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Privacy Policy- for Synappx™, Synappx™ Go and Synappx™ Meeting

Sharp Electronics (Europe) Ltd. (“Sharp”) is committed to protecting Your privacy. Please read the following Privacy Policy (“Privacy Policy”) carefully as it sets out Sharp’s policy for collecting, using, storing, processing and disclosing Your data and information obtained through the Services. When we refer to “we”, “our” or “us” in this Privacy Policy, we are referring to Sharp Electronics (Europe) and its subsidiaries and affiliates (together, “Sharp”) https://global.sharp/worldwide/ as the data controller or the equivalent legal construct under applicable privacy laws.
Users can access the Services through a variety of means and devices, which include via the website, or through a desktop PC, laptop, mobile device, tablet, display system, multi-function peripheral device (“MFP”) or other electronic device. This Privacy Policy governs Your access and use of the Services regardless of how You access them and should be read in conjunction with the Terms of Use for Synappx™ Go and Synappx™ Meeting (“Terms of Use”), as this Privacy Policy is incorporated therein by reference. All defined terms in the Terms of Use shall have the same meaning in this Privacy Policy.
This Privacy Policy only applies to Information provided through, stored in or accessed, processed and collected through the Services and may differ from other Sharp privacy policies. The term “Information” used in this Privacy Policy refers to all forms of data, information and content provided through, stored in or accessed, processed and collected through the Services and also may include Personal Data (defined below). The term “You” or “Your” used within this Privacy Policy shall refer to natural persons residing in the territorial scope of any European Union member state or a state within European Economic Area, including the Customer and its Administrator(s) or End Users (“Data Subjects”)
Specific Software Services available through the Services may have additional terms or disclosures related to privacy or use of Information for that Specific Software Services (hereafter, “Specific Privacy Policies”); as it relates to the Specific Software Services, those additional Specific Privacy Policies shall apply in addition to those set out here. However, if there is any inconsistency between this Privacy Policy and the Specific Privacy Policies, the Specific Privacy Policies shall apply but only to the Specific Software Services.

1. Information Collected
As part of Your use of and access to the Services and any Specific Software Services available through the Services, You may be asked to provide some types of personal information, personally identifiable information, or the equivalent of each under applicable privacy laws. This may include, but is not limited to, information to identify You or contact You, as well as some company information, such as address, post code, telephone number and e-mail address (“Personal Data”).
Sharp may also collect and store additional information through Your use of and access to the Services, some of which may also be deemed Personal Data. This may include, but is not limited to, an IP address, MAC address (a unique identifier of the device), application selection and installation, browser type, language selection, access times, preferences and favorites, as well as storage use, usage patterns, Your general activity using the Services, pages viewed, links clicked and other actions taken in connection with the use of and access to the Services. This Information, including Personal Data may be used to provide or improve the Services, administer Your use of or access to the Services or to authenticate users accessing the Services, and in particular, an End User.
Please note that credit card and financial information are not collected via the Services.
As a responsible organization, we have implemented numerous technical and organisational measures to ensure the most complete protection of any Personal Data processed in the course of providing the Services, in order to meet the General Data Protection Regulation (“GDPR”).

2. Use of Your Information
We limit the collection of Information to only that which is absolutely necessary to carry out our legal or business obligations.
Sharp, Dealer and/or Third Party Service Providers may collect and may use the Information collected to operate and improve Services, deliver the Services and/or access, transmit, process and store the Information requested, and otherwise enhance the overall experience of the Services. This Information may also be used to respond to requests, communicate with You and assist You with questions or support. For instance, Sharp may, without limitation, use the Information to provide customer service and support, personalize the Services, update You on new products, services or marketing efforts, make offers, promotions or new content available to You based on geographic location, interests or preferences, or share information collected with existing or potential Third Party Service Providers to deliver or improve existing Services or help develop new Services.
Sharp may further share Information with third parties: (1) who perform functions, as Sharp’s agent or contractor, including, but not limited to, analyzing data, providing marketing assistance hosting or providing some of the Services, as well as providing support or maintenance for the Services; (2) to comply with the law, applicable regulations, court orders or subpoenas, to enforce the Agreement or other agreements related to the Services, or to protect Sharp’s rights, property or safety or the rights, property or safety of Sharp’s users or others, including Dealers and Third Party Service Providers; (3) if the disclosure is done as part of a purchase, transfer or sale of services or assets (e.g., in the event that substantially all of Sharp’s assets are acquired by another party, customer information may be one of the transferred assets); or (4) as otherwise described in this Privacy Policy. Sharp’s agents or contractors who have access to Information in connection with the above activities are required to keep the information confidential and not to use it for any purpose other than to carry out the services they are performing for Sharp. Other than above, Sharp will provide notice when Information about You may be shared with third parties and You will have an opportunity to choose not to share the information.
Sharp may use Your Personal Data for the purposes outlined above because: (a) the data is required in order to provide you with the Services at Your request and consent, (b) the data is necessary for the performance and fulfilment of contract with You or (c) we are subject to legal or regulatory obligations, such as providing information to a public body or law enforcement agency

3. Cookies
The Services may use Cookies. A “Cookie” is a text-only string of characters which may be temporarily stored in Your browser. Sharp’s Cookies are time-sensitive. If the expiration of a Cookie is set to be longer than the time spent on a site, then this string may be saved in a Cookie on Your browser for future reference, otherwise it disappears from the browser when it times outs. Cookies used by Sharp cannot send viruses.
Sharp may use Cookies to track the pages that a user visits so that information can be customized to the visitor on a session-by-session basis and so that future visits may be enhanced.
Third Party Service Providers may also use Cookies in their Specific Software Services. Please be aware that any information gathered through such Cookies is collected by the Third Party Service Provider and not by Sharp. We have no access to or control over these Cookies or the information contained in them.

