EPSON MOVERIO ASSIST PRIVACY POLICY

Effective Date: March 3, 2021.

1. INTRODUCTION AND OVERVIEW

This Privacy Policy describes how EPSON America, Inc. (“Epson,” “we,” “our,” or “us”) collects, uses, and shares information about you and applies to your use of the Epson Moverio smart glasses devices (“Moverio Devices”), the Epson Moverio Assist service, including all features and functionalities of the Moverio Assist service, the associated Epson website and applications, as well as all Epson and third-party content associated with this service (collectively, the “Service”). This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Service (unless otherwise stated below or at the time of collection).

By using our Service, you consent to our collection, use and disclosure practices, and other activities as described in this Privacy Policy and the Epson Moverio Assist Terms of Service (“Terms”) including applicable limitations of liability and dispute resolution provisions. If you do not agree and consent, discontinue use of the Service.

The Service is not intended for use by or in relation to customers or individuals outside of the United States or Canada. If you are a customer or an individual in the European Union, you should direct your inquiries to websites operated by other Epson entities in that jurisdiction. If Epson receives and/or becomes aware of any personal information of a customer or an individual in the European Union, such information will be forwarded to the appropriate Epson entity for processing in accordance with their privacy policy and the General Data Protection Regulation as applicable, and will not be retained by Epson America, Inc. or Epson Canada, Limited.

2. INFORMATION COLLECTION

A. Information You Provide To Us.

We collect the information you provide directly to us via the Service. For example, we collect information when you create an account, contact us about the Service, or use the Moverio Device to transmit video, photographs, images, files, data and other content. The information we collect may include Personal Information. “Personal Information” is information that can be used to identify you (whether alone or in combination), such as: your first and last name, e-mail address, zip code, physical address, phone number, and financial information.

Registration: when you register to use the Moverio Device and Service, we collect you company name, company postal address, company general email and billing email, and name of the Company contact (“Registration Information”).

Payment: we collect credit card and other payment information from our customers in order to process payments of our fees use of our Services. Such information may be shared with our payment processors that facilitate such payments.

User Content: when you use the Device, you can choose to send a variety of content, including video streams, photos, PDF and JPEG files, text messages and other contest (collectively, “User Content”). This User Content may contain Personal Information, such as a person’s image or name. You are solely responsible for the User Content that you provide and for ensuring that you have all rights, permissions and consents necessary to provide us any Personal Information contained in such User Content as necessary to provide you the Service and that all User Consent you collect complies with the Terms and all applicable laws.

You may choose to voluntarily submit certain other information to us through the Service, including Personal Information, but you are solely responsible for your own Personal Information in instances where we have not collected such information or requested that you submit such information to us.

Personal Information once “de-identified” will not be subject to this Privacy Policy and we and our Service Providers (defined below) may treat it as non-Personal Information and use it without obligation to you except as prohibited by applicable law.

B. Geolocation.

In order to use the Service, we may ask to collect location information from your Moverio Device. If you consent to the collection of such information, we may obtain your physical location information in terms of latitude and longitude from technologies like GPS, Wi-Fi, or cell tower proximity. You are able to withdraw your permission for us to acquire such physical location information from your Moverio Device through your device settings, although we do not control this process. If you have questions about how to disable your Moverio Device location services, please contact us as set forth in the Contact Us section below.

C. Information We Collect Automatically.

We and our Service Providers may automatically collect certain information about you when you access or use our Service or use the Moverio Device (“Usage Information”b>). Usage Information may include your IP address, Moverio Device UUID, browser type, operating system characteristics, data regarding network connected hardware (e.g., computer or mobile device), and information about your use of our Service, such as the time and duration of your visit and how you arrived at our Service. Except to the extent required by applicable law, EPSON does not consider Usage Information to be Personal Information. However, Usage Information may be combined with your Personal Information. To the extent that we combine Usage Information with your Personal Information, we will treat the combined information as Personal Information under this Privacy Policy.

