Privacy Policy

Last updated: April 26th, 2022

1. About this Policy

This Privacy Policy (“Policy”) is to ensure that you (“User” or “You”) understand the type of information acquired, the use of this information and the purpose of this use, the methods used by Ricoh Company, Ltd. (“RICOH” or “We”) for handling your personal data in “RICOH360” (“Services”), which are provided by RICOH and the related websites managed by RICOH (“Websites”). RICOH360 Service includes “RICOH360 Tours” (“RICOH360 Tours Service”) and “RICOH360 Projects” (“RICOH360 Projects Service”). The terms of User and You include potential customers of the Services (“Potential Users”).

Additional information on our personal data practices may be provided in other notices provided prior to or at the time of data collection. The Services and Websites may have their own documentation describing how we handle personal data for the Services or Websites specifically. To the extent a specific notice or documentation for the Services or Websites differs from this Policy, the specific notice or documentation will take precedent.

“Personal Data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Some terms of this Policy are applicable to users of the Services (“European Users of the Services”) whose personal data is protected by the General Data Protection Regulation (“GDPR”).

Some terms of this Policy are applicable to users of the Services located in Japan (“Japanese Users of the Services”).

Some terms of this Policy are applicable to users of RICOH360 Tours Service only (“Tours Users”) and users of RICOH360 Projects Service only (“Projects Users”) respectively.

2. Management of Personal Data

RICOH has stipulated that Personal Data used for business operations will be handled under appropriate protection in accordance with laws and regulations in the Ricoh Group Code of Conduct and the Ricoh Group Personal Information Protection Basic Regulations, which is one of the Ricoh Group Standard. RICOH implements appropriate safety management measures to laws and regulations, guidelines and those internal regulations to prevent leaking, loss, destruction, etc. of Personal Data, and works to protect Personal Data retained by RICOH. RICOH also trains its employees on appropriate handling of Personal Data, etc. and works to fully ensure the protection of this information.

3. Acquisition and Purposes of Use of Personal Data

RICOH will acquire your Personal Data when you provide such Personal Data to us, automatically through the Services and Websites, or through third parties such as our distributors and use your Personal Data within the necessary scope for the purposes stated below.

List of Types of Acquired Information and Purposes of Use

RICOH will process your Personal Data only for fair, lawful and legitimate reasons. The table below lists data subject categories, types of Personal Data and the purposes for processing such Personal Data.

(1) (only for Potential Users)

Type of acquired information: RICOH collects your email address, name, company name, phone number and other personal information when you inquire about the Services or contact RICOH.
Purpose of use: The email address, name, company name, phone number and other personal information is needed to provide information and proposal related to the Services, contact for business negotiations and meetings, and respond to your inquiries.
Legal Basis (only for European Users of the Services): Processing is necessary for taking measures in response to your requests before concluding the contract, Art. 6 (1) (b) GDPR.
Duration: Personal Data will be processed for the duration of the legitimate business needs.
Remarks: Personal Data in this item will be handled in accordance with the provisions of item 2 or later items of this Chapter 3 after the conclusion of the contract between you and RICOH.

(2)

Type of acquired information: RICOH collects your email address, name, company name, phone number and other personal information when you create your Account for using the Services.
Purpose of use: The email address, name, company name, phone number and other personal information is needed to identify and allocate users to specific Service accounts.
Legal Basis (only for European Users of the Services): Processing is necessary for the performance of the contract, Art. 6 (1) (b) GDPR.
Duration: Personal Data will be processed for the duration of the contractual relationship between you and RICOH.

(3) (only for Tours Users)

Type of acquired information: Ricoh collects email address, name, address, phone number and other personal information of your contact information shared on RICOH360 Tours Service.
Purpose of use: The email address, name, address, phone number and other personal data of your contact information is needed to share the data with other users of RICOH360 Tours Service.
Legal Basis (only for European Users of RICOH360 Tours Services): Processing is necessary for the performance of the contract, Art. 6 (1) (b) GDPR.
Duration: Personal Data will be processed for the duration of the contractual relationship between you and RICOH.

