8.Other

8.1Cookie policy

Last Modified :2023/7/1

This Cookie Policy (Policy) provides you with information about the use of technologies that store or access information on your device like cookies, pixels, and plugins by i-PRO Co., Ltd, 2-15-1 Konan, Minato-ku, Tokyo, Japan (referred to as “we”, “us” or “i-PRO”) and certain permitted third parties that provide content, advertising, or other functionalities when you visit our website. For convenience these technologies are all referred to as “cookies”.

This Policy explains what cookies are, which types of cookies we use and what our legal bases are. It also provides you with information on how your personal data (if any) is used, what your rights in relation to cookies are under the EU General Data Protection Regulation (GDPR) and how you can contact us if want to exercise your rights or have a complaint. This Policy lists which cookies are placed and used, for which purposes and for how long these cookies last. In addition, this Policy describes how you can manage and delete cookies.

Please click on the links below for further information on our privacy practices:

1. What are cookies?
2. Which types of cookies do we use and what are our legal bases?
3. How do we and certain permitted third parties use cookies and process your personal data and what are your rights?
4. Which cookies are placed and used by whom, for which purposes and how long do they last?
5. How can you manage and delete cookies?
6. Contact us
7. Changes to this Policy

8.1.1What are cookies?

Cookies are small text files which are stored on your device when you visit our website and act as an identifier. They allow our website to recognize your device when it interacts with and returns to our website, particularly when you are using the same browser as you did when you last visited our website.
Depending on their function and purpose cookies are classified as essential, performance, functional and advertising cookies.
For more information on this, please see section 8.1.2.

In addition, cookies are classified either as first party or as third party cookies. First party cookies are placed by us whereas third party cookies are placed by a third party website while you are visiting our website. For more information about the relevant third parties please see section 8.1.4.

Cookies can be either session or persistent cookies depending on their duration. Session cookies are temporary cookies that last only for the duration of your visit to our website and are deleted when you close your browser. In contrast, persistent cookies are created upon your visit to our website and remain on your device after you close your browser or restart your device until their set expiry date unless you delete them before the expiry date; they are active when you return to our website.

8.1.2Which types of cookies do we use and what is our legal basis?

We use the following categories of cookies on our website:

8.1.2.1Essential cookies

These cookies are essential to make our website work or to provide necessary functions relating to the services you request or to enable communications. They allow us to provide you with a seamless internet experience. We also use them for security purposes.

8.1.2.2Performance cookies

These cookies analyze, how you use our website to improve the way our website works for you and for others visitors to our website. They enable us (and our third party service providers) to recognize and count the visitors and see how visitors move around our website when they are using it. We use them to understand which pages are popular with visitors. This helps us to improve how our website works by, for example, ensuring that you can easily find what you are looking for and to overall enhance visitors’ experience on our website.

8.1.2.3Our legal bases

We rely on our legitimate interests for processing personal data collected through our first-party essential cookies. These cookies are strictly necessary for our website to work and allow us to provide the visitors to our website with the services they request, to enable communications, or to comply with security obligations under the applicable data protection law.
All other non-essential cookies will only be used with your consent.

8.1.3How do we and certain permitted third parties use cookies and process your personal data and what are your rights?

8.1.3.1Cookies owned and placed by i-PRO

To the extent that our first-party cookies and the data we collect with them, qualify as personal data we determine the means and purposes of such processing and are the data controller as defined in the GDPR. Such processing takes place in accordance with our online Privacy Notice that applies in addition to this Cookie Policy. We encourage you to read our Privacy Notice where you can find more about e.g.:
- how we use and protect your personal data collected through cookies (if any);
- your data protection rights; if you are based in the EU/EEA these include the right to access your personal data and obtain a copy thereof, the right to request the correction or update of any inaccurate personal data, the right to object to or restrict the processing of your personal data under the conditions set out in the GDPR and the right to request the erasure of your personal data under certain conditions;
- if you are based in the EU/EEA how you can file a complaint with the competent supervisory authority, https://edpb.europa.eu/about-edpb/board/members_en;
- how long will we store/keep your personal data;
- to whom and where we disclose your personal data; and
- the existence of automated decision-making and, where this is the case, useful information on the underlying logic and the importance and consequences of the processing.

