- Information We Collect
- How We Use the Information We Collect
- “Do Not Track” Requests
- How We Share Your Information with Third Parties
- International Transfers of Data for Processing
- Third Party Features and Websites
- Security; Breach; PCI DSS
- Accessing, Correcting, Updating, Transferring, Restricting, Removing & Retaining Your Information
- Preferences and Opting-out
- Use by Children
- Changes to this Policy
- Data Protection Officer
- Questions? Complaints? How You Can Contact Us
Websites, which include our websites listed here (collectively referred to as “Websites”);
Mobile applications, including, without limitation, Inkspace App, Bamboo Paper, Bamboo Note, Wacom Ink Note, and sign pro PDF (collectively, “Apps”); and
Other software, products and support, including when you interact with us through the Websites, or by phone, email, live chat and social media such as Facebook, Twitter and Google+ (collectively “Support and Other Services).
The Websites, Apps, and Support and Other Services are collectively referred to herein as the “Services.” This Policy discusses how we use your information and how you may interact with us regarding that information.
Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is to not use our Services. By accessing or using the Services, you agree to this Policy.
1. Information We Collect
We collect information from you in several ways. You provide us with certain information when you create a Wacom Account, register for, download, or access and otherwise use our Services. We also collect certain information automatically as you interact with our Services. We may also receive information about you from other sources. We may collect personal information from you when you register as a user or to learn more about our products, request a demo or evaluation period, provide comments and suggestions, sign up for newsletters, enter competitions and promotions, interact with us on our social media channels, order Apps, products or services, request and utilize maintenance and support services, request white papers, sign up for events or seminars, submit content, apply for a job or send us feedback. If you do not want us to collect this information, please do not provide it, but you may not be able to take advantage of our Services or certain features of our Services. For example, where we need to collect information to perform under a contract we have with you and you fail to provide that information when requested, we may not be able to provide you with the contracted for goods or services. Examples of information we directly collect from you include:
1.1. Information You Provide to Us
1.1.1. User information. This means information collected about users of the Services and includes contact information such as the user’s name, e-mail address, mailing address, phone number, password, or other information that you might provide to us in an online form, on a warranty card, or when you contact us by live chat, e-mail or telephone. It includes any content you may create and file, upload or otherwise store on our Services or requests, questions, comments or reviews you may share with us or others who use our Services including through social media. It also includes information that you provide to us in order to purchase goods, license software, pay for Apps or otherwise register, pay for or deliver Services, including payment information, VAT ID and delivery address. It also includes recordings of your communications with customer support.
1.1.2. Business account information. This means business-contact information such as name, title, job function, business name, business address, business e-mail address, and business phone number that we collect about people we serve or work with, including actual and prospective customers, alliance and channel partners, contractors, vendors and other parties interested in Wacom or its products and services.
1.1.3. Affiliates. We may collect information about you from our subsidiaries and corporate affiliates, joint venture partners, or other companies that are or may become under common control with us (our “Affiliates”). A list of our Affiliates can be found here (We and our Affiliates are collectively referred to as the “Wacom Group”).
1.1.4. Job applicants. We may collect information about you during the application or recruitment process, including your name and contact details, your qualifications, skills, references, current and preferred benefits, salary, your CV, cover letter, work experience, education, transcripts, information you provide us when submitting applications or participating in interviews, whether you have a disability for which the organization needs to make reasonable adjustments, information about your ability to work in the specified location, information about moving, information from your passport, driver’s license or other identity or credential documents and other information required by law or deemed necessary by us to evaluate your candidacy. We may process special categories of data when relevant for a position and permitted by law. If we collect special categories of data, you will be provided notice and the opportunity to consent to processing as described at the point of collection and this Policy. If you do not provide us with requested information during the recruitment process, we may not be able to process your job application properly, or at all.
1.2. Information We Automatically Collect from You When You Use the Services. The information we collect automatically is statistical information and may include personal information, or we may maintain it or associate it
with personal information we collect in other ways or which we may receive from third parties. If you do not want us to collect this information, please do not use the Services.
