EPC Privacy and Data Protection Policy
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.
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
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.
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.
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 email@example.com and we will investigate.
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
Please visit www.csileasing.com for the Privacy Shield Policy for CSI Leasing, Inc. and its subsidiaries, which include EPC, Inc.
Contact EPC, Inc.
To “opt out” or make other choices about your Personal Data or to exercise your rights, please email firstname.lastname@example.org.
Effective date: January 1, xxxx.
LICENSE AND OWNERSHIP
EPC grants you a limited, personal, nontransferable, nonsublicensable, revocable license to (a) access and use only the Site and Content only in the manner presented by EPC, and (b) access and use the EPC computer and network services offered within the Site (“EPC Systems”) only in the manner expressly permitted by EPC. Except for this limited license, EPC does not convey any interest in or to the EPC Systems, information or data available via the EPC Systems (the “Information”), Content, Services, Site or any other EPC property by permitting you to access the Site. Except to the extent required by law or as expressly provided herein, none of the Content and/or Information found or accessed via the Site may be reverse engineered, modified, reproduced, republished, translated into any language or computer language, retransmitted in any form or by any means, resold or redistributed without the prior written consent of EPC. You may not make, sell, offer for sale, modify, reproduce, display, publicly perform, import, distribute, retransmit or otherwise use the Content in any way, unless expressly permitted to do so by EPC.
RESTRICTIONS ON THE USE OF THE SITE
(a) You shall not disguise the origin of information transmitted through the Site.
(b) You will not place false or misleading information on the Site.
(c) You will not use or access any service, information, application or software available via the Site in a manner not expressly permitted by EPC.
(d) You will not input or upload to the Site any information which contains viruses, Trojan horses, worms, time bombs or other computer programming routines that are intended to damage, interfere with, intercept or expropriate any system, the Site or that infringes the Intellectual Property rights of another.
(e) You may not use or access the Site in any way that, in EPC’s judgment, adversely affects the performance or function of the Site, or interferes with the ability of authorized parties to access the EPC Systems, Services or the Site.
Any software available for download via the Site is the copyrighted work of EPC and/or its licensors. Use of such software is governed by the terms of the end user license agreement that accompanies or is included with the software. Downloading, installing, and/or using any such software indicates your acceptance of the terms of the end user license agreement. EPC cannot and does not guarantee or warrant that files available for downloading through the Site will be free of infection by software viruses or other harmful computer code, files or programs.
The Site may contain “case studies” describing scenarios where EPC customers benefitted 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.
If you believe, in good faith, that any materials on the Site infringe your copyrights, notifications of claimed copyright infringement should be sent, in accordance with Title 17, United States Code, Section 512(c)(2) (under the “Digital Millennium Copyright Act”) to EPC’s designated agent. Notification should include:
- an electronic or physical signature of the person authorized to act on behalf of the owner of the copyright interest;
- a description of the copyrighted work that you claim has been infringed;
- a description of where the material you claim is infringing is located on the Site;
- a statement by you that you have a good faith belief that the disputed use is not authorized by the copyright owner, its agent or the law; and
- a statement by you, made under penalty of perjury, that the above information in your notice is accurate and that you are the copyright owner or duly authorized to act on the copyright owner’s behalf.
EPC’s agent for notification of claimed copyright infringement is: Ms. Joan Kersting, 314-997-7010, fax: 314-997-7844, Joan.Kersting@csileasing.com.
LIMITATION OF LIABILITY
SUBMISSIONS TO THE SITE
You agree to indemnify and hold harmless EPC from and against any and all claims, losses, expenses, or demands or liabilities, including attorneys’ fees and costs, incurred by EPC in connection with any claim by a third party (including any intellectual property claim) arising out of (i) Submissions that you communicate, submit, post to or transmit through the Site, or (ii) your use of the Site in violation of this Agreement or in violation of any applicable law. You further agree that you will cooperate as reasonably required in the defense of any such claims. EPC reserves the right, at its own expense, to assume the exclusive defense and control of any matter otherwise subject to indemnification by you, and you shall not in any event settle any such claim or matter without the written consent of EPC. You further agree to indemnify and hold harmless EPC from any claim arising from a third party’s use of information or materials of any kind that you post on the Site.
LINKS TO THIRD PARTY SITES
USE OF PERSONALLY IDENTIFIABLE INFORMATION
You agree to use the Site only for lawful purposes. You are prohibited from any use of the Site, including the Content, Services, EPC Systems, which would constitute an illegal offense, give rise to liability or otherwise violate any applicable local, state, national or international law or regulation. EPC makes no claims concerning whether the Content may be downloaded or are appropriate for use outside of the United States. If you access this Site from outside of the United States, you are solely responsible for ensuring compliance with the laws of your specific jurisdiction.
You agree that EPC, in its sole discretion, may terminate or suspend the use of the Site, EPC Systems, Services, and Content at any time and for any or no reason in its sole discretion, even if access and use continues to be allowed to others. Upon such suspension or termination, you must immediately (a) discontinue use of the Site, and (b) destroy any copies you have made of any portion of the Site, or Content. Accessing the Site, EPC Systems or Services after such termination, suspension or discontinuation shall constitute an act of trespass. Further, you agree that EPC shall not be liable to you or any third party for any termination or suspension of your access to the Site, EPC Systems and/or the Services.
Failure by EPC to enforce any provision(s) of this Agreement shall not be as a waiver thereof. THIS AGREEMENT AND ALL OTHER ASPECTS OF YOUR USE OF THE SITE SHALL BE GOVERNED BY AND CONSTRUED IN ACCORDANCE WITH THE LAWS OF THE STATE OF MISSOURI, WITHOUT REGARD TO ITS CONFLICT OF LAWS RULES. All claims and disputes arising out of this Agreement, and applicable federal law or your use of the Site, other than actions for specific performance or injunctive relief brought by EPC, shall be exclusively brought in the federal, state, or local courts located in the State of Missouri, and, with regard to such claims and disputes, you hereby irrevocably (i) submit to the exercise of personal jurisdiction over you by those courts and (ii) waive any jurisdictional, venue, or inconvenient forum objections to such courts. Any cause of action you may have with respect to the Content, Services, EPC Systems and its Information, Site or this Agreement must be commenced within one (1) year after the claim or cause of action arose, or be barred. If any provision of this Agreement is found to be invalid or unenforceable, the remaining provisions shall be enforced to the fullest extent possible, and the remaining provisions of the Agreement shall remain in full force and effect. This Agreement will be binding on, inure to the benefit of, and be enforceable against the parties and their respective successors and assigns. Neither the course of conduct between parties nor trade practice shall act to modify any provision of the Agreement. All rights not expressly granted herein are hereby reserved.
If you have questions regarding the Agreement or the practices of EPC, please contact us by e-mail, telephone or postal mail:
3941 Harry S. Truman Blvd.
St. Charles, Missouri 63301