Last Updated: January 1, 2022

1. General Privacy Policy

INTRODUCTION

Purpose:
The purpose of this Privacy Policy is to describe how Star Micronics Co., Ltd. ( “we”, “our” or “us”) collects, uses, processes and shares information about you and your company through our online interfaces (e.g., websites and mobile applications) owned and controlled by us, including www.starmicronicscloud.com (collectively referred to herein as the “Site”), in connection with the Star Micronics Cloud Services. If we collect your personal data through other methods or channels, we’ll give you timely and appropriate notice describing what personal data we’re collecting, how we’ll use it, and the types of third parties with whom we may share it. We will collect only as much personal data as we need for specific, identified purposes, and we won’t use it for other purposes without obtaining your consent. We will take appropriate steps to make sure the personal data in our records is accurate. Please read this notice carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to Contact Us or as described at the end of this Policy.

Our General Privacy Policy explains:

1-1. Information We Collect and Why We Collect It
1-2. How We Use and Share Your Information
1-3. Access to your Information and Choices
1-4. Security of Your Information
1-5. Your Rights
1-6. Consent to Data Processing in United States
1-7. Changes to Our Privacy Policy
1-8. Questions and How Contact Us
1-9. Our Company's Name, Address, and Representative's Name

Scope; Third Party Sites.
This Privacy Policy applies only to information we collect at and through the Site. Our Site also contains links to third party sites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our Site and to read the privacy statements of each and every website that collects personal data.

Terms of Use.
Please note that your use of our Site is also subject to our Terms and Conditions of Star Micronics Cloud Services.

1-1. INFORMATION WE COLLECT AND WHY WE COLLECT IT

Information About You
We collect and process information about you, including email address, telephone number, company name, country/Region, and optionally your name and address, as well as information about your activities (such as printer operating status and receipt data).
If you opt-in and provide your consent, we will share the information we have about you with certain third parties that can provide services to you, such as information on the usage status of the user's devices (printers and other equipment) registered with Star Micronics Cloud Service. We will only share your information with these third parties if you opt-in through online to participate in third party service providers.

Use Of your Information
We collect and processes personal data for the following purposes:

• Providing services to relevant clients and users;
• Managing customer relationships;
• Legitimate business interests, such as undertaking business research and analysis or managing the operation of the business
• Public relations, such as responding to inquiries
• Engaging in marketing and business development activities in relation to the services. This may include sending client newsletters, marketing communications and other information that may be of interest to them;
• Defense of certain rights or interests; and
• Compliance with legal and regulatory obligations that we have to discharge.

Information Collected Through Google Analytics
We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Site. Google Analytics uses “cookies”, which are text files placed on your computer, to help the Site analyze how users use the site. The information generated by the cookie about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for evaluating your use of the Site, compiling reports on Site activity for Site operators and providing other services relating to Site activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of the Site. By using the Site, you consent to the processing of data about you by Google in the manner and for the purposes set out above. For more information regarding Google Analytics please visit Google’s website, and pages that describe Google Analytics, such as https://marketingplatform.google.com/about/analytics/.

Information Collected Through Cookies and Similar Technologies
We and our service providers use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Site through your computer or mobile device. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the Site again, the cookie allows that site to recognize your browser. Cookies may store unique identifiers, user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some Site features or services may not function properly without cookies.

No Information from Children Under Age 13
If you are under the age of 13, please do not attempt to register with us at the Site or provide any personal data about yourself to us. If we learn that we have collected personal data from a child under the age of 13, we will promptly delete that information. If you believe we have collected personal data from a child under the age of 13, please Contact us or call us at +81 54-263-7114

1-2. HOW WE USE AND SHARE YOUR INFORMATION

To Provide Products, Services, and Information
As described above, we collect and process your information from you so that we can provide the services available at our Site. We may also send you information about our products and services, and new offerings. We may provide information to third party service providers that help us provide the Site and our services to you.
We use third party service providers (including subsidiaries of Star Micronics Co., Ltd.) to provide our products and services, including to provide technical support, host our Site, send out email updates about the Site, provide marketing and advertising services for us, remove repetitive information from our user lists, and process payments. When we use service providers, they may have access to your information in order to provide these services, but when this occurs, we implement reasonable contractual and technical protections to limit their use of that information to helping us provide the service.

Your Consent
In addition to the sharing described elsewhere in this policy, we will share information with companies, organizations or individuals outside of us when we have your consent to do so.