The methods that we and our Service Providers may use to collect Usage Information include:

  • Log Information: We may collect information about your use of our Service, such as IP address, Moverio Device ID, browser type, Internet service provider, wireless carrier, referring/exit pages, operating system, date/time stamps, and related data, and store it in log files.
  • Information Collected by Cookies and Other Tracking Technologies: We may use cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, in-device tracking methods, and other tracking technologies now and hereafter developed (“Tracking Technologies”) to collect information about interactions with our Service, including information about your browsing, use of the Service and purchasing behavior.
    • Cookies
      A cookie is a small text file that is stored on a user’s device. We use both session ID cookies and tracking cookies. Session cookies make it easier for you to navigate our Service and expire when you close your browser. Tracking cookies help us understand how you use the Service, and enhance your user experience. Cookies remain on your hard drive for an extended period of time. If you use your browser’s method of blocking or removing cookies, some features and functionalities of our Service may not work.
    • Web Beacons (“Tracking Pixels”)
      Web beacons are small graphic images, also known as “Internet tags” or “clear gifs,” embedded in web pages and e-mail messages. Web beacons may be used to count the number of visitors to our Service, to monitor how users navigate the Service, and to count how many particular articles or links were actually viewed.
    • Embedded Scripts
      An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your computer from our web server or a third party with whom we work, is active only while you are connected to the Service, and deleted or deactivated thereafter.

For more information on your choices about such tracking technologies, please see Section 7.

D. Information From Other Sources.

We may also obtain information about you from other sources and combine that with information we collect about you. To the extent we combine such third party sourced information with Personal Information we collect directly from you on the Service, we will treat the combined information as Personal Information under this Privacy Policy. We are not responsible for the accuracy of the information provided by third parties or third party practices.

3. USE OF INFORMATION

We may use information about you for any purposes not inconsistent with our statements under this Privacy Policy or prohibited by applicable law, including to:

  • Provide you the Service;
  • Facilitate, manage, personalize, and improve your experience using the Service;
  • Transact with you, respond to your comments, questions and requests, provide customer service, send you informational notices, and contact you if we need to obtain or provide additional information;
  • Conduct research and analysis, including focus groups and surveys;
  • Prevent and address fraud, breach of policies or terms and threats or harm;
  • To enforce our Terms, protect our legal rights, and comply with applicable laws; and
  • Send you advertisements and communicate with you regarding our and third party products, services, offers, promotions, rewards and events we think you may be interested in (for information about how to manage these communications, see Section 7).

4. SHARING INFORMATION

We may share your information, including without limitation, your Personal Information, Registration Information, Usage Information, and User Contest with third parties as follows:

  • Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries solely for the purpose of providing Services to you; however, if we do so, their use and disclosure of your personally identifiable information will be maintained by such affiliates and subsidiaries in accordance with this Policy.
  • Service Providers. We may disclose the information we collect from you to third party agents, vendors, service providers, contractors or agents who perform functions on our behalf (“Service Providers”). These Service Providers are prohibited from using your Personal Information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes.
  • Business Transfers. In connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another company.
  • In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a subpoena.
  • To Protect Us and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which we are involved.
  • Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties and publicly for marketing, advertising, research or similar purposes.

5. THIRD PARTY SERVICES AND SOCIAL FEATURES

Our Service may include hyperlinks to websites, locations, platforms, or services operated by third parties, including social media features (“Third Party Service(s)”). These Third Party Services may use their own cookies, web beacons and other Tracking Technology to independently collect information about you and may solicit Personal Information from you.

The information collected and stored by third parties remains subject to their privacy practices, including whether they continue to share information with us, the types of information shared, and your choices on what is visible to others on Third Party Services. We are not responsible for and make no representations regarding the policies or business practices of any third parties or Third Party Services and encourage you to familiarize yourself with and consult their privacy policies and terms of use.

6. ANALYTICS SERVICES, ADVERTISING, AND ONLINE TRACKING

We may engage and work with third parties to serve advertisements on our behalf on the Service and/or on Third Party Services and to provide analytics services about the use of our Service and the performance of our ads and content on Third Party Services. In addition, we may participate in online advertising networks and exchanges that display relevant advertisements to our Service visitors, on our Service and on Third Party Services and off of our Service, based on their interests as reflected in their browsing of the Service and certain Third Party Services. These entities may use cookies and other Tracking Technologies to automatically collect information about you and your activities, such as registering a unique identifier for your device and tying that to your online activities on and off of our Service. We may use this information to analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on the Service and Third Party Services and better understand your online activity. Further, data collected from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such data was collected, or transferred to a non-affiliate for such purposes.

