Xerox Privacy Policy

DATED 2018-05-01 · VERSION 20180712_rev01 · COMPARED WITH 20170617_rev01 · ARCHIVE SNAPSHOT

Full text changes — 20170617_rev01 to 20180712_rev01

COLOUR MARKS THE SEVERITY OF A FLAGGED CLAUSE · + AND − MARK ADDED AND REMOVED

+## Xerox Online Privacy Policy
 ## Introduction
+**This is the Online Privacy Policy of Xerox Corporation in the United States.**
+This privacy statement covers the websites and applications of Xerox Corporation ("Xerox" or "we") that include a link to this statement. This privacy statement also applies to Xerox's marketing and advertising practices where and when it is referenced. It is meant to inform you about our collection and use of your personal data.
+This privacy policy covers the websites belonging to Xerox Corporation ("Xerox" or "we") in the United States. It does not cover the websites of Xerox subsidiaries or affiliates who publish their own policies.
+## Personal Data We Collect
+At Xerox, privacy on the Internet means that:
+You may choose to give us personal data to allow us to communicate with you, process your orders, provide you with services, or for employment consideration. Data we collect depends on the context of your interactions with Xerox, the choices you make, including your privacy settings, and the products and features you choose. The personal data we collect can include the following:
+- Xerox informs its website users ("you") how it uses personally identifiable information that is collected online;
+- Xerox maintains confidentiality and security safeguards for personally identifiable information;
+- You have control over personally identifiable information you decide to submit to Xerox; and
+- You can opt-out of receiving commercial email from Xerox at any time.
+**Name and Contact Data**. Your first and last name, email address, postal address, phone number and other similar contact data in order to communicate with you, process orders or provide you with products or services. We may also collect your employer name, if you are procuring products or services on behalf of an organization, and information related to your prior purchases and online buying preferences. Some forms may ask for your customer number or product details such as a serial number.
+Xerox maintains the information it receives online in strict confidence; information you submit to Xerox is not sold to or shared with third parties, except our subsidiaries, affiliates, agents and partners as described in this policy.
+**Credentials**. Passwords, password hints and similar security information used for authentication and account access.
+Xerox reserves the right to notify you about administrative matters that pertain to your Xerox products or services. We may disclose your personally identifiable information, as required by law or regulation, in connection with law enforcement, fraud prevention, or other legal action; or if Xerox reasonably believes it is necessary to protect Xerox, our customers, or the public. Although we do not currently anticipate a change in our corporate status, in the event of a merger or acquisition of the company or a substantial portion of its assets, Xerox may disclose, transfer or sell personal information collected online to the surviving or acquiring party, respectively. Personal information collected online will remain subject to promises made in this Online Privacy Policy.
+**Demographic Data**. Data about you such as your country of residence and preferred language.
+If you would like to contact Xerox without submitting personally identifiable information online, you can reach a Xerox representative by calling 1-800-ASK-XEROX.
+**Payment Data**. Data necessary to process your payment if you make purchases, such as your credit card number and the security code associated with your payment card.
+## Certifications
+**Location Data**. We may collect data about your location, which can be either precise or imprecise. Precise location data can be Global Navigation Satellite System (GNSS) data (e.g. GPS), as well as data identifying nearby cell towers and Wi-Fi hotspots, that we collect when you enable location-based products or features. Imprecise location data includes, for example, a location derived from your device or data that indicates where you are located with less precision, such as a city or postal code.
+**Xerox is authorized to display the BBB Accredited Business Seal.**
+**Social Media Data.** We may provide social media features that enable you to share information with your social networks. Your use of these features may result in the collection or sharing of information about you by the social networking site. Please review the privacy policies and settings of social networks you use to understand their practices.
+The BBB Accredited Business Seal reflects our adherence to the BBB's Code of Business Practices.
+**Job Applications/CVs/Resumes**. Information on job applications/CVs/resumes which you provide to us if you submit a job application to Xerox either directly or indirectly. You acknowledge that your application may include sensitive personal data. Xerox uses this information in order to evaluate your application and perform related employment activities.