(4) (only for Tours Users)

Type of acquired information: Ricoh collects the User Name chosen by each user. If you choose your real name, it includes personal data. Instead of using your real name, you are free to choose a pseudonym as User Name as well.
Purpose of use: The User Name is needed to identify and allocate users to specific Service accounts. We further process your User Name in connection with your public 360-degree photos or videos to display it publicly as your User Account. It is necessary to provide RICOH360 Tours Service.
Legal Basis (only for European Users of RICOH360 Tours Service): Processing is necessary for the performance of the contract, Art. 6 (1) (b) GDPR.
Duration: Personal Data will be processed for the duration of the contractual relationship between you and RICOH.

(5)

Type of acquired information: RICOH automatically collects your IP Address, device profile and other personal data when using the Services.
Purpose of use: The IP address, device profile and other personal data is needed to provide the Websites to you. This information is collected to administer the Websites under your terms and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
Legal Basis (only for European Users of the Services): Processing is necessary for the performance of the contract, Art. 6 (1) (b) GDPR.
Duration: Personal Data will be processed for the duration of the contractual relationship between you and RICOH.

(6)

Type of acquired information: Ricoh collects and stores your 360-degree photos or videos, location, and other information related to the photos uploaded and shared on the Services.
Purpose of use: The collection of your photos, location and other information related to the photos that is necessary to provide the Services, e.g. for you to upload and share its photos with other users of the Services. Each of your photos and videos contain its own Universally Unique Identifier (UUID), which allows the system to identify the respective photos. When you share your photo with third parties, the system requires the UUID to allocate the photo and to display it to the third person using the URL. Thus, we process your photo UUID in connection with your 360-degree photos or videos to convert it into a URL to give you the opportunity to share your 360-degree photos or videos with others. Please note that for technical reasons due to the nature of the composition of the respective URL, your photos and videos can be shared with third parties who merely try out UUIDs taking into account the conversion logic to compose a URL.
Legal Basis (only for European Users of the Services): Processing is necessary for the performance of the contract, Art. 6 (1) (b) GDPR.
Duration: Personal Data will be processed for the duration of the contractual relationship between you and RICOH. When you delete your 360-degree photos or videos from the Services, RICOH will no longer process such content.

(7)

Type of acquired information: RICOH collects your contact form, chat history, email address and other personal information when you send a support request.
Purpose of use: This information is collected to administer the Websites under your terms and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
Legal Basis (only for European Users of the Services): Processing is necessary for the performance of the contract, Art. 6 (1) (b) GDPR. Processing is necessary for the performance of the contract (Art. 6 (1) (f) GDPR), particularly in order to improve the Services and their functionality.
Duration: Personal Data will be processed for the duration of the contractual relationship between you and RICOH.

(8)

Type of acquired information: RICOH collects your email address, name, company name, phone number, subscription type, subscription change history, access time and other personal information when you subscribe the Services.
Purpose of use: This information is collected to administer the Websites under your terms and for internal operations and to use marketing and promotions for your use of the Services.
Legal Basis (only for European Users of the Service): Processing is necessary for the performance of the contract (Art. 6 (1) (f) GDPR), particularly in order to improve the Services and their functionality.
Duration: Personal Data will be processed for the duration of the contractual relationship between you and RICOH.

(9)

Type of acquired information: RICOH collects your amounts of payments, payment statuses and other related information related your payment except your credit card and card brand.
Purpose of use: This information is collected to administer the Websites under your terms and for internal operations and to use marketing and promotions for your use of the Services.
Legal Basis (only for European Users of the Services): Processing is necessary for the performance of the contract, Art. 6 (1) (b) GDPR. Processing is necessary for the performance of the contract (Art. 6 (1) (f) GDPR), particularly in order to improve the Services and their functionality.
Duration: Personal Data will be processed for the duration of the contractual relationship between you and RICOH.

(10) (only for Tours Users)

Type of acquired information: Ricoh collects name, address, phone number and other personal information as your delivery address information when you order goods.
Purpose of use: The name, address, phone number and other personal data as your delivery address information is needed to deliver the goods to you.
Legal Basis (only for European Users of RICOH360 Tours Services): Processing is necessary for the performance of the contract, Art. 6 (1) (b) GDPR.
Duration: Personal Data will be processed for the duration of the contractual relationship between you and RICOH.

