EMEA Privacy Policy, effective from 1 July 2018

 

  1. This Policy

 This Policy is issued by Printronix, LLC on behalf of itself, its branches, its subsidiaries and its affiliates,  (together, “Printronix”,  “we”,  “us” or “our”) and is addressed to individuals outside our organization with whom we interact, including visitors to our websites (our “Sites”), customers, Personnel of corporate customers and vendors, and other recipients of our products and services (together, “you”). Defined terms used in this Policy are explained in Section 14 below.

This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy.

 

Creation of Personal Data: We create Personal Data about you, such as records of your interactions with us, and details of your accounts, subject to applicable law.

 

Processing your Sensitive Personal Data: We do not seek to collect or otherwise Process your Sensitive Personal Data, except where:

  • the Processing is necessary for compliance with a legal obligation (e.g., to comply with our diversity reporting obligations);
  • the Processing is necessary for the detection or prevention of crime (including the prevention of fraud) to the extent permitted by applicable law;
  • you have manifestly made those Sensitive Personal Data public;
  • the Processing is necessary for the establishment, exercise or defence of legal rights;
  • we have, in accordance with applicable law, obtained your explicit consent prior to Processing your Sensitive Personal Data (as above, this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way); or
  • Processing is necessary for reasons of substantial public interest and occurs on the basis of an applicable law that is proportionate to the aim pursued and provides for suitable and specific measures to safeguard your fundamental rights and

 

Purposes for which we may Process your Personal Data, and legal bases for Processing: The purposes for which we may Process Personal Data, subject to applicable law, and the legal bases on which we may perform such Processing, are:

  • We Process Personal Data to manage your relationship with Printronix and better serve you when you are using Printronix by personalizing and improving your experience. Examples of how we use information are as follows:
  • Customer Experience: Improving customer experience by maintaining accurate contact and registration data, delivering comprehensive customer support, offering products, services and features that may interest you.
  • Transaction Support: Assisting you in completing transactions and orders of our products or services, processing payments, arranging shipments and deliveries and facilitating repairs and returns.
  • Product Support: Improving the performance and operation of our products, services and support, including warranty support (what else?) to ensure the continued operation of the device.
  • Administrative Communication: Communication with you about Printronix. (for example: enhanced responses to your inquiries or requests, service completion or warranty-related communications, safety recall notifications, communications required by law or applicable corporate updates related to mergers, acquisitions or divestitures). Business operations:
  • Conducting ordinary business operations, verifying your identity, making credit decision if you apply for credit, conducting staff training and quality assurance purposes and outreach
  1. Disclosure of Personal Data to third parties.

We may disclose your Personal Data to other entities within the Printronix group, for legitimate business purposes (including providing services to you and operating our Sites), in accordance with applicable law. In addition, we may disclose your Personal Data to:

  • partners and service providers;
  • you and, where appropriate, your associates and your representatives;
  • clients and customers of our businesses;
  • credit reference agencies;
  • anti-fraud services;
  • Governmental, legal, regulatory, or similar authorities, ombudsmen, and central and/or local government agencies, upon request or where required, including for the purposes of reporting any actual or suspected breach of applicable law or regulation;
  • accountants, auditors, financial advisors, lawyers and other outside professional advisors to  Printronix, subject to binding contractual obligations of confidentiality;
  • debt-collection agencies and tracing agencies;
  • data aggregation services;
  • accreditation bodies;
  • third party processors (such as payment services providers; shipping companies; etc.), located anywhere in the world, subject to the requirements noted below in this Section 3;
  • any relevant party, claimant, complainant, enquirer, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights in accordance with applicable law;
  • any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security in accordance with applicable law;
  • any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation);
  • the press and the media;

 

Our Sites may use third party plugins or content. If you choose to interact with any such plugins or content, your Personal Data may be shared with the third party provider of the relevant platform. We recommend that you review that third party’s privacy policy before interacting with its plugins or content.

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

 

  1. International transfer of Personal Data

Printronix headquarter is located in USA and thus your personal information will be submitted to, stored, and Processed in USA. Furthermore, we may work with third parties while storing or using your personal information (for example, your personal information may be stored in the cloud by our cloud service providers and they may keep your personal information in locations outside the European Economic Area).

We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details below.

If you want to receive more information about the safeguards applied to international transfers of personal data, please use the contact details provided in Section 11-Contacts below.

 

  1. Data Security

 We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law.

