Epson Projector Management Connected

Privacy Information Statement

Effective Date: January 13, 2023

1. INTRODUCTION AND OVERVIEW

This Privacy Policy describes how Seiko Epson Corporation (including its subsidiaries and affiliated companies) ("EPSON") collects, uses, and shares information about you and applies to your use of EPSON Projector Management Connected ("EPMC") and all features, content, and other services that EPSON owns, controls and makes available through EPMC or related software, including the Data Collection Agent and/or the Embedded Status Agent (the "Service"). This Privacy Policy does not apply to EPSON’s data collection activities outside of the Service (unless otherwise stated below or at the time of collection).

You agree to EPSON’s EPMC Terms of Use, and in doing so, you consent to EPSON's collection, use and disclosure practices, and other activities as described in such applicable documentation and this Privacy Policy. If you do not agree and consent, discontinue use of the Service and/or software, as applicable.

This Privacy Policy is intended to apply to the collection and processing of personal information from customers and individuals in Latin America, which shall be defined as: the countries of Argentina, Bolivia, Chile, Colombia, Costa Rica, Dominican Republic, Ecuador, El Salvador, Guatemala, Honduras, Mexico, Nicaragua, Panama, Paraguay, Peru, Uruguay. It does not apply to websites managed or operated by other Epson entities or websites in other countries operated by other Epson entities, including in the European Union. If Epson receives and becomes aware of any personal information of a customer or individual in the European Union, such information will not be processed or retained by Epson America, Inc.

2. INFORMATION COLLECTION

A. Information You Provide to Us.

EPSON collects information you provide directly to EPSON via the Service. For example, EPSON collects information when you use the Service, create an account (including all information submitted as part of your Epson Global ID registration), subscribe to EPSON notifications, or communicate with EPSON through the Service.

The information EPSON collects may include Personal Information. "Personal Information" is information that can be used to identify an individual (whether alone or in combination), such as first and last name and email address.

EPSON may also ask you to provide information about your business, such as your business name.

You may choose to voluntarily submit certain other information to EPSON through the Service, including Personal Information, but you are solely responsible for such Personal Information in instances where EPSON has not collected such information or requested that you submit such information to EPSON.

Personal Information once "de-identified" will not be subject to this Privacy Policy and EPSON and its Service Providers (defined below) may treat it as non-Personal Information and use it without obligation to you except as prohibited by applicable law.

B. Information EPSON Collects Automatically.

EPSON and its Service Providers may automatically collect certain information about you when you access or use the Service ("Usage Information"). Usage Information may include your IP address, device identifier, Ad ID, browser type; operating system characteristics, data regarding network connected hardware (e.g., computer or mobile device), and information about your use of the Service, such as the time and duration of your visit and how you arrived at the Service. Usage Information may be combined with your Personal Information. To the extent that EPSON combines Usage Information with your Personal Information, EPSON will treat the combined information as Personal Information under this Privacy Policy.

The methods that EPSON and its Service Providers may use to collect Usage Information for service providers, includes:

• Data Collection Agent/Embedded Status Agent: EPSON collects certain projector information through the Data Collection Agent ("DCA") and/or the Embedded Status Agent ("ES Agent"). The DCA must be downloaded to a PC that is connected to the same network as the EPSON projector and with Internet access, or the Epson Remote Services must be activated from the device Web page via an ES Agent for devices equipped with embedded Epson Remote Services capability, for device monitoring. Use of the DCA is subject to the license terms in the End User License Agreement that accompanies the DCA. Use of the ES Agent is subject to the license terms in the End User License Agreement that accompanies the ES Agent. The DCA/ES Agent will detect the projection start of your EPSON projector, among other information about use of your EPSON projector such as light-up time, replacement date of your projector’s lamp/laser and fan, serial numbers and other Epson product information, and/or data regarding machine performance such as device settings, device alerts, error history, and will send that information to EPMC through your internet connection. You are fully responsible for maintaining your internet connection in order for the DCA or the ES Agent to continue collecting this information. This information will be used by technicians for device troubleshooting; and by administrators for usage, and by business personnel for research and development of service and product enhancement.
• Log Information: EPSON collects information about your use of the Service, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamps, and related data, and store it in log files.
• Information Collected During a Login Session: EPSON may use session ID which make it easier for you to navigate the Service and expire when you close your browser. EPMC uses “local storage” and “session storage” to keep user interface related information such as language, number of items to be displayed on a page, and account information such as login user, available functions, viewable range for a consistent browser experience.

