Privacy Policy

Effective Date: September 21, 2026

Last Updated or Reviewed on: September 18, 2026

This Privacy Policy describes how Pentel of America, Ltd., an Illinois corporation (the "Company," "we," or "us") collects and processes personal information about our consumers.

Personal Information Collected

Personal information is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (the "personal information"). Personal information does not include:

· Publicly available information, including information from government records, information made available through widely distributed media, and information that the consumer makes publicly available without restricting it to a specific audience.

· Lawfully obtained, truthful information that is a matter of public concern.

· Deidentified or aggregated consumer information.

Personal Information Categories Chart

The following chart indicates whether we collected certain categories of personal information from our consumers within the last 12 months.

Category	Examples	Collected?
A. Identifiers.	A name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.	Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, address, telephone number, credit card number, debit card number, or any other financial information. Note: Some personal information included in this category overlap with other categories.	Yes
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, reproductive health decision-making, military and veteran status, or genetic information (including familial genetic information).	No
D. Commercial information.	Records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
E. Biometric information.	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, health, or exercise data.	No
F. Internet or other similar network activity.	Activity on our websites, mobile apps, and other digital systems, such as internet browsing history, search history, system usage, electronic communications with us, postings on our social media sites.	Yes
G. Geolocation data.	Residence address.	Yes
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information, including customer service call monitoring.	No
I. Professional or employment-related information.	Current or past job history.	No
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
K. Inferences drawn from other personal information to create a profile reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Using information regarding a consumer’s internet activity (Item F above) to serve him or her interest-based advertisements.	Yes
L. Sensitive personal information.	Described below.	No

Sensitive Personal Information Disclosures

The California Consumer Privacy Act (the “CCPA”) gives California residents the right to be notified when their sensitive personal information is collected and to limit the use of such information. Sensitive personal information, as defined by the CCPA, is a subtype of personal information consisting of information in the following categories: social security, driver's license, state identification card, or passport number; financial account information (i.e., account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account); precise geolocation; racial or ethnic origin; citizenship or immigration status; religious or philosophical beliefs; union membership; genetic data; biometric data; health information; sex life; sexual orientation; the contents of a consumer's mail, email, or text messages unless the Company is the intended recipient of the communication; and neural data. However, the CCPA only treats this information as sensitive personal information when we collect or use it to infer characteristics about a consumer. During the last 12 months, we have had access to the contents of messages shared among members of the Pentel Creator Collective in our capacity as the administrator of the collective but have not otherwise collected sensitive personal information regarding California residents. We have not used the contents of such messages to infer characteristics about the members.

How Long We Retain Your Personal Information

We keep the personal information described in this policy for as long as reasonably necessary to fulfill the purposes described or as long as otherwise legally permitted or required, such as operating our organization, complying with our legal obligations, resolving disputes, preventing fraud, and promoting safety and security. This means that we consider our legal and business obligations, potential risks of harm, and the nature of the information when deciding how long to retain personal information. At the end of the retention period, personal information will be deleted, destroyed, or deidentified.

Sources of Personal Information

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

· Directly from you, such as from the forms or other information you provide to the Company.

· Indirectly from you, such as from your interactions with the Company's websites, mobile applications, and social media platforms and participation in contests and drawings sponsored by the Company.

· From our service providers, such as order fulfillment and shipping providers.

How We Use Personal Information

We may use and disclose the personal information we collect to advance the Company's business and commercial purposes, that is, to:

· Develop, offer, and provide you with our products and services.

· Meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections, or to comply with legal requirements.

· Fulfill the purposes for which you provided your personal information or that were described to you at collection and as applicable law otherwise permits.

· Improve our products, services, marketing, and customer relationships and experiences.

· Notify you about changes to our products and services.

· Administer our systems and conduct internal operations, including troubleshooting, testing, research, and surveys.

· Enable your participation in our websites' or mobile apps' interactive, social media, and other similar features.

· Protect our Company, employees, and operations.

· Measure or understand the effectiveness of the advertising we provide to you and others, and to deliver relevant advertising to you.

· Make suggestions and recommendations to our consumers about our goods and services that may interest them.

· Manage your consumer relationship with us, including:

· online account creation, maintenance, and security; and

· reaching you, when needed, about your account.

· Perform data analytics for legitimate business purposes.

· Administer and maintain the Company's systems and operations, including for safety purposes.

