IMPORTANT – READ CAREFULLY BEFORE ACCESSING OR USING ANY FUJITSU FRONTECH NORTH AMERICA SERVICE OR DOWNLOADING, INSTALLING OR USING ANY FUJITSU FRONTECH NORTH AMERICA SOFTWARE OR MOBILE APPLICATION: Fujitsu Frontech North America is committed to protecting and respecting your privacy, and the security of your personal information is part of our essential mission. This Privacy Policy is designed to inform you about how your personal information is collected, used, shared, stored, managed, and otherwise processed by Fujitsu Frontech North America, and your rights related thereto.

This Privacy Policy applies to personal information that we may collect about you as a visitor to any of our websites, including any other media forms, media channels, mobile websites, or mobile applications related or connected thereto (collectively, the “Site”), our premises, as a contact at one of our customers or potential customers, suppliers or potential suppliers, or other business partners, or in any other case where we specifically state that this Privacy Policy will apply. Please feel free to contact us if you have any questions.

Fujitsu Frontech North America Inc. (“Fujitsu Frontech North America”) reserves the right to make changes to this Privacy Policy at any time and for any reason and any such changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site. In addition, Fujitsu Frontech North America may have a privacy policy or statement specific to particular local laws, products or services, in which case such policy or statement shall supersede or supplement this Privacy Policy.

Table of Contents

Section 1. Your Agreement to Our Privacy Policy

Section 2. What Personal Information Do We Collect?

Section 3. Biometric Information

Section 4. IP Addresses

Section 5. Cookies

Section 6. How We Use Your Personal Information

Section 7. How We Share Your Personal Information

Section 8. How You Can Manage and Control Your Personal Information

Section 9. Storage and Data Retention

Section 10. Security

Section 11. Personal Information of Children

Section 12. CAN-SPAM Act

Section 13. DMCA

Section 14. What Are Your Rights?

Section 15. Automated Decision Making

Section 16. California Consumer Privacy Act & California Privacy Rights Act.

Section 17. State Specific Disclosures

Section 18. Information for Users in the European Economic Area (“EEA”) or in the United Kingdom (“UK”)

Section 19. Personal Information Protection and Electronic Documents Act (Canada).

Section 20. Changes to this Privacy Policy

Section 21. Contact Us

Section 1. Your Agreement to Our Privacy Policy

You expressly consent to Fujitsu Frontech North America collecting, using, sharing, storing, managing and otherwise processing information as described in this Privacy Policy when you visit, purchase, license, register to use, access, use, and/or provide information through or in connection with the Site or any of our services.

Section 2. What Personal Information Do We Collect?

Fujitsu Frontech North America collects certain personal information (i.e., information that identifies an individual either alone or in combination with other data). We also collect information that has been de-identified and aggregated, meaning it does not identify an individual, and other non-personal information which does not, on its own, identify an individual person.

Fujitsu Frontech North America obtains information when you or someone acting on your behalf provides such information to us. We also collect information automatically when you access or use the Site or our services or, in some circumstances, when you use a device on which a Fujitsu Frontech North America service is installed.

The following are examples of the personal information we may collect and process:

(a) Personal Information Collected Directly From You (Or Someone Acting On Your Behalf): This is information about you that you give to us, with your consent, by filling in forms on the Site (or other forms that we ask you to complete), giving us a business card (or similar), corresponding with us by telephone, post, email or otherwise, or accessing our partners’ web-based platforms from the Site, and it may include, for example:

• Your contact information, including your name, address, email address and telephone number;
• Information about your business relationship with Fujitsu Frontech North America and your transactions with us and your use of our services;
• Information about your professional role, background and interests;
• Information provided by you through Fujitsu Frontech North America -related communication channels such as forums, technical support, and customer service;
• Username, password, and other information for accounts for Fujitsu Frontech North America services;
• Financial information, such as data related to your payment method (e.g. valid credit card number, card brand, expiration date) that we may collect when you purchase, order, return, exchange, or request information about our services from the Site; and
• Photographs, images, biometrics, and related hash values.

You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features of the Site or our services.