Legal Grounds for Our Processing of Your Personal Data. The legal basis on which we process your Personal Data is as follows:

Where it is necessary to obtain your prior consent to the processing concerned in order for us to be allowed to do it, we will obtain and rely on your consent in relation to the processing concerned (see below for how to withdraw your consent at any time).
We will process your Personal Data where the processing is necessary:

for the performance of a contract to which you are a party to or in order to take steps at your request prior to entering into such a contract;
for compliance with a legal obligation to which we are a subject; or
for the purposes of the legitimate interests pursued by us or another person, provided that this will only be in circumstances in which those legitimate interests are not overridden by your interests or fundamental rights and freedoms which require protection of Personal Data. For further details regarding legitimate interests, please contact us.

In addition, we will process your Personal Data when such processing is permitted under the laws and regulations of each country.

Data Retention. RICOH processes Personal Data only for so long as it is necessary for the purpose(s) for which it was originally collected, after which it will be deleted or archived except to the extent that it is necessary for us to continue to process it for the purpose of compliance with legal obligations to which we are subject to or for another legitimate and lawful purpose.

Merger, Split-up, Business Transfer, etc. When a certain business is transferred to RICOH through merger, split-up, business transfer, etc. so that Personal Data is provided to RICOH, RICOH will use the Personal Data within the scope to which the individual has given consent, or within the scope necessary for accomplishing the purposes of use having been notified or announced before the transfer.

4. Provision of Personal Data to a Third Party

RICOH will not provide Personal Data to third parties except in the following cases:

(1) If prior consent has been received from you,

(2a) [only for European Users of the Services]

Provision to our business partners, including sub-contractors and suppliers with appropriate supervision from RICOH to fulfil a purpose of use:

RICOH transfers Personal Data to its processor and hosting provider, Amazon Web Services, Inc., in the United States of America. This is necessary for the provision of the platform and, thus, for the fulfilment of the Terms of Use, Art. 6 (1) lit. b GDPR.
The transfer of Personal Data to Amazon Web Services, Inc. in the United States of America is conducted under an adequate level of data protection as compared to the GDPR, because Amazon Web Services, Inc. has certified itself under the EU-US-Privacy Shield and is governed by standard contractual clauses.
RICOH transfers Personal Data to its processor, mailing service providers, in the United States of America, who conduct the mailing service for the Services on RICOH’s behalf. This is necessary for the provision of the platform and, thus, for the fulfilment of the Terms of Use, Art. 6 (1) lit. b GDPR.
RICOH transfers Personal Data to its processor, support service providers, in the United States of America or United Kingdom who conduct the support communication service for the Services on RICOH’s behalf. This is necessary for the provision of the platform and, thus, for the fulfilment of the Terms of Use, Art. 6 (1) lit. b GDPR.
RICOH transfers Personal Data to its processor, analysis service providers, in the United States of America, who conduct the analysis service for the Services on RICOH’s behalf. This is necessary for the provision of the platform and, thus, for the fulfilment of the Terms of Use, Art. 6 (1) lit. b GDPR.
RICOH transfers Personal Data to its processor, data integration service providers, in the United States of America, who conduct the data integration service for the Services on RICOH’s behalf. This is necessary for the provision of the platform and, thus, for the fulfilment of the Terms of Use, Art. 6 (1) lit. b GDPR.
RICOH transfers Personal Data to its processor, payment service providers, in the United States of America and Canada, who conduct the payment service for the Services on RICOH’s behalf. This is necessary for the provision of the platform and, thus, for the fulfilment of the Terms of Use, Art. 6 (1) lit. b GDPR.
RICOH transfers Personal Data to its processor, VAT payment service providers, in Europe and Japan, who conduct the VAT payment service for the Services on RICOH’s behalf. This is necessary for the provision of the platform and, thus, for the fulfilment of the Terms of Use, Art. 6 (1) lit. b GDPR.
RICOH transfers Personal Data to its processor, delivery service providers in Japan, who deliver the goods to you on RICOH’s behalf. This is necessary for the provision of the platform and, thus, for the fulfilment of the Terms of Use, Art. 6 (1) lit. b GDPR.
Amazon Web Services, Inc. has certified itself under the EU-US-Privacy Shield, is governed by standard contractual clauses and therefore the transfer of Personal Data to mailing service providers, support service providers, analysis service providers, data integration service providers and payment service providers in the United States of America is conducted under an adequate level of protection in accordance with the GDPR.

