GWS recognizes that privacy is a fundamental human right and further recognizes the importance of privacy, security and data protection to our customers and partners worldwide. As a global organization, with legal entities, business processes, management structures, and technical systems that cross international borders, we strive to provide protections across all of our operations that exceed legal minimums and to deploy consistent, rigorous policies and procedures.
This Privacy Statement informs you of our privacy practices and of the choices you can make and rights you can exercise in relation to your personal data, including information that may be collected from your online activity, use of devices, and interactions you have with GWS offline, such as when you engage with our customer support representatives. This Privacy Statement applies to all GWS companies as well as GWS -owned websites, domains, services (including device management), applications, subscriptions (e.g. Instant Ink) and products, and those of our subsidiaries (collectively " GWS Services").
We have an accountability-based program and are committed to the following principles, which are based on internationally-recognized frameworks and principles of privacy and data protection:
LAWFULNESS, FAIRNESS & TRANSPARENCY
We process personal data in accordance with law and with transparency and fairness to you. Our data processing activities are conducted: 1) with your consent; 2) in order to fulfill our obligations to you; 3) for the legitimate purposes of operating our business, advancing innovation and providing a seamless customer experience; or 4) otherwise in accordance with law.
NOTICE & CHOICE OF DATA USE
We are transparent and provide clear notice and choice to you about the types of personal data collected and the purposes for which it is collected and processed. We will not use personal data for purposes that are incompatible with these Principles, our Privacy Statement or specific notices associated with GWS Services.
We provide you with reasonable access along with the ability to review, correct, amend or delete the personal data you have shared with us.
DATA INTEGRITY & PURPOSE LIMITATION
We only use personal data for the purposes described at the time of collection or for additional compatible purposes in accordance with law. We take reasonable steps to ensure that personal data is accurate, complete and current and we only collect personal data which is relevant and limited to what is necessary for the purposes for which it is collected. We will keep personal data for no longer than is necessary for the purposes for which it was collected and then we will securely delete or destroy it.
To protect personal data against unauthorized use or disclosure we implement strong information security controls in our own operations and offer market-leading products and solutions with high levels of data security protection.
ACCOUNTABILITY FOR ONWARD TRANSFER
We acknowledge our potential liability for transfers of personal data among GWS entities or to third parties. Personal data will only be shared when third parties are obligated by contract to provide equivalent levels of protection.
We collect and use personal data to manage your relationship with GWS and better serve you when you are using GWS Services by personalizing and improving your experience. We use and otherwise process your data for the following business purposes:
Providing you with a seamless customer experience by maintaining accurate contact and registration data, delivering comprehensive customer support, offering products, services, subscriptions and features that may interest you and enabling you to participate in contests and surveys. We also use your data to deliver a tailored experience, personalize the GWS Services and communications you receive and create recommendations based your use of GWS Services.
Assisting you in completing transactions and orders of our products or services, administering your account, processing payments, arranging shipments and deliveries and facilitating repairs and returns.
PRODUCT SUPPORT & IMPROVEMENT
Improving the performance and operation of our products, solutions, services and support, including warranty support and timely firmware and software updates and alerts to ensure the continued operation of the device or service. For more information, please see the section on Information Automatically Collected About Your Use of GWS Services.
Communicating with you about GWS Services. Examples of administrative communications may include 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.
Maintaining the integrity and security of our websites, products, features and services and preventing and detecting security threats, fraud or other criminal or malicious activity that might compromise your information. When you interact with us, we will also take reasonable steps to verify your identity, such as requiring a password and user ID, before granting access to your personal data. We may also maintain additional security measures, such as CCTV, to safeguard our physical locations.
Conducting ordinary business operations, verifying your identity, making credit decisions if you apply for credit, conducting business research and analytics, corporate reporting and management, staff training and quality assurance purposes (which may include monitoring or recording calls to our customer support) and outreach.
RESEARCH & INNOVATION
Innovating new products, features and services using research and development tools and incorporating data analysis activities.
Providing personalized promotional offers on GWS Services and other selected partner websites (for example, you might see an advertisement for a product on a partner site that you have recently viewed on an GWS site). We might also share some of your information with selected partners, marketing service providers and digital marketing networks to present advertisements that might interest you.
COMPLIANCE WITH LAW
Compliance with applicable laws, regulations, court orders, government and law enforcement requests, to operate our services and products properly and to protect ourselves, our users and our customers and to solve any customer disputes.
Personal data is any information that personally identifies you or from which you could be identified either directly or indirectly. We may collect your personal data through your use of GWS Services or during interactions with GWS representatives.
The categories of personal data we collect from you depends on the nature of your interaction with us or on the GWS Services you use, but may include the following:
INFORMATION COLLECTED ABOUT YOU
· Contact Data – We may collect personal and/or business contact information including your first name, last name, mailing address, telephone number, fax number, email address and other similar data and identifiers.
· Payment Data – We collect information necessary for processing payments and preventing fraud, including credit/debit card numbers, security code numbers and other related billing information.
· Account Data – We collect information such as how you purchased or signed up for GWS Services, your transaction, billing and support history, the GWS Services you use and anything else relating to the account you create.
· Location Data – We collect geolocation data when you enable location-based services or when you choose to provide location-related information during product registration or when interacting with our website.