(b) Personal Information Collected By The Site, Our Other Systems, Or From Interactions With Our Services: If you visit the Site, interact with us through social media services, exchange emails, telephone conversations or other electronic communications with our employees and other staff members, or physically enter some of our facilities, we may automatically collect some information about you and your visit or interaction, including, for example:

• Details about your computers, mobile devices, applications, and networks (including IP addresses, browser characteristics, mobile device ID, characteristics and location, operating systems, system languages, and preferences);
• Information about your activities on the Site, usage patterns of services and interactions with or through social media networks (including referring URLs, dates and times of website visits, and clickstream data such as information commonly recorded in web server logs);
• Details about Internet or network usage (including URLs or domain names of websites you visit, information about applications that attempt to access your network, or traffic data);
• Data about files and communications, such as potential malware or spam (which may include computer files, emails and attachments, email addresses, metadata, and traffic data, or portions or hashes of any of this information);
• Details of your conversations with our employees or other staff, including, in some instances, their content;
• Information about your visit to our facilities captured by closed circuit TV systems and other security and access management systems, including video; and
• Other information used in the operation of our services.

(c) Other information: We may also collect information about you from other sources, including, the organization you represent, third party data providers, and publicly available sources.

(d) Social Media Networks and Third-Party Websites: Please note that while Fujitsu Frontech North America makes reasonable efforts to ensure that social media providers have permission from you to allow us to access certain information about you through their services, we are not responsible for the manner in which social media service providers handle your personal information that they may collect from you, as this is their responsibility. In addition, while the Site may use plugins of social media networks such as Twitter, Facebook, LinkedIn, and Google+, or links to websites of third parties who are not affiliated with Fujitsu Frontech North America, your use of these plugins or links will establish a direct connection between your browser and the sites of the respective social media networks or third-party websites. As this transfer takes place directly between your browser and the respective network, Fujitsu Frontech North America does not have any access, knowledge or control over any data sent or the use of this data within the respective social media or third-party network. If you make use of a social media network or third-party website and make content available to them, the terms of use and privacy policies of the respective operators of those social media networks and websites, and not this Privacy Policy, will apply to any such use and shared content. We encourage you to read the privacy policies and terms and conditions of your social media service providers and third-party website operators to understand how they collect and handle your personal information.

(e) De-Identified and Aggregated Information: By visiting, registering to use, accessing, using, interacting with, and/or providing information through the Site or our services, you expressly agree that Fujitsu Frontech North America owns, without restriction, all de-identified and aggregated information and other non-personal information collected and/or created by or on behalf of Fujitsu Frontech North America.

Section 3. Biometric Information

When you register for a Fujitsu Frontech North America user account or a user account with your administrator, you may be asked to provide one or more of the following Biometric Identifiers: (i) fingerprint; (ii) voiceprint; (iii) scan of face geometry; and (iv) passive behavior factors. Such Biometric Identifiers may be captured and processed at account registration and throughout your enrollment in certain Fujitsu Frontech North America services to generate Biometric Information used to identify you. The term “Biometric Identifiers” as used in this Privacy Policy includes “biometric identifier” as defined in the Illinois Biometric Information Privacy Act, 740 ILCS § 14/1, et seq. (BIPA) and the Texas Capture or Use of Biometric Identifier Act, Tex. Bus. & Com. Code Ann. § 503.001 (CUBA), and the term “Biometric Information” as used in this Privacy Policy includes “biometric information” as defined in Illinois’ BIPA, “biometric identifier” as defined in Washington State’s law regarding biometric indemnifiers, RCW 19.375.010, et seq., and “biometric data” as defined in the Regulation (EU) 2016/679 (General Data Protection Regulation (GDPR)).

We only capture the Biometric Identifiers requested to be captured by either you or your administrator, as applicable. If your use of Fujitsu Frontech North America services is administered by a third-party administrator, you may also be subject to that third party’s own privacy policy and terms of use, which you should review in addition to this Privacy Policy before providing any personal information, including Biometric Identifiers, through the Site or any Fujitsu Frontech North America or services.

Your Biometric Information will be encrypted and stored on either one of our authorized service provider’s servers, an applicable administrator’s servers, or your designated device(s). In order to better serve you and detect and prevent fraud, Fujitsu Frontech North America may, but is not obligated to, continue to process your Biometric Information until the earlier of (i) one year from the date that you deactivate your applicable user account or your account is otherwise closed, (ii) the time at which the purpose of the initial collection of your Biometric Information has been satisfied, or (iii) three years from your last interaction with us or Fujitsu Frontech North America services, whereupon your Biometric Information will be permanently destroyed. If you re-open your account or open a new account after we have permanently destroyed your Biometric Information, you will need to re-provide the requested Biometric Information and may be required to re-provide other personal information. We may continue, but are not obligated, to process all personal information other than Biometric Information for as long as we deem necessary for the provision of your account and the applicable Fujitsu Frontech North America services.

