Privacy Policy

Effective: January 1, 2023

Introduction
Protecting your privacy is important to NEC Corporation of America ("NEC", "we", "our," or "us") and we strive to keep your personal information confidential. The purpose of this Privacy Policy (“this Policy”) is to inform you about the types of information we collect about you when you visit www.necam.com and other webpages that we operate which link to this Policy ("Website"), such submit an online job application with NEC, or provide us with the information through NEC’s marketing efforts, how we may use that information, whether we disclose it to anyone, and your rights and choices as it pertains to that information.

Please take a moment to read this Policy to learn how we handle your personal information. If you have any questions regarding this Policy, please contact us using the contact information at the end of this Policy. By continuing to use our Websites you agree to the terms of this Policy.

Scope
This Policy covers only data collected through the Website, and through NEC’s marketing efforts. It does not cover any other data collection or processing, including, without limitation, data collection practices of other web pages to which we link, or data that we or our subsidiaries collect offline or through other websites, communications, products, or services that do not display a direct link to this Policy. Different or separate terms and privacy policies may apply to the solutions and services we provide to our commercial partners, enterprise clients, and customers; for example, we process data that our enterprise clients provide to us pursuant to our agreements with them, and such processing is governed by the applicable data processing agreements that we have entered with them.

How We Collect Information
We collect information from a variety of sources. The following are categories of sources from which information may be collected:

• From you when you contact us via the "Contact Us" section on the Website, or otherwise actively send us data (in each such instance, you will know what data we collect through the Website, because you actively submit it);
• From business partners, third parties, and service providers (referred to as “processors” in certain jurisdictions) (including advertising networks and data analytics providers);
• Automatically from your computer or mobile device through cookies and other online tracking technologies (see the “Cookies” section of this Policy for more information);
• Public sources of data such as government databases or entities; and
• From our commercial partners, enterprise clients, and customers who request certain services to be provided.

Information We Collect
The specific pieces of personal information that NEC collects, uses, and discloses depends on how you use our Websites and/or on our marketing efforts.

The categories of personal information we may collect on our Website include:

• Contact information (such as your name, institution, specialty, email address(es), mailing address(es), country)
• Internet or other Electronic/Online Network Activity Information (such as your browser type, operating system, IP address, domain name from which you accessed the Website, type of mobile device, date and time you visit the Website, areas or pages of the Website that you visit, the amount of time you spend viewing the Website, the number of times you return to the Website, and other click-stream data)

Though our marketing efforts (including trade show and product demonstrations), we may also collect the following categories of personal information:

• Personal identifiers (such as your Social Security number, Driver's License/State ID number, and/or Passport number).
• Financial information (such as credit/debit card number, and/or bank account number).
• Employment/Professional information (such as occupation, title, and/or work experience).
• Demographic information (such as age, date of birth, gender, and/or ethnicity).
• Personal characteristics (such as veteran status, marital status, sexual orientation, and/or familial information).
• Health-related information (such as medical history).
• Biometric information (such as fingerprints, facial scanning, voice recordings, and/or photographs/images).
• Sensory data (such as audio recordings of customer support calls, electronic, thermal, visual, and/or similar information).
• Geo-location information (such as city/state, zip code, physical location and/or movements).
• Internet or other Electronic/Online Network Activity information (such as IP address, browsing history, search history, device type, operating system, and/or duration of session).
• Inferences drawn from the above categories of personal information reflecting your preferences, characteristics, behaviors, attitudes and/or abilities.

In addition to the above categories, you may provide us with additional pieces of information when you fill in a form or communicate with us. To the extent permitted by applicable law, we may combine various types of data that we collect, including data from our commercial partners, enterprise clients, customers, or other sources for use in an aggregated and anonymized manner.

Cookies
We may use cookies, web beacons or similar online tracking technologies to collect the information described above. A cookie is a small text file that may be stored on the hard drive of your computer or device when you access the Website. We may also use cookies to: (1) provide you with customized content or offers on the Website; (2) monitor Website usage; (3) remember you when you return to the Website; and (4) conduct internal research to improve our content and services. You are free to decline cookies, but by doing so, you may not be able to use certain features on the Websites, or take full advantage of all of our offerings. Check the "Help" menu of your browser to learn how to change your cookie preferences.

How We Use Information
We use the data we collect for the following purposes:

• To provide a product or service to our commercial partners, enterprise clients, and customers;
• To respond to requests that you send us, such as orders, questions or product registrations;
• To administer, protect and improve our Website and our systems;
• To better understand the preferences of our Website visitors;
• To compile aggregated statistics about Website usage;
• To help personalize your experience of our Website;
• To improve our products and services and for other internal business purposes;
• To provide you with information about our technologies, product or service releases, news, and other communications; and
• Any other business purpose permitted by applicable law or as we describe at the point where we collect the data.

Retaining Your Personal Data
Except as otherwise permitted or required by applicable law or regulation, to satisfy any legal or regulatory obligations, or to resolve disputes, we will retain your personal information (including the categories of personal information discussed in the sections above) for as long as necessary to fulfil the purposes for which we collected it. In determining what constitutes an appropriate retention period for personal information, we consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, and whether those purposes can be achieved through other means.