8.1.3.2Cookies owned and installed by authorized third parties

On our website we have integrated links to third party websites, plug-ins and applications e.g. for marketing purposes and, for example, to allow you to easily share content in social media networks. We have no control over these third party websites’ use of those cookies and refer to their Privacy Policies for further information on how they use these cookies. For more information on the third parties please see section 8.1.4.

8.1.4Which cookies are placed and used by whom, for which purposes and how long do they last?

The following table lists all cookies in use on our website. We will update this table as our website changes and evolves.

8.1.4.1Essential cookies


Cookie	Purpose	Placed by	Used by	Data collected and purpose of collection	Duration
Session ID	Managing Session Information	We	We	For managing sessions to access the Services	Session
Session data	Managing Session Information	We	We	For managing sessions to access the Services	Session
Session Expiration	Managing Session Information	We	We	For managing sessions to access the Services	Session
Consent to use cookies	Cookie consent	We	We	It is used to manage the status of consent to the use of cookies	1 year
Cookie settings	Setting cookies	We	We	This cookie keeps track on if the end user agreed to use category of cookies on this site.	1 year

8.1.4.2Performance cookies


Cookie	Purpose	Placed by	Used by	Data collected and purpose of collection	Duration
_ga	Website usage analysis	Google	We	To analyze the usage status of this service and improve the service	2 years
_ga_QHKY9WZV3Z	Website usage analysis	Google	We	To analyze the usage status of this service and improve the service	2 years
_gid	Website usage analysis	Google	We	To analyze the usage status of this service and improve the service	1 day

8.1.5How can you manage and delete cookies?

8.1.5.1. Except for essential cookies you can change your preferences and withdraw your cookie consent at any time by navigating to “Cookie settings”.

8.1.5.2. You can manage and delete non-essential cookies by changing your browser settings. The methods for doing so vary from browser to browser. Please bear in mind that if you block all cookies some features and services on our website might not be delivered to you and you will be served with advertising less tailored to your interests.

You can obtain information on how to manage and how to delete cookies for the most popular browsers by following these links:
- Chrome : https://support.google.com/chrome/answer/95647?hl=en
- Edge : https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09

For further information on how to manage and delete cookies, please visit https://www.allaboutcookies.org/

8.1.6Contacts us

If you have any questions about how we as the controller of your personal data (if any) use cookies on our website or would like to exercise your rights, you can contact us at 2-15-1 Konan, Minato-ku, Tokyo, Japan.

8.1.7Changes to this policy

We may from time to time make changes to this Policy which was first published on July 1st, 2023. Changes to this Policy will be published on our website and will be effective as of the date of publication. This Policy was last updated in July 1st, 2023.
If the changes materially alter how we use cookies, we will post a notice on our website and request your consent again for the use of cookies. Please check back frequently to any updates or changes to our Cookie Policy.

8.2Privacy Notice

This Privacy Notice is intended to tell you how we use any information we collect about you (called Personal Data as defined below) and what your rights and our obligations are in relation to the processing of your Personal Data, in accordance with the General Data Protection Regulation (the "GDPR").

This Privacy Notice applies to the use of our Remote Monitoring (collectively, our "Services") and will apply whether you access our Services using a computer, mobile phone, tablet, TV or other devices.

If you are a California resident, additional privacy notice applies to you, in accordance with the California Privacy Rights Act. Please see CPRA Appendix.