· Comply with applicable laws and regulations.

· Exercise and defend the legal rights of the Company and its employees.

· Respond to law enforcement requests.

· Comply with applicable law or court order.

We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you with notice. If required by law, we will also seek your consent before using your personal information for a new or unrelated purpose.

We may collect, process, and disclose aggregated or deidentified consumer information for any purpose, without restriction. When we collect, process, or disclose aggregated or deidentified consumer information, we will maintain and use it in deidentified form and will not to attempt to reidentify the information, except to determine whether our deidentification processes satisfy any applicable legal requirements.

Disclosing Personal Information to Third Parties

Disclosures to Our Service Providers and Contractors

We may disclose the personal information we collect to service providers and contractors for the business purposes described in the chart below. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, prohibit using the disclosed information for any purpose except performing the contract, and meet the other privacy law contract requirements for engaging service providers or contractors.

The following chart identifies the categories of personal information we disclosed to service providers or contractors for a legitimate business purpose over the preceding 12 months, the specific business or commercial purpose for disclosing that information, and the categories of entities to whom we have disclosed such information for such purpose.

Chart: Disclosures to Our Service Providers and Contractors

Category of Business Purpose Disclosure Recipients

Personal Information Categories Disclosed

Business Purpose Disclosures

Order Fulfillment and Shipping Providers

A. Identifiers.

B. California Customer Records.

D. Commercial information.

To deliver products you purchased from us.

Customer Service Support Providers

A. Identifiers.

B. California Customer Records.

D. Commercial Information.

F. Internet or other similar network activity.

To support customers using our products and services, including online account management and troubleshooting.

Other Disclosures to Third Parties

We do not sell your personal information. Accordingly, we have not sold your personal information in the preceding 12 months.

We share your personal information with third parties for cross-context behavioral advertising purposes.

Our personal information sharing does not include information about consumers we know are under age 16.

The chart below identifies the categories of third parties with whom the Company shared consumers' personal information for cross-context behavioral advertising purposes over the preceding 12 months, along with the personal information categories shared and the business or commercial purposes for sharing that information.

Chart: Other Disclosures to Third Parties

Category of Third Parties with Whom We Shared Personal Information

Personal Information Shared

Commercial or Business Purposes

Advertising partners.

F. Internet or other similar network activity.

To increase Company revenue.

To provide customers with ads of interest on other websites.

We do not transfer or provide personal information about you to third parties except (i) as noted above under “Disclosures to Our Service Providers and Contractors” and “Other Disclosures to Third Parties” above, (ii) as otherwise set forth in this Privacy Policy, (iii) to protect you and other users of our websites and mobile applications, (iv) when necessary or appropriate to comply with law or to protect our rights or property or the safety of our websites, and (v) if required to do so by subpoena or other legal process.

Cookies and Other Tracking Technologies

We use cookies, tracking pixels, and similar technologies. A cookie is a small file that a web server automatically sends to your computer when you browse certain websites. Cookies are stored as text files on your hard drive and contain information that identifies a user by, for example, login or username, passwords, shopping cart information, and preferences. When a user revisits a website, his or her computer automatically "serves up" the cookie, which establishes the user's identity, thus eliminating the need for the customer to reenter the information. Cookie technology also makes shopping cart technology possible. For example, when you select items that you intend to purchase in an online catalog, cookies make it possible for you to continue shopping and to "check-out" later.

Tracking pixels are small pieces of code embedded in emails, ads, or web pages that collect user behavior data and transmit it to third-party platforms (e.g., Google Analytics, Meta Pixel, Firework) to measure ad performance and conversions, attribute sales or leads to specific campaigns, and track user behavior across touch points.

You can choose whether to allow us to collect information through cookies and other tracking technologies by going to the “Cookies Preference” setting in the footer of our website or by clicking https://www.pentel.com/policies/#shopifyReshowConsentBanner. If you disable or refuse cookies or similar tracking files, some website or application features may be inaccessible or not function properly.

Some browsers include a "Do Not Track" (the “DNT”) setting that can send a signal to the online services you visit indicating you do not wish to be tracked.

If you do not opt out of our use of cookies and other tracking technologies, you will be deemed to have consented to such use.

Your Legal Rights: Non-California Residents

This section describes mechanisms you can use to control certain uses and disclosures of your information and rights you may have under state law, depending on where you live. If you are a California resident, see “Your Legal Rights: California Residents” below.