+**Privacy Complaints.**
+**Feedback and Product Reviews.** Information you provide to us and the content of messages you send to us, such as feedback and product reviews you write, blog posts or questions and information you provide for customer support. When you contact us via our website, a Xerox application or a Help Desk, such as for customer support, phone conversations or chat sessions with our representatives may be monitored and recorded. Your feedback, posts and reviews will be used to seek improvements in our products and services.
+Xerox commits to resolve complaints about your privacy and our collection or use of your personal information. Inquiries or concerns regarding this privacy policy should be directed to the Xerox Business Ethics and Compliance Office.
+**Website Browsing.** Information about your visits to our websites and your browsing patters. This may include data about your device, including Internet Protocol (IP) address, browser type, and regional and language settings. This is more fully described under the section entitled "Cookies, Web Beacons and Privacy Choices" below. We collect this information to determine such things as the number of visitors to various parts of our websites, to personalize your experience on our sites, and tailor our interactions with you.
+To report your inquiries or concerns to the Business Ethics and Compliance Office please contact the Xerox Ethics Helpline. The Xerox Ethics Helpline is confidential and anonymous, if you so desire, and is available online and via a toll-free number listed below.
+**Products.** Certain Xerox products collect data, such as product registration, meter reads, supply levels, equipment configuration and settings, software version, and fault codes. Xerox uses this information for product improvement, billing, report generation, supplies replenishment and support services.
+- Web Reporting: [www.xeroxethicshelpline.com](http://www.xeroxethicshelpline.com/)
+- US & Canada Toll-Free Number: 1-866-979-0001
+- [Direct Dial Toll-Free Numbers Outside US & Canada](http://www.xerox.com/downloads/usa/en/h/HowtoContacttheXeroxEthicsHelpline.pdf) available at [www.xerox.com/ethics](http://www.xerox.com/about-xerox/citizenship/ethics/enus.html)
+**Third Party Sources**. We also obtain data from third-parties. These third-party sources vary over time, but they are sources deemed credible by us and may be publicly available or available on a commercial basis. They can include:
+You may also contact us via postal mail at:
+- Data brokers from which we purchase demographic data to supplement the data we collect;
+- Social networks when you grant permission to a Xerox product to access your data on one or more networks;
+- Designated entities within your business or enterprise (such as a member of your IT department) in the course of providing services to you;
+- Partners with whom we offer branded services or engage in joint marketing activities. If you purchase Xerox services or products from a Xerox partner we may receive certain information about your purchase from that partner;
+- Fraud prevention agencies or credit reporting agencies in connection with credit determinations; and
+- Publicly available sources such as open government databases or other data in the public domain.
+Xerox Corporation
+Xerox Business Ethics and Compliance
+Merritt 7
+Norwalk, CT 06851-1056
+USA
+## How We Use Personal Data
+## Collection of Personally Identifiable Information
+We collect and process personal data with your consent, as required by law, or as necessary to fulfill the legitimate interests of Xerox, including to: (i) provide you with products and services; (ii) manage, administer and operate our business; (iii) meet our contractual and legal obligations; (iv) carry out direct marketing; (v) prevent fraud; and (vi) protect the security of our systems and our customers.
+You may choose to give us personally identifiable information online to allow us to communicate with you, process your orders, or provide you with services. Our online forms ask for a small amount of relevant information, such as name, email, street address, and phone number. Some forms may ask for your customer number or product serial number. If you make a purchase, we may ask for your credit card number and billing information. Job applicants may be requested to provide information such as educational background, employment experience, and job interest.
+Personal data that is submitted in a business capacity may be merged with available business database directories. Xerox uses personal data to:
+We may also collect information about your visits to our websites, including your Internet Protocol (IP) address, browser type and language, location information and details of your browsing patterns. This is more fully described under the section entitled "Cookies, Web Beacons and AdChoices" below. We collect this information to determine such things as the number of visitors to various parts of our websites and to personalize your experience on our sites, and tailor our interactions with you.
