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Sharp IoT Privacy & Data Utilization Policy

Effective: August 3, 2020

FOR CUSTOMERS IN THE UNITED STATES AND CANADA

Introduction

Sharp is committed to protecting Your Privacy.  This privacy policy ("Privacy Policy") applies solely to the information gathering and data sharing practices of Sharp through the use of the Sharp User Account System, Sharp App, and Connected Services and does not apply to other Sharp affiliates or our parent company and such entities may have their own privacy policy.

This Privacy Policy should be read in conjunction with the Sharp IoT Terms of Use, available at http://www.sharpusa.com/sharpapps/termsofuse.aspx, 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 policy provides You with information about the type of personally identifiable information that is gathered and tracked, how the information is used, stored, secured and with whom the information is shared. In general, You can use Your Sharp Device without providing any information about Yourself. However, when You connect to WiFi, there may be times when we need information from You or we obtain information about You when You or others provide us with such information.

For California residents, additional disclosures required by California law may be found in our California Consumer Privacy Act Disclosure at the end of this Privacy Policy.

Application of Local Laws

The application of this Privacy Policy is subject to the requirements and provisions of applicable privacy laws of the United States of America and Canada and is designed to provide compliance with the laws in those countries. Sharp recognizes that certain laws might be modified to require stricter standards than those described in this Privacy Policy, in which case the stricter standards shall apply. If the applicable law provides for a lower level of protection of personal information than that established by this Privacy Policy, then this Privacy Policy shall prevail. Any questions about applicable laws and Sharp's compliance with it may be addressed using the contact information provided below.

Personal Information

We may collect Your name, address, email address, client IP address, phone number, demographic information or information related to Your preferences and interests, and other personally identifiable information about You ("personal information") and the products or services You purchase or obtain from us. This information is collected, in general, from information You provide to us complete a product registration and/or when You connect Your Sharp Device to the Sharp App or otherwise enable the Connected Services. With Your consent, we may also collect Your precise geographic location information.

Principles for Collection, Use, and Disclosure of Personal Information

Sharp respects the privacy of its customers and is committed to protecting personal information in compliance with applicable privacy laws. Sharp will observe the following principles when collecting, using, or disclosing personal information:

  • Personal information will be collected, used, and disclosed in accordance with applicable laws;
  • personal information will be collected for specified, reasonable purposes and not used or disclosed in ways incompatible with those purposes;
  • Personal information will be relevant to and not excessive for the purposes for which it is collected and used;
  • You will be asked to provide Your consent for the collection, use, or disclosure of Your personal information where consent is the legal basis for the collection, use or disclosure; 
  • Personal information will be used or disclosed only for the purposes for which it was collected. Those purposes shall be described in this Privacy Policy;
  • Appropriate technical, physical, and organizational measures will be taken to prevent unauthorized access, unlawful use or disclosure, and unauthorized or accidental loss, destruction, or damages to personal information.

Collection, Use, and Disclosure of Personal Information

a. Types of Personal Information Collected

With Your consent, Sharp may collect the following personal information about You through the use of the Sharp App or Connected Services:

  • Name
  • Date of birth
  • E-mail address
  • Individual account information including account password and application access information.

Additionally, when Your Sharp Device is connected to Wi-Fi, Sharp, or Affiliates may automatically collect and receive the following personal information from Your Sharp Device:

  • IP address
  • MAC address (which is a unique identifier of the appliance/device)
  • Other individual device identifiers
  • User preferences
  • Usage patterns including for instance, how often You use Your Sharp Device, the duration You use it, and which features You use most often
  • Your geographic location
  • Cache data
  • Other actions taken in connection with the use of Your Sharp Device.

b. Purposes of Collection, Use, and Disclosure of Personal Information

Sharp and its Affiliates collect, use, and disclose Your personal information for the following purposes:

  • To operate and improve upon Your Sharp Device and the services associated with Your Sharp Device;
  • To deliver the services and/or Connected Services You have requested or may be interested in;
  • To provide customer service and support for Your Sharp Device;
  • To provide updates on new Sharp products and services;
  • To provide specific updated content to You based on Your geographic location, interests, or preferences;
  • To provide personal information to existing Third-Party Content Providers, to deliver or improve existing content, or to provide new content via the Sharp App and Sharp Device or for any of the purposes listed below;
  • To contact You regarding services provided in connection with Your Sharp Device.