Section 4. IP Addresses

All Internet-enabled devices have an Internet protocol address or IP address. The Site and other Fujitsu Frontech North America services use IP addresses to help keep security measures current and relevant.

Section 5. Cookies

Fujitsu Frontech North America uses “cookies” to remember user preferences and to maximize the performance of the Site and our services. Cookies also help us to identify returning users so, for example, we don’t need to ask them to enter their email and password on every visit. Please note the information gathered by cookies may be necessary to provide some Fujitsu Frontech North America services, including certain subscriptions. We cannot provide such services to users who do not give their consent to the data processing carried out through cookies or whose browsers are set to reject all cookies. For example, when you purchase a subscription to an online technology, a cookie is set that identifies the software, version, and when it expires. We use this information to alert you that a newer version is available or if your subscription is going to expire.

Cookies may also be used to control the type and frequency of ads, promotions, or other marketing messages the customer views. These ads may be placed by Fujitsu Frontech North America or third-party advertising companies which are our vendors. Fujitsu Frontech North America also uses “web beacons” (small transparent image files) to count visitors to the Site and analyze how visitors use our Site. The information collected is generally anonymized and is not used to identify any particular user.

Fujitsu Frontech North America also maintains log files of the traffic on the Sites. For example, our servers may automatically record the information you or your browser send when you visit the Site. These log files may include information such as your requests, IP address, browser type, browser language, the date and time of your request, and one or more cookies that may uniquely identify your system.

Section 6. How We Use Your Personal Information

Having accurate information about you permits Fujitsu Frontech North America to provide you with a smooth, efficient, and customized experience. Specifically, Fujitsu Frontech North America and the providers and partners that help provide Fujitsu Frontech North America’s services may collect and use your personal information for the following purposes:

• to operate, manage, develop and promote our business (including the Site, our products and services);
• to perform accounting, auditing, billing, reconciliation, and collection activities, and, if applicable, process payments and complete transactions through our third-party payment processor;
• to operate recruiting activities;
• to protect our business from fraud, money-laundering, breach of confidence, theft of proprietary materials and other financial or business crimes, and to investigate and respond to potential or actual claims, liabilities, prohibited behavior, and criminal activity;
• to comply with and enforce our legal and regulatory obligations, agreements, and policies, and bring and defend legal claims and assert legal rights;
• to predict future security threats and vulnerabilities and investigate, respond to, and manage security related incidents and events;
• to authenticate your inputted biometrics;
• to provide security advisories, information, and updates;
• to help safeguard your devices and your data;
• to conduct research and analysis, and to communicate about, and administer participation in, special events, programs, surveys, contests, sweepstakes, and other offers and promotions;
• to establish and manage Fujitsu Frontech North America and/or its affiliates’ user accounts, provide customer support, manage subscriptions, and respond to requests, questions and comments;
• to personalize and manage our relationship with you;
• to enable posting on our blogs and other communications;
• to customize, measure, and improve the Site and our services; and
• to perform other activities consistent with this Privacy Policy.

We may from time to time review your information held in our systems – including the contents of and other information related to your email and other communications with us – for compliance and business-protection purposes as described above. This may include reviews for the purposes of disclosure of information relevant to litigation and/or reviews of records relevant to internal or external regulatory or criminal investigations. To the extent permitted by applicable law, these reviews will be conducted in a reasonable and proportionate way and approved at an appropriate level of management. They may ultimately involve disclosure of your information to governmental agencies and litigation counterparties as described below. Your emails and other communications may also occasionally be accessed by persons other than the member of staff with whom they are exchanged for ordinary business management purposes (for example, where necessary when a staff member is out of the office or has left Fujitsu Frontech North America).

We will only process your personal information as necessary so that we can pursue the purposes described above and where we have a legal basis for such processing. Where our lawful basis for processing is that such processing is necessary to pursue our legitimate interests, we will only process your personal information where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest. In exceptional circumstances we may also be required by law to disclose or otherwise process your personal information.

Because de-identified and aggregated information and other non-personal information cannot be used to personally identify you, we may use such information for any lawful purpose.