Disclosures of Personal Information
NEC does not sell your personal information for money. However, we disclose the categories of personal information listed above with the following categories of recipients for the purposes outlined in this Policy:

• Affiliated Entities. We may disclose your personal information to our subsidiaries and corporate affiliates, including future subsidiaries and affiliates of NEC, to use your information consistent with this Policy.
• Service Providers. We may disclose personal information with Service Providers who provide us with services, such as data analysis, online advertising, payment processing, order fulfillment, IT services, credit information services, customer service, and other similar services. We grant our service providers access to personal information only to the extent needed for them to perform their functions, and we require them to protect the confidentiality and security of such personal information.
• Commercial Purposes. We may disclose personal information with unaffiliated parties (commercial partners and/or enterprise clients) who partner or enter into commercial agreements with us to deliver our services or on our commercial activities. Depending on the choices you have made and the nature of the joint activity, these parties may contact you regarding products or services of interest. However, we do not sell or share personal information with these unaffiliated parties.
• Government Authorities. We may disclose personal information to government authorities. For example, we may do so as required by law or in the interest of protecting or exercising our or others' legal rights, such as without limitation, in connection with requests from law enforcement officials and in connection with court proceedings.
• Business Transfers or Assignments. In the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including, without limitation, in connection with any bankruptcy or similar proceedings), we may transfer any information that we collect from Website users or offline to a third party.
• Permission. We may disclose personal information with recipients where you have granted us permission, and we reserve the right to fully use and disclose any information collected via the Website that is not in personally identifiable form.

Your Rights
Depending on your jurisdiction, applicable law may entitle you to certain rights and choices as it pertains to your personal information. Specifically, when the applicable laws become effective, if you are a resident of California, Colorado, Connecticut, Utah, or Virginia you have the rights to know (including whether your personal information is sold or disclosed and the purpose, and with whom your personal information was disclosed), delete, access, and opt out of sale/share, and profiling of personal information. If you are a resident of California, Colorado, Connecticut, or Virginia you have the right to correct your personal information that is no longer accurate, current, or complete. If you are a resident of Colorado, Connecticut, or Virginia, you have the right to opt-in for us to use your sensitive personal information. If you are a resident of California or Utah, you have the right to limit the use and disclosure of sensitive personal information. If you are a resident of California, you also have the right to non-discrimination.

We do not “sell” or “share” personal information for money. Under some state laws, the manner in which we may use cookies may constitute a “sale.” You may have the right to opt-out of the sale of personal information depending on how your state defines “sale.” Please see our Cookies section for more on how we use cookies and other online tracking technologies.

We do not use sensitive personal information for the purpose of inferring characteristics about you; notwithstanding any of the forgoing, if NEC discloses sensitive personal information, it would only be for the following enumerated reasons: to provide our goods and services, or as needed: to ensure security and integrity; to prevent fraud or illegal activity; for physical safety; for short-term, transient use, including for non-personalized advertising; to perform services on behalf of the business; and to verify or maintain the quality or safety of a service or device owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance such services or devices.

Exercising Your Rights
In connection with our Websites or marketing efforts, we may ask you specifically whether you have objections against a certain kind of data use or disclosure. If you opt-out under such circumstances, we will respect your decision.

To exercise any other rights as described in this Policy, please submit a verifiable request by contacting us using the contact information at the end of this Privacy Policy. Because we take the protection of your information seriously, your identity must be verified in order to process any requests to know/access, delete, correct, or exercise any other rights you may have under applicable laws. We reserve the right to verify your identity in connection with any requests regarding personal information to help ensure that we provide the information we maintain to the individuals to whom it pertains and allow only those individuals or their authorized representatives to exercise rights with respect to that information. If you are an authorized agent or parent/guardian making a request on behalf of an individual or your child who is a minor, we may require and request additional information to verify that you are authorized to make that request.

We reserve the right to deny your request if we cannot verify your identity. Where we deny your request in whole or in part, we will inform you of the denial, provide an explanation of our actions, and the reason(s) for the denial. Residents of Colorado, Connecticut, or Virginia may have the right to appeal requests that have been denied by contacting us at [email protected].

We will not restrict or deny you access to our services because of choices and requests you make in connection with your personal information.

Security
Transmissions over the Internet are never 100% secure or error-free. While we take reasonable steps to protect your personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, we cannot warrant the security of any information users transmit to us.

Children and Minors
We do not knowingly collect or use any information from children (we define "children" as minors younger than 15 years of age on our Websites. If you are a parent and become aware that your child has provided us with information, please contact us using the contact information at the end of this Policy, and we will work with you to address the issue.

California's "Shine the Light" Law
If you are a California resident, you are entitled, once a year and free of charge, to request information regarding our disclosure, if any, of certain categories of Personal Information to third parties for their direct marketing purposes in the preceding calendar year. Note: NEC does not sell or share personal information with third parties for their own direct marketing purposes, as those terms are defined by the statute, without your consent or providing the option to opt-out.

Amendments
This Privacy Policy is effective January 1, 2023. We may update and amend this Privacy Policy from time to time, so please check the most recently posted version whenever you visit this Website.

Contact Us
If you have questions about your personal information or your rights under this policy, please feel free to contact us at [email protected] or at the following address:

Customer Information Privacy Practices
c/o Legal Department
NEC Corporation of America
5205 N. O'Connor Blvd.
Suite 400
Irving, Texas 75039