+- respond to your questions and communicate with you;
+- provide customer support;
+- share news, updates, or helpful tips about Xerox products and services;
+- enable online shopping;
+- inform you of special promotions and other advertising;
+- allow you to sign up for online services;
+- create reseller partnerships;
+- receive and evaluate job applications;
+- customize, analyze, and improve our products, services, technologies, communications and relationships with you;
+- deliver products and services requested by you;
+- notify you about administrative matters that pertain to your Xerox products or services; and
+- in the event of a merger or acquisition of Xerox or a substantial portion of its assets, disclose or transfer personal data to the surviving or acquiring party, respectively.
+If you do not want to give personally identifiable information to Xerox online you may communicate with us through the postal addresses or the phone or fax numbers that we also provide on our websites or in this policy. Xerox does not direct any part of its website to children under 13 years old and does not knowingly collect personally identifiable information from children.
+We share your personal data as necessary to complete a transaction or provide a product or service you have requested or authorised. For example, when you provide payment data to make a purchase, we will share your payment data with banks and other entities that process payment transactions or provide other financial services, and for fraud prevention and credit risk reduction.
+Personally identifiable information that is submitted in a business capacity may be merged with available business data base directories.
+We share personal data among Xerox affiliates and subsidiaries to efficiently manage the operation of our business. We also share personal data with vendors or agents working on our behalf for the purposes described in this statement or in our contracts with you. For example, companies we've hired to provide customer service support or assist in maintaining and servicing products via our systems and services may need access to personal data to provide those functions. In such cases, these companies are required by contract to abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. We may also disclose personal data as part of a corporate transaction such as a merger or sale of assets.
+Personally identifiable information collected may be stored and processed in the United States or any other country in which Xerox or its subsidiaries, affiliates, agents or partners maintain facilities, and by using this website, you consent to any such transfer of information outside of your country.
+Finally, we will transfer or disclose personal data when we have a good faith belief that doing so is necessary to:
+## Why Does Xerox Collect Personally Identifiable Information?
+- Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies;
+- Protect our customers, for example to prevent attempts to defraud users of our products, or to help prevent the loss of life or serious injury of anyone; or
+- Operate and maintain the security of our products, including to prevent or stop an attack on our computer systems or networks.
+Xerox uses personally identifiable information submitted online to:
+## Where We Process and Store Personal Data
+- respond to your questions;
+- provide customer support;
+- share news, updates, or helpful tips about Xerox products and services;
+- enable online shopping;
+- inform you of special promotions;
+- sign up for online services;
+- create reseller partnerships;
+- evaluate job applications;
+- customize, analyze, and improve our products, services, technologies, communications and relationships with you; and
+- deliver products and services requested by you.
+Personal data collected by Xerox may be transferred to, stored and processed in your region, the United States, or any other country in which Xerox or its subsidiaries, affiliates, sub-contractors, agents or partners maintain facilities. Our subsidiaries, affiliates, sub-contractors, agents and partners are required by contract to safeguard any personal data they receive from us and are prohibited from using the personal data for any purpose other than to perform the services as instructed by Xerox. We also take steps to provide adequate protection for any transfers of your personal data in accordance with applicable law.
+**Communication Preferences.**
+Our privacy guidelines are communicated to Xerox employees on an annual basis as part of our mandatory training program. We take steps to ensure that the data we collect under this privacy statement is processed according to the provisions of this statement and the requirements of applicable law wherever the data is located. Sometimes we transfer personal data from the European Economic Area and Switzerland to other countries. When we do, we use a variety of legal mechanisms, including contracts, to help ensure any required rights and protections apply to your data.
+Xerox may send commercial email to you advertising our products and services. You can also subscribe to various product and service-specific communications on our websites. If you receive commercial email from Xerox and wish to discontinue these mailings, you may unsubscribe at [www.xerox.com/unsubscribe](http://www.xerox.com/perl-bin/formeng.pl). You may also mail an unsubscribe request to:
+## Period of Storage
+Marketing Privacy Preferences
+Xerox Corporation
+Xerox Square 16th Floor
+Clinton Avenue South
+Rochester, NY
+-1801
+Xerox retains personal data for as long as necessary to provide the products and fulfill the services and transactions you have requested or for other essential purposes such as complying with our legal obligations, resolving disputes and enforcing our agreements. Actual retention periods can vary. The criteria used to determine the retention periods include: (i) how long personal data is needed to provide our products or operate our business; (ii) whether the personal data is of a sensitive type; and (iii) whether Xerox is subject to a legal, contractual or similar obligation to retain the data.