You are responsible for ensuring that any Personal Data that you send to us are sent securely.

 

  1. Data Accuracy

 We take reasonable steps designed to ensure that:

  • your Personal Data that we Process are accurate and, where necessary, kept up to date; and
  • any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without

From time to time we may ask you to confirm the accuracy of your Personal Data.

 

  1. Data Minimization

 We take reasonable steps designed to ensure that your Personal Data that we Process are limited to the Personal Data reasonably required in connection with the purposes set out in this Policy.

 

  1. Data Retention

We take reasonable steps designed to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will retain your Personal Data are as follows:

 

  • we will retain copies of your Personal Data in a form that permits identification only for as long as:
    1. we maintain an ongoing relationship with you (e.g., where you are a recipient of our services, or you are lawfully included in our mailing list and have not unsubscribed); or
    2. your Personal Data are necessary in connection with the lawful purposes set out in this Policy, for which we have a valid legal basis (e.g., where your Personal Data are included in a contract between us and your employer, and we have a legitimate interest in processing  those data  for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data),

plus:

  • the duration of:
  1. any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data may be relevant); and
  2. an additional two (2) month period following the end of such applicable limitation period (so that, if a person bring a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim),

and:

  • in addition, if any relevant legal claims are brought, we may continue to Process your Personal Data for such additional periods as are necessary in connection with that

During the periods noted in paragraphs (2)a and (2)b above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.

Once the periods in paragraphs (1}, (2) and (3) above, each to the extent applicable, have concluded, we will either:

  • permanently delete or destroy the relevant Personal Data;
  • archive your Personal Data so that it is beyond use; or
  • anonymize the relevant Personal Data.

 

  1. Your legal rights

 Subject to applicable law, you may have a number of rights regarding the Processing of your Personal Data, including:

  • the right to request access to, or copies of, your Personal Data that we Process or control, together with information regarding the nature, processing and disclosure of those Personal Data; –
  • the right to request rectification of any inaccuracies in your Personal Data that we Process or control;
  • the right to request, on legitimate grounds:
    • erasure of your Personal Data that we Process or control; or
    • restriction of Processing of your Personal Data that we Process or control;
  • the right to have your Personal Data that we Process or control transferred to another Controller, to the extent applicable;
  • where we Process your Personal Data on the basis of your consent, the right to withdraw that consent; and
  • the right to lodge complaints with a Data Protection Authority regarding the Processing of your Personal Data by us or on our

This does not affect your statutory rights.

Subject to applicable law, you may also have the following additional rights regarding the Processing of your Personal Data:

  • the right to object, on grounds relating to your particular situation, to the Processing of your Personal Data by us or on our behalf; and
  • the right to object to the Processing of your Personal Data by us or on our behalf for direct marketing 

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact details provided in Section 11 below.

 

  1. Cookies 

Our website stores cookies on your computer. These cookies are used to collect information about how you interact with our website and allow us to remember you. We use this information in order to improve and customize your browsing experience and for analytics and metrics about our visitors both on this website and other media. You can set up your browser not to accept cookies. However, in a few cases, some of our web site features my not work as a result.

.

  1. Direct Marketing

We may Process your Personal Data to contact you, primarily by mail and email and also on occasion by telephone, so that we can provide you with information concerning products and services that may be of interest, provided that we have first obtained your consent, to the extent required by, and in accordance with, applicable law.

If you do not wish to receive marketing communications from us you can opt out at any time by contacting your regular Printronix contact, or by electronically unsubscribing from emails we have sent to you. After you unsubscribe, we will not send you further promotional emails, but we may continue to contact you to the extent necessary for the purposes of any services you have requested.

 

  1. Contact details

If you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the Processing of Personal Data by Printronix, please contact your regular Printronix client service contact, or:

 

Printronix, LLC

6440 Oak Canyon Road, Suite 200

Irvine, CA 92618

Email: webmaster@printronix.com

 

  • Definitions

Controller: The entity that decides how and why Personal Data is Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws. For the purposes of this Policy, the relevant Controller is Printronix, LLC

Data Protection Authority: An independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.

Personal Data: Information that is about any individual, or from which any individual is identifiable.

Process or Processor, or Processing: Anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Personnel: Any current, former and prospective directors, officers, consultants, employees, temporary staff, individual contractors, interns, and other personnel.

Processor: Any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).

Sensitive Personal Data: Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, or any other information that may be deemed to be sensitive under applicable law.