General Privacy Policy of Brother Industries, Ltd. (for CanvasWorkspace web service/application software/plug-in software)

Welcome to CanvasWorkspace. This service ("Service") is provided and licensed to you by Brother Industries, Ltd. ("Brother", "we" or "us). We are a company incorporated in Japan, whose registered office is at 15-1, Naeshiro-cho, Mizuho-ku, Nagoya 467-8561, Japan.

This privacy notice describes how we collect and process personal information about you, how we use and protect this information, and your rights in relation to this information.

This privacy notice applies to all personal information we collect or process about you in the Service. Personal information is information, or a combination of pieces of information that could reasonably allow you to be identified.

Please note that we operate globally either directly or through our subsidiaries ('Brother Group companies') . The Brother Group companies have their own privacy notice and where they collect and process your personal information, their own respective privacy notice will apply.

The Italian branch office of Brother International Europe, Ltd., a company incorporated and located in United Kingdom with its address at Brother House, 1 Tame Street, Audenshaw, Manchester M34 5JE, U.K. ('BIE'), is our representative in the European Union.

1. Personal Information We Use

We will collect personal information about you from a variety of sources, including information we collect from you directly (e.g. if you are a customer when you register your Brother products), and information we collect about you from other sources, including commercially available sources, such as public databases (where permitted by law).

We may be required by law to collect certain personal information about you or as a consequence of any contractual relationship we have with you. Failure to provide this information may prevent or delay the fulfilment of these obligations.

The categories of information that we may collect directly from you include the following:

• a. personal details (e.g. name, date of birth, job title);
• b. contact details (e.g. phone number, email address, postal address or mobile number);
• c. payment details and transactions;
• d. if you are a customer serial numbers of Brother products (these will identify you once you have registered your Brother product with us);
• e. IP addresses and MAC identifiers (while you access our websites and other online services.

Include generated information such as profiles, history of our relationship with you, etc.

2. How We Use Your Personal Information and the Basis on Which We Use It

We use your personal information to:

• a. ensure that our records are kept accurate and up to date;
• b. comply with legal obligations to which we are subject;
• c. check and maintain quality control;
• d. carry out analysis of our stock, ensure correct functioning of logistics and check stocks;
• e. provide you with customer service, after sale support and software updates;
• f. ship products to you;
• g. recall products;
• h. identify and administrate your log-in IDs;
• i. provide you with the Service; and
• j. provide you with other services as described when we collect your personal information.

[Applicable only for those who have registered as US users]
If you have chosen the United States of America (U.S.A.) for "Country of Residence" in the registration, we will send your e-mail address to our affiliate, Brother International Corporation ("BIC"), before being recorded in our server. This is to allow you to use the Service and Software and to provide you with important information about other Brother products and services. You will always have the opportunity to opt-out of receiving these messages. If you want to know more about your e-mail address controlled by BIC, please refer to the privacy policy of BIC. ( https://www.brother-usa.com/privacy-policy ) Please note that once you have chosen the U.S.A. for "Country of Residence" in the registration, you will be deemed that you are the citizen of U.S.A. residing within the territory thereof.

We must have a legal basis to process your personal information. In most cases the legal basis will be one of the following:

• a. to fulfil our contractual obligations to you. If you are a customer our contractual obligations to you include shipping products, providing customer service, after sale support, software updates, and recalling products when necessary.
• b. to comply with our legal obligations to you, for example health and safety obligations while you are on our premises, or to a third party (e.g. the taxation authorities); and
• c. to meet our legitimate interests for example, maintaining quality control and logistics, carrying out analysis for product development and market research, checking stocks and ensuring that our records are kept up to date and accurate.

3. Your Rights Over Your Personal Information

You have certain rights regarding your personal information, subject to local law. These include the following rights to:

• access your personal information;
• rectify the information we hold about you;
• erase your personal information;
• restrict our use of your personal information;
• object to our use of your personal information;
• receive your personal information in a usable electronic format and transmit it to a third party (right to data portability); and
• lodge a complaint with your local data protection authority.

