What is this Privacy Notice about?
Sumitomo Electric Lightwave (“SEL”) has prepared this Privacy Notice (“Notice”) to inform you about the types of information we may collect when you use this Ribbon Fiber Inspection App (“App”) and about how SEL collects, processes, stores and otherwise uses such information. This Notice also describes your rights in relation to that information, including your right to object to some of the processing which SEL carries out. SEL is the controller for your personal data collected through or in connection with the App. If you do not agree with our policies and practices, do not download, register with, or use this App. By downloading, registering with, or using this App, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this App after we revise this policy means you accept those changes, so please check the policy periodically for updates.
Who is this Notice relevant to?
This Notice is relevant to you if you use the App. For California residents please also refer to the “State Privacy Rights” section below. For EEA and UK residents, please also refer to the “Additional Information for the EEA and UK Residents” below.
What categories of information does SEL collect about me?
SEL collects information from users of the App:
- Directly from you when you provide it to us.
- Automatically when you use the App.
SEL collects, processes and uses the following categories and types of personal data about you:
- Usage Details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, logs, and other communication data and the resources that you access and use on or through the App.
- Device Information. We may collect information about your mobile device, including the device’s unique device identifier.
- Stored Information and Files. The App also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
- Location Information. The App does not collect real-time information about the location of your device.
SEL processes your personal data for the following purposes:
- Providing the App to our customers and end users.
- Developing and improving the App.
- Carrying out any other purpose described to you at the time the information was collected.
Who might SEL share my personal data with?
SEL does not sell to or share personal data with any third party. However, in limited circumstances personal data may be accessed by:
- Data processor service providers. As necessary for the Processing Purposes described above, personal data may be accessed by service providers to process personal data under appropriate instructions (“Data Processors”). The Data Processors will be subject to contractual obligations to implement appropriate technical and organisational security measures to safeguard the personal data, and to process the personal data only on SEL’s instructions.
- Regulators, authorities, advisors and representatives. As necessary for the Processing Purposes described above, personal data may be transferred to regulators, courts, and other authorities (e.g., tax and law enforcement authorities), independent external advisors (e.g., auditors), internal compliance and investigation teams (including external advisers appointed to conduct internal investigations) and our EU and UK representatives (please refer to “Additional Information for the EEA and UK Residents” for more details).
- Acquiring entities. If SEL business is sold or transferred in whole or in part (or such a sale or transfer is being contemplated), your personal data may be transferred to the acquirer or potential acquirer as part of the transfer itself or as part of an initial review for such transfer (i.e. due diligence), subject to any rights provided by applicable law, including jurisdictions where the acquirer or potential acquirer is located.
Does SEL transfer my personal data outside of the country where I live?
We may transfer and process any personal data you provide to us to countries other than your country of residence. Those countries may not have the same data protection laws as the country of your residence, and your personal data will be subject to applicable foreign laws and regulations. When we transfer your personal data to other countries, we will implement safeguards to protect your personal data required under each applicable laws and regulations. Please see the “Additional Information for the EEA and UK Residents” below for information on transfers from the EEA and UK.
How long will SEL keep my personal data for?
Personal data processed for the Processing Purposes will be stored for a period of up to 6 years and 1 month from collection.
If a judicial or disciplinary action is initiated, the personal data may be stored until the end of such action, including any potential periods for appeal, and will then be deleted or archived as permitted by applicable law.
What rights do I have in respect of my personal data?
As long as it is permitted under applicable data protection regulations, you have a number of rights in relation to your personal data, which can be summarised as follows:
(i) Right of access
You have the right to confirm with us whether your personal data is processed, and if it is, to request access to that personal data including a copy of the personal data processed, the categories of personal data processed, the purpose of the processing and the recipients or categories of recipients. We do have to take into account the interests of others though, so this is not an absolute right.
(ii) Right to rectification
You have the right to request the rectification of inaccurate or incomplete personal data concerning you
(iii) Right to erasure (right to be forgotten)
You may have the right to ask us to erase your personal data.
(iv) Right to restriction of processing
In certain circumstances, you may have the right to request that we restrict processing of your personal data.
(v) Right to data portability
You may have the right to receive personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to request that we transmit that data to another entity.
(vi) Right to object
You may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data by us and we can be required to no longer process your personal data.
(vii) Right to not to be subject to automated decision-making
In certain circumstances, you may have the right not to be subject to solely data-based, automated decision-making (including profiling) that produces any legal or similar material effect on you.
(viii) Right of withdrawal of consent
You may have the right to withdraw your consent for the processing of your personal data, which consent is the legal ground to process your personal data.
To exercise any of these rights, please contact us as stated under below (Who can I contact about this Notice and to exercise my rights?). These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have a compelling legitimate interest in keeping.
You also have the right to lodge a complaint with the competent data protection supervisory authority.
Changes to this Notice
We may have to update this Notice from time to time, notably to make sure that it reflects our current data processing activities. If we update this Notice, we will inform you of such update and will provide you with or access to the updated Notice.
Who can I contact about this Notice and to exercise my rights?
