Privacy Notice

    
Panasonic ID Privacy Notice
Panasonic values the protection of its customers’ personal data and treats it appropriately and cautiously in order to respect their fundamental rights to privacy and data protection.  Panasonic wants to be a reliable company to which an individual customer (such as you) can trustfully provide his/her personal data.
This Privacy Notice applies when you create and use our customer account (the "Panasonic ID"), a service operated and provided by Panasonic Corporation of Japan, a company having its registered office at 1006, Oaza Kadoma, Kadoma-shi, Osaka 571-8501, Japan (together "Panasonic", "we", "us", or "our"). The Panasonic ID is used to access all our services that are developed by each Panasonic divisional business company on a Panasonic-built platform (e.g. cloud services) (the "Services"). This Privacy Notice supplements the Terms of Use of Panasonic ID https://csapl.pcpf.panasonic.com/Agreement/ShowDocuments?DocId=pf00010001 which apply whenever you use your Panasonic ID.
This Privacy Notice explains (1) how and why we use any information about you (referred to in this Privacy Notice as Personal Data, as further defined below) that you provide to us or that we collect through your use of the Panasonic ID to access the Services and (2) what your rights and our obligations are in relation to the processing of your Personal Data.  This Privacy Notice is further formed in accordance with the European data protection legislation, including the General Data Protection Regulation (the "GDPR"). 
Please read this Privacy Notice carefully. 
Panasonic is represented in the European Economic Area (i.e. the European Union, Iceland, Liechtenstein and Norway) for any data protection related matters by its German entity, Panasonic Marketing Europe GmbH, having its registered office at Hagenauer Strasse 43, 65203 Wiesbaden Germany.

If you are a California resident, additional privacy notice applies to you, in accordance with the California Consumer Privacy Act.  Please see Appendix in the link below.
CCPA PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This Privacy Notice does not apply to:
・the specific data processing activities which may occur when using the actual Service (i.e. after you have logged in/connected to the relevant Service with your Panasonic ID) - a separate privacy notice will be made available for each Service; 
・information that may be collected by or through third party applications that are available through the Services; or 
・our services which cannot be accessed through your Panasonic ID.
We may change this Privacy Notice over time. The "Date last updated" mentioned at the end of this document states when the notice was last updated and changes will become effective upon our notification of the revised Privacy Notice to you. Where required by applicable law, we will request your consent to any such changes. We will notify you of these changes by contacting you via email if you have provided your email address, and/or by posting a notice on this page to ensure that you are aware of any changes.

1.What is Personal Data?

For the purposes of this Privacy Notice, "Personal Data" consists of any information that relates to an identified or identifiable individual (such as you). For example, information which identifies you may consist of your name, address, telephone number, payment details, a specific Panasonic 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.

2.What Personal Data do we collect about you?

A.Personal Data you provide directly about yourself
Although you can use some of our Services without providing your Personal Data, the Service which are accessible using your Panasonic ID require the collection and processing of your Personal Data. You can choose whether or not to create a Panasonic ID and provide your Personal Data for that purpose, but you may not be able to access our full Services if you choose not to do so. 

We have detailed below the circumstances where we collect your Personal Data in relation to your Panasonic ID. 

I.When you create a Panasonic ID 
When you create a Panasonic ID on a Panasonic website to use the Services and/or their functions, we ask you to provide the following categories of Personal Data:
・your name and surname;
・your email address;
・your password; 
・your country of residence;
・your gender; and
・your date of birth (we use this data for identification purpose in case you forget your password to log in)
II.When you use your Panasonic ID to access one of our Services 
You will be prompted to enter (i) your email address and (ii) password each time you wish to log in to a website or access a Service using your Panasonic ID.
III.When you register a product or device with Panasonic
If you choose to register the relevant product or device with us in order to benefit from certain features (such as product/device warranty) using your Panasonic ID, we may collect information about the Panasonic product or device you purchased, such as its serial numbers (or other product/device identifier) and the date of purchase (in addition to the Personal Data provided upon creation of your Panasonic ID). 
IV.When you communicate with us
If you contact us to exercise your rights under the GDPR or make inquiry about this Privacy Notice, we may ask you to provide certain additional information, including your Panasonic ID. 