(2b) [for the Users except European Users of the Services]

Provision to our business partners, including sub-contractors and suppliers with appropriate supervision from RICOH to fulfil a purpose of use. You hereby consent to international transfers for the following uses:

RICOH transfers Personal Data to its processor and hosting provider, Amazon Web Services, Inc., in the United States of America.
RICOH transfers Personal Data to its processor, mailing service providers, in the United States of America, who conducts the mailing service for the Services on RICOH’s behalf.
RICOH transfers Personal Data to its processor, support service providers, in the United States of America or United Kingdom, who conducts the support communication service for the Services on RICOH’s behalf.
RICOH transfers Personal Data to its processor, analysis service providers, in the United States of America, who conducts the analysis service for the Services on RICOH’s behalf.
RICOH transfers Personal Data to its processor, data integration service providers, in the United States of America, who conducts the data integration service for the Services on RICOH’s behalf.
RICOH transfers Personal Data to its processor, payment service providers, in the United States of America and Canada, who conducts the payment service for the Services on RICOH’s behalf.
RICOH transfers Personal Data to its processor, indirect tax payment service providers, in Europe and Japan, who conduct the indirect tax payment service for the Services on RICOH’s behalf.
RICOH transfers Personal Data to its processor, delivery service providers in Japan, who deliver the goods to you on RICOH’s behalf.

(3) If the Personal Data is required to protect human life, limb, or property, and it is difficult to obtain the consent from you.

(4) If it is particularly necessary to improve public health or promote the sound development of children, and it is difficult to obtain the consent from you.

(5) If it is necessary to cooperate with a national agency, local public entity, or a person entrusted thereof with carrying out the affairs prescribed by laws and regulations, and there is risk that obtaining the consent from you will interfere with the execution of said affairs.

(6) If a judicial or administrative organization demands provision of Personal Data according to laws and regulations.

(7) If the recipient third party is an academic research institution, etc., and it is necessary for such third party to use the Personal Data for academic research purposes (including situations were a part of the purpose of using Personal Data is for academic research purposes but excluding situations where there is a risk of unfairly infringing on your rights and interests).

(8) If RICOH provides the Personal Data to other parties because of merger, split-up, business transfer, etc.

(9) RICOH may share your Personal data with our subsidiaries, joint ventures, or other companies under a common control (“Affiliates”). The Personal Data we may share with such Affiliates are limited to necessary data, such as name, company name, address, phone number, email address, contract information, purchase history, payment information, IP address, etc. and the purpose of use by such Affiliates are described in the purpose of use described in Chapter 3 of this Policy. The data is managed responsibly by our representative described in Chapter 7 of this Policy. We will require our Affiliates to honor this Policy.

Payment Processing Information. For online payments, RICOH use the payment services of Stripe directly or through the intermediary of RICOH's affiliates. RICOH and RICOH's affiliates if applicable do not process, record or maintain your credit card or other related information necessary to complete your payments. For more information on how payments are handled, or to understand the data security and privacy afforded such information, please see https://stripe.com/us/privacy.

(only for Tours Users)Social Networking Sites. RICOH360 Tours Service enables you to post content to a social network site or other online community (e.g., Facebook, and each, an “SNS”) through the “share” function. If you choose to do this, RICOH will provide information to such SNSs in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of each SNS that you post content to, and that it is your responsibility to review the terms of use and privacy policy of the third party provider of such SNSs. We will not be responsible or liable for: (a) the availability or accuracy of any SNS; (b) the content, products or services on or availability of any SNS; or (c) your use of any such SNS.

Consent to the Provision of Personal Data Outside Japan. [only for Japanese Users of the Services]

RICOH may provide Personal Data provided by you to service providers outside Japan in order to achieve the purposes of use described in Chapter 3 of this Policy. The list of service providers outside Japan used by RICOH and their purposes of use are listed in the Exhibit. You agree to provide your Personal Data to outside Japan based on the content described in the Exhibit.