We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate.

Please note that we will likely require additional information from you in order to honour your requests.

If you would like to discuss or exercise such rights, please contact us at the details below.

4. Information Sharing

We may share your personal information with third parties under the following circumstances:

• Cloud service providers. We partner with cloud service providers such as Microsoft and Amazon to store your personal information in the cloud.
• Business service providers. We engage business service providers to send newsletters and marketing emails, support email and messaging services, provide data analytics services and to process secure payments and fulfil orders.
• Brother Group companies. is owned by Brother Industries, Ltd, so we work closely with other businesses and companies that fall under the Brother Group family. We may share certain information about customers' using serial numbers, buying and browsing history, and customers’questions or concerns with Brother Industries, Ltd and other Brother Group companies for marketing purposes, internal reporting, and response to customers' questions or concerns.
• Law enforcement agencies, courts, regulators, government authorities. We may share your personal information with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
• Asset purchasers. We may share your personal information with any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this Privacy Note.

5. Information Security and Storage

We implement technical and organisational measures to ensure a level of security appropriate to the risk to the personal information we process. These measures are aimed at ensuring the on-going integrity and confidentiality of personal information. We evaluate these measures on a regular basis to ensure the security of the processing.

We will keep your personal information for as long as we have a relationship with you. When deciding how long to keep your personal information after our relationship with you has ended, we take into account our legal obligations and regulators' expectations. We may also retain records to investigate or defend potential legal claims.

We will retain your personal information in accordance with our data retention policy which sets out data retention periods required or permitted by applicable law.

6. International Data Transfers

Please note that Brother Industries Ltd. is located in Japan and thus your personal information will be submitted to, stored, and processed in Japan and which is currently regarded as ensuring an adequate level of protection for personal information under European Union data protection law. Furthermore, we may work with third party service provides while storing or processing your personal information, for example, your personal information may be stored in the cloud by our cloud service providers and they may keep your personal information in locations outside the European Economic Area, which do not provide an adequate level of protection.

We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details below.

7. Contact Us

Brother Industries, Ltd. is the controller responsible for the personal information we collect and process.

If you have any questions or concerns regarding the way in which your personal information has been used, please contact us at the email address provided below. Please note that, depending on the nature of your request or inquiry, we may need to confirm your identity before we process it.

data.protection@brother.co.jp

8. Changes to the Notice

You may request a digital copy of this privacy notice from us using the contact details set out above.

Amendments and modifications to this privacy notice may be made without your prior consent in the cases:

A) when the amendments or modifications are in your general interest, or

B) when the amendments or modification are rational and reasonable and do not conflict with the purpose of this privacy notice.

Notwithstanding the foregoing, in principle, the contents of the amendments or modifications shall be published on Brother's website or by any other appropriate methods and be notified before the effective date of the amendments or modifications, and enter into effect from the date that is separately specified in the notification.

Privacy Notice for California Residents

This Privacy Notice for California Residents supplements the information contained in Brother Industries, Ltd.’s Privacy Policy for CanvasWorkspace website/application. We adopt this notice to comply with the California Consumer Privacy Act (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

The CCPA provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as rights to access and control Personal Information. The CCPA defines “Personal Information” to mean “information that identifies, relates to, describes, is 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 because it is considered public information (i.e., it is made available by a government entity) or covered by a 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, that information, our practices, and your rights are described below.

Right to Information Regarding the Categories of Personal Information Collected, Sold, and Disclosed

Please see our Notice of California Consumer Data Collection and Sharing Practices below.

Right to Access Information

You have the right to request access to Personal Information collected about you 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. To protect our customers’ Personal Information, we are required to verify your identity before we can act on your request.

Right to Request Deletion of Information

You have the right to request in certain circumstances that we delete any Personal Information that we have collected directly from you. To protect our customers’ 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, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

Your California Privacy Rights

Residents of the State of California also have the right to request information regarding third parties to whom the company has disclosed certain categories of Personal Information during the preceding year for the third parties’ direct marketing purposes. To make a request, please send your request by mail to Brother Industries, Ltd. Attn: Data Protection Team, 15-1, Naeshiro-cho, Mizuho-ku, Nagoya, 467-8561, Japan or email to data.protection@brother.com.