Please click on the links below for further information on our privacy practices:

1. Who are we?
2. What is Personal Data?
3. What Personal Data do we collect about you?
4. On which legal basis do we process Personal Data?
5. Why do we use your Personal Data?
6. To whom and where do we disclose your Personal Data?
7. What do we do to keep your Personal Data secure?
8. What are your rights and how can you exercise them?
9. How long do we store your Personal Data?
10. Third-party links and products on our Services
11. Cookies
12. Changes to this Privacy Notice
13. Representative

1. Who are we?

I. i-PRO Co., Ltd. Shinagawa Intercity A Tower 14F, 2-15-1 Konan, Minato-ku, Tokyo, Japan is responsible for the processing of your Personal Data acting as controller ("i-PRO", "we", "us" or "our");

II. We are part of the i-PRO Company, headquartered in Tokyo, Japan;

2. What is Personal Data?

For the purposes of this Privacy Notice, "Personal Data" consists of any information that relates to an identified individual (such as you).
For example, information which identifies you may consist of your name, address, telephone number, photographs, payment details, a specific i-PRO product/device identification number that you purchased, location data, an online identifier (e.g. cookies and your IP address).
Information which does not identify you on its own but that we link to you also qualifies as Personal Data.

3. What Personal Data do we collect about you and how?

Personal Data you provide directly about yourself.
Some Services we offer enable/require you to directly provide us with Personal Data relating to you.

Essential cookies

I. These cookies are essential to make our website work or to provide necessary functions relating to the services you request or to enable communications.

They allow us to provide you with a seamless internet experience.
We also use them for security purposes.

Performance cookies

I. These cookies analyze, how you use our website to improve the way our website works for you and for others visitors to our website. They enable us (and our third party service providers) to recognize and count the visitors and see how visitors move around our website when they are using it. We use them to understand which pages are popular with visitors. This helps us to improve how our website works by, for example, ensuring that you can easily find what you are looking for and to overall enhance visitors’ experience on our website.

Account Information

I. When you create a i-PRO account or profile for our websites.
When you create an account or profile for a i-PRO website, we ask you to provide certain Personal Data, including your name, country, industry and email address. You will use your email address and your password to login to your account/profile.

4. On Which legal basis do we process Personal Data?

Essential cookies

I. We rely on our legitimate interests for processing personal data collected through our first-party essential cookies.

Performance cookies

I. Performance cookies will only be used with your consent.

Account Information

I. We will only process your Personal Data when: the processing is necessary to perform our contractual obligations towards you or to take pre-contractual steps at your request;

5. Why do we use your Personal Data?

We may use the Personal Data we collect for the following purposes:

Essential cookies

I. To make our website work or to provide necessary functions relating to the services you request or to enable communications.
They allow us to provide you with a seamless internet experience. We also use them for security purposes.

Performance cookies

I. These cookies analyze, how you use our website to improve the way our website works for you and for others visitors to our website. They enable us (and our third party service providers) to recognize and count the visitors and see how visitors move around our website when they are using it. We use them to understand which pages are popular with visitors. This helps us to improve how our website works by, for example, ensuring that you can easily find what you are looking for and to overall enhance visitors’ experience on our website.

Account information

I. Create an Account/Log in on our Websites – to enable you to create a profile on our websites, and to enable you to log in to such websites;
II. Provide our Services – to provide our Services or any specific feature that you may request, including to enable us to fulfil our obligations under any contract with you (such as any product or device warranty);
III. Legal Obligations – to comply with our legal obligations under European Member States laws or under European Union law;
IV. Security – to protect our customers (e.g. to prevent spam or attempts to defraud users of our Services); to operate and maintain the security of our Services (e.g. to prevent or stop an attack on our systems or networks); or to protect the rights or property of i-PRO, including enforcing any terms or agreements governing the use of our Services;
V. Updates – to communicate with you, including communicating with you about your account, profiles or transactions with us, giving you important information about your products, devices, application or other Services, sending you notices about any material changes to our Privacy Notice;
VI. Corporate Transaction – to manage corporate transactions involving our company, including reorganization, merger, transfer, sale, joint venture, assignment or other disposition of all or any portion of i-PRO's business, assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding.