5. Inquiries and Procedures Relating to Enforcement of the Data Subject’s Rights

(1) You have the following rights in relation to Personal Data relating to you that RICOH processes:

The right to require free of charge (i) disclosure of the Personal Data concerned (in addition, you may request access to third party transfer records, where legally applicable) (ii) access to and/or (iii) duplicates of the Personal Data retained.
Where legally applicable, the right to request proper rectification, removal or restriction of your Personal Data;
Where legally applicable, in case processing of your Personal Data is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, the right to receive the Personal Data concerning you in a structured, commonly used and machine-readable format or to have your Personal Data transmitted directly to another company, where technically feasible (data portability);
Where legally applicable, in case the processing of your Personal Data is based on your consent, the right to withdraw your consent at any time without impact to data processing activities that have taken before such withdrawal or to any other existing legal justification of the processing activity in question;
The right not to be subject any automatic individual decisions which produces legal effects on you or similarly significantly affects you; and
The right to take legal actions in relation to any breach of your rights regarding the processing of the Personal Data, as well as to lodge complaints before the competent data protection regulators.

In addition, you may object to the processing of the Personal Data, at any time if we are processing Personal Data relating to you on the basis of legitimate interests.

[Only for European Users of the Services] As far as RICOH processes Personal Data on the basis of RICOH’s legitimate interest (Art.6 (1) lit. f GDPR), you may object to processing (Art.21 (1) GDPR) at any time. You may find a detailed description of RICOH’s processing activities and the legal basis in Chapter 3 of this Policy. If you object to such processing, RICOH asks you to state the grounds of your objection in order for RICOH to examine the processing of your Personal Data and decide whether to adjust the processing accordingly.

[Only for European Users of the Services] Processing of Personal Data may involve direct marketing activities as described above. If you do not want to have your activity on RICOH’s Services processed for direct marketing activities, you can object to any data processing free of charge at any time via e-mail (Art.21 (2) GDPR).

(2) When you wish to submit a request regarding the usage of your Personal Data for the Services, please contact at the contact information set forth in Chapter 7 hereof. Persons making inquiries may be asked to confirm that they are the data subject or a legitimate agent of the data subject. Notwithstanding the above section, we may ask you to bear a reasonable fee for requests for disclosure, etc. For details, please contact the inquiry window described in Chapter 7 of this Policy.

(3) Please be aware that requests may not be granted in cases in the following categories:

If the requester cannot confirm that they are the data subject or a legitimate agent of the data subject.
If your request is relating to Personal Data of other individuals.
If disclosure of Personal Data is likely to harm the life, body, property, or other rights or interests of yours or another individual.
If disclosure, deletion, or cessation of use of Personal Data is likely to seriously impede the proper execution of our business.
If disclosure of Personal Data held by RICOH violate other laws or regulations.
In the case of requests being manifestly unfounded, not based on facts or excessive, in particular because of their repetitive character.
In the case of a request for deletion or cessation of use of Personal Data held by RICOH if, to the extent that processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation which requires processing by Union or Member State law to which RICOH is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in RICOH; for reasons of public interest in the area of public health; for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in so far as the right for deletion is likely to render impossible or seriously impair the achievement of the objectives of that processing; or for the establishment, exercise or defence of legal claims.
If your request for deletion or cessation of use of Personal Data is not based on our violation.
If it is difficult to suspend the use of Personal Data held by us and your rights and interests can be protected by alternative means; or RICOH is otherwise permitted under applicable laws to refuse your request.

(4) (only for Tours Users) RICOH360 Tours Service uses IDs provided by a party other than RICOH, namely Facebook, Inc. and Twitter, Inc. The registered content for these services is not managed by RICOH. Please contact the issuer for inquiries.

6. Handling of Access Log Information on the Websites

(1) SSL

Encryption technologies using SSL (Secure Sockets Layer) is used to prevent information theft etc. by a third-party during communication when you provide highly confidential information such as Personal Data via this Websites.

It may not be possible to use these technologies depending on your devices (including, but not limited to computer or mobile phone). In this case, please be aware that you may not use this Services.

(2) Use of Cookies and Web Beacons

RICOH uses Cookies and other similar technologies (Web Beacons, Flash Cookies, etc.) in order to enhance the experience using the Websites.

Although most web browsers automatically accept Cookies, the decision of whether to accept or not is yours. You have the choice to accept or decline Cookies by way of consent. RICOH only drops strictly necessary Cookies (see below) without your consent. If you do not accept Cookies, RICOH will not be able to produce customized website content to you and you will receive only non-customized content.