· Security Credentials Data– We collect user IDs, passwords, password hints, and similar security information required for authentication and access to GWS accounts.
· Demographic Data – We collect, or obtain from third parties, certain demographic data including, for example, country, gender, age, preferred language, and general interest data.
· Preferences – We collect information about your preferences and interests as they relate to GWS Services (both when you tell us what they are or when we deduce them from what we know about you) and how you prefer to receive communications from us.
· Social Media Data – We may provide social media features that enable you to share information with your social networks and to interact with us on various social media sites. Your use of these features may result in the collection or sharing of information about you, depending on the feature. We encourage you to review the privacy policies and settings on the social media sites you use to make sure you understand the information that is collected, used, and shared by those sites.
· Body and biometric Data – When you use our products, you might provide us with information about your body, such as your height or weight, or gait to create personalized objects with our 3D Print technology. With your permission, some of our products may collect biometric information (such as a fingerprint) to perform functions on the device.
· Other Unique Identifying Information – Examples of other unique information that we collect from you include product serial numbers, information you provide when you interact in-person, online or by phone or mail with our services centers, help desks or other customer support channels, your responses to customer surveys or contests or additional information you have provided to us to facilitate delivery of GWS Services and to respond to your inquiries. We may ask you to provide additional personal data such as salary, government-issued identification number, banking/financial account information, and other information (for example from credit reporting agencies) for authentication purposes and to verify credit worthiness to participate in certain custom services.
INFORMATION AUTOMATICALLY COLLECTED ABOUT YOUR USE OF GWS SERVICES
· Product Usage Data – We collect product usage data such as pages printed, print mode, media used, ink or toner brand, file type printed (.pdf, .jpg, etc.), application used for printing (Word, Excel, Adobe Photoshop, etc.), file size, time stamp, and usage and status of other printer supplies. We do not scan or collect the content of any file or information that might be displayed by an application.
· Device Data – We collect information about your computer, printer and/or device such as operating system, firmware, amount of memory, region, language, time zone, model number, first start date, age of device, device manufacture date, browser version, device manufacturer, connection port, warranty status, unique device identifiers, advertising identifiers and additional technical information that varies by product.
· Application Data – We collect information related to GWS applications such as location, language, software versions, data sharing choices and update details. In cases where we incorporate technologies from third parties, data may be shared between the third party and GWS and appropriate notice will provided at the application level.
· Performance Data – We collect information regarding the performance of individual device hardware components, firmware, software and applications. Examples of the data we collect include information relating to memory and processor performance, environmental conditions and systems failures, printing events, features, and alerts used such as "Low on Ink" warnings, use of photo cards, fax, scan, embedded web server, and additional technical information that varies by device.
· Website Browsing Data – We collect information about your visits to and your activity on our GWS websites, applications or websites "powered by" another company on our behalf including the content (and any ads) that you view and interact with, the address of the website from which you arrived and other clickstream behavior (such as the pages you view, the links you click or which items you've added to your shopping basket). Some of this information is collected using cookies, web beacons embedded web links and similar technologies.
· Anonymous or Aggregated Data – We collect anonymous answers to surveys or anonymous and aggregated information about how our GWS Services are used. In certain cases, we apply a process of de-identification or pseudonymisation to your data to make it reasonably unlikely to identify you through the use of that data with available technology.
Please note: Some web browsers incorporate "Do Not Track" features. Currently, no industry standard exists for handling "Do Not Track" requests, therefore at this time, our websites may not respond to "Do Not Track" requests or headers from these browsers.
INFORMATION FROM THIRD-PARTY SOURCES
We collect data from the following third parties:
· Data brokers, social media networks and advertising networks – Commercially-available data such as name, address, email address, preferences, interests, and certain demographic data. For example, personal data may be collected when you access our applications through social media logins (i.e., logging in to our applications using your Facebook or other social media credentials). The basic details we receive may depend on your social network account privacy settings.
· GWS Partners – If you purchase GWS Services from an GWS partner, we may receive certain information about your purchase from that partner. We may also receive cookie data and insights.
· Fraud prevention or credit reporting agencies – Data collected to prevent fraud and in connection with credit determinations.
· GWS Enterprise Customers – In order to provide certain GWS Services at an enterprise level, your business contact data may be provided to GWS by a designated entity within your business or enterprise (such as a member of your IT department).
· Analytics Providers – We also receive non-personal data, such as aggregated or de-identified demographic/profile data, from third-party sources including select partners and companies that specialize in providing enterprise data, analytics and software as a service.
In order to ensure data accuracy and offer a superior customer experience by providing you with better personalized services, content, marketing and ads, in some cases we link or combine the information that we collect from the different sources outlined above with the information we collect directly from you. For example, we compare the geographic information acquired from commercial sources with the IP address to derive your general geographic area. Information may also be linked via a unique identifier such as a cookie or account number.
Where necessary, we obtain information to conduct due diligence checks on business contacts as part of our anti-corruption compliance program and in accordance with our legal obligations.
IF YOU CHOOSE NOT TO PROVIDE DATA
You are not required to share the personal data that we request, however, if you choose not to share the information, in some cases we will not be able to provide you with GWS Services, certain specialized features or be able to effectively respond to any queries you may have.