Your privacy is important to Executive Personal Computers (EPC), Inc., and its global affiliates (collectively “EPC” or “we” or “our”). This Policy explains what Personal Data we collect from you, why we collect and process your personal data, when and with whom your personal data is shared, and your rights with respect to your Personal Data.

This policy applies to all EPC employees and employees of the EPC global
solutions affiliates.

In this Policy the term “Personal Data” means data that identifies or may be used to identify an individual person, including, but not limited to, a person’s name, date of birth, job title, address, email, phone number, or employer. In order to provide outstanding service, we must collect, maintain and process certain Personal Data about our customers, suppliers and other business contacts. We recognize and respect your privacy concerns and expectations about how we use this information. We want you to know about our privacy policies and practices, and what we do to protect your Personal Data.

Personal Data We Collect on our Website
In general, you can visit EPC websites without telling us who you are and without giving any personal data about yourself. There are times, however, when we may need information from you. When you select the “Contact EPC” button, we will ask you to read and agree to this Privacy Policy before you submit your Personal Data to us.

If you apply for a job through our websites, we may collect and process Personal Data you submit to us such as name, address, references, and employment history in order to evaluate your qualifications for a job and contact your references. We will retain your information until the position is filled and for up to six months after the position is filled in case other positions become available.

In all cases in which you submit personal information over our websites, you may tell us that you do not want us to use this information to make further contact with you beyond fulfilling your requests, and we will respect your wishes. If you give us personal information about someone else, such as a spouse, a reference, or a work colleague, we will assume that you have that person’s permission to do so. In any case, we will only retain your personal data for as long as we have a legitimate and lawful reason to do so.

When you visit our websites, EPC may collect certain non-personal data by various means, one of which is “cookies.” Cookies tell website operators to recognize your computer when you revisit a site. Cookies help to improve the use of the website. Cookies also allow Web sites to analyze aggregate traffic on the site, in order to streamline navigation and keep the content fresh for all visitors. You can configure your browser to reject cookies. Cookies do not contain personal data, nor can they read or transmit any data on your computer’s hard drive. Regardless of cookies, all web-browsers transmit the IP address of the computer on which they are running. For most users accessing our websites from an Internet Service Provider (ISP), the IP address will be different every time you log on. IP addresses may be used for various purposes, including to: (1) diagnose service or technology problems reported by our users or engineers that are associated with the IP addresses controlled by a specific Web company or ISP, (2) develop the most appropriate advertising based on geographic area or information derived from IP addresses, (3) estimate the total number of users visiting EPC from specific countries or regions of the world, (4) assist EPC to track visits to our Web site, and (5) help determine which users have access privileges to certain EPC Web site content.

Personal Data We Collect from Customers and Suppliers
In order to carry out our business and to fulfill our contractual obligations, EPC must collect and process Personal Data of prospective and existing customers or suppliers. Examples of the types of Personal Data that EPC may collect from its customers, suppliers and other business contacts are:

• Name, title, address, email, and telephone number
• Proof of address such as copies of utility bills
• Copies of passports or other government issued identification
• Tax identification numbers
• Signatures on legal contracts
• Payment information
• Financial statements or other financial information

Why We Collect Personal Data
EPC only collects Personal Data for lawful purposes. These include:

• To provide customers with IT Asset Disposition products or services
• To facilitate the approval of transactions
• To obtain financing in connection with our products or services
• To respond to requests from the customer, financier, or supplier
• To detect or prevent fraud
• To assess or manage risk
• To perform internal audits
• To comply with anti-terrorism, anti-bribery, or anti-money laundering laws or other laws
• To comply with legal process, subpoenas, or other requests from government bodies
• As part of a sale, merger, acquisition, or similar change of control
• To ensure data security

Specific Rights regarding Personal Data of European Citizens
If you are a citizen of Europe residing within the European Economic Area, you may have the following rights under the General Data Protection Regulation:

• to be informed of this Policy and how EPC uses and processes your Personal Data;
• to request a copy of the Personal Data we have collected;
• to request that we correct any Personal Data that is inaccurate or incomplete;
• to request that we to delete or transfer to your possession such Personal Data for which we no longer have lawful reason to keep;
• to object to the processing of your Personal Data and to lodge a complaint with the relevant data protection authority.

Specific Rights regarding Personal Data of Residents of California
If you are a resident of the state of California you may have the following rights under the California Consumer Privacy Act “CCPA”:

• to be informed of your rights under the CCPA and how EPC uses and processes your Personal Data;
• to request a copy of the Personal Data we have collected;
• to request disclosure of Personal Data processed for a business purpose;
• to request that we delete or transfer to your possession such Personal Data for which we no longer have lawful reason to keep;
• and to be free of discrimination for exercising your rights under the CCPA.

Our Data Protection Principles:
EPC will treat your Personal Data as confidential. We respect your right to privacy. In all cases in which we collect your Personal Data according to this Policy, we will abide by the following principles:

• We will only collect your Personal Data with your full knowledge
• We will only collect and keep your Personal Data for a lawful purpose
• We will only keep that Personal Data which is necessary for the lawful purpose
• We will only keep your Personal Data for as long as the lawful purpose exists
• We will keep your Personal Data accurate to the extent it is reasonably practicable to do so
• We will store your Personal Data securely to prevent unauthorized or unnecessary disclosure
• We will process your Personal Data in accordance with your rights under the relevant data protection laws
• We will not transfer your Personal Data outside of its country of origin unless adequate protections are in place

Transfer or Sharing of Your Personal Data
Subject to the above Data Protection Principles and the terms of any valid and fully-executed non-disclosure agreement, EPC may transfer or share your personal data in the following circumstances:

1. Among our affiliates, including our sole shareholder, CSI Leasing, Inc. and it’s sole shareholder, Tokyo Century Corporation for the lawful purposes described in this Policy;
2. To third parties such as our banks, financiers, couriers and suppliers in order to deliver our services or to fulfill or enforce a contract;
3. To our attorneys, auditors, IT professionals or other third party service providers for the lawful purposes described in this Policy;
4. To government, regulatory, judicial or law enforcement bodies in response to official requests.

EPC may also utilize cloud based customer relationship management or IT service providers to store and process personal data. In all cases EPC will take reasonable steps to ensure that adequate technical and organizational measures are in place so that the transfer and storage of your personal data is secure from unauthorized disclosure, alteration or deletion.
EPC does not sell, rent, or share Personal Data we collect directly from you or about you from third parties with third party Advertisers for their own marketing purposes.

Case Studies
EPC websites may contain “case studies” describing scenarios when EPC customers benefited from EPC’s services and expertise. Because no two customers are alike, these case studies should only serve as examples of other customers’ experiences, and thus may differ from your experience.

Anti-Spam Policy
EPC does not tolerate spam and is committed to proper Web practices and full compliance with the CANSPAM Act of 2003 (15 U.S.C. §7701.) We do not sell or rent e-mail addresses to any unauthorized third party. This does not mean that we can prevent all spam from happening on the internet. If you believe that you have received an unsolicited e-mail from us, please contact EPC at privacy@epcusa.com and we will investigate.

Children
EPC websites are not intended for visitors under 18 years of age. We do not knowingly solicit or collect personal data from or about children, nor do we knowingly market our products or services to children.

Notices and Revisions
EPC may revise this privacy policy from time to time. You should periodically check the revision date at the top of this Web page to learn of any revisions.

Contact EPC, Inc.
To “opt out” or make other choices about your Personal Data or to exercise your rights, please email privacy@epcusa.com.