Sharp will not collect, use, or disclose Your personal information for any new purpose without first identifying the new purpose and obtaining Your consent where applicable.

Sharp may also use information it collects about You in the aggregate for statistical purposes such as customer usage habits. We may publish and/or disclose aggregate statistics to third parties but never identifiable personal information (except in accordance with this Privacy Policy).

c. Disclosure of Personal Information to Affiliates and Third-Party Service Providers

In connection with the use of the Sharp App or Connected Services, Sharp may transfer Your personal information to its Affiliates for the purposes noted above.

Sharp's Affiliates include:

  • Sharp Electronics Corporation Limited (SEC Limited); and
  • Sharp Corporation (Sharp Corp.) and its subsidiaries.

Your personal information may be collected by or transferred to Sharp in the United States, SEC Limited in Canada or Sharp Corp. in Japan and as a result may be subject to access by law enforcement and/or national security authorities of those countries.

The privacy policies of SEC Limited and Sharp Corp. may be accessed here: https://sharp.ca/en/privacy-policy  and https://global.sharp/privacy/.

While connected to the Sharp App or Connected Services, Third-Party Content Providers may also directly collect Your personal information from the Sharp App and Your Sharp Device for any of the purposes noted above. For example, SideChef, Inc. may collect information regarding Your usage of the Sharp App and certain Sharp appliances. Sharp and its Affiliates may also disclose Your personal information to third parties such as its service providers with whom it has contracted to provide certain services ("Third-Party Service Providers"). For example, Sharp uses Third-Party Service Providers to:

  • analyze data;
  • provide marketing assistance;
  • host websites and provide customer support;
  • comply with the law, applicable regulations, court orders or subpoenas as required and applicable;
  • enforce the Terms of Use or other agreements;
  • protect our rights, property or safety or the rights, property or safety of our users or others;
  • as part of a transfer or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, customer information may be one of the transferred assets); or
  • as otherwise described in this Privacy Policy.

The Third-Party Service Providers may have access to Your personal information but are only provided the limited amount of information required to perform their services or functions. When Sharp utilizes Third-Party Service Providers, it requires them to protect personal information in accordance with applicable laws and privacy standards and to provide equivalent or more stringent security safeguards than Sharp. Any disclosure of personal information by Sharp to a Third-Party Service Provider will be conditional upon the information being used solely for the purpose for which it has been disclosed. If You do not wish Sharp to provide Your personal information to Third-Party Service Providers, Sharp may be unable to provide You with certain services related to Your Sharp Device.

d. Consent to Collection, Use and Disclosure of Personal Information

It is important that Your personal information is collected, used, or disclosed with Your consent.  Your consent may be implied, deemed, or express. Express consent can be given orally, electronically, or in writing. Implied consent is consent that can reasonably be inferred from Your action or inaction. For example, if You provide Your personal information to Sharp for a particular purpose, Sharp may have implied consent to use and disclose Your personal information for that purpose.

Typically, Sharp will seek Your consent at the time that it collects Your personal information. In certain circumstances, Your consent may be obtained after collection but prior to use or disclosure of Your personal information. If Sharp plans to use or disclose Your personal information for a purpose not previously identified (either in this Privacy Policy or separately), it will advise You of that purpose before such use or disclosure and will seek Your consent.

By connecting Your Sharp Device to Wi-Fi and registering for the Sharp App, You acknowledge and agree that Sharp may collect, use, and disclose Your personal information in accordance with this Privacy Policy. You may withdraw Your consent at any time by following the process described below.

e. Withdrawing Consent

You may withdraw Your consent for Sharp to collect, use, or disclose Your personal information for one or more of the above purposes by disabling Your use of the Sharp App and disconnecting Your Sharp Device from Wi-Fi. You may also contact Sharp directly at the email addresses provided below. By withdrawing Your consent, You acknowledge that Sharp may not be able to provide certain services or information to You.

