P. Your U.S. State Privacy Notice and Rights (Continuous)
e. Correct Your PI
Consumers may bring inaccuracies they find in their PI that we maintain to our attention, and we will act upon such a request as required by applicable law. You can also make changes to your online account in the account settings section of the account. That will not, however, change your information that exists in other places.
f. Automated Decision Making/Profiling and Limit Processing of Sensitive PI
We do not engage in Automated Decision Making or Profiling or Process Sensitive PI in a manner that is subject to a limitation request.
g. How to Exercise Your Consumer Privacy Rights
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.).
1. Your Request Must be a Verifiable Consumer Request
As permitted or required by applicable U.S. Privacy Laws, any request you submit to us must be a Verifiable Consumer Request, meaning when you make a request, we may ask you to provide verifying information, such as your name, e-mail address, phone number and/or account information. We will review the information provided and may request additional information (e.g., transaction history) via e-mail or other means to ensure we are interacting with the correct individual. We will not fulfill your Right to Know (Categories), Right to Know (Specific Pieces), Right to Delete, or Right to Correction request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI. We do not verify opt-outs of Sell/Share/Target requests unless we suspect fraud.
We verify each request as follows:
* Right to Know (Categories) (available for California residents only): If you do not have a password-protected account, we verify your Request to Know Categories of PI to a reasonable degree of certainty, which may include matching at least two data points provided by you with data points maintained by us, which we have determined to be reliable for the purpose of verifying you. If we cannot do so, we will refer you to this Notice for a general description of our data practices.
* Right to Know (Specific Pieces): If you do not have a password-protected account, we verify your Request to Know Specific Pieces of PI to a reasonably high degree of certainty, which may include matching at least three data points provided by you with data points maintained by us, which we have determined to be reliable for the purpose of verifying you. If you fail to provide requested information, we will be unable to verify you sufficiently to honor your request, but we will then treat it as a Right to Know Categories Request if you are a California resident.
* Do Not Sell/Share/Target: No specific verification required unless we suspect fraud.
* Right to Delete: If you do not have a password-protected account, we verify your Request to Delete to a reasonable degree of certainty, which may include matching at least two data points provided by you with data points maintained by us, or to a reasonably high degree of certainty, which may include matching at least three data points provided by you with data points maintained by us, depending on the sensitivity of the PI and the risk of harm to the Consumer posed by unauthorized deletion. If we cannot verify you sufficiently to honor a deletion request, you can still make a Do Not Sell/Share/Target request.
* Correction: If you do not have a password-protected account, we verify your Request to Correct PI to a reasonable degree of certainty, which may include matching at least two data points provided by you with data points maintained by us, or to a reasonably high degree of certainty, which may include matching at least three data points provided by you with data points maintained by us, depending on the sensitivity of the PI and the risk of harm to the Consumer posed by unauthorized correction.
To protect Consumers, if we are unable to verify you sufficiently, we will be unable to honor your request. We will use PI provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave it to us for another purpose.
2. Authorized Agent Requests
You may use an authorized agent to make a request for you, subject to our verification of the agent, the agent’s authority to submit requests on your behalf, and of your identity directly from you. You can learn how to do this by visiting the agent section of our Consumer Rights Request Portal. Once your agent’s authority is confirmed, they may exercise rights on your behalf subject to the agency requirements of applicable U.S. Privacy Laws. If we are unable to verify your identity, to help protect your privacy and maintain the security of your information, we will not be able to fulfill your request. If we deny your request, you may appeal the decision, in which case we will provide you with information about the appeals process.
3. Appeals
You may appeal Epson’s decision regarding a request to exercise your Consumer privacy rights by sending us an e-mail at epson.privacy@ea.epson.com and responding to any follow-up inquiries or requests we make.
h. Our Responses
Some PI that we maintain is insufficiently specific for us to be able to associate it with a Consumer (e.g., clickstream data tied only to a pseudonymous browser ID). We do not include that PI in response to Consumer requests. If we deny a request, in whole or in part, we will explain the reason in our response.