+This unsubscribe option does not apply to communications primarily for the purpose of administering order completion, contracts, support, product safety warnings, software updates, or other administrative and transactional notices, the primary purpose of which is not promotional in nature.
+## Your Rights Regarding Personal Data
+## Security of Personally Identifiable Information
+You have choices about the data we collect. When you are asked to provide personal data, you may decline. However if you choose not to provide data that is necessary to provide a product or feature, you may not be able to use that product or feature.
+**Xerox maintains strict access control over personally identifiable information.**
+- If the processing of personal data is based on your consent, you have a right to withdraw consent at any time for future processing;
+- Where applicable, you have a right to request from us, (i) access to and receipt of personal data, (ii) transfer of personal data, and (iii) rectification or deletion of your personal data;
+- You may also have a right to object to or restrict the processing of your personal data;
+- You have the right to object to direct marketing; and
+- You have a right to file a complaint with a regulator or data protection authority.
+Only authorized Xerox personnel, and those of our subsidiaries, affiliates, agents, and partners are allowed to handle information submitted to Xerox online.
+You may contact Xerox to check the accuracy of your personal data or to request that your information be updated or deleted by writing to ethics@xerox.com. Please indicate "Access" in the subject line and let us know the details of your request in the body of the message. You may also contact us at the Xerox Ethics Helpline at 1-866-XRX-0001. Xerox reserves the right to confirm your identity and to modify the scope and number of requests. In certain cases, your request may be denied on the basis of a legitimate exception or where we are legally prevented from honoring such request.
+Xerox's websites store personally identifiable information in password-protected environments on servers that are located in the United States. These servers are subject to Xerox's information security policies, standards, and procedures.
+## Children
+**Credit card data is encrypted.**
+Xerox does not direct any part of its website to children under 13 years old (or such age as a child is defined by local law if higher) and does not knowingly collect personal data from children or target its website or products to children.
+To ensure that you can purchase with confidence from the Xerox website, Xerox protects credit card information submitted online with industry-standard encryption technology.
+## Security of Personal Data
+**Our agents and partners protect personally identifiable information.**
+Xerox is committed to protecting the security of your personal data and maintains strict access control over it. We utilize reasonable and appropriate physical, technical and administrative procedures to safeguard personal information we collect and process. Only authorized Xerox personnel, and those of our subsidiaries, affiliates, agents, and partners are allowed to handle information submitted to Xerox.
+When you purchase equipment or supplies or arrange for services online from Xerox it may be necessary to transfer personally identifiable information to our subsidiaries, affiliates, agents or partners, who then fill the orders or provide the services. Xerox requires that its subsidiaries, affiliates, agents and partners handle personally identifiable information with the same concern for personal privacy as Xerox.
+Xerox websites store personal data in password-protected environments on servers that are subject to Xerox's information security policies, standards, and procedures. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. When we transmit sensitive personal data such as a password over the Internet, we protect it through the use of encryption.
+## Access to Information
+To ensure that you can purchase with confidence from Xerox websites, Xerox protects credit card information submitted online with industry-standard encryption technology or tokenization.
+You may contact Xerox to check the accuracy of your personally identifiable information or to request that your information be updated or deleted by writing to ethics@xerox.com. Please indicate "Access" in the subject line and let us know the details of your request in the body of the message. You may also contact us at the Xerox Ethics and Privacy Hotline at 1-866-XRX-0001. Xerox reserves the right to confirm your identity and to modify the scope and number of requests.
+## Our Agents and Partners Protect Personal Data
+When you provide personal data to Xerox, it may be necessary to transfer personal data to our subsidiaries, affiliates, agents or partners, who then fulfill the orders or provide the services. Xerox requires that its subsidiaries, affiliates, agents and partners handle personal data with the same concern for personal data privacy as Xerox.
