. Where longer retention is required for legal compliance or legal claims, the information is retained for that period.
Personal information described in Cal. Civ. Code §1798.80(e)	Retained in accordance with the statutory retention obligations applicable to, and the business needs relating to, the contract, transaction, customer and business partner, inquiry and other records containing the information.
Commercial information	Retained for the duration of the contract, transaction or service relationship and, after its termination, for the period reasonably necessary for accounting and tax, contract management, audit, dispute resolution and other purposes. Sales and marketing information is retained until it is no longer necessary in light of our relationship with you, your opt-out and other choices, and the purposes of collection.
Internet or other electronic network activity information	Retained for the period necessary for the provision of services, system operation, security, failure analysis, audits and fraud prevention, in accordance with the retention standards for each system and log.
Geolocation data	Geolocation data collected in connection with the provision of services, system operation, security and failure analysis is retained in accordance with the retention standards for each system and log. Geolocation data collected for research and development of autonomous driving systems, safety evaluation and other purposes is retained for a period determined taking into account the duration of the project, the needs of research and development and safety validation, statutory retention obligations and the need to respond to legal claims.
Audio, electronic, visual or similar information	Video collected for the research, development, demonstration, evaluation and safety improvement of autonomous driving systems is retained for a period determined taking into account the duration of the project, the needs of research and development and safety validation, the need to analyze accidents and malfunctions, statutory retention obligations and the need to respond to legal claims.
Professional or employment-related information	Retained for the period reasonably necessary to manage relationships with customers, business partners, alliance partners and other business contacts, and to carry out necessary follow-up, legal compliance and dispute resolution.
Sensitive personal information	Passwords, access tokens and other credentials are retained for the period necessary depending on the life of the account or integration, authentication and security needs, the status of renewal, expiration or revocation, and other circumstances; credentials that are no longer needed or have expired are appropriately deleted or rendered unusable.

3. Rights of California Residents

Subject to the limitations and exceptions under the CCPA, California Consumers generally have the following rights with respect to their personal information:

a) Right to know (right of access): the right to request the categories of personal information we have collected, the categories of sources, the business or commercial purposes for collecting, using or disclosing it, the categories of personal information disclosed for a business purpose and the categories of recipients, and access to the specific pieces of personal information about you.

b) Right to delete: the right to request the deletion of personal information we have collected from you, subject to exceptions under the CCPA.

c) Right to opt out of sale and sharing: the right to opt out of the sale of personal information or its sharing for cross-context behavioral advertising. We currently do not sell or share personal information.

d) Right to correct: the right to request the correction of inaccurate personal information we maintain.

e) Right to limit the use and disclosure of sensitive personal information: where we use or disclose sensitive personal information beyond the purposes permitted by the CCPA, the right to limit such use or disclosure. We currently do not use or disclose sensitive personal information for purposes that would require us to offer this right to limit.

f) Right to non-discrimination: the right not to receive discriminatory treatment prohibited by the CCPA for exercising your rights under the CCPA.

4. How to Exercise Your Rights

a) Requests to Know (Access), Correct and Delete

We accept requests relating to the right to know (right of access), the right to correct or the right to delete through the request form on our website [Request Form]. You may also contact us at personalinfo@tier4.jp. In your request, please include your name, contact details, the type of request, your relationship with the Covered Companies and the information necessary to identify the subject of the request.
To protect the personal information of you and third parties, we may verify your identity, depending on the type of request, the information concerned and the risks involved, by matching information you provide against our records, by confirmation through your registered email address or by other reasonable methods. If we are unable to verify your identity, we may be unable to respond to all or part of your request.

b) Right to Opt Out of Sale and Sharing and Right to Limit the Use and Disclosure of Sensitive Personal Information

Because we currently do not sell or share personal information, and do not use or disclose sensitive personal information for purposes subject to the right to limit under the CCPA, we do not have specific procedures for exercising these rights. In addition, because we do not sell or share personal information, we do not process opt-out preference signals (such as Global Privacy Control) sent by browsers or other platforms. If in the future we sell or share personal information, or use or disclose sensitive personal information for purposes subject to the right to limit, we will provide the necessary methods for exercising these rights in accordance with the CCPA.

c) Authorized Agents

California Consumers may submit requests through an authorized agent. We may require the agent to provide written or other proof that you have authorized the agent and, where necessary, require you to verify your identity directly with us or to confirm directly with us that you have authorized the agent.

5. Contact Us

If you have any questions about this Notice or our processing of personal information, or wish to make a privacy request, please contact us at:

TIER IV, Inc. Personal Information Contact Desk
Jacom Building, 1-12-10 Kitashinagawa, Shinagawa-ku, Tokyo 140-0001, Japan
Email: personalinfo@tier4.jp