ScanSnap Privacy Policy Last updated on March 28, 2024 1. Applicable Scope This Privacy Policy applies to the personal information collected and processed by PFU America, Inc.（"PFU"）in the services and the ScanSnap Account (collectively, the "ScanSnap Services") provided in relation to scanner products of the ScanSnap series. PFU notifies you (hereinafter, "you" or "customer") of additional information for some of the ScanSnap Services in [Use of personal information in ScanSnap Improvement Program.] 2. Personal Information to be Collected and the Purposes of Use Thereof (1) Personal Information to be Collected When using the ScanSnap Services, you are required to install dedicated software. With your installation of the dedicated software, PFU collects information regarding the scanner and device you are using in accessing the ScanSnap Services. This information includes, for example, the IP-address, device category, and the version number of the app. In addition, if you so choose, you may register your ScanSnap Account and use the ScanSnap Cloud Services and ScanSnap Mail Services. When using these services, you are required to provide your personal information as set forth below: *The areas where you can use the ScanSnap Account and ScanSnap Cloud Services are shown here. • When using the ScanSnap Account: In registering your account, you are required to choose the country or region where you live, and register your e-mail address and password as your Account ID. PFU will collect information on your usage status of the ScanSnap Account. This information includes information on the number of devices available to you in the ScanSnap Account you are using, and the usage status of the ScanSnap Cloud Services, etc. • When using the ScanSnap Cloud Services: After completing your ScanSnap Account registration, you may take procedures for using the ScanSnap Cloud Services. When using the ScanSnap Cloud Services, PFU may collect information on the scanner usage data and reading settings for scanned documents uploaded onto the ScanSnap Cloud. Information to be collected includes your scanner usage data, status of the ScanSnap Cloud Services, document/reading settings on the scanned images you uploaded onto the ScanSnap Cloud, etc. For example, reading settings including image quality and color mode, types of read error, size and number of scanned image data are all included; provided, however, that PFU's collection and use of such scanner usage data and reading settings for scanned documents, and the transmitting of your scanned images’ contents are limited to provide you with the ScanSnap Services, and the cases where your consent has been obtained, such as "3. Personal information disclosure (3) In the case where there is any reasonable need for disclosure, including cases based on legal grounds" is applicable. • When using the ScanSnap Mail Services included in the ScanSnap Cloud Services You may use the ScanSnap Mail Services included in the ScanSnap Cloud Services. When using the ScanSnap Mail Services included in the ScanSnap Cloud Services, PFU collects your designated e-mail delivery address; provided, however, that PFU shall not use such e-mail address for any purpose other than sending e-mail designated by you. Among the personal information described above, you are required to enter information including your Account ID (e-mail address), password, and the country or region where you live, at the time of preparing the ScanSnap Account. You are not required to provide any personal information other than such personal information in accordance with laws and contracts; however, please be aware that if you do not provide the additional personal information, you may be unable to utilize some of the functionality of the ScanSnap Services. (2) Purposes of Use of Personal Information to be Collected PFU uses the information collected from the ScanSnap Services for the following purposes: (i) Provision of Services PFU uses your information to provide the ScanSnap Services. For example, PFU uses your information to certify that you are the (principal) person who can access scanner products and the ScanSnap Account, to automatically correct the position of image data you scanned, and to transmit the data to the services provided by other companies you choose to link to the ScanSnap Cloud Services. *Processing of personal data for this purpose is required in order for PFU to perform contracts with you regarding the ScanSnap Services or to take steps at your request before entering into such contracts. (ii) Maintaining and Improving Services PFU uses your information to operate the ScanSnap Services as intended. For example, PFU uses your information to track failure events or resolve problems reported by you. In addition, PFU uses your information to improve the services. For example, in the scan mode for photos, PFU detects faces contained in image data to help improve automatic position correction functions. For users that consent to participating under the ScanSnap Improvement Program, PFU may automatically collect certain diagnostic data automatically through use of the ScanSnap Services. For more information, see [Use of personal information in ScanSnap Improvement Program] below. *Processing of personal data for this purpose is required in order for PFU to pursue legitimate interests; namely, to perform normal business operations. (iii) Developing New Services PFU uses the information collected by existing ScanSnap Services to develop new services. In this case, PFU requires advance consent from the customer. *Processing of personal data for this purpose is performed in accordance with your consent. (iv) Communication with Customers PFU uses your e-mail address collected to directly inform you of information. For example, PFU informs you of maintenance regarding the system you are using, security and legal information. In addition, PFU may inform you of any scheduled changes of or improvements to PFU's services. *Processing of personal data for this purpose is required for PFU to perform contracts with you regarding the ScanSnap Services, or to take steps on your request before entering into such contracts, or to pursue legitimate interests; namely, to perform normal business operations. Furthermore, if your consent is obtained, PFU and its affiliates may use your e-mail address for e-mail delivery for marketing purposes. *Processing of personal data for this purpose is performed in accordance with your consent. On the other hand, if you contact PFU or PFU's affiliates, PFU records the contents of your inquiries in order to aid in resolving your problems. In such case, any personal information you provide will be processed by PFU in accordance with PFU's Personal Information Protection Policy. *Processing of personal data for this purpose is required in order for PFU to pursue legitimate interests; namely, to perform normal business operations. If PFU uses your information for any purposes not set forth in this Privacy Policy or PFU's Personal Information Protection Policy, PFU will request your consent in advance. 3. Personal Information Disclosure Except for the following cases, PFU shall not disclose your personal information with any third parties such as companies or organizations other than PFU. (1) In the case where your consent has been obtained: If PFU obtains your consent, PFU may disclose your personal information with any third parties other than PFU. (2) In the case of outsourcing: PFU provides its affiliates and other reliable companies with your personal information for the purpose of outsourcing all or part of the processing of personal information. PFU outsources all or part of the provision of support for the ScanSnap Services or customer support, and discussion/implementation of improving/enhancing the functionality/accuracy of the ScanSnap Services to PFU's affiliates, and outsources the provision of e-mail delivery and sending functions to outside e-mail delivery service operators. In addition, PFU constructs the environment for the ScanSnap Services on the cloud services provided by the cloud vendor. (3) In the case where there is any reasonable need for disclosure, including cases based on legal grounds If PFU faithfully determines that the disclosure of personal information is reasonably necessary based on any of the following grounds, PFU may disclose the information to any third parties: - To satisfy requests made under applicable laws, regulations, legal procedures, or by competent governmental agencies; - To prevent harm being caused to the rights, property or safety of the general public; - To conduct detection, prevention or other measures against improper acts, or security or technical problems. 4. Personal Information Retention Period PFU retains the information collected as follows: (1) Account information If you register your ScanSnap Account, PFU retains the data you registered as account information until you delete your own ScanSnap Account. You may modify or delete the data you registered with the ScanSnap Account at any time by yourself; provided, however, that there may be a time gap between the time when you delete your ScanSnap Account and the time when your ScanSnap Account is actually deleted from PFU's system. (2) Data to be deleted after elapse of certain period For some of the data, PFU retains such part of data only for a period designated in advance. For example, if you use the ScanSnap Cloud Services, the image data you transmit will be retained on a PFU server for two (2) weeks, and will then be automatically deleted. See the ScanSnap Cloud Terms of Service here. For data other than the foregoing (including logs, etc., to improve functionality), PFU retains such data for the period necessary for achieving the purpose of processing of such data or for a period designated by the laws or regulations. The determination of the personal data retention period will be based on the following: (i) Whether or not the relation with you, as a data subject, is continuing; (ii) Whether or not there are legal obligations that PFU must comply with; (iii) Whether or not it is necessary for PFU to perform a contract you, a data subject, are party to. 5. Securing the Safety of Personal Information PFU takes necessary and appropriate measures against risks including leakage, loss and damage of personal information, to ensure the safety management of personal information, and also conducts necessary and appropriate supervision over PFU employees. If PFU outsources all or part of the processing of personal information, PFU conducts necessary and appropriate supervision so that the safety management of personal information will be ensured at the outsourcee. For details of the system for obtaining personal information at PFU and contents of the measures taken by PFU, please contact us at the contact point stated in section "8. Contact Information." 