 ## Cookies, Web Beacons and Privacy Choices
+**What is a cookie?**
+**What is a Cookie?**
 Cookies are small text files that are placed on your computer or mobile device by websites that you visit. They are widely used in order to make websites work efficiently, as well as to provide information to the owners of the site. Cookies are useful because they allow a website to recognize your device, letting you navigate between pages efficiently, remembering your preferences, and generally improving your experience.
+**How does Xerox use cookies?**
+**How Does Xerox Use Cookies?**
 Xerox uses cookies to recognize repeat visits to our websites and to facilitate Web navigation and online shopping. The cookies store your country and language, along with an assigned random session ID. In some cases, the cookies store name and address information so you do not have to re-enter this information in multiple forms.
 The cookie information that Xerox collects helps us track the number of visitors to our websites over time and determine whether these were new or repeat visits.
+Xerox also works with third party advertising partners that use cookies to deliver Xerox advertising on other websites and to measure the performance of our advertising campaigns.
+Xerox also works with third party advertising partners that use cookies to deliver Xerox advertising on other websites and to measure the performance of our advertising campaigns. For example, we use Google Analytics to track website usage and activity. Read more about how Google Analytics uses your information [here](https://www.google.com/policies/privacy/partners/).
 **What is a Web Beacon?**
 A web beacon is an electronic image that can be used to recognize a cookie on your computer or other device when you view a web page or email.
+**How does Xerox use Web Beacons?**
+**How Does Xerox Use Web Beacons?**
 Xerox and our third party advertising partners may use web beacons on our websites, in our emails, and in our advertisements on other websites to measure the effectiveness of our websites and our advertising. For example, web beacons may count the number of individuals who visit our websites from a particular advertisement or the number of individuals who open or act upon an email message.
+**Can I block cookies and web beacons?**
+**Can I Block Cookies and Web Beacons?**
 Yes, the ability to enable, disable or delete cookies can be controlled though your website browser. Consult the "Help" menu of your browser application for details. If you block the use of cookies, you will not be able to use some of the features on Xerox websites, including the shopping cart and online account management services. You can make some web beacons unusable by disabling cookies.
+**Links to non-Xerox websites.**
+**Links to Non-Xerox Websites.**
+Other websites that may be accessed through our website, such as through social media buttons or other links, may collect certain information about you through the use of cookies, web beacons and other features. We do not have access to or control over the cookies or other features that these third party sites may use, and the information practices of these third party websites are not covered by this Online Privacy Policy. Please contact them directly for more information about their privacy practices.
+Other websites that may be accessed through our website, such as through social media buttons or other links, may collect certain information about you through the use of cookies, web beacons and other features. We do not have access to or control over the cookies or other features that these third party sites may use, and the information practices of these third party websites are not covered by this privacy statement. Please review the privacy notices and settings of the third party site to understand their practices.
+## Privacy Choices: How does Xerox use Interest-Based Advertising
+**Privacy Choices: How Does Xerox Use Interest-Based Advertising?**
 Websites cooperate with online advertisers to collect information about visitors to present ads that are more useful and relevant. This is known as interest-based advertising or online behavioral advertising. Xerox and our third party advertising partners may use cookies and web beacons to deliver interest-based ads that are relevant and targeted to our customers and prospects. When delivering interest-based ads, Xerox adheres to the Self-Regulatory Program for Online Behavioral Advertising.
+**What information do Xerox websites collect for interest-based advertising?**
+**What Information Do Xerox Websites Collect for Interest-Based Advertising?**
 Xerox and our third party advertising partners may use cookies or web beacons to collect information for the purposes of interest-based advertising based on your visits to Xerox.com and other web sites. These cookies identify the pages you view, the links and ads you click on, other actions you take on those websites, and the referring website. Similarly, online advertisers use cookies to deliver advertising to you for companies other than Xerox based on your visits to Xerox.com and other websites.
+**Can I control the interest-based advertising that Xerox web sites collect about me?**
+**Can I Control the Interest-Based Advertising that Xerox Websites Collect About Me?**
 Yes, Xerox provides [a tool to opt-out of data collection](http://preferences-mgr.truste.com/) by companies that adhere to the [Self-Regulatory Program for Online Behavioral Advertising](http://www.aboutads.info/principles/).