Section 7. How We Share Your Personal Information

We may share your personal information, where reasonably necessary for the various purposes set out above, with:

• other business entities that are legally related to Fujitsu Frontech North America, such as other members of the Fujitsu group of companies or any third party that may take over all or part of Fujitsu Frontech North America’s business or functions in the future (provided that such party agrees to use such personal information in a manner that is consistent with this Privacy Policy);
• your colleagues within the organization that you represent, to the extent necessary to carry out any business opportunities between us and your organization;
• authorized service providers and partners who perform services for us, including those who host our web services or other information technology systems, or otherwise hold or process your information on our behalf, under conditions of confidentiality and security required by law;
• business partners, channel partners, service partner, agents, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• your administrator, if applicable, with your consent, or
• third parties with your consent.

We may also disclose personal information: (a) if we are required to do so by law or legal process; (b) in response to requests by government agencies, such as law enforcement authorities or other authorized third parties; (c) as may be required for purposes of national security; (d) when we believe disclosure is necessary and appropriate to prevent physical, mental, financial, or other harm, injury, or loss; or (e) in connection with an investigation of suspected or actual illegal or inappropriate activity or exposure to liability.

These disclosures may involve transferring your personal information to countries other than the country in which the information originally was collected. Those countries may not have as comprehensive data protection laws as the country from which Fujitsu Frontech North America initially obtained the information. When we transfer the information to other countries, we use a reasonable standard of care and appropriate organizational, physical, and technical security practices and procedures

Because de-identified and aggregated information and other non-personal information cannot be used to personally identify you, we may share such information for any lawful purpose.

Section 8. How You Can Manage and Control Your Personal Information

Many Fujitsu Frontech North America services allow users to make choices about the personal information collected. For instance:

• You may choose not to receive marketing communications from us by clicking on the unsubscribe link or other instructions in our marketing emails or contacting us as specified in the “How to Contact Us” section below.
• Many Fujitsu Frontech North America services contain settings that allow users or administrators to control how the service collects information. Please refer to the relevant service manual or contact us through the appropriate technical support channel for assistance.
• To remove your personal information, please contact us.

If you chose to no longer receive marketing information, Fujitsu Frontech North America may still communicate with you regarding such things as security updates, functionality, responses to service requests, or other transactional, non-marketing/administrative related purposes.

Section 9. Storage and Data Retention

The information we collect may be stored and processed in servers in the United States and wherever Fujitsu Frontech North America and our service providers have facilities around the globe.

The time periods for which we retain your personal information depend on the purposes for which we use it. Generally, Fujitsu Frontech North America will keep your personal information for as long as it is necessary to fulfil the purposes for which we had collected it or you remain a registered subscriber or user of our services and, thereafter, for no longer than is required by law, or Fujitsu Frontech North America’s Records Retention Policy, reasonably necessary for internal reporting and reconciliation purposes, or to provide you with feedback or information you might request. In certain circumstances, we may be required to retain data we have about you for a longer period (such as for tax, litigation (threatened, anticipated, or actual), other business purposes, or if required by law enforcement). We will delete your personal information if we believe that your personal information that we hold is inaccurate, or when you have informed us that you no longer consent to our processing of your personal information.

Section 10. Security

We implement appropriate organizational, physical, and technical security practices and procedures for storing and transmitting the personal information we collect and process. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, and availability. Periodically, we test our website, services, data centers, systems, and other assets for security vulnerabilities.

Section 11. Personal Information of Children

Fujitsu Frontech North America respects the privacy of children and does not knowingly collect, use or disclose personal information of children under 16 years of age without verifiable consent from a parent or guardian. If Fujitsu Frontech North America becomes aware that the information submitted to or collected by Fujitsu Frontech North America is personal information of children without first receiving verifiable consent from a parent or guardian, Fujitsu Frontech North America will take prompt steps to delete such personal information. If a parent or guardian wishes to raise a concern regarding personal information pertaining to a child, please email our Privacy Officer at [email protected].

Section 12. CAN-SPAM Act

Fujitsu Frontech North America is committed to being compliant with the Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003 (“CAN-SPAM Act”). All emails you receive from us are intended to fully comply with the CAN-SPAM Act. If at any time you would like to unsubscribe from receiving future emails, you can email us at [email protected], and we will promptly remove you from ALL correspondence.

