Xerox Privacy Policy

DATED 2020-01-01 · VERSION 20200327_rev01 · COMPARED WITH 20190321_rev01 · ARCHIVE SNAPSHOT

Full text changes — 20190321_rev01 to 20200327_rev01

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

 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.
 ## Personal Data We Collect
 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:
+**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.
+**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.
 **Credentials**. Passwords, password hints and similar security information used for authentication and account access.
 **Demographic Data**. Data about you such as your country of residence and preferred language.
+**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.
+**Payment Data**. Data necessary to process your payment if you make purchases, such as your payment card number, expiration date, and the security code associated with your payment card.
+**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.
+**Geolocation Data**. We may collect data about your location, which can be either precise or imprecise. Precise location data can be obtained through Global Navigation Satellite System data, as well as through nearby cell towers and Wi-Fi hotspots 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 an internet protocol (IP) address or a city or postal code.
 **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.
+**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.
+**Job Applications/CVs/Resumes**. Professional, education and employment-related information on job applications/CVs/resumes which you provide to us if you submit a job application to Xerox either directly or indirectly, which may include sensitive personal data. Xerox uses this information in order to evaluate your application and perform related employment activities.
 **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.
+**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.
+**Website Browsing and Commercial Information.** Information about your visits to our websites and your browsing patterns, including inferences drawn from this information. This may include information related to your prior purchases and online buying preferences or data about your device, including 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.
+**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.
+**Products.** Certain Xerox products collect data, such as product registration, device serial number, 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.
 **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:
 - 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.
 ## How We Use Personal Data
+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.
+We collect and process personal data with your consent, as required by law, or as necessary to fulfill the legitimate interests or business purposes 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.
+Personal data that is submitted in a business capacity may be merged with available business database directories. Xerox uses personal data to:
+Xerox uses personal data to:
 - 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;
 - 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.
+We share your personal data as necessary to complete a transaction or provide a product or service you have requested or authorized. 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.
+Personal data that is submitted in a business capacity may be merged with available business database 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.
+We share your personal data as necessary for Xerox's business purposes, to complete a transaction or provide a product or service you have requested or authorized. 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 with consumer reporting agencies for fraud prevention and credit risk reduction.
+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 or servicing business accounts or products via our systems and services may need access to personal data to provide those functions. In addition, we may share information with third parties for the joint offering of a product or service. 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.
 Finally, we will transfer or disclose personal data when we have a good faith belief that doing so is necessary to:
 - 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.
+We do not sell your personal data to third parties.
 ## Where We Process and Store Personal Data
 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.
+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.
+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 Standard Contractual Clauses, to help ensure any required rights and protections apply to your data.
 ## EU-U.S. Privacy Shield
 Xerox Corporation complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework established by the U.S. Department of Commerce regarding the collection, use and retention of personal data transferred from the European Union and Switzerland to the United States. Xerox Corporation has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If third-party agents process personal data on our behalf in a manner inconsistent with the Privacy Shield Principles, we remain liable unless we prove we are not responsible for the event giving rise to the damage. If there is any conflict between the terms in this privacy statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit [www.privacyshield.gov](https://www.privacyshield.gov/).
 In compliance with the Privacy Shield Principles, Xerox commits to resolve complaints about our collection or use of your personal data. European Union or Swiss individuals with inquiries or complaints regarding this privacy statement should first contact Xerox at: [privacy@xerox.com](mailto:privacy@xerox.com) and indicate "Privacy Shield" in the Subject line.
 The Federal Trade Commission has jurisdiction over Xerox's compliance with the Privacy Shield.
 ## Period of Storage
 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.
+## Your Rights Regarding Personal Data
+## Your Privacy Rights
 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.
 - 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 the right to object to direct marketing (you may unsubscribe at [www.xerox.com/unsubscribe](https://www.xerox.com/unsubscribe) or via an 'opt-out' provided in the communication); and
 - You have a right to file a complaint with a regulator or data protection authority.
 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 [privacy@xerox.com](mailto:privacy@xerox.com). Please indicate "Access" in the subject line and let us know the details of your request in the body of the message. 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.
 ## Children
+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.
+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. If we learn we have collected or received personal data from a child under 13 years old without verification of parental consent, we will delete the information.
 ## Security of Personal Data
+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.
+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 collected by 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.
 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.
 ## Our Agents and Partners Protect Personal Data
 ## Communication Preferences
 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
 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.
 - 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
 Xerox Limited is our representative for the European Economic Area and Switzerland:
 Xerox Limited, Riverview, Oxford Road, Uxbridge, UB8 1HS, UK
 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 is available on [www.xerox.com](https://www.xerox.com/) if you have questions about support, sales, corporate information, scholarships, research and innovation, or services.
 ## Statement Updates
 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.
+Statement Effective Date: October 23, 2018.
+Statement Effective Date: January 1, 2020.
 **What Was Revised in this Update?**
+This privacy statement has been updated to reflect changes to address European data protection regulation.
+This privacy statement has been updated to reflect changes to address California data protection regulation.