Legal Proceedings
We will share your information with third party companies, organizations or individuals outside of Star Micronics if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

• Meet any applicable law, regulation, subpoena, legal process or enforceable governmental request.
• Enforce applicable Terms of Use, including investigation of potential violations.
• Detect, prevent, or otherwise address fraud, security or technical issues.
• Protect against harm to the rights, property or safety of us, our users, customers or the public as required or permitted by law.

Transfer in the Event of Sale or Change of Control
If the ownership of all or substantially all of our business changes or we otherwise transfer assets relating to our business or the Site to a third party, such as by merger, acquisition, bankruptcy proceeding or otherwise, we may transfer or sell your information to the new owner. In such a case, unless permitted otherwise by applicable law, your information would remain subject to the promises made in the applicable privacy policy unless you agree differently.

1-3. ACCESS TO YOUR INFORMATION AND CHOICES
If you have any questions about what information we collect and how we use it, please Contact Us or call us at +81 54-263-7111. Where applicable or legally required, we will give you choices about the ways we use and share your personal data, and we’ll respect the choices you make.

1-4. SECURITY OF YOUR INFORMATION
In order to control of your information including preventing the leakage, loss or damage, we have established this Privacy Policy and have taken necessary and appropriate security measures, including "compliance with related laws, regulations, and guidelines" and "contact points for questions and complaints". We will also supervise employees and contractors (including subcontractors, etc.) who handle personal data in a necessary and appropriate manner. Please refer to the following "Information Security Statement" for the specific details of security measures.
Microsoft Word - 2.1_InformationSecurityStatement.doc (star-m.jp)
However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that e-mails and other communications you send to us through our Site are not encrypted, and we strongly advise you not to communicate any confidential information through these means. We will keep your personal data only as long as we need it for the purposes for which we collected it, or as permitted by law.

1-5. Your Rights
Data subjects have the right to access, request correction of, request deletion of, request the limitation of processing of, object to the processing of, and request the data portability of their personal data retained by us. When we receive a request based on the right specified above, we shall conduct any necessary investigation without delay and provide data subjects or nominated third parties with personal data or respond to such rights without delay.

1-6. CONSENT TO DATA PROCESSING IN UNITED STATES
In order to provide our products and services to you, we may be transferred and stored your personal data (also commonly referred to as personal data) to the United States. Accordingly, your personal data may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your personal data. We are also committed to protecting the privacy and confidentiality of personal data when it is transferred. By using and accessing our Site, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal data on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.

1-7. CHANGES TO OUR PRIVACY POLICY
Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your consent in accordance with applicable law. We will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes).

1-8. QUESTIONS AND HOW CONTACT US
If you have any questions, concerns, complaints or suggestions regarding our General Privacy Policy or otherwise need to contact us, please Contact Us, email us at info@starcloudservices.com, call us at +81 54-263-7111, or contact us by postal mail at the following address:
Star Micronics Co., Ltd.
20-10 Nakayoshida, Suruga-ku,
Shizuoka, Japan 422-8654

1-9. Our Company's Name, Address, and Representative's Name
Star Micronics Co., Ltd.
20-10 Nakayoshida, Suruga-ku,
Shizuoka, Japan 422-8654
Representative Director, President and CEO Mamoru Sato

2. GDPR Privacy Policy

INTRODUCTION

Purpose:
In accordance with this Section 2 in addition to Section 1 (General Privacy Policy), Star Micronics Co., Ltd. (“we”, “our” or “us”) may have occasion to collect and process personal data (as defined below). This Section 2 applies to the processing of personal data concerning data subjects in the European Economic Area (“EEA”) in accordance with the General Data Protection Regulation (the “GDPR”).

This Privacy Policy (“GDPR Privacy Policy”) explains:

2-1. Personal data
2-2. Use of Personal data
2-3. Disclosure to Third Parties
2-4. Cross-Border Transfer
2-5. Retention of Personal data
2-6. Rights of Data Subjects
2-7. Right to Lodge Complaint with Data Protection Authority
2-8. Questions and How Contact Us

2-1. PERSONAL DATA
In this GDPR Privacy Policy, Personal data means any data relating to an identified or identifiable natural person (“Personal data”). We may collect and process personal data, including name, address, telephone number, email address and website/social networking service address of a natural person in the EEA.

