P. Your U.S. State Privacy Notice and Rights (Continuous)
b. PI Use and Disclosure – By Processing Purpose
We use and disclose PI for the processing purposes described below:
Processing Purpose(s) Examples(s) of Processing Purpose
1. Performing Services Provide our services/communicate about our services: to provide you with information or services, to send you electronic newsletters and push notifications (if you have elected to receive such), to communicate with you about your use of the services, to provide you with special offers or promotions.
Enable additional features of our Service: to enable you to participate in a variety of our Service’s features, including customizing your experience and account preferences.
Process orders: to process or fulfill an order or transaction.
Contact You: to contact you about your use of our services and, in our discretion, changes to our services or our service’s policies.
Account management: to process your registration with our services, verify your info is active and valid, manage your account, and to administer our customer loyalty program.
Customer Service: to respond to any questions, comments, or requests you have for us or for other customer service purposes.
Payment and other purchase-related purposes: to facilitate a purchase made using our services, including payment.
2. Managing Interactions and Transactions Auditing: related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with user interaction or transaction specifications and standards (e.g., ecommerce activities).
3. Security Security/fraud prevention: to protect the security of Epson, our services, or its users and to prevent and address fraud.
4. Debugging Repairs: identify and repair errors that impair existing intended functionality of our services.
5. Advertising & Marketing (excluding Cross-Context Behavioral Advertising and Targeted Advertising) Content and offers customization: to customize your experience on our Service, or to serve you specific content and offers that are relevant to/customized for you (e.g., pricing and discounts based on your profile, location, or shopping history).
Advertising, marketing, and promotions: to assist us in determining relevant advertising and the success of our advertising campaigns; to help us determine where to place our ads, including on other websites; for promotional activities such as running sweepstakes, contests, and other promotions.
6. Quality Assurance Quality and Safety of Service: undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.
7. Processing Interactions and Transactions Short-term, transient use: including, but not limited to, non-personalized advertising shown as part of a Consumer’s current interaction with Epson and use of our services’ features and functionality (e.g., e-commerce transactions).
8. Research and Development Research and analytics: to better understand how users access and use our services, both on an aggregated and individualized basis, to improve our services and respond to user preferences, and for other research and analytical purposes.
Market research and customer satisfaction surveys: to administer surveys and questionnaires, such as for market research or customer satisfaction purposes.
9. Additional Business Purposes Compliance with legal obligations: to comply with legal obligations, as part of our general business operations, and for other business administration purposes and in response to legal obligations or process.
Prevention of illegal activities, fraud, injury to others, or violation of our terms and policies: to investigate, prevent or take action if someone may be engaged in illegal activities, fraud, or in ways that may threaten someone’s safety or violate of our terms or this Notice.
Purposes disclosed at PI collection: We may provide additional disclosures at the time of PI collection, such as on a checkout page.
Related or compatible purposes: for purposes that are related to and/or compatible with any of the foregoing purposes.
10. Commercial Purposes Cross-context Behavioral Advertising.
Targeted Advertising.
Strategic partnerships.
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2. Your Consumer Rights and How to Exercise Them
As described more below, subject to meeting the requirements for a Verifiable Consumer Request (defined below), Epson provides Consumers the privacy rights described in this section. For residents of states without Consumer privacy rights, we will consider requests but will apply our discretion with respect to how we process such requests. We will also consider applying state law rights prior to the effective date of such laws but will do so in our discretion.
To submit a request to exercise your Consumer privacy rights, or to submit a request as an authorized agent, use our Consumer Rights Request Portal, or call us at 1-800-822-0313, and respond to any follow-up inquiries we make. Please be aware that we do not accept or process requests through other means (e.g., via fax, chats, social media etc.). More details on the request and verification process is in Section g below. The Consumer rights we accommodate, subject to your state law, are as follows:
a. Right to Limit Sensitive PI Processing
With regard to PI that qualifies as Sensitive PI under U.S. Privacy Laws, as of January 1, 2023, if you elect to provide us with that Sensitive PI you will have consented to such Processing. However, California Personnel can limit certain Sensitive PI Processing and if you choose to do so we will explain in a response what Processing purposes U.S. Privacy Laws do not allow you to limit.
b. Right to Know/Access
Residents of California, Virginia, and Colorado are entitled to access their PI up to twice in a 12-month period. Residents of Connecticut and Utah are entitled once every 12-month period to access their PI maintained by Epson, with subsequent requests subject to a service fee. To the extent we permit consumers to exercise rights where their states of residence do not include such rights under applicable state law, we apply the same limitation on number of Verifiable Consumer Requests in Connecticut and Utah to all states other than California, Virginia, and Colorado.
1. Categories (available for California Residents Only)
California residents have a right to submit a request for any of the following for the period that is 12-months prior to the request date:
* The categories of PI we have Collected about you.
* The categories of sources from which we Collected your PI.
* The Business Purposes or Commercial Purposes for our Collecting, Selling, or Sharing your PI.
* The categories of Third Parties to whom we have disclosed your PI.
* A list of the categories of PI disclosed for a Business Purpose and, for each, the categories of recipients, or that no disclosure occurred.
* A list of the categories of PI Sold or Share about you and, for each, the categories of recipients, or that no Sale or Share occurred.