6. Extraterritorial Transfer of Personal Information In order to achieve the purposes set forth above in section "2. Personal Information to be Collected and the Purpose of Use Thereof, (2) Purposes of Use of Personal Information to be Collected", PFU may process your information by transferring the same to any country other than the country where you live. In transferring the personal information of customers who live in EU countries or the UK, to a country other than the EU countries or the UK, PFU complies with specified legal frameworks regarding data transfer, including entering into standard contractual clauses in accordance with the GDPR with the company or organization to which data will be transferred. If you wish to obtain more detailed information, including obtaining a copy of the documents to be used for protection of data subjects' information, please contact us at the contact point stated in section "8. Contact Information." 7. Changes to this Policy This Privacy Policy will be changed from time to time. If there are any significant changes, PFU will notify you of such significant changes by way of publishing the same on the website of the ScanSnap Services in an easy to understand manner, or by sending you an e-mail. 8. Contact Information If you have any questions on PFU's services or this Privacy Policy, or wish to be notified of the purposes of use for your personal information, or receive the disclosure, correction or deletion etc. of your personal information, please contact us at the following: [Contact Point] PFU America, Inc. Legal, 3900 Freedom Circle, Suite 240, Santa Clara, CA 95054, USA E-mail: privacy@pfu-us.ricoh.com Phone: 1-833-975-1289 9． Customer's Rights If you wish to receive the disclosure, etc., of your personal information (meaning a request for notification of the purposes of use of your personal information, or a request for disclosure, correction, addition or deletion of your personal information, or a request for discontinuation of use or discontinuation of provision to any third party) or disclosure of records of provisions of your personal information, PFU confirms that the person applying is the customer him/herself, and takes appropriate measures within a reasonable period in accordance with the laws and regulations. If you wish to exercise such rights, please contact us at the contact point stated in section "8. Contact Information." PFU confirms that the person applying is the customer him/herself, and takes prompt measures. *For the rights of customers who live in California, USA, please refer to "10. Rights of Residents in California, USA" *For the rights of customers who live in the EEA or the UK, please refer to "11. Rights of Residents in the EEA or the UK" 10. Rights of Residents in California, USA This section applies only to customers who live in California, USA. Such customers are entitled to request PFU, up to a maximum of two times during a twelve (12) month-period, to disclose the following information regarding the collection and use of personal data by PFU during the past twelve (12) month-period: • Categories of your personal data collected by PFU; • Categories of sources from which the relevant personal data is obtained; • Business or commercial purposes based on which the relevant personal data is collected; • Retention period during which the relevant personal data is retained by PFU; • Categories of third parties with whom the relevant personal data is shared (as defined under the California Consumer Privacy Act, as amended); • Your specific personal data collected by PFU; • Categories of your personal data disclosed by PFU for business purposes; • Categories of third parties to whom each category of the relevant personal data is disclosed. In addition, customers are entitled to request PFU to modify or delete certain personal data collected by PFU from the customer. Customers are entitled not to be treated in a discriminatory manner based on the grounds of having exercised their rights in accordance with the California Consumer Privacy Act. Customers are entitled to object to PFU selling their personal data; PFU has never sold any customer's personal data in the past, nor will it sell any customer's personal data in the future without prior notice. In addition, if PFU obtains consent from the customer, PFU and its affiliates may use the information of the customer's e-mail address for e-mail delivery for marketing purposes; customers may withdraw their consent at any time and object to PFU using their e-mail delivery for marketing purposes. If you are a customer who lives in California, USA and you wish to exercise the foregoing rights, please contact us at the contact point stated in section "8. Contact Information." If you exercise your rights through your agent, you are required to submit your power of attorney to PFU directly or through your agent. 