B.Information about your use of the Services
In addition to the information that you provide, we automatically collect information when you access the Services via your Panasonic ID and how you use them.  For example, when you use the Services, we may automatically collect certain information from you such as IP address, unique device identifier, device configurations and device, our Services usage data (however we do not collect data on what you do on such Services). Please review the respective privacy policies in relation to each of our Services which you access using your Panasonic ID.

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

We are not allowed to process Personal Data if we cannot rely on a valid legal ground. Therefore, we will only process your Personal Data when:
I.the processing is necessary to perform our contractual obligations towards you pursuant to the Terms of Use of Panasonic ID;
II.the processing is necessary to comply with our legal or regulatory obligations; 
or
III.the processing is necessary for our legitimate interests except where they are overridden by your interests or fundamental rights and freedoms. Examples of such ‘legitimate interests’ include:
I.to protect the security of our IT systems, architecture and networks;
II.to meet our corporate and social responsibility objectives.

4.How do we deal with Children’s Personal Data?

For cases other than where GDPR applys as specified in the second paragraph in this Clause
You have to be 13 years or older to create a Panasonic ID.  We do not solicit or knowingly collect Personal Data from or about children under the age of 13 without the consent of a parent or guardian. If we nevertheless become aware that Personal Data that relates to children under the age of 13 has been submitted to us without the consent of a parent or guardian, we will delete such information from our systems as quickly as possible or, where deletion is not possible, we will ensure that the Personal Data is not used for any purpose or disclosed to any third party.
In case where GDPR applys: 
You have to be 16 years or older to create a Panasonic ID.  We do not solicit or knowingly collect Personal Data from or about children under the age of 16 without the consent of a parent or guardian. If we nevertheless become aware that Personal Data that relates to children under the age of 16 has been submitted to us without the consent of a parent or guardian, we will delete such information from our systems as quickly as possible or, where deletion is not possible, we will ensure that the Personal Data is not used for any purpose or disclosed to any third party.

5.Why do we use your Personal Data?

We will use your Personal Data for the following purposes:
I.Create an Account/Log in on our Websites - to enable you to create a Panasonic ID account on our websites, and to enable you to log in to such website using your Panasonic ID;
II.Provide the Services - to provide the Services which you access via your Panasonic ID and enable us to fulfil our obligations under our contract with you, namely the Terms of Use of Panasonic ID;
III.Registering products/devices - to register your devices or products or any of our Services with your Panasonic ID;
IV.Proof of identity - to identify you when you login to the relevant Services with your Panasonic ID, including when you use the Services in conjunction with third party applications or devices (e.g. Amazon Alexa). If you log in with your Panasonic ID to benefit from some Services in connection with such third party applications or devices, the respective terms of use and privacy notices of these third parties will apply and we ask you to review them carefully;
V.Statistics - to create anonymous, aggregated statistics about the use of Panasonic ID and the related Services. This anonymised data may be shared with third parties;
VI.Customer Support Services - to provide customer support services for the Panasonic ID and the related Services, or to deal with any other support queries you may have (such as complaint handling);
VII.Security - to protect our customers (e.g. to prevent spam or attempts to defraud users of our service); to operate and maintain the security of the Panasonic ID and the related Services (e.g. to prevent or stop an attack on our systems or networks); or to protect our rights or property, including enforcing the Terms of Use governing the use of your Panasonic ID or the related Services; 
VIII.Updates - to communicate with you, including communicating with you about your Panasonic ID or transactions with us, to give you important information about your use of Panasonic ID; and to provide the latest version of this Privacy Notice; and
IX.Combining Personal Data - to combine Personal Data we collect from you directly, or through other Panasonic Affiliates (as defined below), for example to allow us to provide better support services and more personalised content, to the extent permitted by applicable laws and regulations. 