Section 13. DMCA

The Digital Millennium Copyright Act of 1998 (“DMCA”) provides recourse for copyright owners who believe that material appearing on the Internet infringes their rights under U.S. copyright law. If you believe in good faith that any content made available in connection with the Site or Fujitsu Frontech North America’s services infringes your copyright, you (or your agent) may send us a notice requesting that the content be removed, or access to it blocked. Notices and counter-notices must meet the then-current statutory requirements imposed by the DMCA (see http://www.loc.gov/copyright for details). Notices and counter-notices with respect to the Site or our services should be sent to:

Fujitsu Frontech North America

36 Technology Drive, Suite 150 Irvine, CA 92618 Attn: DMCA Notice

Section 14. What Are Your Rights?

You have the following rights (subject to applicable local laws) in relation to the personal information that we hold about you:

• to access your personal information, and some related information, under relevant data protection law;
• to require any inaccurate personal information to be corrected or deleted;
• to object to our use of your personal information for direct marketing purposes at any time and you may have the right to object to our processing of some or all of your personal information (and require them to be deleted) in some other circumstances;
• to require us to delete your personal information in certain circumstances;
• to require us to restrict or block the processing of your personal information in certain circumstances (when processing is restricted, we can still store your personal information, but may not use it further);
• to obtain from us your personal information, in a structured, commonly used and machine-readable format in certain circumstances. Further, you may have the right to require us to transmit your personal information directly to another person (for instance a new provider) where it is technically feasible to do so; and
• where we are processing your personal information based on your consent to such processing, to withdraw your consent at any time.

Further information and advice about your rights can be obtained from the data protection regulator in your country. If you wish to exercise any of these rights (subject to applicable local laws) or have complaints about our processing of your personal information, please email our Privacy Officer at [email protected].

Section 15. Automated Decision Making

We may use technology which tracks your use of our website and your interactions with us, and which helps us to build a profile of your preferred products and information requests. If we do this, what this means for you is that you are more likely to receive offers and information that are tailored to your specific preferences, based on your previous profile activity.

If we use automated decision making in respect of any specific service or product and such automated decision making produces legal effects concerning data subjects or similarly significantly affects them, we will provide information required by applicable laws in respect of such automated decision making.

Section 16. California Consumer Privacy Act & California Privacy Rights Act

(a) General: The California Consumer Privacy Act of 2018 (“CCPA”), as supplemented by the California Privacy Rights Act (“CPRA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” over the past 12 months, as well as rights to know/access, delete, limit sharing of Personal Information, and have incorrect Personal Information corrected and/or deleted The CCPA defines “Personal Information” to mean “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Certain information we collect may be exempt from the CCPA/CPRA because it is considered public information (i.e., it is made available by a government entity) or covered by a specific federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.

To the extent that we collect Personal Information that is subject to the CCPA/CPRA, that information, our practices, and your rights are described below.

(b) Right to Notice at Collection Regarding the Categories of Personal Information Collected: You have the right to receive notice of the categories of Personal Information we collect, and the purposes for which those categories of Personal Information will be used. This notice should be provided at or before the time of collection. The categories we use to describe the information are those enumerated in the CCPA/CPRA.

• Identifiers, such as name, contact information, IP address. device information, and other online identifiers;
• Personal information, as defined in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) customer records law, such as name, contact information, and payment card number;
• Characteristics of protected classifications under California or federal law, such as age and gender;
• Commercial information, such as transaction information and purchase history;
• Internet or network activity information, such as browsing history and interactions with our website;
• • Geolocation data, such as device location;
• Audio, electronic, visual, and similar information; and
• Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.

We collect this Personal Information from you as well as from our affiliates, publicly available databases, and joint marketing partners. We use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, as described above in this Privacy Policy under “How We Use Your Personal Information.”

We do not sell Personal Information and in the preceding twelve (12) months, we have not sold any Personal Information.

We may share, and may have shared, any of the above-listed Personal Information with related companies and third parties consistent with this Privacy Policy. The types of parties with whom we share information and the services they provide are described in this Privacy Policy under Section 7. above, “How We Share Your Personal Information,” and may include affiliates: resellers and distributors, consultants and other third-party service providers; our event co-sponsors and allegiance partners; third parties to permit them to send you marketing communications, consistent with your choices; and third-party sponsors of contests, surveys or similar promotions.

(c) Right to Know/Access Information: If you are a California resident, you have the right to request access to Personal Information we have collected about you over the past 12 months and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. Below is a complete list of the Personal Information that you can include in your request.

