California Consumer Privacy Notice

Please submit requests to exercise your privacy rights here.

This California Privacy Notice (“Notice”) is provided on behalf of Seagate Technology LLC and any of its affiliates, (collectively, “Seagate” or “we” or “us”). As required by the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq. (“CCPA”) and its implementing regulations, as modified by the California Privacy Rights Act (“CPRA”), this Notice provides additional information to California residents on Seagate’s collection, use, and disclosure of Personal Information and the rights available to California residents. Please refer to Seagate’s Privacy Statement at https://www.seagate.com/legal-privacy/ (“Statement”) for more information about our privacy practices. Capitalized terms used in this Notice that are not otherwise defined in this Notice are as defined in the Statement. Certain terms used in this Notice have the meaning given to them in the CCPA or CPRA and their implementing regulations.

Please note that this Notice does not apply in situations where we collect Personal Information about our job applicants, employees, contractors, owners, directors, or officers as it relates to their current, former, or potential role at Seagate.

Collection of Personal Information

“Personal Information” is defined as the information that can identify, relates to, or could reasonably be linked with a particular California resident or household.

We collect Personal Information from our interactions with you. For example, when you contact us via our Site or on the phone, respond to a survey, or register or return a Seagate product. We also collect Personal Information from other sources, for example when public databases and joint marketing partners share the information with us, in accordance with applicable law.

We may have collected within the last 12 months the following categories of Personal Information:

• Identifiers, such as your name, telephone number, postal address, email address, user account name, and IP address;
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as your contact information and profile picture;
• Characteristics of protected classifications under California or federal law, such as your gender;
• Commercial information, such as transaction information and purchase history;
• Internet or network activity information, such as your browsing history and interactions with our Site;
• Geolocation data, such as your approximate location based on your IP address;
• Audio, electronic, visual, and similar information, such as call and video recordings;
• Professional or employment-related information, such as your title or industry;
• Sensitive personal information as defined in the CPRA, such as your account log-in in combination with the password or credentials to access the account (if you have an account with us); and
• Inferences drawn from any of the above Personal Information to create a summary about you, for example of your preferences and characteristics.

Sources of Personal Information

We may obtain the categories of personal information listed above from the following categories of sources:

• Directly from you – for example, from forms you complete on our websites or when you contact us;
• Indirectly from you – for example, from your device when you access our Site of Offerings or from observing your actions on our Site or Offerings;
• From third parties that assist us in providing relevant services for our Site or Offerings;
• From joint marketing partners that share the information with us; and
• From public sources (such as public records).

Use of Personal Information

We may use your Personal Information described in this Notice to operate, manage, and maintain our business, to provide our Site and Offerings, for our employment and vendor management purposes, and to accomplish our business purposes and objectives. For example, we may use your Personal Information to:

• Perform the services or provide the goods you request;
• Create, maintain, customize, and secure your account with us;
• Provide customer service and support, including investigating your concerns, responding to your requests, and monitoring and improving our responses;
• Develop, improve, repair, and maintain our Site and Offerings;
• Personalize, advertise, and market our products and services;
• Conduct research and data analysis;
• Maintain our facilities and infrastructure;
• Undertake quality and safety assurance measures;
• Conduct risk and security control and monitoring to maintain the safety, security, and integrity of our Sites, Offerings, databases and other technology assets, and business;
• Detect and prevent fraud;
• Perform identity verification;
• Perform accounting, audit, and other internal functions, such as internal investigations;
• Comply with law, legal process, and internal policies;
• Respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• Maintain records;
• Exercise and defend legal claims; and
• To evaluate or conduct dissolution, divestiture, restructuring, reorganization, merger, or other sale or transfer of some or all our assets, including as part of bankruptcy, liquidation, or similar proceedings.

We may collect and process the sensitive personal information described in this Notice for:

• Performing the services or providing the goods reasonably expected by an average consumer who requests those goods or services;
• Helping to ensure security and integrity of our Site and Offerings;
• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing analytic services, providing storage, or providing similar services on our behalf; and
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

Retention of Personal Information

We will retain your Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained.

The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you and to provide the Site or Offerings to you (for example, for as long as you have an account with us or keep using the Site or Offerings); (ii) whether there is a legal or business obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations regulatory investigations, or other legal matters).

Disclosures of Personal Information to Third Parties

In the past 12 months, we may have disclosed the above categories of Personal Information to third parties, such as our service providers and affiliates, for our operational business purposes, as described in the Statement.