We will make commercially reasonable efforts to identify Consumer PI that we Process to respond to your Consumer request(s). In some cases, particularly with voluminous and/or typically irrelevant data, we may suggest you receive the most recent or a summary of your PI and give you the opportunity to elect whether you want the rest. We reserve the right to direct you to where you may access and copy responsive PI yourself. We will typically not charge a fee to fully respond to your requests; provided, however, that we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome. If we determine that the request warrants a fee, or that we may refuse it, we will give you notice explaining why we made that decision. You will be provided a cost estimate and the opportunity to accept such fees before we will charge you for responding to your request.
Consistent with applicable U.S. Privacy Laws and our interest in the security of your PI, we will not deliver to you your Social Security number, driver’s license number, or other government-issued ID number, financial account number, any health or medical identification number, an account password, security questions or answers, in response to a Consumer privacy rights request.
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3. Non-Discrimination/non-retaliation
We will not discriminate or retaliate against you in a manner prohibited by applicable U.S. Privacy Laws for your exercise of your Consumer privacy rights.
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4. Notice of Financial Incentive Programs
We may offer discounts or other rewards (“Incentives”) from time-to-time to Consumers that provide us with PI, such as name, phone number, e-mail address, IP address, or location. You may opt-in to Incentives by subscribing to the applicable program or other loyalty and Incentive programs we may offer from time-to-time (“Program(s)”). Each Program may have additional terms, available on the Program page or at Program sign-up. The Incentives will be described in the Program page, or at Program sign-up. If you subsequently wish to withdraw from the Programs, the method for doing so will be explained in the Program terms. We do not limit Program participation to consumers that do not exercise their CCPA rights. However, a deletion request will not delete Program PI because it is necessary to maintain your participation in the Program. If you desire to delete Program PI, terminate your participation in the Program before making a CCPA deletion request.
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5. Our Rights and the Rights of Others
Notwithstanding anything to the contrary, we may collect, use, and disclose your PI as required or permitted by applicable law and this may override your rights under U.S. Privacy Laws. In addition, we are not required to honor your requests to the extent that doing so would infringe upon our or another person’s or party’s rights or conflict with applicable law.
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6. Additional Notices for California Residents
In addition to the CCPA, certain Californians are entitled to certain other notices, as follows:
a. California Minors
Although our services are intended for an audience over the age of majority, any California residents under the age of eighteen (18) who have registered to use our services, and posted content on the service, can request removal by contacting us, emailing us at contentremoval@ea.epson.com with “California Under 18 Content Removal Request” in the subject line, and detailing where the content is posted and attesting you posted it. We will then make reasonable, good faith efforts to remove the post from prospective public view or anonymize it, so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines we do not control.
b. Shine the Light
We do not disclose “personal information,” as defined by California’s “Shine the Light” law, to third parties for such third parties own direct marketing purposes without consent. California residents may confirm this by contacting us at epson.privacy@ea.epson.com or Epson America, Inc., 3131 Katella Avenue, Los Alamitos, CA 90720 (Attn: Privacy Coordinator). You must put the statement “Shine the Light Request” in the body of your correspondence. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. This right is different than, and in addition to, CCPA rights, and must be requested separately.
See the Contacting Us section below for more information on how to reach Epson for privacy-related questions, comments, or concerns.
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Q. Contacting Us
If you have any questions about our Privacy Policy, our practices, or your dealings with the Service, wish to request access to or correction or update of your personal information, wish to withdraw your consent (subject to legal or contractual restrictions and reasonable notice), or you have reason to believe Epson may have failed to adhere to this Privacy Policy, you can contact us by email, via the electronic mail address indicated below, by calling us at 1-800-822-0313, or by writing to: Epson America, Inc., Attn: Privacy Coordinator, 3131 Katella Avenue, Los Alamitos, CA 90720 epson.privacy@ea.epson.com
Please do not include any sensitive information in your e-mail or written correspondence with us.
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