Fujitsu and data privacy

Fujitsu Limited and its subsidiaries (“Fujitsu”) are committed to protecting and respecting your privacy.

This privacy policy sets out the basis on which we will process any personal information that we may collect about you as a visitor to our website or premises or a contact at one of our customers or potential customers, suppliers or potential suppliers or other business partners or in any other cases where we specifically state that this policy will apply.

This privacy policy also sets out how we protect your privacy and your rights in respect of our use of your personal information.

Fujitsu may have a privacy policy or statement specific to particular local laws, products or services in which case such policy or statement shall supersede or supplement this privacy policy.

What personal information do we collect from you?

We may collect and process the following personal information about you:

Personal information that you give us: This is information about you that you give to us by filling in forms on our website (or other forms that we ask you to complete), giving us a business card (or similar) or corresponding with us by telephone, post, email or otherwise. It may include, for example, your name, address, email address and telephone number; information about your business relationship with Fujitsu; and information about your professional role, background and interests.

Personal information that our website and other systems collect about you:

Other information: We may also collect some information from other sources. For example:

How will we use your personal information?

We may collect, store and use your personal information for the following purposes:

to operate, manage, develop and promote our business (including our products and services) and, in particular, our relationship with the organisation you represent (if any) and related transactions including, for example:

to protect our business from fraud, money-laundering, breach of confidence, theft of proprietary materials and other financial or business crimes;

to comply with our legal and regulatory obligations and bring and defend legal claims and assert legal rights; and if the purpose is directly connected with an assigned purpose previously made known to you.

We may from time to time review your information held in our systems – including the contents of and other information related to your email and other communications with us – for compliance and business-protection purposes as described above. This may include reviews for the purposes of disclosure of information relevant to litigation and/or reviews of records relevant to internal or external regulatory or criminal investigations. To the extent permitted by applicable law, these reviews will be conducted in a reasonable and proportionate way and approved at an appropriate level of management. They may ultimately involve disclosure of your information to governmental agencies and litigation counterparties as described below. Your emails and other communications may also occasionally be accessed by persons other than the member of staff with whom they are exchanged for ordinary business management purposes (for example, where necessary when a staff member is out of the office or has left Fujitsu).

We will only process your personal information as necessary so that we can pursue the purposes described above and where we have a legal basis for such processing. Where our lawful basis for processing is that such processing is necessary to pursue our legitimate interests, we will only process your personal information where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest. In exceptional circumstances we may also be required by law to disclose or otherwise process your personal information.

Disclosure and international transfer of your personal information

We may disclose your personal information, where reasonably necessary for the various purposes set out above:

to the other members of the Fujitsu group of companies;

to your colleagues within the organisation that you represent;

to service providers who host our web services or other information technology systems or otherwise hold or process your information on our behalf, under conditions of confidentiality and security required by law;

business partners, channel partners, service partner, agents, suppliers and sub-contractors for the performance of any contract we enter into with them or you;

to a person who takes over our business and assets, or relevant parts of them; or

in exceptional circumstances:

These disclosures may involve transferring your personal information overseas. If you are dealing with us within the European Economic Area, you should be aware that this may include transfers to countries outside the European Economic Area, which have not been determined by the European Commission to have an adequate level of data protection. In those cases, where we transfer your personal information to other members of the Fujitsu group or our service providers, we will ensure that our arrangements with them are governed by relevant legal mechanisms and safeguards including data transfer agreements, designed to ensure that your personal information is protected, on terms approved for this purpose by the European Commission.

How long do we keep your personal information?

We will delete your personal information when we no longer need such personal information, for instance where:

i. it is no longer necessary for us to retain your personal information to fulfil the purposes for which we had collected it;

ii. we believe that your personal information that we hold is inaccurate; or

iii. in certain cases where you have informed us that you no longer consent to our processing of your personal information.

Sometimes, however:

a. there are legal or regulatory requirements which may require us to retain your personal information for a specified period, and in such cases we will retain your personal information for such specified period; and

b. we may need to retain your personal information for certain longer periods for product liability purposes or in relation to legal disputes, and in such cases we will retain it for such longer periods to the extent required.

Note that we may retain some limited information about you even when we know that you have left the organisation that you represent, so that we can maintain a continuous relationship with you if and when we are in contact with you again, representing a different organisation.

What are your rights?

You have the following rights (subject to applicable local laws) in relation to the personal information that we hold about you:

to access your personal information, and some related information, under relevant data protection law;

to require any inaccurate personal information to be corrected or deleted;

to object to our use of your personal information for direct marketing purposes at any time and you may have the right to object to our processing of some or all of your personal information (and require them to be deleted) in some other circumstances;

to require us to delete your personal information in certain circumstances;

to require us to restrict or block the processing of your personal information in certain circumstances (when processing is restricted, we can still store your personal information, but may not use it further);

to obtain from us your personal information, in a structured, commonly used and machine-readable format in certain circumstances. Further, you may have the right to require us to transmit your personal information directly to another person (for instance a new provider) where it is technically feasible to do so; and where we are processing your personal information based on your consent to such processing, to withdraw your consent at any time.