• The categories of Personal Information that Fujitsu Frontech North America has collected about you.
• The categories of sources from which Fujitsu Frontech North America collected the Personal Information.
• The business or commercial purpose for collecting or selling Personal Information.
• The categories of third parties with whom Fujitsu Frontech North America shares Personal Information.
• The specific pieces of Personal Information Fujitsu Frontech North America has collected about you.
• The categories of Personal Information that Fujitsu Frontech North America disclosed about you for business purpose.
• The categories of Personal Information that Fujitsu Frontech North America has sold about you, as well as the categories of third parties to whom Fujitsu Frontech North America sold your Personal Information.

If you would like to exercise your right to request disclosure, you may submit such a request as described below. To protect our users’ Personal Information, we are required to verify your identity before we can act on your request.

(d) Right to Request Deletion of Information and Correction of Inaccurate Information: If you are a California resident, you also have the right to request in certain circumstances that we delete any Personal Information that we have collected directly from you, or likewise, to correct any inaccurate information we have about you. You may submit such a request as described below. To protect our users’ Personal Information, we are required to verify your identity before we can act on your request. We may have a reason under the law why we do not have to comply with your request, may need to retain certain information for legal or internal business purposes, or why we may otherwise comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

(e) How to Submit a Request: You may submit a request to exercise your rights to know/access or delete your Personal Information by sending an email to the Privacy Officer at [email protected], or by writing us at the address listed under “Contact Us” on the Site. We will respond to your request consistent with applicable law.

Only you or your authorized agent may make a verifiable consumer request related to your Personal Information. If you use an authorized agent to submit a request on your behalf, we may require that you (1) provide the authorized agent written permission to do so, and (2) provide a copy of the authorization or provide a copy of a power of attorney that complies with California Probate Code sections 4000 to 4465 so that we can verify the identity of the authorized agent.

In verifying requests, we employ reasonable measures to detect fraudulent requests and prevent unauthorized access to your Personal Information. To meet our obligations, we are required to verify your identity, and the identity of your authorized agent, if the request is submitted via an agent, by associating the information provided in your request to Personal Information previously collected by us.

If we suspect fraudulent or malicious activity on or from the password-protected account, we may decline a request or request that you provide further verifying information.

You may only make a verifiable consumer request twice within a 12-month period. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify your identity or authority to make the request.

(f) Right to Opt-Out of Sale of Personal Information to Third Parties: We do not sell information to third parties. However, under the CPRA you have the right to opt out of any sale of your Personal Information by Fujitsu Frontech North America to third parties by either contacting us at the contact information listed in Section (e) above, or through the “Do Not Sell My Personal Information” link on the Site, if applicable, if and when Fujitsu Frontech North America activates such a link due to its selling of Personal Information.

(g) Right to Information Regarding Participation in Data Sharing and Prohibition on Discrimination: You have the right to be free from discrimination based on your exercise of your CCPA and CPRA rights. We do not discriminate against anyone who chooses to exercise their CCPA and CPRA rights.

Section 17. State Specific Disclosures

(a) Nevada Privacy Rights. The provisions of this Privacy Policy, including the provisions of Section 16, apply to Nevada consumers. We do not sell your personal information or data. If and when we do, however, you can opt out of the sale of your personal information by contacting the Privacy Officer at [email protected], or by writing us at the address listed under “Contact Us” on the Site. Our personnel will take your request and keep you up to date on the progress of your request.

(b) Utah Privacy Rights under Utah Consumer Privacy Act. If you are a resident of Utah, you have certain rights under the Utah Consumer Privacy Act (UCPA). The provisions of this Privacy Policy, including the provisions of Section 16, also apply to Utah consumers, and conform to the requirements of the UCPA. In addition, the following provisions are applicable to those governed by the UCPA:

• Your choices: We do not send unsolicited promotional materials without your request. If you do receive any such materials, you may opt-out of receiving promotional materials from us and/or may request that we delete your personal information by contacting us at [email protected], calling us at 1-800-FUJITSU (1-800-385-4878), or by writing us at the address listed under “Contact Us” on the Site. However, we may be required to retain certain information for legal or business purposes.