There are different types of Cookies:

Strictly necessary Cookies. These are Cookies that are required for the operation of the Services. They include, for example, Cookies that enable you to log into secure areas of the Services.
Functionality Cookies. These are used to recognize you when you return to the Services. This enables RICOH to personalize its content for you, greet you by name and remember your preferences (for example, choice of language or region).
Analytical cookies. They allow RICOH to recognize and count the number of users and to see how they move around the website when using it. This helps RICOH for its legitimate purposes to improve the way the website works, for example, by ensuring that you are finding what you are looking for easily.
Targeting Cookies. These Cookies record your visit to the Services, the pages you have visited and the links you have followed.

This Websites may use Cookies or web beacons for the following purposes:

To identify your browser or you and reduce the work required for authentication.
To assess usage of the Website and make improvements.
To make advance assessments of your use of services on which Personal Data will be registered and make improvements.

It may not be possible to use some of the features provided by this Websites if your browser is set not to receive Cookies or is set not to display images while you use the Websites.

The following list of cookies are those used on the Websites which we have identified:

(a)

Information on the cookies: “Google Analytics”, a cookie which is used when you use the web analytics service provided by Google Inc. (“Google”)
Purpose of the cookies: To assess usage of the Websites and to make improvements by RICOH and Google
Types of the cookies: 3. Analytical cookies, 4. Targeting Cookies

(b)

Information on the cookies: “Stripe”, a cookie which is used when you use the payment service provided by Stripe
Purpose of the cookies: To process and complete your payment by Stripe
Types of the cookies: 1. Strictly necessary Cookies

(c)

Information on the cookies: A cookie which is used when you use the Services
Purpose of the cookies: To customize your user interface
Types of the cookies: 2. Functionality Cookies

(d)

Information on the cookies: “Zendesk”, a cookie which is used when you use helpdesk
Purpose of the cookies: To assess usage of the Websites and make improvements
Types of the cookies: 3. Analytical cookies, 4. Targeting Cookies

(e)

Information on the cookies: “AWS”, a cookie which is used when you log in the Services
Purpose of the cookies: To administer your log in session in the Services
Types of the cookies: 1. Strictly necessary Cookies

(f)(only for Tours Users)

Information on the cookies: “Google Maps”, a cookie which is used when you use the web analytics service provided by Google
Purpose of the cookies: To assess usage of the Website and to make improvements by Google
Types of the cookies: 3. Analytical cookies, 4. Targeting Cookies

(3) Use of Cookies and Web Beacons by Third Parties

Cookies and Web beacons in your browser may be used by third parties, including advertisers, to distribute advertisements optimized for each user. You can set their browser not to receive cookies. Refer to the help of your browser for details.

(4) Disabling of Cookies

The effect of disabling cookies depends on which cookies you disable, but in general the website may not operate properly if cookies are disabled. If you only disable third party cookies, you will not be prevented from using our Service. If you disable all cookies, you will be unable to use our Services. See below for details of how to disable cookies on commonly used browsers.

Disabling cookies on Internet Explorer:

Select “Tools” and then choose “Internet Options”
Click on the “privacy” tab
Select the appropriate setting

Disabling cookies on Google Chrome:

Select Settings and then choose Advanced
Under "Privacy and security," click “Content settings”
Select “Cookies”

Disabling cookies on Safari:

Select Preferences and then choose Privacy
Click on “Remove all Website Data”

Disabling cookies on Firefox:

Select “Tools” in the menu and then choose “Options”
Click on the “privacy” icon
Find the “cookie” menu and select the relevant options

(5) Use of Google Analytics

RICOH uses Google Analytics, a web analytics service provided by Google Inc. (“Google”), 1600 Amphitheatre Parkway Mountain View, CA 94043, USA. Google Analytics uses Cookies, which are text files placed on users’ devices, to help the Website analyze how users use the Website. The information generated by the Cookie about the use of the Websites (including your IP address) will be transmitted to and stored by Google on servers in the United States of America. In case of activation of the IP anonymization, Google will truncate/anonymize the last octet of the IP address. Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA. Google will use this information for the purpose of evaluating your use of the Websites on RICOH’s behalf, compiling reports for RICOH and providing RICOH with other services relating to services activity and internet usage. Google will not associate your IP address with any other data held by Google. You may refuse the use of Cookies by selecting the appropriate settings on their browser and app. However, in that case, it may not be possible to use the full functionality of the Websites.