Further information and advice about your rights can be obtained from the data protection regulator in your country.

If you wish to exercise any of these rights (subject to applicable local laws), or have complaints about our processing of your personal information, please email privacy@fujitsu.com

You can also lodge a complaint about our processing of your personal information with the body regulating data protection in your country.

Sensitive Information

We request you not send to or share with us any sensitive personal information (e.g. information related to racial or ethnic origin, political opinions, religion or other beliefs, health, genetic, or biometric data, criminal background or trade union membership).

Personal Information of Children

Fujitsu respects the privacy of children and does not knowingly collect, use or disclose personal information of children under 16 years of age without verifiable consent from a parent or guardian.

If Fujitsu becomes aware that the information submitted to or collected by Fujitsu is personal information of children without first receiving verifiable consent from a parent or guardian, Fujitsu will take prompt steps to delete such personal information.

If a parent or guardian wishes to raise a concern regarding personal information pertaining to a child, please email our Data Protection Office at privacy@fujitsu.com

Automated Decision Making

We may use technology which tracks your use of our website and your interactions with us and which helps us to build a profile of your preferred products and information requests. If we do this, what this means for you is that you are more likely to receive offers and information that are tailored to your specific preferences, based on your previous profile activity.

If we use automated decision making in respect of any specific service or product and such automated decision making produces legal effects concerning data subjects or similarly significantly affects them, we will provide information required by applicable laws in respect of such automated decision making.

Contact us

If you have any questions, comments and requests regarding this privacy statement or our processing of personal information, please send an email to privacy@fujitsu.com

Changes to this policy

This privacy policy is valid from the time of its publication on the Fujitsu websites, and all previous versions of this privacy policy become invalid as of such time. Any changes we make to this privacy statement in the future will be posted to our website and also available if you Contact us at privacy@fujitsu.com

Please check back frequently to see any changes.

CALIFORNIA CONSUMER PRIVACY ACT ADDENDUM

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we (as defined in the Privacy Policy above) are providing the following additional details regarding the categories of Personal Information about California residents that we have collected (online and offline) or disclosed within the preceding 12 months. This CCPA Addendum does not apply to our job applicants, employees, contractors, owners, directors, or officers where the Personal Information we collect about those individuals relates to their current, former, or potential role with us.

Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular California resident or household.

(1) We collected the following categories of Personal Information:

A. Identifiers, such as name, contact information, IP address and other online identifiers;

B. Personal information, as defined in the California customer records law, such as name, contact information, and payment card number;

C. Characteristics of protected classifications under California or federal law, such as age and gender;

D. Commercial information, such as transaction information and purchase history;

E. Internet or network activity information, such as browsing history and interactions with our website;

F. Geolocation data, such as device location;

G. Audio, electronic, visual, and similar information; and

H. Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.

We collect this Personal Information from you as well as from our affiliates, publicly available databases, and joint marketing partners. We use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, as described above in this Privacy Policy under “The Data We Collect and How We Use It.”

(2) We disclosed the following Personal Information to third parties for our operational business purposes:

A. Identifiers, such as name, contact information, IP address and other online identifiers;

B. Personal information, as defined in the California customer records law, such as name, contact information, and payment card number;

C. Characteristics of protected classifications under California or federal law, such as age and gender;

D. Commercial information, such as transaction information and purchase history;

E. Internet or network activity information, such as browsing history and interactions with our website;

F. Geolocation data, such as device location;

G. Audio, electronic, visual, and similar information; and

H. Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.

We disclosed these categories of Personal Information to: our affiliates: resellers and distributors; consultants and other trusted third-party service providers; our event co-sponsors and alliance partners; third parties to permit them to send you marketing communications, consistent with your choices; and third-party sponsors of contests, surveys or similar promotions.

(3) We have not “sold” Personal Information for purposes of the CCPA the following categories of Personal Information:

A. Identifiers, such as name, contact information, IP address and other online identifiers;

B. Personal information, as defined in the California customer records law, such as name, contact information, and payment card number;

C. Characteristics of protected classifications under California or federal law, such as age and gender;

D. Commercial information, such as transaction information and purchase history;

E. Internet or network activity information, such as browsing history and interactions with our website;

F. Geolocation data, such as device location;

G. Audio, electronic, visual, and similar information; and

H. Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.

For purposes of this Privacy Policy, “sold” or “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.

If you are a California resident, you may request that we:

(1) Disclose to you the following information covering the 12 months preceding your request:

The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;

The specific pieces of Personal Information we collected about you;

The business or commercial purpose for collecting or selling (if applicable) Personal Information about you;

The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).

(2) Delete Personal Information we collected from you.

To make a request for the disclosures or deletion described above, please contact us by e-mail at privacy@fujitsu.com or by phone at 1-800-FUJITSU. We will respond to your request consistent with applicable law.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

Last updated: 21 January 2021

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