(c) Colorado Privacy Rights under Colorado Privacy Act. We do not sell your personal information or data or process it for targeted marketing. The provisions of this Privacy Policy, including the provisions of Section 16, also apply to Colorado consumers, and conform to the requirements of the Colorado Privacy Act (CPA). In addition, the following apply to those governed by the CPA:

• YOU HAVE THE RIGHT TO OPT OUT OF THE PROCESSING OF PERSONAL DATA FOR TARGETED ADVERTISING OR FOR THE SALE OF SUCH PERSONAL DATA, if and when Fujitsu Frontech North America ever implements a practice selling personal information or data, or the processing of personal information or data.
• You have the right to access certain personal data in a portable, readily usable format, with the right to correct inaccuracies and to delete personal data concerning you.
• We shall not collet “sensitive” personal information (as defined in the CPA) without first obtaining your consent.
• You may opt-out of the collection and use of any personal information and data, and may exercise your right to access, correct inaccuracies to, and/or delete such personal data by contacting the Privacy Officer at [email protected] or by writing us at the address listed under “Contact Us” on the Site.

(d) Virginia Privacy Rights under Virginia Consumer Data Protection Act. The disclosures in this Privacy Policy are made pursuant to the Virginia Consumer Data Protection Act (VCPDA) and supplement our general privacy notice. The provisions of this Privacy Policy, including the provisions of Section 16. References to “personal information” in our general privacy notice describe our practices with respect to “personal data” as defined under the VCPDA. We do not use your personal data in such a way that is considered a “sale” under VCPA, and do not process personal data for targeted advertising purposes. If at any point we do, you have the right to opt out of both practices. Information on how to exercise your opt-out rights as well as other rights you have under VCPDA is below. If you are a Virginia resident, subject to certain conditions and restrictions set out in the VCPDA and other applicable laws, you have the following rights regarding your personal data:

• Right to access. You have the right to request access to and obtain a copy of any personal data that we may hold about you.
• Right to correct. You have the right to request that we correct inaccuracies in your personal data.
• Right to delete. You have the right to request that we delete personal data that we have collected from or obtained about you.
• Although we do not sell your personal data, if we adopt a policy to do so, you have the right to opt out of the sale of personal data. You may request that we stop sharing data in a way that is considered a “sale”.
• Right to opt out of targeted advertising. You may request that we stop disclosures of your personal data for targeted advertising.
• Right to opt out of profiling. You have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. We do not profile in a manner that would result in legal or similarly significant effects and as such do not offer this right.
• Right to appeal. If you are unsatisfied with our actions related to exercising one of your privacy rights above, you may appeal our decision.
• Right to non-discrimination. If you choose to exercise any of the privacy rights described above, we will not deny our products or services to you, charge you different prices or provide a different level or quality of products or services to you unless those differences are related to the value of your personal data.

You may submit a request to exercise your rights to know/access or delete your Personal Information by sending an email to the Privacy Officer at [email protected] or by writing us at the address listed under “Contact Us” on the Site. We will respond to your request consistent with applicable law.

We will only use personal data provided in a request to verify the request. We will not further disclose the personal data and will retain it only as necessary for the purpose of verification and to meet our legal obligations. We cannot fulfill your request if we cannot verify your identity or authority to make the request and confirm the personal data that is subject of the request relates to you.

(e) Connecticut Privacy Rights under Connecticut Data Privacy Act (CTDPA) . If you are a resident of Connecticut, you have certain rights under the (CTDPA). The provisions of this Privacy Policy, including the provisions of Section 16, apply to Connecticut consumers, and conform to the requirements of the CTDPA. The disclosures in this section are made pursuant to the and supplement this Privacy Policy. References to personal information in this Privacy Policy describe our practices with respect to personal data as defined under the CTDPA. We do not use your personal data in such a way that is considered a “sale” under CTDPA. In addition to this Privacy Policy, the following provisions apply to those covered by the CTDPA:

• We shall not collet “sensitive” personal information (as defined in the CPA) without first obtaining your consent.
• We limit the collection of personal data to what is adequate, relevant, and reasonably necessary for the disclosed purposes for which the data is processed.
• Without your consent, we shall not process personal data for purposes that are neither reasonably necessary to, not compatible with, the disclosed purposes for which such personal data is processed, as disclosed to you.
• You may revoke your consent to process personal data by contacting us via the contact information listed below.
• You may designate an authorized agent to exercise your rights hereunder. If you use an authorized agent to submit a request on your behalf, we may require that you (1) provide the authorized agent written permission to do so, and (2) provide a copy of the authorization or provide a copy of a power of attorney
• You may opt-out of the collection and use of any personal information and data, and may exercise your right to access, correct inaccuracies to, and/or delete such personal data by contacting at the Privacy Officer at [email protected], or by writing us at the address listed under “Contact Us” on the Site.