Some information about your use of the Service and certain Third Party Services may be collected across time and services and shared with third parties to deliver ads and/or other content to you on the Service and certain Third Party Services. We may receive information about Third Party Services that you have visited and use it for marketing purposes—a practice sometimes termed “(re)-targeting,” “interest-based advertising,” and “online behavioral advertising” (collectively, “Interest-based Ads”). We are not responsible for third parties or Third Party Services associated with advertising and analytics services, and related tracking activities, and encourage you to familiarize yourself with and consult their privacy policies and terms of use.

You may have certain choices regarding Tracking Technologies as explained in Section 7.

7. YOUR CHOICES

A. Tracking Technologies Generally.
Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Please be aware that if you disable or remove these technologies some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.

B. California Do Not Track Disclosure.
Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in the previous section (e.g., by disabling cookies), but such disabling may impair use of our website and Services.

C. Analytics Services and Interest-Based Ads.
EPSON may use Google Analytics or other Service Providers for analytics services. You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.

Certain companies may participate in the Digital Advertising Alliance (“DAA”) AdChoices Program and may display an Advertising Option Icon for Interest-based Ads that links to an opt-out tool which allows you to exercise certain choices regarding targeting. You can learn more about the DAA AdChoices Program at http://www.youradchoices.com/ and its opt-out program for mobile apps at http://www.aboutads.info/appchoices. In addition, certain advertising networks and exchanges may participate in the Network Advertising Initiative (“NAI”). NAI has developed a tool that allows consumers to opt out of certain Interest-based Ads delivered by NAI members’ ad networks. To learn more about opting out of such targeted advertising or to use the NAI tool, see http://www.networkadvertising.org/choices/. Please be aware that such opt-outs do not affect non-targeted ads. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. However, we support the ad industry’s 2009 Self-regulatory Principles for Online Behavioral Advertising available at http://www.iab.net/media/file/ven-principles-07-01-09.pdf and expect that ad networks EPSON directly engages to serve you Interest-based Ads will do so as well, though we cannot guaranty their compliance.

D. Communications.
You can opt out of receiving promotional e-mails from us at any time by following the instructions as provided in e-mails to click on the unsubscribe link or by changing your communication preferences by logging onto your account. Notwithstanding the forgoing, we reserve the right to send you emails relating to your account or use of our Service, such as administrative and service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving promotional e-mail. Please note that your opt-out is limited to the e-mail address used.

8. YOUR CALIFORNIA PRIVACY RIGHTS

We do not share Personal Information with third parties or affiliates for those third parties’ or affiliates’ own direct marketing purposes. Under California’s “Shine the Light Law”, if you are a California resident, you may request information about our compliance with this law by contacting us using the information provided in the Contact Us section below. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this e-mail address or mail address.

9. CHILDREN’S PRIVACY

Our Service is not intended for nor targeted toward children under the age of thirteen (13). We do not knowingly collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) from children under the age of thirteen (13), and if we learn that we have collected such information, we will delete the information in accordance with COPPA.

10. DATA SECURITY

We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the Internet or through wireless services is not completely secure and we cannot guarantee the security of your information collected through our Service.

11. INTERNATIONAL TRANSFER

We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored and used in the U.S. and that U.S. laws are different from and may offer less protection than the laws of your jurisdiction of residence. You are responsible for ensuring that any transfer of Personal Information to the U.S. complies with applicable data protection laws. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing and storage of your information, including Personal Information, in the U.S. as set forth in this Privacy Policy.

12. CHANGES TO THIS PRIVACY POLICY

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Subject to applicable law, your continued use of our Service indicates your consent to the privacy policy posted. If the changes are material, we may provide you additional notice to your e-mail address.

13. CONTACT US

For any requests relating to your Personal Information, or if you have any questions about this Privacy Policy, please contact us by using the Privacy Feedback Form, or you can write to:

Epson America, Inc.
Attn: Privacy Coordinator
3131 Katella Ave.
Los Alamitos, CA 90720