Security Measures

Sharp is committed to protecting the security of Your personal information. Sharp has put into place physical, electronic, and organizational procedures and processes designed to safeguard and help prevent theft and misuse, as well as unauthorized access, loss, disclosure, alteration, and destruction of personal information. Sharp applies security safeguards appropriate to the sensitivity of the information, such as retaining information in secure facilities and making personal information accessible only to authorized employees on a need-to-know basis.

Your personal information is stored on secure database servers of Sharp, located in the United States; SEC Limited, located in Canada; or Sharp Corp., located in Japan, or hosted by third parties who have entered into agreements with Sharp that require them to observe this Privacy Policy and implement suitable safeguards and provide a comparable level of security to the information. Sharp has implemented technological measures designed to prevent individuals from accessing personal information without authorization. Data centers are designed to be physically secure and protected from unauthorized access by unauthorized persons.

Although we take appropriate measures to safeguard against unauthorized loss, misuse, or access of personal information by third parties, You should be aware that there is always some risk that Your personal information may be subject to unauthorized use, access, or disclosure by a third party.

Third-Party Websites and Applications

The Sharp App may also reference or contain links to other websites or applications of third parties and Your Sharp Device may be capable of connecting to websites or applications of third parties. These other websites and applications may collect and subsequently use and/or disclose Your personal information. Sharp does not assume any responsibility for the privacy practices, policies, or actions of the third parties that operate these websites or applications. Sharp is not responsible for how such third parties collect, use, or disclose Your personal information. When leaving the Sharp App or connected to a Linked Site via Your Sharp Device, You should be aware that Sharp's Privacy Policy and Terms of Use no longer govern Your activities; Sharp does not have any control over non-Sharp websites or applications. Please ensure to always review the applicable terms and policies, including privacy and data-gathering policies, and practices of the Linked Sites or applications prior to using any other site or providing any personal information to a third party.

Access To and Correction of Personal Information

You may request access to Your personal information in the possession and control of Sharp. If You want to obtain access to Your personal information, please submit a written request to Sharp at the email addresses provided below. The written request must provide sufficient detail to allow Sharp to identify the personal information being sought. Unless exempted by law, Sharp will provide You with access to Your personal information within Sharp's possession and control.

Sharp may request specific information from You to enable it to confirm Your identity and right to access, as well as to search for and provide You with the personal information that Sharp holds about You.

In some cases, Sharp may not be able to provide access to Your personal information. There are instances where applicable law or regulatory requirements allow or require Sharp to refuse to provide some or all of the personal information that it holds about You. Additionally, Your personal information may have been destroyed, erased or made anonymous in accordance with Sharp's record retention obligations and practices. In the event Sharp cannot provide You with access to Your personal information, it will advise You of the reasons why the personal information cannot be provided and will provide the name, title, and contact information of the individual who can discuss the reasons for the refusal.

It is important that the information contained in Sharp's records is both accurate and current. If Your personal information changes during the course of Your relationship, please advise us of such changes.

In some circumstances Sharp may not agree with Your request to change Your personal information and will instead append an alternate text to the record in question. We will advise You when this occurs.

Personal Information of Children

At Sharp, we are committed to protecting the personal information of children. As such, the Sharp App is not meant for use by individuals under the age of 18 and Sharp will not knowingly collect personal information from individuals under such age. If we learn that a child under the age of 18 has provided any personal information, we will use commercially reasonable efforts to delete such information promptly. Sharp encourages parents and legal guardians to participate in all online activities of their children and instruct them to not provide any personally identifiable information to Sharp. Sharp requests and collects the date of birth of individuals to ensure that the Sharp App is not being used by individuals under 18.

Updating This Policy

Sharp may revise or update this Privacy Policy from time to time as we change or add new services or content or develop better ways to serve its users. Please review our Privacy Policy regularly for updates. When we make a change, we will post a new effective date on the Privacy Policy and will provide notice to You.