4. Third Party Sites
This Privacy Policy only applies to Service Software provided listed below and does not pertain to any other site, whether owned or operated by Sharp or a Third Party Service Provider, that does not display or link to this statement, even if accessible or made available through the Services. These other sites may collect Personal Data about You. The information practices of those sites are not covered by this Privacy Policy and such sites may have their own privacy statements. You should review the privacy policies of those sites before providing any Personal Data
Service Software:
•    Synappx Go
•    Synappx Meeting

5. Analytics
At times Information may be used by Sharp or Third Party Service Providers to monitor and analyze use of the Services, for the technical administration of the Services, to increase the functionality of the Services or its user-friendliness, and to verify authorization of access to and use of the Services. For additional information related to how Sharp may use Aggregated Data, please refer to the Terms of Use.

6. Security
Sharp takes precautions, including administrative, technical and physical measures, to safeguard and help protect Information, and particularly Personal Data, collected from loss, theft and misuse, as well as unauthorized access, disclosure, alteration and destruction. Information collected will be stored on a secure database. In addition, all credentials used within the Services may be temporary encrypted within the secure database and/or transmitted using Transport Layer Security protocol. The credentials are not stored permanently.
Although we take appropriate measures to safeguard against unauthorized disclosures of Information, no electronic transmission or storage of Information can ever be guaranteed. You must take care and are responsible for protecting against unauthorized access to Your password and log-in information, as well as Your accounts.

7. Third Party Service Providers
Certain third parties may help us provide, analyze and improve the Services. These Third Party Service Providers may provide authentication services, data storage, web analytics, cloud email or maintenance services. Third Party Service Providers include Microsoft Azure, Amazon Web Service, and others. These Third Party Service Providers may have access to Information only for the purposes of performing these tasks on Sharp’s behalf and under obligations similar to those in this Privacy Policy.

8. Compliance with Laws and Law Enforcement Requests; Sharp’s Rights
Sharp may disclose Information processed through or stored within the Services if there is a good faith belief that the disclosure may be reasonably necessary to a) comply with a legal or regulatory obligation; b) to protect the safety of any person from death or bodily injury or to protect the vital interest of the Data Subject c) to assist with investigation and prevention of crime; or d) to protect Sharp or any Third Party Service Provider’s intellectual property.

9. Your Rights
As a Data Subject, you have the following rights to control your Personal Data according to GDPR principles:
1.    Access and obtain a copy of your Personal Data on request;
2.    Require Sharp to change incorrect or incomplete Personal Data;
3.    Require Sharp to delete or stop processing your Personal Data, for example where the data is no longer necessary for the purposes of processing;
4.    Object to the processing of your Personal Data where Sharp is relying on its legitimate interests as the legal ground for processing;
5.    Ask Sharp to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override Sharp's legitimate grounds for processing data

10. Specific Software Services
Sharp may share Information with Specific Software Applications with Your consent, such as when You access the Specific Software Services through the Services or for verifying credentials.

11. Information Retention
Following termination or expiration of the Agreement and the forty five (45) day period referred to in the Agreement, all Information may be deleted unless the law requires otherwise, including, but not limited to, data, information or content stored, transmitted, processed or accessed via the Services by You. Sharp may, however, retain some Information regarding a Customer Account, including Personal Data of End Users, log-in credentials, as well as activity information related to a Customer Account and this Information may be used by Sharp, Dealers or Third Party Service Providers to comply with any legal obligations, resolve disputes or enforce any agreements. Please note that even if any Information is deleted, it may continue to exist on some servers or backed-up versions which are used to help protect Your Information from loss or destruction, or help ensure the Services are functioning optimally and working as intended.

12. Business Administrator Access
The Business Administrator for a Customer Account may be able to: a) access Information in and about a Customer Account that it acts as a Business Administrator for and any accounts associated with it; and b) activate/disable a Customer Account and any Business Administrator Account. For additional information regarding the Business Administrator role, please refer to the Agreement.

13. Data transfers
Where we process Personal Data originating in the EU outside of the European Union, we will ensure any such transfer complies with Chapter 5 of the GDPR. This requires one of the following conditions to apply: (a) the European Commission has decided that the country provides an adequate level of protection for Your Personal Data; (b) the transfer is subject to a legally binding and enforceable commitment on the recipient to protect the Personal Data on the basis of Standard Contractual Clauses; (c) the transfer is made subject to binding corporate rules; or (d) the transfer is based on a derogation from the GDPR restrictions on transferring personal data outside of the EU.

14. Updating this Privacy Policy
This Privacy Policy may change from time to time. Please review the Privacy Policy regularly for updates. In the event Sharp makes a change, it will post a new effective date on the Privacy Policy. Therefore, Customer, Administrators and End Users should regularly visit this Privacy Policy in order to be aware of such notices. By continuing to use the Services after any changes to this Privacy Policy becomes effective, You agree to be bound by the revised Privacy Policy. We will notify you about changes to this notice or the way we use Your Personal Data when we are legally required to do so.

15. Questions or Concerns
If you wish to contact the Data Protection Officer for Sharp based at the European headquarters, please contact us via email at DPOEurope.SEE@sharp.eu
Sharp Electronics (Europe) Limited
4 Furzeground Way
Uxbridge, Middlesex, UB11 1EZ
United Kingdom

Update: TBC