How to Submit a Request

You may submit a request to exercise your rights through one of the following means:

By filling out a Consumer Data Request Form available here.
⇒Consumer Data Request Form

By calling 1-855-996-0289 Monday through Friday during the hours of 9:00 AM to 6:00 PM Eastern Time.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Notice of California Consumer Data Collection and Sharing Practices

The following is a description of our data collection practices for CanvasWorkspace, including the Personal Information we collect, the sources of that information, the purposes for which we collect information, and whether we disclose that information to external parties. The categories we use to describe the information are those enumerated in the CCPA.

• Personal Identifiers:
• We collect your name and e-mail address when you create an account for our services. If you choose to create an account, you will also be asked to create a login ID and password. We use this information to identify you, provide our services, respond to your requests and inquiries, and send information and advertisements to you.
• We collect a unique numerical identifier, assigned to you by a first-party cookie, automatically when you use our website in order to identify you, provide our services, keep you logged in to our website, prevent fraud, and provide you with targeted information and offers.
• We do not collect your financial information.
• We do not collect your driver’s license number or passport number.
• We do not collect your social security number.
• We do not collect your medical information or health information.
• We do not collect your insurance policy number.
• We collect your IP address when you use our website, products, software, and services. We may also be able to determine your general location and your company information based on your IP address. We use this information to gauge online activity on our website and software, measure the effectiveness of our website, online services, software, and tools, and serve targeted advertisements based on your online activities.
• We collect your product serial number and/or device ID when you use our products, software, and services. We use this information to monitor your use of our products and the effectiveness of our services, to identify you, and to provide you with targeted information and offers.
• Protected Classifications: We collect information related to your gender, if you choose to provide it, for the purpose of communicating with you. We collect information related to your date of birth when you create an account with us, and we may be able to determine your age. We use this information for the purpose of confirming your identity in case you forget your login ID or password. We do not collect your racial or ethnic origin, disability status, or sexual orientation.
• Commercial Information: When you access our website and software, we collect and analyze the information on the products or services you viewed or considered. We use this information to measure and improve the usability and effectiveness of our products and services, carry out internal research and marketing analysis, and provide you with targeted information, advertisements, and offers.
• Biometric Information: We do not collect information about your physiological, biological, or behavioral characteristics.
• Internet or Other Electronic Network Activity Information: We collect information about your browsing history, search history, and information regarding your interaction with websites, software, or advertisements automatically when you use our website, software, and services. We use this information to gauge online activity on our website and software, measure the usability and effectiveness of online services, software, and tools, personalize websites, and serve targeted advertisements based on your online activities.
• Geolocation Data: We collect your country or region of residence when you create an account with us for the purpose of communicating with you. We may also be able to determine your general location based on the IP address.
• Audio, electronic, visual, thermal, olfactory, or similar information: We do not collect your audio, electronic, visual, thermal, or olfactory information.
• Professional or employment-related information: We may be able to determine your company information based on your IP address. We use this information to carry out internal research and marketing analysis.
• Education information: We do not collect any information about the institutions you have attended or the level of education you have attained.
• Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics: We may adopt automated decision-making involving profiling based on your Personal Information in providing our service.

We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the Personal Information was collected.

We may share any of the above-listed information with service providers, which are external parties that we engage for business purposes and are restricted from using Personal Information for any purpose that is not related to our engagement. We may also disclose information to other external parties who are not listed here when required by law or to protect us or other persons. For details, please see our Privacy Policy for CanvasWorkspace website/application.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information described in the Privacy Notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by mail to Brother Industries, Ltd. Attn: Data Protection Team, 15-1, Naeshiro-cho, Mizuho-ku, Nagoya, 467-8561, Japan or email to data.protection@brother.com.