Further information concerning the terms and conditions of use and data privacy can be found at https://www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time.

(6) Links to Websites Other than This Websites

Links to the websites of companies related to RICOH or third-party companies (hereinafter "Websites Managed by Third Parties") are placed in some areas of the Websites of the Services to improve convenience for you. Accessing these links may take you away from RICOH's Websites. Although RICOH or RICOH THETA logo may be displayed on some parts of the Websites Managed by Third Parties, RICOH is not involved in the content posted on the Website Managed by a Third Party and does not accept responsibility for the website's handling of Personal Data.

Websites Managed by Third Parties may issue Cookies, gather data or gather Personal Data according to their own policies. This Policy does not apply to the handling of information on other, linked websites. Therefore, in the event that you access a Website Managed by a Third Party, RICOH recommends that you read the policies of the Website Managed by a Third Party relating to protection of Personal Data before providing Personal Data.

(7) Access Log Information

The Services and Websites may automatically collect your technical or usage information including details regarding your access and use, browser type and version, page browsing history, IP address, operating system and device information (hereafter referred to as “Access Log Information”). We may process the Access Log Information for the purposes listed in Chapter 3 of this Policy.

(8) Requests to Underage Users

In the event that Personal Data is provided to RICOH by underage users, RICOH request that this information is provided by a legal guardian of the underage users with the consent of the legal guardian. Personal Data therefore cannot be provided by underage users even with the consent of a legal guardian. If it becomes known to RICOH that Personal Data has been provided by underage users, the information and the underage user's account will be deleted immediately.

7. Contact for Inquiries Relating to Personal Data / Complaints

If you have any complaints and other inquiries relating to the handling of Personal Data, please contact us at privacy@ricoh360.com, or by writing to us at the following representative:

Ricoh Company, Ltd. Smart Vision Business Center Personal Data Protection and Management Officer: Wataru Ohtani 1-3-6 Nakamagome, Ohta-ku, Tokyo 143-8555 Japan

Ricoh Company, Ltd. is the data controller for the purposes of the Personal Data processed under this Policy.

8. Amendments

RICOH may update this Policy in response to changes to or improvements of the purposes of use, improvement of safety, or according to revisions of related laws, regulations and rules. Therefore, RICOH recommends to periodically check this Policy on the Website.

9. Controlling Text

[only for Japanese Users of the Services] The governing language of this Policy is Japanese. Only the original Japanese language version of this Policy has the effect of a policy, and any translation of the Policy has no contractual or any other effect.

[for the Users except Japanese Users of the Services] The governing language of this Policy is English. Only the original English language version of this Policy has the effect of a policy, and any translation of the Policy has no contractual or any other effect.

Exhibit

[only for Japanese Users of the Services]

The list of service providers outside Japan used by RICOH

RICOH use the following service providers outside Japan to provide the Services to you. RICOH may review and update this list from time to time.

Name of service provider and its privacy policy	Purpose of use	Country
Shopify, Inc.	Payment service	Canada
Amazon, Inc.	Hosting service	United States of America
Stripe, Inc.	Payment service	United States of America
Hubspot, Inc.	Mailing service	United States of America
Zendesk, Inc.	Support service	United States of America
Zapier, Inc.	Data integration service	United States of America
Capsule, Inc.	Support service	United Kingdom
Octobat, Inc.	Tax payment service	France
Slack, Inc.	Data integration service	United States of America
Asana, Inc.	Data integration service	United States of America
Jotform, Inc.	Support service	United States of America
Datawarehouse, Inc.	Analysis service	United States of America
Intercom, Inc.	Support service	United States of America
Tableau, Inc.	Analysis service	United States of America
Calendly, Inc.	Support service	United States of America
Google, Inc.	Analysis service, Mailing service, Data integration service	United States of America

With respect to Personal Data Protection System of the Country, please refer to the “Investigation of systems related to the protection of personal information in foreign countries“ on the website of Personal Information Protection Commission.

Each Provider have taken all steps to address The OECD’s Eight Principles set forth in OECD Guidelines on the Protection of Privacy and Transborder Flows of Personal Data.