Your State Privacy Rights

Depending on your state of residency, you may have certain rights related to your personal information, including:

· Access and Data Portability. You may have the right to confirm whether we process your personal information and access a copy of the personal information we process. To the extent feasible and required by state law, depending on your state, information will be provided in a portable format. Depending on your state, you may have the right to receive additional information. If so, it will be included in the response to your access request.

· Correction. You may have the right to request that we correct inaccuracies in your personal information, taking into account the information's nature and processing purpose.

· Deletion. You may have the right to request that we delete your personal information, subject to certain exceptions under applicable law.

· Opt-Out of Using Personal Information for Sales, Targeted Advertising, and Profiling for Certain Automated Decisions. You may have the right to request that we not use your personal information for these purposes. Some states may also grant you the ability to learn more about or challenge automated decisions.

The exact scope of these rights vary by state. There are also several exceptions where we may not have an obligation to fulfill your request.

Some browsers and browser extensions support the Global Privacy Control (the “GPC”) that can send a signal to process your request to opt out from certain types of data processing, including data "sales" as defined under certain laws. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting as required by applicable law.

Nevada provides its residents with a limited right to opt out of certain personal data sales. We do not currently sell information triggering that statute's opt-out requirements.

Your Legal Rights: California Residents

If you are a California resident, the CCPA grants you the following rights regarding your personal information:

Right to Know and Data Portability Requests

You have the right to request that we disclose certain information to you about our collection and use of your personal information (the "right to know"), including the specific pieces of personal information we have collected about you (a "data portability request"). Our response will cover the 12-month period preceding the request, although we will honor requests to cover longer periods that do not extend past January 1, 2022, unless doing so would be impossible or involves disproportionate effort. You may exercise your right to know twice in any 12-month period. Once we receive your request and confirm your identity, we will disclose to you:

· The categories of:

· personal information we collected about you; and

· sources from which we collected your personal information.

· The business or commercial purpose for collecting your personal information and, if applicable, selling or sharing your personal information.

· If applicable, the categories of third parties to whom we disclosed your personal information, including separate disclosures identifying the categories of your personal information that we:

· disclosed for a business purpose to each category of third parties; and

· sold or shared to each category of third parties.

· When your right to know submission includes a data portability request, a copy of your personal information, subject to any permitted redactions.

For more on exercising this right, see “How to Exercise Your Legal Rights” below.

Right to Delete and Right to Correct

You have the right to request that we delete any of your personal information that we collected, subject to certain exceptions and limitations (the "right to delete"). Once we receive your request and confirm your identity, we will delete your personal information from our systems unless an exception allows us to retain it. We will also notify our service providers, contractors, and other recipients, if any, to take appropriate action.

You also have the right to request correction of personal information we maintain about you that you believe is inaccurate (the "right to correct"). We may require you to provide documentation, if needed, to confirm your identity and support your claim that the information is inaccurate. Unless an exception applies, we will correct personal information that our review determines is inaccurate and notify our service providers, contractors, and other recipients, if any, to take appropriate action.

For more on exercising these rights, see “How to Exercise Your Legal Rights” below.

Right to Limit Sensitive Personal Information Use and Disclosure to Permitted SPI Purposes

You have a right to ask businesses that use or disclose your sensitive personal information to limit those actions to just the CCPA's permitted SPI purposes (the "right to limit"). As we do not use or disclose sensitive personal information beyond the CCPA's permitted SPI purposes, we do not currently provide this right.

Personal Information Sales or Sharing Opt-Out and Opt-In Rights

You have the right to request that businesses stop selling or sharing your personal information at any time (the "right to opt-out"), including through a user-enabled opt-out preference signal. This right does not apply to our disclosures of your personal information to certain or our contractors and service providers for the purposes described above under “Disclosures to Our Service Providers and Contractors” above.

The CCPA prohibits businesses from selling or sharing the personal information of consumers it actually knows are under 16 years old without first obtaining consent from consumers who are between 13 and 15 years old or the consumer's parent or guardian for consumers under age 13 (the "right to opt-in"). As we do not sell or share the personal information of consumers under 16 years of age, we do not currently provide a right to opt-in.

ADMT Rights

When a business uses automated decision-making technology (“ADMT”) to make significant decisions about you, you may have rights to:

· Obtain certain information about how the business uses ADMT that is specific to you.