C. Information EPSON Collects from Third Party Dealers.

EPSON may collect certain non-personal information from you or the provider of certain third party services regarding your products and systems, their performance as well as the products and the services provided by the third party servicer for those products and systems ("Third Party Dealers"). This data may be used by EPSON for its business purposes, which may include to provide and improve the quality of products, features and services, as well as offer you other products, services and features you may be interested in, all in accordance with the terms of this privacy policy. EPSON is not responsible for the accuracy of the information provided by Third Party Dealers.

D. Information From Other Sources.

EPSON may also obtain information about you from other sources and combine that with information EPSON collects about you. To the extent EPSON combines such third party sourced information with Personal Information EPSON collects directly from you on the Service, EPSON will treat the combined information as Personal Information under this Privacy Policy. EPSON is not responsible for the accuracy of the information provided by third parties or third party practices.

3. USE OF INFORMATION

EPSON may use information about you for any purposes not inconsistent with the statements under this Privacy Policy or prohibited by applicable law, including to:

• Facilitate, operate, manage, personalize and improve the Service or the online experience through the Service, including your account;
• Transact with you, respond to your comments, questions and requests, provide customer service, send you informational notices, and contact you if EPSON needs to obtain or provide additional information;
• Conduct research and analysis, including focus groups and surveys;
• Monitoring and analyzing trends, usage and activities;

• Developing and sending you direct marketing, including advertisements and communications about our and other entities’ products, offers, promotions, rewards, events, and services; and

• Prevent and address fraud, breach of policies or terms and threats or harm.

4. ACCESSING EPMC FROM THIRD-PARTY APPLICATIONS

Epson is not responsible or liable for the third-party applications that you download onto your mobile device or its availability, content, accuracy or privacy and data collection practices. Applications developed by third-parties are not operated or controlled by Epson. These third-party applications may  enable  you to project on your Epson device. The data collected by these third-party applications is subject to such third-party application’s terms of use and privacy policy. If you decide to download or access the third-party application, you do so entirely at your own risk. We recommend that you review the privacy and data collection practices of such third-party application.

5. SHARING INFORMATION

EPSON's agents, vendors, consultants, integrators and other service providers (collectively "Service Providers") and EPSON’s affiliated companies, including Epson’s parent company, may receive, or be given access to your information, without limitation, Personal Information and Usage Information, in connection with their work on EPSON's behalf. Each party is prohibited from using Personal Information for any purpose other than to provide this assistance, although EPSON may permit them to use aggregate information (which does not identify the data subject) or de-identified data for other purposes. EPSON may also share information about you as follows:

• To comply with the law, law enforcement or other legal process, and except as prohibited by applicable law, in response to a government request;
• To protect the rights, property, life, health, security and safety of EPSON, the Service or any third party;
• For internal business purposes; and
• In connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of EPSON's assets, or transfer of all or a portion of EPSON's business to another company.

Without limiting the foregoing, in EPSON's sole discretion, EPSON may share aggregated information which does not identify you or de-identified information about you with third parties or affiliates for any purpose.

6. Additional Disclosures for California Residents

These additional disclosures for California residents apply only to individuals who reside in California. The California Consumer Privacy Act of 2018 ("CCPA") provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.