Third parties with whom we may share Personal Information include:

• Affiliates and Subsidiaries: We may share Personal Information with our affiliates and subsidiaries for our operational business purposes.
• Service Providers: We may share Personal Information with service providers, such as for technical or customer support, web or data hosting, billing, accounting, analytics, auditing, legal consultancy, security, marketing, or otherwise assisting us to provide, develop, maintain, and improve our business, our Site, and our Offerings.
• Parties Involved with Business Transfers: We may share Personal Information to third parties in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation).

When we disclose Personal Information for a business purpose, we enter into 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 fulfilling the contract.

Sales and Sharing of Personal Information

We have not “sold” or "shared" Personal Information within the meaning of the CCPA or the CPRA in the preceding 12 months. For purposes of this Notice, and as per the CCPA / CPRA:

• “sold” or “sale” means the disclosure of Personal Information for monetary or other valuable consideration, but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business; and
• “shared” or “share” means the disclosure of Personal Information to a third party for cross-context behavioral advertising, but does not include, for example, the disclosure of Personal Information to a third party at your direction or as a result of your intentional interaction with one or more third parties.

We also do not sell or share the personal information of individuals under 16 years of age.

Your Rights

If you are a California resident, you may request that a business:

(1) Provide access to Personal Information collected or retained about you:

You have the right to request access to Personal Information that we may collect or retain about you subject to certain exceptions including where responding to your request is impossible or involves disproportionate effort. Once we receive and confirm your verifiable request, we will disclose such Personal Information to you. You also have the right to receive your Personal Information in a structured and commonly used format.

(2) Disclose to you certain information covering the 12 months preceding your request:

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information subject to certain exceptions including where responding to your request is impossible or involves disproportionate effort. Once we receive and confirm your verifiable request, we will disclose to you the following, unless an exception applies:

• The categories of Personal Information collected about you;
• The categories of sources from which the business collected Personal Information about you;
• The business or commercial purpose for collecting Personal Information about you;
• The categories of third parties with whom the business discloses Personal Information about you; and
• The specific pieces of Personal Information the business has collected about you.

(3) Delete Personal Information the business collected from you:

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 request, we will delete your Personal Information from our records, unless an exception applies.

(4) Correct inaccurate Personal Information that the business maintains about you:

You have the right to request that we correct any of your Personal Information that we collected from you that is inaccurate, subject to certain exceptions. Once we receive and confirm your verifiable request, we will correct such inaccurate information from our records, unless an exception applies.

(5) Disclose to you whether the business sells or shares Personal Information and what Personal Information is sold to or shared with a third party and to which third party/parties:

As described in the Section "Sale and Sharing of Personal Information" above, we do not “sell” or "share" Personal Information within the meaning of the CCPA or CPRA.

(6) Not sell or share your Personal Information with a third party:

As described in the Section "Sale and Sharing of Personal Information" above, we do not “sell” or "share" Personal Information within the meaning of the CCPA or CPRA.

(7) Limit the use and disclosure of your “sensitive personal information”, as defined by the CPRA:

We do not use or disclose "sensitive personal information" other than as described in the Section "Use of Personal Information" above or as otherwise permitted under the CPRA. In addition, and as explained above, we do not “sell” or "share" Personal Information within the meaning of the CCPA or CPRA.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA and CPRA. We will not discriminate against you for exercising any of your CCPA or CPRA rights.

California’s “Shine the Light” law (Civil Code Section § 1798.83) also permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not disclose Personal Information to third parties for their direct marketing purposes.

Making Rights Requests

To make a request for the disclosures, correction, or deletion of your Personal Information as described above, please submit your rights request here. You may also contact us at 1-800-SEAGATE (1-800-732-4283).

To protect the personal information that we maintain, we will verify your identity when you make a request. To verify your identity, we will request your first and last name, email address related to your account, and country of residence.

An authorized agent may submit a rights request on your behalf by contacting us at data.protection.officer@seagate.com. We may require an authorized agent to verify their authority to submit a request on your behalf, or we may require you to verify your own identity or confirm with us that you provided the agent with permission to submit the request. We will only use the information provided for verification to confirm the requestor’s identity or authority to make the request.

We endeavor to respond to a verifiable request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. In some instances, we may decline to honor your request where an exception applies. For example, we may decline your request when we are unable to verify your identity or if the rights and freedoms of another individual would be negatively affected.

Changes to Notice

We may make changes to this Notice. Notification of changes will be posted on this page. You should review this Notice periodically to keep up to date on our most current policies and practices.

LAST UPDATED: December 22, 2022