2. Specific Pieces
You may request to confirm if we are Processing your PI and, if we are, to obtain a transportable copy, subject to applicable request limits, of your PI that we have collected and are maintaining. For your specific pieces of PI, as required by applicable U.S. Privacy Laws, we will apply the heightened verification standards as described below. We have no obligation to re-identify information or to keep PI longer than we need it or are required to by applicable law to comply with access requests.
c. Do Not Sell / Share / Target
Under the various U.S. Privacy Laws there are broad and differing concepts of “Selling” PI for which an opt-out is required. California also has an opt-out from “Sharing” for Cross-Context Behavioral Advertising (use of PI from different businesses or services to target advertisements). Other states have an opt-out of “Targeted Advertising” (defined differently but also addressing tracking, profiling, and targeting of advertisements). We may Sell or Share your PI and/or use your PI for Targeted Advertising, as these terms apply under U.S. Privacy Laws. However, we provide U.S. Consumers, and in some cases their authorized agents, an opt out of Sale/Sharing/Targeting that is intended to combine all of these state opt-outs into a single opt-out available regardless of state of residency. You can opt-out by clicking the “Your Privacy Choices” link in our Site footer or by going here.
Third-Party digital businesses (“Third-Party Digital Businesses”) may associate cookies and other tracking technologies that Collect PI about you on our services, or otherwise Collect and Process PI that we make available about you, including digital activity information. We understand that giving access to PI on our Services, or otherwise, to Third-Party Digital Businesses could be deemed a Sale and/or Share under some state laws and thus we will treat such PI (e.g., cookie ID, IP address, and other online identifiers, and internet or other electronic activity information) collected by Third-Party Digital Businesses, where not limited to acting as our Service Provider (or Contractor or Processor), as a Sale and/or Share and subject to a Do Not Sell/Share/Target opt-out request. We will not Sell your PI, Share your PI for Cross-Context Behavioral Advertising, or Process your PI for Targeted Advertising if you make a Do Not Sell/Share/Target opt-out request.
Opt-out for non-cookie PI: If you want to limit our Processing of your non-cookie PI (e.g., your email address) for Targeted Advertising, or opt-out of the Sale/Sharing of such data, make an opt-out request here.
Opt-out for cookie PI: If you want to limit our Processing of your cookie-related PI for Targeted Advertising, or opt-out of the Sale/Sharing of such PI, you need to exercise a separate opt-out request on our cookie “consent manager” tool here. This is because we have to use different technologies to apply your opt-out of cookie PI and to non-cookie PI. Our consent manager enables you to exercise such an opt-out request and enable certain cookie preferences on your device. You must exercise your preferences on each of our websites you visit, from each browser you use, and on each device that you use. Since your browser opt-out is designated by a cookie, if you clear or block cookies, your preferences will no longer be effective and you will need to enable them again via our consent manager. Note that if you use ad blocking software, our consent manager may not appear when you visit our Services and you may have to use the link above to access the tool.
Opt-out preference signals (also known as global privacy control or “GPC”): Some of the U.S. Privacy Laws require businesses to process GPC signals, which is referred to in California as opt-out preference signals (“OOPS”), which are signals sent by a platform, technology, or mechanism, enabled by individuals on their devices or browsers, that communicate the individual’s choice to opt-out of the Sale and Sharing of personal information. To use an OOPS/GPC, you can download an internet browser or a plugin to use on your current internet browser and follow the settings to enable the OOPS/GPC. We have configured the settings of our consent manager to receive and process GPC signals on our Sites for visitors with IP Address indicating they are from a state where this is required. We process OOPS/GPC with respect to Sales and Sharing that may occur in the context of Collection of cookie PI by tracking technologies online by Third-Party Digital Businesses, discussed above, and apply it to the specific browser on which you enable OOPS/GPC. We currently do not, due to technical limitations, process OOPS/GPC for opt-outs of Sales and Sharing in other contexts (e.g., non-cookie PI). We do not: (1) charge a fee for use of our Service if you have enabled OOPS/GPC; (2) change your experience with any product or service if you use OOPS/GPC; or (3) display a notification, pop-up, text, graphic, animation, sound, video, or any interstitial in response to the OOPS/GPC.
We do not knowingly Sell or Share the PI of Consumers under 16, unless we receive affirmative authorization (“opt-in”) from either the Consumer who is between 13 and 16 years old, or the parent or guardian of a Consumer who is less than 13 years old. If you think we may have unknowingly collected PI of a Consumer under 16 years old, please Contact Us.
We may disclose your PI for the following purposes, which are not a Sale or Share: (i) if you direct us to disclose PI; (ii) to comply with a Consumer rights request you submit to us; (iii) disclosures amongst the entities that constitute Epson as defined above, or as part of a Corporate Transaction; and (iv) as otherwise required or permitted by applicable law.
d. Right to Delete
Except to the extent we have a basis for retention under applicable law, you may request that we delete your PI. Our retention rights include, without limitation:
* to complete transactions and services you have requested;
* for security purposes;
* for legitimate internal Business Purposes (e.g., maintaining business records);
* to comply with law and to cooperate with law enforcement; and
* to exercise or defend legal claims.
Please also be aware that making a deletion request does not ensure complete or comprehensive removal or deletion of PI or content you may have posted.
Note also that, depending on where you reside (e.g., California and Utah), we may not be required to delete your PI that we did not Collect directly from you.
(To be continued)