A. Notice of Collection

In the past 12 months, we have collected the following categories of personal information enumerated in the CCPA:

• Identifiers, including name, email address, account name, IP address, and an ID or number assigned to your account.
• Customer records, including name, email address.
• Internet activity, including your interactions with our Service.
• Device Information, including device serial number and configuration information
• Device and Usage Data, data about the type of device or browser you use, your device's operating software, projecting status, laser/lamp/fan usage, your device’s regional and language settings, and device identifiers such as IP address.

For more information on information we collect, including the sources we receive information from, review Section 2. We collect and use these categories of personal information for the business purposes described in Section 3, including to provide and manage our Services.

We use and partner with different types of entities to assist with our daily operations and manage our Service. Please review Section 5 for more detail about the parties we have shared information with.

B. Right to Know and Delete

If you are a California resident, you have the right to delete the personal information we have collected from you and the right to know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information was collected;
• The categories of personal information about you we disclosed for a business purpose or sold;
• The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
• The business or commercial purpose for collecting or selling the personal information; and
• The specific pieces of personal information we have collected about you.

To exercise any of these rights, please submit a request through our online form available at https://dsar.goepson.com or call our toll free number at 1-800-822-0313. In the request, please specify which right you are seeking to exercise. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

C. Authorized Agent

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent's permission to do so and verify your identity directly.

D. Shine the Light

Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties' own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in "Contact Us" above and specify that you are making a "California Shine the Light Request." We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.

7. Additional Disclosures for Nevada Residents.

Nevada consumers may submit requests directing businesses not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to obtain information about our compliance with Nevada law, please contact us at privacy.contact@ea.epson.com.

8. CHILDREN'S PRIVACY

The Service is not intended for nor targeted toward children under the age of thirteen (13). EPSON does not knowingly collect personal information as defined by the U.S. Children's Privacy Protection Act ("COPPA") from children under the age of thirteen (13), and if EPSON learns that it has collected such information, EPSON will delete the information in accordance with COPPA. If you are a child under the age of thirteen (13), you are not permitted to use the Service and should not send any information about yourself to EPSON through the Service. If you are a parent or guardian and believe EPSON has collected information in a manner not permitted by COPPA, please contact EPSON using the information provided at the bottom of this policy statement.

9. DATA SECURITY

EPSON takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the Internet is not completely secure, and EPSON cannot guarantee the security of your information collected through the Service.

10. INTERNATIONAL TRANSFER

EPSON is based in the U.S. and the information it collects is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored and used in the U.S. Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing and storage of your information, including Personal Information, in the U.S. and Japan as set forth in this Privacy Policy.

11. CHANGES TO THIS PRIVACY POLICY

EPSON reserves the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Subject to applicable law, your continued use of the Service indicates your consent to the privacy policy posted. If the changes are material, EPSON may provide you additional notice, to your e-mail address.

12. CONTACT

For any requests relating to your Personal Information, or if you have any questions about this Privacy Policy, please contact EPSON at:

3131 Katella Ave, Los Alamitos, CA 90720 or via the following link: Privacy Feedback Form

13. ADDITONAL DISCLOSURES FOR ARGENTINA

If you reside in Argentina, the following additional sections will apply, complement or prevail over any conflicting provisions in this Privacy Statement:

Data controller: [include the local entity’s name and street address].

You are not obliged to provide your Personal Information, but if you do not provide such or if you provide false or inaccurate data, EPSON will not be able to carry out the purposes described in this Privacy Policy.

You have the right to request and obtain information about yourself stored by EPSON. You also have the right to request the rectification, updating and, where appropriate, deletion of your Personal Information. To exercise these rights, you may contact EPSON via email at privacy.contact@ea.epson.com. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests.

EPSON's Service Providers and EPSON’s affiliated companies with whom EPSON may share your Personal Information may be located in countries that have different laws and standards of protection than your country of residence. By accepting this Privacy Policy you are accepting that your Personal Information be transferred to such Service Providers and affiliated companies in their respective countries.