6.How long do we store your Personal Data?
We will retain your Personal Data (A) for up to 5 year following the collection of the Personal Data for the purposes as outlined in this Privacy Notice, or (B) for up to one year after you terminate the use of Panasonic ID, whichever is longer.
When your Personal Data is no longer required for the purpose for which it was collected or as required by applicable law, it will be deleted in accordance with applicable law. 

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

A.Third parties recipient of the Personal Data
We may disclose your Personal Data to third parties listed in this Section 7 to achieve the purposes described in this Privacy Notice. We require these third parties to take steps to maintain the confidentiality of any Personal Data they may receive from us to perform their tasks, consistent with our Privacy Notice, and we require them not to use this information for any other purpose. We may disclose your information as follows:

I.Panasonic Affiliates
We may need to transfer your Personal Data to other Panasonic Affiliates to enable you to create a Panasonic ID or use your Panasonic ID to access any Service/assistance. All Panasonic Affiliates are required to follow the privacy related rules set forth in this Privacy Notice. "Affiliates" means any corporate entity that is directly or indirectly controlled by Panasonic. 
II.Service Providers
We share Personal Data about you with third party service providers solely for the purpose of enabling them to perform services on our behalf that are related to the Panasonic ID and provided they operate in compliance with our instructions.
Examples of such third party service providers are:
・service providers who provide us with data hosting services to store data in relation to your Panasonic ID or in relation to the Services accessed via your Panasonic ID; and
・service providers who provide us with maintenance services for the Panasonic ID and the Services access via your Panasonic ID. 
III.Third parties when required by law or to protect the Services
We will disclose your Personal Data as required by the laws of the European Union and of its Member States, such as in response to an order from a court, public authority or competent regulator of the European Union or one of its Member States.
IV.Third parties when required by law outside of EU or protect the Services
We will disclose your Personal Data in connection with legal requirements, such as in response to an authorized subpoena, governmental request or investigation, or as otherwise required by law, in full compliance with all applicable laws (including without limitation the GDPR).
V.Other parties in connection with corporate transactions
As our business develops, we may sell, buy, or transfer corporate assets. In such transactions, customer information, including your Personal Data, can be part of the transferred business assets to the extent permitted by applicable law. Also, in the event that we, the Panasonic ID, the Service, or substantially all of our assets are acquired, your Personal Data will be one of the assets transferred in such acquisition to the acquiring company.
VI.Third parties to which you agreed to disclose your Personal Data
With your consent or upon your request, we may also disclose your Personal Data to other third parties. 

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 your country of residence, including, in respect of residents of a country within the European Economic Area (the "EEA"), to a country outside the EEA including but not limited to Japan or in any other country which does not offer an adequate level of data protection as recognised by the European Commission and where we or our affiliates or service providers, maintain facilities. Your Personal Data may also be processed by staff operating inside or outside your country of residence, including staff located outside of the EEA, who work for us or for one of our suppliers or service providers.
Where we transfer your Personal Data outside the EEA, we will ensure that suitable safeguards are in place to help ensure that our third party service providers provide an adequate level of protection to your Personal Data. For the processing of your Personal Data in relation to your use of your Panasonic ID, we have put in place an appropriate transfer agreement incorporating the Standard Contractual Clauses approved by the European Commission. 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 11 below.

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

A.General
Panasonic has put in place appropriate technical and organisational measures to safeguard the Personal Data we collect in connection with your Panasonic ID and the Services accessed via your Panasonic ID. 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.Security of storage
All Personal Data you provide to us is stored on our secured servers. You are responsible for keeping the password of your Panasonic ID confidential and we ask you not to share it with anyone.

C.Other security measures
Information security, including the protection of Personal Data is organized in a global Panasonic Program called "Information Security Management" (ISM). The related aim, standards and implementation measures are organized in globally valid policy, standards and guidelines. The IT systems which deal with your Panasonic ID 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. 

9.How about third party websites and applications?
The websites where you can log in to your Panasonic ID and the Services accessed via your Panasonic ID may include links to third party websites and/or applications that are not operated by us. The linked sites and applications are not under our control and as such, we are not responsible for the privacy practices or the content of these websites or applications and we encourage you to read carefully the privacy policies provided by these developers before you provide Personal Data to them.