+## Contact Us
+## Communication Preferences
+We welcome questions or comments about our Online Privacy Policy. You may also contact us if you feel that your personal information is used in a way inconsistent with this policy. [Email](mailto:mailto:ethics@xerox.com) us or call 1-866-XRX-0001 if you are in North America. International numbers and a Web submission tool are available on [www.xerox.com/ethics](http://www.xerox.com/ethics). You may also contact us via postal mail at:
+Xerox may send commercial email to you advertising our products and services. You can also subscribe to various product and service-specific communications on our websites. If you receive commercial email from Xerox and wish to discontinue these mailings, you may unsubscribe at [www.xerox.com/unsubscribe or via an 'opt-out' provided in the communication](https://www.xerox.com/perl-bin/formeng.pl). You may also mail an unsubscribe request to:
+Marketing Privacy Preferences
 Xerox Corporation
+Xerox Business Ethics and Compliance
+Marketing Manager
+SW Canyon Creek Road,
+Building 63 MS 7063-630,
+Wilsonville, OR 97070
+This unsubscribe option does not apply to communications primarily for the purpose of administering order completion, contracts, support, product safety warnings, software updates, or other administrative and transactional notices, the primary purpose of which is not promotional in nature.
+Xerox commits to resolve complaints about your privacy and our collection or use of your personal data. Inquiries or concerns regarding this privacy statement and your rights under privacy laws can be directed to the Xerox Business Ethics and Compliance Office.
+To report your inquiries or concerns to the Business Ethics and Compliance Office please contact the Xerox Ethics Helpline. The Xerox Ethics Helpline is confidential and anonymous, if you so desire, and is available online and via the toll-free number listed below.
+- Web Reporting: [www.xeroxethicshelpline.com](http://www.xeroxethicshelpline.com/)
+- US & Canada Toll-Free Number: 1-866-XRX-0001
+- [Direct Dial Toll-Free Numbers Outside US & Canada](https://www.xerox.com/downloads/usa/en/h/HowtoContacttheXeroxEthicsHelpline.pdf) available at [www.xerox.com/ethics](https://www.xerox.com/en-us/about/corporate-citizenship/ethics)
+You may also contact us via postal mail at:
+Xerox Corporation
+Xerox Business Ethics and Compliance Office
 Merritt 7
 Norwalk, CT 06851-1056
 USA
+- If you have questions about Xerox products or services, call us toll-free at 1-800-ASK-XEROX or 1-800-275-9376.
+- [More contact information](http://www.xerox.com/about-xerox/contact-us/enus.html) is available on [www.xerox.com](http://www.xerox.com/) if you are outside the United States and Canada, and/or if you have questions about support, sales, corporate information, scholarships, research and innovation, or services.
+Xerox Limited is our representative for the European Economic Area and Switzerland:
+## Policy Updates
+Xerox Limited, Riverview, Oxford Road, Uxbridge, UB8 1HS, UK
+Xerox reserves the right to make changes to this policy. If we make changes, we will revise this Online Privacy Policy to reflect such changes and revise the effective date of the policy.
+The Xerox subsidiary in your country or region can be found [here](https://www.xerox.com/en-us/about/contact-us).
+Policy Effective Date: February 24, 2014.
+If you have questions about Xerox products or services, call us toll-free at 1-800-ASK-XEROX or 1-800-275-9376. [More contact information](https://www.xerox.com/en-us/about/contact-us) is available on [www.xerox.com](https://www.xerox.com/index/enus.html) if you have questions about support, sales, corporate information, scholarships, research and innovation, or services.
+**What was revised in the last update?**
+## Statement Updates
+The privacy practices at Xerox did not change with the last update of this policy. No changes were made to the substance of this policy. We added the following content to the policy:
+Xerox reserves the right to make changes to this statement. If we make changes, we will revise this privacy statement to reflect such changes and revise the effective date of the statement.
+- Additional information was provided regarding the use of cookies.
+- Additional information was provided regarding Xerox's advertising practices.
+Statement Effective Date: May 1, 2018.
+**What Was Revised in this Update?**
+This privacy statement has been updated to reflect changes to address European data protection regulation.