We inform you that the Agency for Access to Public Information, in its capacity as the Control Body of Law No. 25,326, has the authority to deal with complaints and claims made by those whose rights have been affected by non-compliance with the regulations in force regarding the protection of personal data.

14. ADDITONAL DISCLOSURES FOR COLOMBIA

If you reside in Colombia, the following additional sections will apply, complement or prevail over any conflicting provisions in this Privacy Statement:

Data controller: [include the local entity’s name and street address].

Rights for Colombian data subjects

Colombian data subjects have the right to access, update and rectify their data, the right to revoke their consent or request the deletion of their data (when the purposes for processing their data have been exhausted and there is no legal or contractual obligation to remain in the database), request evidence of consent given, and the right to bring claims before the Colombian data protection authority (the Superintendencia de Industria y Comercio).

Procedure to access your personal data

You, your successors, representatives and/or proxies may file requests regarding what personal data is stored in our databases, the processing to which it is subject to, and the purposes sought in addition to that. The following rules will guide this procedure:

- Requests must be submitted in writing and via email.

- The request will be reviewed to verify your identity. If the request is submitted by somebody other than you (the data subject), and the person cannot provide evidence that is legitimately acting on your behalf, the request will be rejected.

- We will provide answers to you within ten (10) business days following the date on which we received your complete request.

- In the event that a response to the request cannot be provided within ten (10) business days, we will inform you of the reasons why the request is still in process and provide the date on which the request will be addressed, which in any case will not exceed five (5) business days following the expiration of the first term.

- A final response to all requests will not take longer than fifteen (15) business days following the date on which we received the initial complete request.

Procedure for submitting claims to update, modify and eliminate your personal data and withdraw consent

You, your successors, representatives and/or proxies, who consider that the information included on our databases must be rectified, updated or eliminated, or when they forewarn the alleged breach of your rights, may submit a claim.

This procedure will be guided by the following rules:

- The claim must be submitted in writing and via email.

- The claim will be reviewed to verify your identification. If the request is submitted by somebody other than you (the data subject), and the person is not able to provide evidence that it is legitimately acting on your behalf, the request will be rejected.

- The claim must include the following information: (i) your name an identification; (ii) your contact information (physical address and/or electronic address and phone number); (iii) the documents that prove your identity or the corresponding representation documents in case you are successor, representative and/or proxy; (iv) a clear and accurate description of personal data of which you seek to update, modify, eliminate, or withdraw consent; (v) a description of the events giving rise to the claim; (vi) all the documentation that you want to make use of; and (vii) your signature and identification.

- If the claim or the documentation is incomplete, we will require you, within the five (5) business days following the receipt of the claim, to remedy the faults. If you do not submit the documentation and information required within two (2) months following the date of the initial claim, we will understand that you have waived the claim.

We will provide an answer for the claim in no more than fifteen (15) business days from the day following the date of its receipt. When the claim cannot be addressed within said term, you will be informed on the reasons for the delay and the date on which your claim will be addressed, which in any case call not exceed eight (8) business days following the data in which the initial claim was received.

15. ADDITONAL DISCLOSURES FOR CHILE

If you reside in Chile, the following additional sections will apply, complement or prevail over any conflicting provisions in this Privacy Statement:

Data controller: [include the local entity’s name and street address].

1. Section on Legal Bases.

The legal basis to process data will be your written and express consent. When EPSON must comply with a legal or administrative obligation, or a request from a public authority, the legal basis to process data will be the legal authorization. Nevertheless, the data processing will always be in line with the purposes of such legal authorization.

2. Data Subjects’ Rights. The Privacy Policy should include the following section:

You will be entitled to exercise the following rights:

· Access: to request information about the personal data that EPSON holds of you, its source and recipients, the purpose of the collection and storage, and information of the parties to whom their data is regularly transferred.

· Modification: to request the change of incorrect, inaccurate or incomplete data.