· Opt-out of the ADMT use unless (i) the business provides you with a method to appeal the decision to a human reviewer with the authority to overturn the decision or (ii) another exception applies.

ADMT is technology that processes personal information and uses computations to execute a decision and either replace or substantially replace human decision-making, resulting in decisions made without human involvement. Decisions are significant when they result in the provision or denial of financial or lending services, housing, education enrollment or opportunities, employment or independent contracting opportunities or compensation, or healthcare services. Advertising is not a significant decision.

We do not currently use ADMT to make significant decisions about consumers, so we do not provide ADMT access, opt-out, or appeal rights.

Right to Non-Discrimination

You have the right not to be discriminated or retaliated against for exercising any of your privacy rights under the CCPA.

How to Exercise Your Legal Rights

To request that we not share your personal information with third parties, click https://www.pentel.com/pages/data-sharing-opt-out. You can also submit your request to opt-out of personal information sharing through an opt-out preference signal such as the Global Privacy Control opt-out preference signal.

To exercise other rights described above under “Your Legal Rights: Non-California Residents” or “Your Legal Rights: California Residents,” as applicable, contact us at social@pentel.com or 1-800-421-1419 during normal business hours in California.

Please describe your request with sufficient detail so we can properly understand, evaluate, and respond to it. You may only submit a “request to know,” including a “data portability” request, twice in a 12 month period.

Verification Process and Authorized Agents

Only you, or someone legally authorized to act on your behalf, may make a request to know, delete, or correct your personal information. If your minor child is our consumer, you may also make a verifiable request on his or her behalf. To designate an authorized agent, contact us at social@pentel.com. We may request specific information from you or your authorized representative to confirm your or his or her identity before we can process your right to know, delete, or correct your personal information. The requested information may include, for example, the consumer's name, email address, and, if applicable, account username

You do not need to create an account with us to submit a request to know, correct, or delete.

We will only use personal information provided in the request to verify the requestor's identity or authority to make the request.

California Residents

Responding to Your Requests to Know, Delete, or Correct

We will confirm receipt of your request within ten business days. If you do not receive confirmation within ten business days, please contact us at social@pentel.com.

We endeavor to substantively respond to a verifiable request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and the extension period in writing. We will deliver our written response to your verified email address. Our substantive response will tell you whether we have complied with your request. If we cannot comply with your request in whole or in part, we will explain the reason, subject to any legal or regulatory restrictions. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed or deleted your personal information or made it anonymous in compliance with our records retention policies and obligations.

Any disclosures we provide will cover information for the 12 month period preceding the request's receipt date. We will consider requests to provide longer disclosure periods that do not extend past January 1, 2022, unless providing the longer timeframe would be impossible or involves disproportionate effort.

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.

We will not charge a fee to process or respond to your verifiable 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.

Response and Timing on the Right to Opt-Out

In response to your request to opt-out, we will process your request as soon as practicable but no later than 15 business days from the date we receive the request. You do not need to create an account with us to exercise your opt-out right. We will only use personal information provided from your request to comply with the request.

We will also notify downstream recipients of your personal information, if any, of your request to opt out and instruct them to:

· Comply with your request; and

· Forward the request to their own downstream recipients, if applicable.

Once you make a request to opt-out, we will wait at least 12 months before asking you to reauthorize personal information sharing. However, you may change your mind and opt back in at any time by sending an email with your request ot social@pentel.com

How We Protect Your Personal Data

We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with our websites or mobile applications. In particular, email, texts, and chats sent to or from our websites and mobile applications may not be secure, and you should carefully decide what information you send to us through our websites or mobile applications. Any transmission of personal data is at your own risk.

The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.

Privacy Policy Changes

We reserve the right to update this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will update the policy's effective date and post the updated policy on our website. We encourage you to check our website to check for updated versions of this policy

Contact Information

If you have questions or comments about this policy, the ways in which we collect and use your information described here, or your choices and rights regarding such use, you may contact us at:

Phone: 1-800-421-1419

Website: www.pentel.com

Email: social@pentel.com

Postal Address:

Pentel of America, Ltd.

2715 Columbia Street

Torrance, CA 90503

Alternate Format

If you need to access this Privacy Policy in an alternate format due to a disability, please contact us at social@pentel.com or 1-800-421-1419.