1.2.1. Information collected through our cookies. Cookies are small amounts of data that are stored within your Internet browser, which saves and recognizes your browsing habits. Web beacons, which are also called pixel tags or clear GIFs are small web page elements. Wacom uses both session cookies (which track a user’s progression during one site visit) and persistent cookies (which track a user over time). We, or service providers on our behalf, may use technologies, including “cookies” and “web beacons,” to automatically collect information from you when you use the Services. We collect this information to, among other things, improve our Services and your experience, see which areas and features of our Services are popular and count visits, provide you targeted advertising based upon your interests and to analyze trends, administer our Websites, track users’ movements around our Websites, gather demographic information about our user base as a whole, and to remember users’ settings and for authentication purposes. Our collection and processing of cookies is described in greater detail in our Cookie Notice which may be found here.
We also use web beacons to help deliver cookies, count visits, track browser type, identify your IP address, understand usage and marketing campaign effectiveness, recognize certain types of information on your computer, in your email or on your mobile device, such as the time and date you viewed a page, which emails are opened, which links are clicked, and similar information.
1.2.2. Log files. As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses and usage data such as browser type, browser language, device identifier, Internet service provider (ISP), referring/exit pages, length of visit, pages viewed, operating system, date/time stamp, clickstream data, crashes, system activity, hardware settings, the date and time of requests, referral URL and other usage data. We may combine this automatically-collected log information with other information we collect about you. If you reach out to us over the telephone or via facsimile, we may also log telephony information such as your phone number, forwarding calls, SMS routing information and types of calls.
1.2.3. Services Use. We may use technologies to automatically collect information from your use of the Services, including without limitation metadata from your use of our cloud-hosted Services. We collect this information to analyze and benchmark your use of the Services. Such information may also be used to generate reports for trends, usage, administration, and other usage with the Services, both for your individual use, as well as our customer user base as a whole. We may also use this information to improve or create new products and services and to make recommendations to you and our customers about how to better use our products and services.
1.2.4. Mobile Applications. When using the Services, we may automatically collect information about the devices running our software, such as the type of device, the version of the operating system, and the device identifier (or "UDID"). We use analytics to allow us to better understand how our mobile Services are used by our customers. We may record information such as how often the application is used, the events that occur within the application, aggregated usage, performance data, any exceptions that occur within the software and the source from which the application was downloaded.
1.2.5. Device Information. When you use our Services, we collect information about the devices you are using to access our Websites and our Services, including without limitation information about your computers, tablets, phones, stylus, pen, or other tools. We may collect the hardware model, operating system and version, unique device identifiers and mobile network information.
1.2.6. Local Storage of Information. Our Services may collect and store information locally on your device, including without limitation browser web storage and application data caches.
1.3. Information We Get from Others. If you choose to login to our Services using social media accounts, we will receive your name and email address and in some circumstances your social media handle. We receive information about you from third parties who support our Services including our payment processor, third party marketplaces and other providers in our sales channel. We may add this third party provided information to the information we collect on you from our Websites. If you apply for a position with us, we may request and receive information about you from references, your schools, your employers and others in compliance with applicable laws and regulations. We will comply with the terms of this Policy with regard to our use of this information.
2. How We Use the Information We Collect
We may use information collected from or about you for any of the following purposes:
2.1. How We Use Your Information under GDPR. If our processing of your information is subject to the General Data Protection Regulation 2016/679 (“GDPR”), we use your information according to the
2.1.1. We will use your information when it is necessary for us to perform a contract we are about to enter into or have entered into with you, including without limitation when we respond to your requests about entering into a contractual relationship, to help you create an account, to process your orders, to manage our relationship with you, to help you participate in and to process your contest or sweepstakes entry or pay a reward.
2.1.2. We will use your information where needed to comply with a legal or regulatory obligations, including without limitation, to comply with job applicant reporting or background check obligations and to manage our relationship with you by providing this Policy and any changes and updates thereto.