2-2. USE OF PERSONAL DATA
We collect and processes personal data for the following purposes:

• Providing services to relevant clients and users;
• Managing customer relationships;
• Legitimate business interests, such as undertaking business research and analysis or managing the operation of the business
• Public relations, such as responding to inquiries
• Engaging in marketing and business development activities in relation to the services. This may include sending client newsletters, marketing communications and other information that may be of interest to them;
• Defense of certain rights or interests; and
• Compliance with legal and regulatory obligations that we have to discharge.

We rely on the following legal grounds to process personal data:

• The data subject’s consent expressly given to process his/her personal data in such manner. The data subject may withdraw his/her consent to this processing at any time; however, this will not affect the lawfulness of any processing carried out before withdrawal of the consent;
• Entering into a contract with a data subject or performing obligations under a contract with a data subject;
• Legitimate interests, some examples of which are given above; and
• Compliance with applicable laws or regulations

2-3. DISCLOSURE TO THIRD PARTIES
We may supply or disclose personal data, without the data subjects’ prior consent, to our service assignees. We may also supply or disclose personal data to third party service providers (including subsidiaries of Star Micronics Co., Ltd.) when it is necessary for some other justifiable reason permitted by the laws and regulations.

2-4. CLOSS-BORDER TRANSFER
Personal data may be transferred to entities in countries or jurisdictions outside the EEA, such as United State and Japan, if required for the purposes as described above. Please note that such countries or jurisdictions may not have the same data protection laws as the EEA and will not afford many of the rights conferred upon data subjects in the EEA. Star Micronics will ensure that any such international transfers are made subject to appropriate and suitable safeguards as required by the GDPR or other relevant laws. When doing so, we will comply with applicable data protection requirements and take appropriate safeguards to ensure the security and integrity of personal data.

2-5. RETENTION OF PERSONAL DATA
We will retain personal data for the period necessary to fulfill the purposes outlined in this GDPR Privacy Policy, unless a longer retention period is required or permitted by law.

2-6. RIGHTS OF DATA SUBJECTS
Data subjects have the right to access, request correction of, request deletion of, request the limitation of processing of, object to the processing of, and request the data portability of their personal data retained by us. When we receive a request based on the right specified above, we shall conduct any necessary investigation without delay and provide data subjects or nominated third parties with personal data or respond to such rights without delay.

While there will not generally be any detrimental effects for the data subjects if they fail to provide their personal data, we may need to collect personal data to process data subjects’ instructions or perform contracts with them. In such case, we may have to cancel the engagement or contract such data subjects have with us, and will notify them thereof at that time.

2-7. RIGHT TO LODGE COMPLAINT WITH DATA PROTECTION AUTHORITY
Data subjects have the right to lodge a complaint with the local data protection authority if they have a complaint with regard to our processing of their personal data.

2-8. QUESTIONS AND HOW CONTACT US
If you have any questions, concerns, complaints or suggestions regarding our GDPR Privacy Policy, our privacy practices, your rights described in “Section 2-6. Rights of Data Subjects”, please Contact Us, email us at info@starcloudservices.com, call us at +81 54-263-7111, or contact us by postal mail at the following address:
Star Micronics Co., Ltd.
20-10 Nakayoshida, Suruga-ku,
Shizuoka, Japan 422-8654

3. PRIVACY POLICY FOR CALIFORNIA RESIDENTS

INTRODUCTION

Purpose:
In accordance with this Section 3 in addition to Section 1 (General Privacy Policy), Star Micronics Co., Ltd. (“we”, “our” or “us”) may have occasion to collect and process personal data (as defined below). This Privacy Policy for California Residents applies to the processing of personal data of who are residents of California (“consumers” or “you”) in accordance with the California Consumer Privacy Act (the “CCPA”),

Our Privacy Policy for California Residents (“CCPA Privacy Policy”) explains:

3-1. INFORMATION WE COLLECT
3-2. USE OF PERSONAL DATA
3-3. SHARING OR DISCLOSURE OF PERSONAL DATA
3-4. SALES OF PERSONAL DATA
3-5. YOUR RIGHTS AND CHOICES UNDER THE CCPA
3-6. RIGHTS OF CHILDREN
3-7. QUESTIONS AND HOW CONTACT US

3-1. INFORMATION WE COLLECT
In this CCPA Privacy Policy, Personal data means any data that directly or indirectly identifies, relates, describes, references or can reasonably be linked to a particular consumer or device (“personal data”).

We have collected the following categories of personal data within the last twelve (12) months.