6. To whom and where do we disclose your Personal Data?

A. Third parties recipient of the Personal Data
We may disclose your information to the following entities:

I. i-PRO Affiliates
We may need to transfer your Personal Data to other i-PRO Affiliates to provide the Services you require or any other
services/assistance.
All i-PRO Affiliates are required to follow the privacy practices set forth in this Privacy Notice.
II. Selected Partners
We may share your Personal Data with our business partners.These partners may use your Personal Data to provide you
with i-PRO Services you request.
III. Service Providers
We use third party service providers to help us to administer certain activities and services on our behalf, such as
analyzing usage of our Services.
We share Personal Data about you with such third party service providers solely for the purpose of enabling them to
perform services on our behalf and they will operate only in accordance with our instructions.
IV. Third parties when required by Law or to Protect our Services
We will disclose your Personal Data to comply with applicable Member State or European Union law or respond to valid
legal process, including from law enforcement or other government agencies.
V. Other Parties in Connection with Corporate Transactions
We may disclose your Personal Data to a third party (or other i-PRO Affiliate) as part of a reorganization, merger,
transfer, sale, joint venture, assignment or other disposition of all or any portion of i-PRO’s business, assets or
stock, including, without limitation, in connection with any bankruptcy or similar proceeding.

B. International transfer of Personal Data
The Personal Data that we collect from you may be stored and processed in your region, or transferred to, stored at or
otherwise processed outside the European Economic Area ("EEA"), including but not limited to Japan or in any other
country which do not offer an adequate level of data protection as recognised by the European Commission and where i-PRO
or its Affiliates, subsidiaries or service providers maintain facilities
Where we transfer your Personal Data outside the EEA, we will ensure that suitable safeguards such as appropriate
transfer agreements and mechanisms (such as the EU Model Clauses) are in place to help ensure that our third party
service providers provide an adequate level of protection to your Personal Data. You may request additional information
in this respect and obtain a copy of the relevant safeguards upon request through sending a request to the contact
indicated in section 8 below.

7. What do we do to keep your Personal Data secure?

A. General
i-PRO has put in place appropriate technical and organisational measures to safeguard the Personal Data we collect in
connection with our Services.
These measures take into account:

I. the state of the art of the technology;

II. the costs of its implementation;
III. the nature of the data; and
IV. the risk of the processing.

The purpose thereof is to protect against accidental or unlawful destruction or alteration, accidental loss,
unauthorized disclosure or access and against other unlawful forms of processing.

However, please note that although we take appropriate steps to protect your Personal Data, no website, product, device,
online application or transmission of data, computer system or wireless connection is completely secure and therefore we
cannot guarantee the security of your Personal Data.

B. Encryption
All Personal Data you provide to us is stored on our secure servers. Where we have given you (or where you have chosen)
a password that enables you to access certain Services, you are responsible for keeping this password confidential and
we ask you not to share your password with anyone.

C. Other security measures
Information security, including the protection of Personal Data is organized in a global i-PRO Program called
"Information Security Management" (ISM).
The related aim, standards and implementation measures are organized in globally valid policy, standards and guidelines.
All central European IT systems are externally assessed and fall under the information security management rules
applicable under the ISO 27001 certification.
The program in all its parts follow a strong yearly PDCA (Plan-Do-Check-Act) approach to secure the confidentiality,
integrity and availability of all data (including your Personal Data) for the whole information lifecycle from
collection to destruction of such data.

8. What are your rights and how can you exercise them?

A. What are your rights?
i-PRO will collect, store and process your Personal Data in accordance with your rights under any applicable data
protection laws.
Your rights under the GDPR include, the right to access a copy of your Personal Data, the right to request the
correction or the update of any inaccurate Personal Data and the right to object to the processing of your Personal
Data under the conditions set out in the GDPR.
You also have the right to request the erasure of your Personal Data and, where you have consented to the processing of
your Personal Data, you have the right to withdraw such consent at any time (without this withdrawal affecting the
lawfulness of the processing prior to such withdrawal).
In addition, you also have the right to data portability in certain cases.
This is the right to request the return of the Personal Data you have provided to us in a structured, commonly used and
machine-readable format and to request the transmission of such Personal Data to a third party, without hindrance from
us and subject to your own confidentiality obligations.
B. Exercising your rights
If you wish to exercise any of the above rights, please contact us by using any of the communication means below.
When doing so, please provide us with a proof of your identity for identification purpose.
By mail:
Shinagawa Intercity A Tower 14F, 2-15-1 Konan, Minato-ku, Tokyo, Japan
We will respond to your request without undue delay and no later than one month from receipt of any such request,
unless a longer period is permitted by applicable data protection laws.
C. Complaints
If you are not satisfied with how we process your Personal Data, you may also file a complaint with the competent
supervisory authority, in addition to your rights outlined above.
EEA/EU authorities: Members | European Data Protection Board (europa.eu)
https://edpb.europa.eu/about-edpb/board/members_en