2.1.3. We will use your information where necessary for our legitimate interests or those of a third party’s, and your interests and fundamental rights do not override those interests, including without limitation, to process and deliver your orders, to manage our relationship with you, to enable you to participate in a contest, sweepstakes, reward or prize, to administer and protect our business and our Services, to deliver the Services, content and advertisements to you and to evaluate the effectiveness of the Services, content and advertising, to tailor the Services, content and advertising, to use data analytics and other automated processing to evaluate and improve the Services, to make recommendations to you and to process your job applicant and related information when you participate in the recruiting process.
2.1.4. We will use your information when we have provided you with notice of processing and obtained your consent in a manner compliant with the requirements set forth in GDPR, including without limitation allowing you to opt-in and opt-out of the marketing of our Services to you. You may withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
We may rely on more than one lawful basis for processing your specific information described in Section 1 of this Policy for the uses set forth in this Section 2.
2.3. To provide services to you. We may use the information to provide and manage the Services, communicate with you about our Services, and fulfill any contractual obligations we otherwise have with you. These may include reports, consulting, educational, training, maintenance and support services for which you have inquired or contracted. For instance, as part of support services, our technical staff may require periodic access to Services data to troubleshoot or monitor your system. We may provide technical support and related product information via our Websites. We may require access to your systems to implement our Software or Apps. Any temporary copies of data accessed, used or created as a necessary part of these services are only maintained for time periods relevant to those purposes. As part of these services, we may be required to remotely access your systems or an individual computer in order to troubleshoot a support issue or have direct physical access as part of an onsite engagement. We may also use this data to provide you service and product updates and notices, security alerts, support and administrative messages. We record all calls for support, and we may keep a record of your communications and ours to provide improved customer service to you and others. We may use your information to otherwise support your account, including performing accounting functions. We may also use your information to customize your interaction with our Websites, to provide you with more relevant information and advertisements, and to provide any necessary customer service and carry out any other purpose for which the information was provided by you (subject to applicable data protection laws).
2.4. To provide informational services. We may use your information while providing online forums such as user groups and bulletin boards. We may also do so while delivering live or online events such as training seminars or conferences, including third party events sponsored by Wacom.
2.5. Prevent improper or illegal activity. We may use information to protect, investigate and deter against fraudulent, unauthorized or illegal activity.
2.6. To meet legal requirements. Wacom may be required to provide personal information to comply with legally mandated reporting, subpoenas, court orders, or other legal process requirements.
2.7. To market and improve our products and services and to create new products and services. We may inform you about our products, services or events and otherwise perform marketing activities. We may conduct surveys about our Services and your use of our Services. Further, we may use information for analytics purposes and to operate, maintain and improve our products and services. We may also use information to create new products and services.
2.8. Verify users. We may use personal information to manage and verify your account and the identity of users of the Services.
2.10. Job applicants. We may use your information to comply with applicable laws and regulations, to negotiate and enter into an employment agreement with you, to process your job application and evaluate your candidacy, for our record keeping, analyzing the job recruitment process and other employment related processing, including retaining information for alternate job positions. We may use your information to make reasonable adjustments for candidates with a disability. We may also use your information to seek appropriate consent when legally required for processing special categories of data.
2.11. Other purposes. We may use your information for any other legal, business or marketing purposes that are not inconsistent with the terms of this Policy.
2.12. But not for sale or rent. Wacom does not sell or rent your information to third parties.
3. “Do Not Track" Requests. Your Internet browser and mobile device may allow you to adjust your browser settings so that “do not track” (DNT) requests are sent to the websites you visit. Wacom respects your wishes and will not track user activity once DNT signals have been activated. However, our third party service providers may not respond to DNT signals.
4. How We Share Your Information with Third Parties. Wacom may disclose your information in the following circumstances:
4.1. Business Partners, Resellers and Subcontractors. Wacom may share information with business partners, resellers and subcontractors (such as third party distributors and resellers, vendors, suppliers and other service providers), who may use the information to fulfill product orders, process payments, develop and improve products, contact you about product orders or in connection with the performance, operation, and support of the Services or solutions, performing marketing or consulting services, respond to your requests or as otherwise appropriate in connection with a legitimate business need. Further, we may disclose personal information to service providers who host or facilitate the delivery of online training, seminars and webinars; email-delivery services and other technology providers; and third parties that may assist in the delivery of marketing materials, technical support services or other products, services or information. We also share information with our third party payment processor.