11. Rights of Residents in the EEA or the UK Customers who live within the EEA or the UK are entitled to request PFU to permit access to their personal data possessed by PFU, to copy, rectify or erase such personal data, and to restrict the processing of certain types of their personal data. Furthermore, customers may be entitled to receive their personal data from PFU in a structured and machine-readable format (data portability right). If data processing is conducted in accordance with the customer's consent, the customer is entitled to withdraw his/her consent at any time. This withdrawal will not affect the processing of personal data performed in the past to which the customer has already consented. In addition, in the case where data processing is conducted based on PFU's legitimate interests, or for direct marketing purposes, you are entitled to raise objections against the personal data processing. Other than the foregoing, if you consider that PFU has processed your personal data in breach of the applicable data protection law, you are entitled to lodge a complaint to the related data protection authority. If you are a resident of the EEA or the UK and wish to exercise the following rights, please contact us at the contact point stated in section "8. Contact Information." [Use of personal information in ScanSnap Improvement Program.] You may participate in the following ScanSnap Improvement Program: • "ScanSnap Improvement Program" : ScanSnap Home for Windows / Mac • "ScanSnap Improvement Program" : ScanSnap Home for iOS / Android • "ScanSnap Improvement Program" : ScanSnap Manager (V6) By participating in the ScanSnap Improvement Program, you can contribute to improving the functionality, reliability, and performance of the ScanSnap Services to enhance convenience and usability. Participation in the Program is optional. Information on the use of the ScanSnap Services is automatically collected from participants who consent to participate with this ScanSnap Improvement Program only. The collected information is encrypted and is periodically sent to PFU via the Internet. The information is collected anonymously and is used by PFU and the PFU group to improve their products and related services. For users that participate under the ScanSnap Improvement Program, the following information is automatically collected from a device on which the ScanSnap Services is being used: • "ScanSnap Improvement Program" : ScanSnap Home for Windows / Mac • Name of the ScanSnap model • ID for uniquely identifying the ScanSnap (this is created by irreversibly encrypting the serial number of the ScanSnap) • The number of devices on which the ScanSnap is being used, the version of the OS, and the language • ID for uniquely identifying the user account that is used on the device on which the ScanSnap is being used (this is irreversibly encrypted then collected) • The day and time on which the ScanSnap is used • Scan Settings such as the image quality and the color mode (this does not include the location for saving an image or a file name) • The size of the document scanned, the number of pages, and the application used with the ScanSnap (the content of the scanned document is not included) • The type of scanning errors such as a paper jam or a multifeed • Setting values of a profile such as the image rotation, scanning side, and title options • Account information such as the ScanSnap account (e-mail address) and ID for uniquely identifying the device on which the ScanSnap is being used (this is irreversibly encrypted then collected) • "ScanSnap Improvement Program" : ScanSnap Home for iOS / Android • Name of the ScanSnap model • ID for uniquely identifying the ScanSnap (this is created by irreversibly encrypting the serial number of the ScanSnap) • The name of devices on which the ScanSnap is being used, the number of devices, the version of the OS, and the language • ID for uniquely identifying the user account that is used on the device on which the ScanSnap is being used (this is irreversibly encrypted then collected) • The day and time on which the ScanSnap is used • Scan Settings such as the image quality and the color mode (this does not include the location for saving an image or a file name) • The size of the document scanned, the number of pages, and the application used with the ScanSnap (the content of the scanned document is not included) • The type of scanning errors such as a paper jam or a multifeed • Setting values of a profile such as the image rotation, scanning side, and title options • Account information such as the ScanSnap account (e-mail address) and ID for uniquely identifying the device on which the ScanSnap is being used (this is irreversibly encrypted then collected) • Historical Operations in ScanSnap Home. • "ScanSnap Improvement Program" : ScanSnap Manager (V6) • Please check "ScanSnap Improvement Program" : ScanSnap Manager (V6) End