United Kingdom (UK): Make a complaint | ICO
https://ico.org.uk/make-a-complaint/

9. How long do we store your Personal Data?

We will retain your Personal Data for the period necessary to fulfil the purposes for which your Personal Data has been collected as outlined in this Privacy Notice unless a longer retention period is required by law.

When your Personal Data is no longer required for the purpose it was collected or as required by applicable law, it will be deleted and/or returned to you in accordance with applicable law.

10. Third-party links and products on our Services

Our websites, applications and products may contain links to other third party websites that are not operated by i-PRO, and our websites or your products and devices may contain applications that you can download from third parties.

These linked sites and applications are not under i-PRO’s control and as such, we are not responsible for the privacy practices or the content of any linked websites and online applications.

If you choose to use any third party websites or applications, any Personal Data collected by the third party’s website or application will be subject to any existing privacy policy of that third party.

We strongly recommend that you take the time to review the privacy policies of any third parties to which you provide Personal Data.

11. Cookies

A. What are Cookies?
i-PRO, as well as certain other third parties that provide content, advertising, or other functionality on our
Services, may use cookies and other technologies in certain areas of our Services.
Cookies are small text files which may be placed on your device when visiting our website.
It can be read by the web server which put the cookie on your hard drive.
We may use cookies to store your preferences and settings, help you with signing in, provide targeted advertisement and
to analyse your browsing experience on our website.
Please note that you can modify your browser so that it notifies you when cookies are sent to it.
If you do not want to receive cookies, you may also refuse cookies altogether by activating the relevant settings on
your browser.
Please note that if you choose to refuse all the cookies, some features of the Services may not be accessible to you or
not work properly.
Finally, you can also delete cookies that have already been sent.
B. Further information on cookies
For further information on cookies and how i-PRO and other third parties use them, and for details of how cookies can
be disabled, please see our Cookie Policy.

12. Changes to this Privacy Notice

i-PRO may change this Privacy Notice from time to time. The "Date last updated" mention at the bottom of this page states when the notice was last updated and any changes will become effective upon our posting of the revised Privacy Notice.
Where required by applicable law, we will request your consent to any such changes.
We will provide this notice by email or by posting notice of the changes on the i-PRO website or through any relevant Services.

13. Representative

If you have questions about Data Protection in Europe, please contact us at:

i-PRO EMEA B.V.
Laarderhoogtweg 25, 1101 EB, Amsterdam, The Netherlands

data_protection.eu@i-pro.com

If you have any questions about Data Protection in the United Kingdom (UK), please contact us at:
i-PRO EMEA B.V. - UK Branche
1010 Cambourne Business Park, Cambridgeshire CB23 6DP, Cambridge

uklegal@i-pro.com

Date last updated: 1, January 2023

CPRA Appendix

Date last updated: 1, January 2023

This CPRA Appendix complements Privacy Notice and tells you what your rights and our obligations are in relation to the processing of your Personal Data in accordance with the California Privacy Rights Act (the “CPRA”). If there is any discrepancy between the terms of this CPRA Appendix and those of Privacy Notice, this CPRA Appendix will prevail.

We may change this CPRA Appendix from time to time. The “Date last updated” mention at the top of this page states when the CPRA Appendix was last updated and any changes will become effective upon our posting of the revised CPRA Appendix to the extent permitted by applicable laws. Where required by the CPRA or other applicable law, we will request your consent to any such changes. We will provide the revised CPRA Appendix by email or by posting notice of the changes on our website or through any relevant Services.