Category	Examples
A. Identifiers	Real name, address, e-mail address
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Name, address, and telephone number

We obtain the categories of personal data listed above from only directly from you.

3-2. USE OF PERSONAL DATA
We collect and processes personal data for the following purposes:

• Providing services to relevant clients and users;
• Managing customer relationships;
• Legitimate business interests, such as undertaking business research and analysis or managing the operation of the business
• Public relations, such as responding to inquiries
• Engaging in marketing and business development activities in relation to the services. This may include sending client newsletters, marketing communications and other information that may be of interest to them;
• Defense of certain rights or interests; and
• Compliance with legal and regulatory obligations that we have to discharge.

3-3. SHARING OR DISCLOSURE OF PERSONAL DATA
We may share or disclose your personal data to a third party for business purposes. When we disclose personal data to third party service providers for business purposes, we enter a contract that describes such purposes and requires third party service providers to both keep that personal data confidential and not use it for any purpose except for performing the contract.

In the preceding twelve (12) months, we have shared or disclosed the following categories of personal data from the above list to the following categories of third parties for business purposes:

Our third party service providers (including subsidiaries of Star Micronics Co., Ltd.): Categories A and B

3-4. SALES OF PERSONAL DATA
We have not sold any personal data to a third party in the preceding twelve (12) months.

3-5. YOUR RIGHTS AND CHOICES UNDER THE CCPA
The CCPA provides consumers (California residents) with specific rights regarding personal data. This Section 3-5 describes your CCPA rights and explains how to exercise those rights.

Right to request disclosure
You have the right to request that we disclose following information to you about our collection, sharing, disclosure or use of your personal data over the past twelve (12) months from the time of your request. However, we will only respond to your disclosure request only if we can verify your identity.

• The categories of personal data we collected about you;
• The categories of sources for the personal data;
• Our business or commercial purpose for collecting or selling that personal data;
• The categories of third parties with whom we share that personal data;
• The categories of personal data that the business sold about the consumer and the categories of third parties to whom the personal data was sold, by category or categories of data for each third party to whom the personal data was sold.
• The categories of personal data disclosed for business purposes or commercial;
• The specific pieces of personal data we collected about you.

Please note that we have not sold any personal data to third party in the preceding twelve (12) months.

Deletion Request Rights
You have the right to request that we delete any of your personal data that we have collected from you. However, we will only respond to your deletion request only if we can verify your identity.

Notwithstanding the foregoing, we may not be able to respond to your request for deletion primarily in the following cases:

• To complete the transaction between you and us, to provide our products and service requested by you, or to perform a contract with you;
• To detect security incidents, to protect against illegal or inappropriate activity, or to prosecute those responsible for such activity;
• To debug to identify and repair errors that impair intended functionality;
• To exercise free speech, to ensure the right of another consumer to exercise his or her right of free speech, or to exercise another right provided for by law;
• For internal use, when reasonably meeting with your expectations or in appropriate manner consistent with the purpose for which you provided the information.
• To comply with legal obligations.

Opt-Out Rights
We do not sell any personal data to third party.

Non-Discrimination
We do not discriminate against you due to the exercise of any of your rights under the laws and regulations, including, but not limited to, by:

• Denying you goods or services;
• Charging you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties;
• Providing you a different level or quality of goods or services; or
• Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Access and Deletion Rights
To exercise the rights described above, please submit a verifiable consumer request to us by contacting us in the manner set forth in Section 3-7.(QUESTIONS AND HOW CONTACT US).

The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative (e.g. a copy of your passport, residence certificate, etc.)

3-6. RIGHTS OF CHILDREN
We do not sell personal data collected from users to third parties, and therefore we do not sell personal data of users under the age of 16. Further, if you are under the age of 13, please do not attempt to register with us at the Site or provide any personal data about yourself to us. If we learn that we have collected personal data from a child under the age of 13, we will promptly delete that information. If you believe we have collected personal data from a child under the age of 13, please Contact us.

3-7. QUESTIONS AND HOW CONTACT US
If you have any questions, concerns, complaints or suggestions regarding our CCPA Privacy Policy or your rights described in Section 3-5., Please email us at info@starcloudservices.com, call us at +1 (800) 782-7636, or contact us by postal mail at the following address:
Star Micronics Co., Ltd.
20-10 Nakayoshida, Suruga-ku,
Shizuoka, Japan 422-8654