· Deletion: to request the deletion of data when: (i) its storage does not have a legal basis; (ii) the data has expired; or (iii) the data subject wilfully authorized the use of their personal data for commercial purposes but wishes to no longer receive such type of communication.

· Blocking: to request a temporary suspension of any data processing.

To exercise your rights, you should submit your application via email at privacy.contact@ea.epson.com. EPSON will be entitled to request any reasonable measure to verify your identity.

3. Retention of Personal Information.

Your Personal Information will be held for as long as it is necessary to carry out the purposes set out in this Privacy Policy (unless a longer retention period is required by applicable law). In general, this means that we will keep such information, at least, for as long as you keep your registered account.

16. ADDITONAL DISCLOSURES FOR COSTA RICA

If you reside in Costa Rica, the following additional sections will apply, complement or prevail over any conflicting provisions in this Privacy Statement:

We inform you expressly, precisely, and unequivocally about the following:

(a) EPSON has a personal database that includes your personal data. This personal data is collected directly from you and through ‘Service Providers’, ‘Third Party Dealers’ and ‘Other Sources’, as described in Section 2 (Information Collection) of EPSON’s Privacy Information Statement.

(b) Your responses to our requests for information will be optional.  In addition, the fact that we can obtain data about you through third parties as explained in paragraph (a) above will be optional for you.

(c) If you do not wish to provide the requested personal data or do not consent to Epson receiving your personal data from third parties as set forth in paragraph (a) above, then Epson may not provide the services to you.

(d) You may exercise at any time the rights of informative self-determination, access, rectification, modification, revocation, or deletion. In addition, you are protected by the rights set forth in EPSON's Privacy Information Statement. You may request information on the scope of these rights as well as the procedure to exercise them via email at privacy.contact@ea.epson.com.

(e) Data controller:  [include the local entity’s name and street address].

17. ADDITONAL DISCLOSURES FOR MEXICO

If you reside in Mexico, the following additional sections will apply, complement or prevail over any conflicting provisions in this Privacy Statement:

(1) This Privacy Statement is considered a Full Privacy Notice in terms of the data protection and privacy legal framework in Mexico.  

(2) Data Controller. The data controller of your personal data is [include the Mexican entity’s name and street address].

(3) Consent. Your express consent, provided at the time of registration, is the lawful basis for us processing your Data.

(4) Use of Information: Except for “Developing and sending you direct marketing…”, which is a secondary purpose, the rest of the processing purposes listed in Section 3 are considered primary purposes.

If you do not want to receive our marketing and advertising purposes, please opt-out from those communications in the Settings Section.

(5) Your Rights. You have the following rights regarding your personal data: i) access; ii) rectification; iii) objection; iv) cancellation; v) limit the use or disclosure of your personal data, and vi) revoke your consent.

If you want to exercise any of your rights previously mentioned please send us an email at privacy.contact@ea.epson.com. Your request must include: (i) full name; (ii) a copy of your official identification; (iii) a description of the personal data which is intended to be exercised; and (iv) any other element or document that facilitates the location of your personal data.

We will respond to any complete request within 20 business days. The response will indicate whether the request is admissible. If it is admissible, we will make the determination within 15 business days from the date you communicate the response. The deadlines may be extended in accordance with the applicable law. If you exercise your right of access, we will provide digital documents.

(6) Data Transfers. Your consent is required for the following transfer: “In connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of EPSON's assets, or transfer of all or a portion of EPSON's business to another company.” With your consent to this data privacy you agree with the mentioned data transfers.

Your consent is not required for the rest of the data transfers mentioned in Section 4.

18. ADDITONAL DISCLOSURES FOR PERU

If you reside in Peru, the following additional sections will apply, complement or prevail over any conflicting provisions in this Privacy Statement:

Data controller: [include the local entity’s name and street address].

Personal Information will be stored for as much time as required to comply with the purposes mentioned in section 3 “Use of the Information”, or until the data subject requests the cancellation of their account and the deletion of their personal data via email at  privacy.contact@ea.epson.com.