If you have concerns or questions regarding this Notice or if you would like to exercise your rights as a data subject, please reach out to:
Postal address:
Sumitomo Electric Lightwave
201 South Rogers Lane, Suite 100
Raleigh, NC 27610
phone: 1-800-358-7378
CALIFORNIA PRIVACY RIGHTS
Privacy Policy for California Residents
Effective Date: May 11, 2023
This Privacy Policy for California Residents supplements the information contained in the Ribbon Inspector Privacy Notice and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy.
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
In particular, we may collect the following categories of personal information from consumers:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers. | Device identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. | YES |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | NO |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | NO |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | NO |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | YES |
| G. Geolocation data. | Physical location or movements. | NO |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | NO |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you download or purchase.
- Indirectly from you. For example, from observing your actions on our App.
Use of Personal Information
We may use, or disclose the personal information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
- To provide, support, personalize, and develop our App, products, and services.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- For testing, research, analysis, and product development, including to develop and improve our App, products, and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We do not sell to or share personal data with any third party. In the preceding twelve (12) months, SEL has not disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.
We do not sell or share personal information. For more on your personal information sale rights, see Personal Information Sales Opt-Out Rights.
| Personal Information Category | Category of Third-Party Recipients | |
|---|---|---|
| Business Purpose Disclosures | Sales | |
| A: Identifiers. | None | None |
| B: California Customer Records personal information categories. | None | None |
| C: Protected classification characteristics under California or federal law. | None | None |
| D: Commercial information. | None | None |
| E: Biometric information. | None | None |
| F: Internet or other similar network activity. | None | None |
| G: Geolocation data. | None | None |
| H: Sensory data. | None | None |
| I: Professional or employment-related information. | None | None |
| J: Non-public education information. | None | None |
| K: Inferences drawn from other personal information. | None | None |
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- We do not sell or share personal information. If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
- The specific pieces of personal information we collected about you (also called a data portability request).
Right to Delete
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a request by either:
- Calling us at 1-800-358-7378
- Contacting us via mail at:
Sumitomo Electric Lightwave
201 South Rogers Lane, Suite 100
Raleigh, NC 27610
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. You may only submit a request to know twice within a 12-month period. Your request to know or delete must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
- Providing two data points that you provide against information we may have about you.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
You do not need to create an account with us to submit a request to know or delete.
We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.
For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact SEL at 1-800-358-7378.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
No Personal Information Sales or Sharing
We do not sell or share any information collected about you. We do not sell or share the personal information of consumers we actually know are less than 16 years old.
Changes to Our Privacy Policy
We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the App and update the notice’s effective date. Your continued use of our App following the posting of changes constitutes your acceptance of such changes.
Contact Information
If you have any questions or comments about this notice, the ways in which SEL collects and uses your information described here and in the Ribbon Inspector Privacy Notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Phone: 1-800-358-7378
Postal Address:
Sumitomo Lightwave Corporation
Attn: Customer Service
201 South Rogers Lane, Suite 100
Raleigh, NC 27610
Additional Information for the EEA and UK Residents
Legal grounds to process personal data
We process your personal data for the following purposes on the following legal grounds.
• Providing the App to our customers and end users; This processing is necessary for us to perform the contract to which you are party. Where we do not have a contract with you directly, we will process your personal data based on our legitimate interest in providing the App to our customers and end users.
• Developing and improving App and products and services; This processing is based on the legitimate interest of us to develop or improve the Appand other products and services.
• Administering and managing our contractual relationship with our customers; This processing is necessary for us to perform the contract to which you are party.
• Communicating with you about the products and services offered by us, including, without limitation, responding to your enquiries, requests and complaints; This processing is based on our legitimate interest in communicating with you about our products and services.
• Analysis of user’s activity for marketing purposes; This processing is based on our legitimate interest in understanding how users interact with our products and services.
• Sending direct marketing communication to you; This processing is based on your consent when it is required by law. In some cases, we will rely on legitimate interest to send direct marketing communication to you, but you will always have the right to opt-out of direct marketing. You can do this by following the instructions within the communication itself, or contacting us at the details set out above.
• Complying with applicable laws, regulations and other requirements (e.g. providing assistance to law enforcement agencies, regulatory authorities and other governmental agencies); This processing is based on legal obligation if the applicable law is the EU or the UK law. If this is not the case, then this processing will be based on our legitimate interest in assisting law enforcement and government and regulatory authorities.
• Carrying out any other purpose described to you at the time the information was collected; The legal grounds shall be notified separately.
Legal grounds to transfer personal data outside the EEA or UK
The European Commission and the United Kingdom have each adopted an adequacy decisions regarding Japan. We therefore rely on the EU and UK Japan adequacy decision when we transfer your personal data to Japan.
To transfer personal data to countries other than the country to which adequacy decision is made, we will execute the standard contractual clauses (Article 46.2 of GDPR or UK GDPR). Please contact us at any time if you would like to know more about details regarding the safeguards we have in place for transfers of personal data outside the EEA or the UK.
EU and the UK Representative
SEI’s representative in the European Union is Sumitomo Electric Europe Ltd. (Italy Branch), a branch of a company incorporated under England and Wales law, whose office is located at Via Belvedere 45, 22100 Como Italy.
SEI’s representative in the UK is Sumitomo Electric Europe Ltd., a company incorporated under England and Wales law, whose office is located at Unit 220, Centennial Park, Elstree, Hertfordshire, WD6 3SL, U.K.