10.Cookies and similar technology

A.What are cookies?
Panasonic may use cookies and other technologies in certain areas of the Service. 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 settings, help you with signing in, 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 our 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 Panasonic and other third parties use them, and for details of how cookies can be disabled, please see our Cookie Policy.
https://csapl.pcpf.panasonic.com/Agreement/ShowDocuments?DocId=pf00010003 

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

A.What are your rights?
We 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, where technically feasible, 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 writing at the following contacts;
Panasonic ID Contact
https://csapl.pcpf.panasonic.com/Account/top 

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.

CCPA Appendix

This CCPA Appendix complements Panasonic ID Privacy Notice (the “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 Consumer Privacy Act (the “CCPA”). If there is any discrepancy between the terms of this CCPA Appendix and those of the Privacy Notice, this CCPA Appendix will prevail. We may change this CCPA Appendix from time to time. The “Date last updated” mention at the bottom of this page states when the Privacy Notice and/or this CCPA Appendix was last updated and any changes will become effective upon our posting of the revised CCPA Appendix. Where required by the CCPA or other applicable law, we will request your consent to any such changes. We will provide the revised CCPA 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 do we collect about you? 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. Children’s Personal Date 1. What is Personal Data? For the purposes of this CCPA 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 do we collect about you?
Categories of personal data Categories of sources Business or commercial purpose(s) Categories of third parties with whom we share personal data
1. Your name and surname, your email address, your password, your country of residence, your gender, and your date of birth Direct collection from data subject

To create an account (“Panasonic ID”) and to log in on Panasonic websites : to enable you to create a Panasonic ID account on such websites, and to enable you to log in to such website using your Panasonic ID to use the Services and/or their functions For your date of birth, to identify yourself in case you forget your password to log in.

2. Your email address and password Direct collection from data subject -Customer Support Services :to provide customer support services for the Panasonic ID and the related Services, or to deal with any other support queries you may have (such as complaint handling), such as contacting us to exercise your rights under the CCPA or make inquiry about this CCPA Appendix to the Privacy Notice -Security :to protect our customers (e.g. to prevent spam or attempts to defraud users of our service); to operate and maintain the security of the Panasonic ID and the related Services (e.g. to prevent or stop an attack on our systems or networks); or to protect our rights or property, including enforcing the Terms of Use governing the use of your Panasonic ID or the related Services -Updates :to communicate with you, including communicating with you about your Panasonic ID or transactions with us, to give you important information about your use of Panasonic ID; and to provide the latest version of the Privacy Notice; and -Combining Personal Data:to combine Personal Data we collect from you directly, or through other Panasonic Affiliates (as defined in the Privacy Notice), for example to allow us to provide better support services and more personalised content, to the extent permitted by applicable laws and regulations.
3. Information about the Panasonic product or device you purchased, such as its serial numbers (or other product/device identifier) and the date of purchase (in addition to the Personal Data provided upon creation of your Panasonic ID) Direct collection from data subject -Registering products/devices :To enable you to register the relevant product or device with us in order to benefit from certain features (such as product/device warranty) using your Panasonic ID
4. A certain information when you access the Services via your Panasonic ID and how you use them, such as IP address, unique device identifier, device configurations and device, our Services usage data (however we do not collect data on what you do on such Services) Automatical collection of information about your use of the Services -Statistics :to create anonymous, aggregated statistics about the use of Panasonic ID and the related Services. This anonymised data may be shared with third parties;
3. On which legal basis do we process Personal Data? We process Personal Data of residents in California in compliance with the CCPA. 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 CCPA include, the right to know about your Personal Data that we collect, use the right to request the deletion of 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 CCPA 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 If you wish to exercise any of the rights of A(1) above, please contact us by using the following means in addition to the communication means described in the Privacy Notice. I. By telephone (Toll-free telephone number) +1-855-772-2891 II. By online request form https://na.panasonic.com/us/ccpa-privacy-request We will confirm receipt of your requests to exercise your rights within 10 days 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. 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 CCPA 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. Children’s Personal Date We do not sell Personal Data of anyone under the age of 16. Date last updated: January 2020