Onward transfers to third party service providers who are our processors will be made in accordance with all applicable data protection laws. These third party processors are only authorized to use your information as necessary to provide the respective service. We may also share your information at your request or as a consequence of your choices with (i) business partners, resellers and independent software vendors from which you purchase products or services or license mobile applications, software or a software service via our Websites; (ii) the operator of a social media network (e.g., YouTube, Facebook, Twitter, Tumblr, Pinterest, LinkedIn and Instagram) with whom you share content; or (iii) the operator of a third party communications or storage provider with whom you share content via email, cloud storage, photo storage, or any other third party with whom you have chosen to export your content.
4.2. Third Party Analytics Providers. To third parties who conduct marketing studies and data analytics, including those that provide tools or code which facilitates our review and management of our Services, such as Google Analytics or similar software products from other providers. For example, we use Google Analytics to analyze usage to our Services (e.g., our products, Websites and Apps). We may also use Google Analytics in conjunction with Google’s advertising services, such as those using the DoubleClick cookie. With this capability, we or Google may link Google Analytics information with information about visits to multiple sites. We use these tracking technologies to provide tailored advertising and evaluate our marketing efforts. For more information about how Google collects and processes data when you visit websites or use apps that use Google technologies, please see “How Google uses data when you use our partners' sites or apps” at www.google.com/policies/privacy/partners
4.5. To Our Affiliates. We may share some or all of your information with our Affiliates. We will require all entities to comply with the terms of this Policy with regard to their use of your information.
4.6. Publicly Posted Content. If you post comments, images, and other content to a location which is public-facing, including any public-facing Websites, Apps, storage locations, or social media, your posted information will be publicly viewable.
4.7. With Your Consent. We may share some or all of your information to any other third party with your affirmative consent. For instance, we display personal testimonials of satisfied customers on our Websites in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at email@example.com.
4.8. Anonymized Data. We may share information that has been anonymized with others for their own uses, in accordance with applicable laws and regulations.
4.9. Job Application Data. If your application is successful, we may share your job applicant information with our Affiliates and with other third parties to obtain references, perform background checks and other actions necessary for the employment process.
5. International Transfers of Data for Processing
Please be aware that any information processed under this Policy may be transferred to or from another country or territory which provides different or less comprehensive privacy and/or security protections for the information.
Because of the global nature of our business, a cooperation among the Affiliates in the Wacom Group is established with respect to certain parts of the Services. As a consequence, when certain information is shared within the Wacom Group, information relating to you might be processed outside of your local jurisdiction, including without limitation in the United States, the European Economic Area (EEA) and/or Japan. All information collected and transferred under this Policy to other Affiliates in the Wacom Group will remain subject to this Policy and applicable data protection laws and regulations.
Also, many of our third party processors are based in different jurisdictions, including the United States, the EEA and/or Japan. Information transferred to our processors will contractually be required to comply with the obligations set forth in this Policy.
Whenever we transfer your information out of the EEA to one of our processors, we will ensure that at least one of the following shall apply: (i) the transfers will be to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; (ii) we have used specific model contracts approved by the European Commission which are intended to give personal data the same protection it has in Europe; (iii) where we use providers based in the US, we may transfer information to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US; or (iv) any alternative transfer mechanism that can under GDPR lawfully support the transfer. Please contact us as provided for in this Policy if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
6. Third Party Features and Websites
7. Security; Breach; PCI DSS
Wacom takes reasonable and appropriate precautions to help protect your information, taking into due account the risks involved in the processing and the nature of the information.However, given the nature of the internet and the fact that network security measures are not infallible, we cannot guarantee the security of your information.
When registering for access to a secure area of one of our Services, we will ask you to select a username and password. We recommend that you do not divulge your password to anyone. We will never ask you for your password in an unsolicited phone call or in an unsolicited email. Also, remember to sign out of the Service and close your browser window, your software, application or other Service when you have finished your work. This is to ensure that others cannot access your information and correspondence when accessing your computer.