Section 18. Information for Users in the European Economic Area (“EEA”) or in the United Kingdom (“UK”)

Fujitsu Frontech North America may transfer Personal Data from the EEA or the UK to the United States, including Personal Data we receive from individuals residing in the EEA or the UK who visit the Site and/or who may use our services or otherwise interact with us. Please note that the term “Personal Data” used in this section is equivalent to the term “personal data” under applicable European and UK data protection laws for individuals located in the EEA or the UK. When Fujitsu Frontech North America engages in such transfers of Personal Data, it relies on (a) Adequacy Decisions as adopted by European Commission on the basis of Article 45 of Regulation (EU) 2016/679 (“GDPR”), or (b) Standard Contractual Clauses issued by the European Commission. The European Commission has determined that the Standard Contractual Clauses provide sufficient safeguards to protect personal data transferred outside the EU or EEA. For more information, please visit https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en. Fujitsu Frontech North America continually monitors the circumstances surrounding such transfers in order to ensure that these maintain, in practice, a level of protection that is essentially equivalent to the one guaranteed by the GDPR.

Section 19. Information for Users in Canada related to rights under PIPEDA

The Federal Canadian Personal Information and Protection of Electronic Documents Act (PIPEDA), as well as similar legislation now in effect in Quebec, Alberta and British Columbia, defines requirements for all organizations regarding the handling of personal information of Canadian residents. Although the specific federal and provincial legislation may vary slightly, they are based on the same principles. Fujitsu Frontech North America’s policy has been developed to be comprehensive enough to comply with the combined requirements of all applicable legislation, and is committed to the Privacy principles of PIPEDA as stated below:

• Accountability. Fujitsu is responsible for maintaining and protecting the personal information under its control and has designated a Privacy Officer to be accountable for ensuring compliance with the requirements of all applicable privacy legislation.
• Identifying Purposes. The purposes for which personal information is collected shall be identified before or at the time the personal information is collected. If Fujitsu intends to use the personal information that has been collected for a new purpose, this new purpose will be identified and notice to or consent for such new purpose will be obtained prior to its use.
• Notice and Consent. Fujitsu will provide notice to, or obtain consent from, an individual for the collection, use or disclosure of his/her personal information according to applicable legislative requirements.
• Limiting Collection. Personal Information collected shall be limited only to that which is necessary for the purposes identified.
• Limiting Use, Disclosure and Retention. Personal information shall only be used or disclosed for the purposes for which it was collected, unless an individual has otherwise consented or when it is required or permitted by law. Personal information shall be retained only as long as necessary for the fulfilment of those purposes.
• Accuracy. Fujitsu will take reasonable steps to ensure that personal information is as accurate, complete and up-to-date as may be necessary to fulfil the purposes for which it is to be used.
• Safeguards. Reasonable efforts will be taken to protect personal information using security safeguards that are appropriate to the sensitivity level of the personal information collected. This may include secured access to computer applications / files and paper files, and protection clauses in contracts and communications with third parties. Employees who have access to the information will be made aware of the importance of maintaining the confidentiality of personal information.
• Openness. Fujitsu will provide information to individuals about our policies and procedures relating to the management of personal information that is under its control.
• Individual’s Access. Upon request and as permitted by law, Fujitsu will provide access to the personal information retained about an individual as well as how the information was collected, how it is being used and to whom it has been disclosed. Individuals are entitled to challenge the accuracy and completeness of that personal information and request that it be amended, if appropriate.
• Handling Enquiries or Complaints. Fujitsu Frontech north America will ensure all questions, enquiries or complaints concerning compliance with privacy policies and procedures are addressed.

Section 20. Changes to this Privacy Policy

This Privacy Policy is valid from the time of its publication on the Site, and all previous versions of this Privacy Policy become invalid as of such time. Any changes we make to this privacy statement in the future will be posted to the Site. Please check back frequently to see any changes. If an update changes how we use your personal information or applicable law otherwise requires your consent, we will also seek your consent prior to such update applying to you. Upon providing notice as noted above, updates which do not require your consent will be effective regardless of whether your consent is obtained.

Section 21. Contact Us

If you have any questions, comments, requests or concerns regarding this privacy statement or our processing of personal information, or would like to update information we have about you or your preferences, please contact us by sending an email to the Privacy Officer at [email protected] or contact us by writing us at:

Fujitsu Frontech North America
36 Technology, Suite 150
Irvine, CA 92618

Last updated: 26 January 2024