Questions or Concerns

If You have any questions, comments, or concerns about how we collect, use, or disclose Your personal information or regarding this Privacy Policy, You may contact Sharp. Customers in the United States should contact Sharp at 100 Paragon Drive, Montvale, NJ 07645, email: privacypolicy@sharpsec.com. Customers in Canada should contact Maria Alves, Manager, Sharp Electronics of Canada Ltd., 335 Britannia Rd., East, Suite 101, Mississauga ON L4Z 1W9, Tel: 905-890-2100 ext. 7070, Fax: 905-568-7141, email: privacy@sharpsec.com.

If You have unresolved concerns or complaints regarding the handling of Your personal information You have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority of the country: (i) of Your habitual residence; (ii) of Your place of work; or (iii) in which You consider the alleged infringement has occurred.

 

California Consumer Privacy Act

Notice for California Consumers

This notice describes the rights of California residents under the California Consumer Privacy Act of 2018 ("CCPA"). The CCPA requires businesses like us to provide certain information to consumers. We fully describe our practices to all our visitors in our Privacy Policy, but use this separate notice to ensure that we meet the CCPA's requirements. This notice contains the following four parts:

  • We Do Not Sell Your Personal Information
  • Your Rights Under the CCPA
  • The CCPA Categories of Personal Information We Collect and the Sources
  • The CCPA Categories of Personal Information We Share for a "Business Purpose"

1. We Do Not Sell Your Personal Information

The CCPA requires us to disclose whether we sell Your personal information. We do not sell Your personal information.

2. Your Rights Under the CCPA

The CCPA provides California residents with the following rights:

2.1 Requests for Information

As a California consumer, You have the right to request the personal information we have collected about You and for what purpose. For quicker access, You can also review our Privacy Policy, which explains the kind of information we may collection about You.

2.2 Your Right to Opt Out of Sales of Personal Information

We do not sell personal information, so we do not have an opt out.

2.3 Your Right to Notification

Under the CCPA, our company cannot collect new categories of personal information or use them for materially different purposes without first notifying You.

2.4 Nondiscrimination for exercising Your CCPA Rights

The CCPA prohibits business from discriminating against You for exercising Your rights under the law. Such discrimination may include denying services, charging different prices or rates for services, providing a different level or quality of services, or suggesting that You will receive a different level or quality of goods or services as a result of exercising Your rights.

2.5 Your Right to Delete Personal Information

You have the right to request we delete Your personal information. We honor such requests, unless an exception applies, such as when the information is necessary to complete the transaction or contract for which it was collected or when it is being used to detect, prevent, or investigate security incidents, comply with laws, identify and repair bugs or ensure another consumer's ability to exercise their free speech rights or other rights provided by law.

3. The CCPA Categories of Personal Information We Collect and the Sources

Contact Details and Identifiers:

Identifiers such as a real name, alias, postal address, phone number, email address, unique personal identifier, online identifier, account name, or other similar identifiers.

Customer Services Information:

Customer records containing personal information, such as name, address, telephone number, or any other customer related information, opinions and feedback collected from the various types of customer services, surveys, and community site data.

Purchase History and Account Information:

Commercial information, including records of products or services purchased, obtained, or considered.

Online, Performance and Technical Information:

Tracking information such as Internet Protocol address, device identifier, Uniform Resource Locator, geolocation data, language, access times, other unique identifiers and other technical data, server log records (including page requests), data collected by automated means to measure consumer response to online content, error reports and performance information, credentials, telemetry data, Internet or other electronic network activity information, including, but not limited to information regarding a resident's interaction with an internet website, application, or advertisement.

Our Privacy Policy also describes the information we collect and its sources. Please see the Collection of Personal Information section on our Privacy Policy page for additional details.

4. The CCPA Categories of Personal Information We Share for a "Business Purpose"

We do not sell Your personal information. We may use Your personal information as described in the Use and Disclosing of Personal Information section on our Privacy Policy page.

Questions Regarding California Consumer Privacy Act?

If You have any question about this CCPA Disclosure Statement, please contact us at privacypolicy@sharpsec.com or by calling our toll-free number: 1-800-BE-SHARP.

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