Please click on the links below for further information on our privacy practices for residents in California:

1. What is Personal Data?
2. What Personal Data did we collect about you in the preceding 12 months?
3. On which legal basis do we process Personal Data?
4. What are your rights and how can you exercise them?
5. Disclosure of Personal Data
6. Sale of Personal Data
7. Share of Personal Data
8. Children's Personal Data
9. Contact Information

1. What is Personal Data?

For the purposes of this CPRA Appendix, "Personal Data" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. For example, Personal Data includes, but is not limited to, audio, electronic, visual, thermal, olfactory, or similar information or inferences drawn from other Personal Data to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends among other things.

2. What Personal Data did we collect about you in the preceding 12 months?


Categories of Personal Data collected	Categories of sources	Categories of sources Business or commercial purpose(s) for collecting Personal Data	Retention duration
Essential cookies	Direct collection	Business	Until end of service
Performance cookies	Direct collection	Business	Until end of service
Account information	Direct collection	Business	Until end of service

3. On which legal basis do we process Personal Data?

We process Personal Data of residents in California in compliance with the CPRA. If we are to use your Personal Data for purposes other than the purposes we notified on or before collecting your Personal Data, we will notify the new purposes to you and obtain your express consent.

4. What are your rights and how can you exercise them?

A. What are your rights?

(1) Your rights under the CPRA include, the right to know about your Personal Data that we collect, use, disclose the

right to request the deletion of your Personal Data, and the right to limit the use of your Sensitive Personal
Data, and the right to request the corrections to your Personal Data.

(2) We will not unreasonably discriminate against you for exercising the rights such as the right to know about

Personal Data information under the CPRA by using methods including but not limited to the following:

I. Denying to provide goods or services to you

II. Charging different prices or rates for goods or services, including through the use of discounts or other
benefits or imposing penalties
III. Providing a different level or quality of goods or services to you
IV. Suggesting that you will receive a different price or rate for goods or services or a different level or
quality of goods or services

B. Exercising your rights (right to know and right to request the deletion of your Personal Data)

If you wish to exercise the right to know or the right to request the deletion of your Personal Data, and
the right to limit the use of your Sensitive Personal Data, and the right to request corrections to your Personal Data
under the rights of A. (1) above, please contact us by using the following means in addition to the communication means
described in Privacy Notice. Upon receiving your request to exercise such rights, we will require you to submit your
[name and e-mail address] in order to verify your identity.

I. By online request form

https://i-pro.com/us/en/surveillance/contact-us/

We will confirm receipt of your requests to exercise your rights within 10 business days in the same manner in which the request was received and provide information about how we will process the request and the limit of our response. We will respond to requests to know and requests to delete within 45 days, and if we exceed the period, we will notify you and respond within 90 days from the day that we receive the requests. If we cannot verify your requests within the 45-day time period, we may not process your requests.

We will record your requests and store them for 24 months.

If you use an authorized agent to submit a request to know or a request to delete, the authorized agent is required to submit to us a written permission proving the authorized agent is permitted to do so and the authorized agent’s own identity verification document(s).

5. Disclosure of Personal Data

We have not and will not disclose your Personal Data to any third party for a business purpose.

6. Sale of Personal Data

We have not and will not sell your Personal Data to any third party.

For the purposes of this CPRA Appendix, “sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, your Personal Data by us to another business or a third party for monetary or other valuable consideration.

7. Share of Personal Data

We have not and will not share your Personal Data to any third party.

For the purposes of this CPRA Appendix, “share" means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, your Personal Data by us to another business or a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

8. Children's Personal Data

We do not sell Personal Data of anyone under the age of 16.

9. Contact Information

You may contact us with questions or concerns about this CPRA Appendix and your choices and rights under CPRA at:

Company name: i-PRO CO., Ltd

Company address: Shinagawa Intercity A Tower 14F, 2-15-1 Konan, Minato-ku, Tokyo, Japan