When you make a payment at our Websites, we comply with our obligations under the Payment Card Industry Data Security Standard (PCI DSS), and we ensure that any third party service providers to our Services who process customer credit cards also comply with the requirements set forth in the PCI DSS.
Any sharing of your information with third party processors who are operating at our instruction will be made in accordance with applicable data protection laws. These third party processors will be required to comply with appropriate security and breach notification measures to protect your information.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
If you have any questions about the security of our Services, you can contact us at firstname.lastname@example.org.
8. Accessing, Correcting, Updating, Transferring, Restricting, Removing & Retaining Your Information
You may access, modify, amend, restrict or remove your Wacom Account data by logging into your Wacom Account and accessing your Wacom Account info. You may transfer, restrict or remove your account by contacting us by email at email@example.com.
Furthermore, you are entitled to request information about the personal data we store about you at any time. You may also request to correct, update or remove information about yourself at any time. For any such request you may contact us by email at firstname.lastname@example.org. If your information is provided to us by your employer,you should direct your requests to your employer.
You will not have to pay a fee to access your information; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We will retain your information and the data we process on behalf of our customers as necessary to fulfill the purposes for which we have collected the information, for as long as your Wacom Account is active, as needed to provide you our Services or to comply with legal or regulatory obligations. We will retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you delete any of your Wacom Account information, we may retain certain information if required by law or for legitimate business purposes or to complete our contractual obligations to you.
If you become an inactive customer, or if we close or suspend your Wacom Account, we will continue to adhere to the then current Policy when we collected your information so long as we retain it in our possession.
If your application for a job is successful, your information gathered during the recruitment process will be transferred to your human resources files subject to our internal human resources policies and procedures and retained as employment data. If your application is unsuccessful, we may, with your consent, keep your information on file for future employment opportunities. You may withdraw your consent at any time.
We may delete any or all of your information at any time without notice to you for any reason or no reason unless otherwise required by law or contract to retain it.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your information (or to exercise any of your other rights). This is a security measure to ensure that your information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We will attempt to respond to any request to access your information within 30 days. It may take us longer if your request is complex or you have made multiple requests in which circumstances we will notify you and keep you apprised of our progress.
9. Preferences and Opting-Out
Our Services provide visitors and customers the opportunity to opt-out of receiving specific types of communications from us and our partners at the point where we request information about the visitor or customer. In addition, if you have previously signed up to receive information about our Services, you may unsubscribe or opt out of all future marketing communications from us that do not relate to products or services you have already ordered by removing your contact and other information from our marketing and communications databases by (a) sending an email to email@example.com; or (b) clicking the unsubscribe link on any email marketing communication you receive.
10. Use by Children
Our policy is that we do not knowingly directly collect, use, disclose or otherwise process information about you if you are under the age of 16 without verifiable parental consent prior to such processing. If you are the parent or guardian of a child under 16 years of age and believe that your child has directly disclosed information to us, then please contact us at firstname.lastname@example.org so that we may delete the child’s information. We may process information about you if you are under the age of 16 under the instruction of our customers and such processing shall be subject to our customer’s privacy policies.
11. Changes to this Policy
We reserve the right to modify this Policy at any time, so we encourage you to review it frequently. If we make a material change to this Policy, we will notify you by email or by means of a notice on our Websites prior to the changes taking effect. We will post any modifications or changes to the Policy on our Websites. It is your responsibility to keep current your contact information that we have on file.
12. Data Protection Officer
You may reach our Data Protection Officer at email@example.com. You can also write to our Data Protection Officer at the following address:
Wacom Europe GmbH
Attention: Data Protection Officer
Völklinger Str. 1, 40219 Düsseldorf, Germany
13. Questions? Complaints? How You Can Contact Us
If you have any questions or concerns about this policy, or you want to object to or restrict any processing of your information, please contact us at firstname.lastname@example.org.
You can also write to us at the following address.
Wacom Europe GmbH
Attention: Data Privacy
Völklinger Str. 1, 40219 Düsseldorf, Germany
You have the right to reach out and communicate with a supervisory authority (i.e., an independent public authority which is established by a Member State) to lodge a complaint, but we would appreciate the opportunity to speak with you first and resolve your issues.