Last Updated: April 15, 2023
1 Our Contact Details
2 About Wacom
3 Scope of this Privacy Policy
4 Summary of How We Use Your Personal Information
i. User Information
ii. Business account contact information
iii. Usage Information
iv. Social media information
v. Other third-party information
5 Information We Collect
6 How We Use the Information We Collect
7 “Do Not Track Requests”
8 How We Share Your Information with Third Parties
9 International Transfers of Data for Processing
10 Third Party Features and Websites
11 Security; Breach; PCI DSS
12 Accessing, Correcting, Updating & Retaining Your Information
13 Preferences and Opting-Out
14 California Privacy
15 Use by Children
16 Changes to this Policy
1. Our Contact Details
This privacy policy is issued on behalf of Wacom Technology Corporation, 1455 NW Irving St, Portland, OR 97209, USA.
If you have questions about this policy or our use of your personal information, you may contact us at privacy-wtc@wacom.com or call toll free at 1-855-669-2266.
You can also write to us at the following address:
Wacom Technology Corporation
Attention: Privacy
1455 NW Irving St.
Portland, OR 97209, USA
2. About Wacom
Wacom (“Wacom,” “WTC,” “we,” “us,” or “our”) provides customers with pen tablets, interactive pen displays, digital interface technologies, cloud storage, and software applications. We also provide guidance, services, and support on these products. Wacom respects your privacy and takes our responsibility to protect your privacy seriously.
A list of our subsidiaries and corporate affiliates under common control with us (our “Affiliates”) can be found here. Wacom and our Affiliates are collectively referred to as the “Wacom Group.”
3. Scope of this Privacy Policy
- use our websites, which include our websites listed here;
- use our mobile applications (“Apps”), including Inkspace App, Bamboo Paper, Bamboo Note, Wacom Ink Note, and Sign Pro PDF;
- use our other software and products; or
- interact with us through our websites, phone, email, live chat, social media presences on platforms like Facebook and Twitter, fax, postal mail, courier, or face-to-face.
4. Summary of How We Use Your Personal Information
5. Information We Collect
• internet protocol (IP) addresses
• browser type,
• browser language,
• device identifier,
• device type,
• internet service provider (ISP),
• referring/exit pages,
• length of visit,
• pages viewed,
• operating system,
• date/time stamp,
• clickstream data,
• crashes,
• system activity,
• hardware settings,
• time zone,
• the date and time of requests, and
• referral URL
6. How We Use the Information We Collect
• To provide Services and support. We use your personal information to provide and manage the Services, communicate with you about our Services, and fulfill any contractual obligations we otherwise have with you. In addition, we use your personal information to support your use of the Services and to ensure the quality and security of the Services.
o In response to your inquiry, request, or purchase, we use your personal information to provide reports, consulting services, educational services, training, maintenance, technical support, customer support, or other support services.
o We use your personal information, including information stored on your systems, to implement our Software or Apps. We keep any temporary copies of data that we access, use, or create to do so only for the time period necessary.
o We may also use your personal information to provide you updates, notices, and security alerts along with support and administrative messages.
o We record all calls for support and keep records of your communications and ours to provide and improve customer service to you and others.
o We also use personal information to manage your account and verify your identity.
o We use your personal information to otherwise support your account.
o We use your personal information when needed to perform accounting functions.
o We use your personal information to provide relevant product information via our Websites. We may also provide you with information about third parties and their terms of use and privacy policies when you purchase their applications on the Websites.
o We may also use your information to customize your interaction with our Websites and carry out any other purpose for you provided us with your personal information (subject to applicable data protection laws).
• To authenticate your identity and to tailor content. When you create or login to an account with Wacom, we use your personal information for the purpose of providing you a login to the Services. We use personal information to verify your identity and manage access to your Wacom account. This account enables us to provide a verifiable way for us to respond to your requests or inquiries, including processing your orders, accepting orders and payments, sending confirmations, providing invoices, processing requests for information about our products, processing downloads for whitepapers or product demonstrations/evaluations, and processing warranty requests). And, if you elect to link your Wacom account to your personal social media account, we use personal information relating to your social network accounts you have elected to use (e.g., Facebook, Twitter or Google+) to create or access your Wacom account.
• For online forums, online events, and in-person events. We may use your information to facilitate your participation on our online forums such as user groups and bulletin boards. We may also do so to facilitate your participation in live or online events such as training seminars or conferences.
• Prevent improper or illegal activity. We use personal information to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity on or relating to our Services.
• To meet legal requirements. Wacom may be required to use or discloses your personal information when necessary to comply with legally mandated reporting, subpoenas, court orders, or other legal process requirements.
• To market and improve our products and services and to create new products and services. We use your personal information to:
o conduct marketing activities to inform you about our products, services, and events.
o conduct surveys about our Services and your use of our Services.
o Administer, contests or sweepstakes, to send promotional emails, process entries, notify participants of the winners, comply with applicable laws and regulations for the contests, sweepstakes and rewards, and to deliver rewards.
• 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.
• Other purposes. We may use your information for any other legal, business or marketing purposes that are compatible with this Policy.
7. “Do Not Track Requests.” Your web 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.
8. How We Share Your Information with Third Parties. Wacom may disclose your information in the following circumstances:
• Business Partners, Resellers and Subcontractors. Wacom may share your personal 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 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.
• Analytics Providers. To third parties conducting 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. 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.
• Transfer or Assignment in Connection with Business Transfers or Bankruptcy. In the event of a business transition, such as a merger, acquisition, reorganization, bankruptcy or other sale of all or a portion of our assets, any information owned or controlled by us may be one of the assets transferred to third parties. Wacom shall provide notice of such a business transition via prominent notice on our Websites. We reserve the right, as part of this type of transaction, to transfer or assign your information and other information we have collected from customers and users of the Services to third parties. Other than to the extent ordered by a bankruptcy or other court, or as otherwise agreed to by you, the use and disclosure of all transferred information will be subject to this Policy. However, any information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity in compliance with applicable laws and regulations.
• Response to Subpoenas or Court Orders; Protection of Our Rights; Safety. As required or permitted by law, regulation, legal process or other legal requirement, or when we believe in our sole discretion that disclosure is necessary or appropriate, to respond to an emergency or to protect our rights, protect your safety or the safety of others, investigate fraud, comply with a judicial proceeding or subpoenas, court order, law-enforcement or government request, including without limitation to meet national security or law enforcement requirements, or other legal process and to enforce our agreements, policies and terms of use.
• 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.
• 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.
• 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 the address shown at the top of this policy.
• Anonymized Data. We may share information that has been anonymized with others for their own uses, in accordance with applicable laws and regulations.
9. International Transfers of Data for Processing.
10. Third-party Features and Websites
11. Security; Breach; PCI DSS
12. Accessing, Correcting, Updating & Retaining Your Information
13. Preferences and Opting-Out
14. California Privacy
In 2018, the state of California enacted the California Consumer Privacy Act, and amended it in 2020 under the California Privacy Rights Act (collectively, “CCPA”), which affords certain rights for California residents. This section specifically addresses the rights of California residents under the CCPA.
As explained above in Sections 4 and 5, we collect a variety of categories of information, including sensitive personal information, in connection with providing the Services. We explain these categories again, specifically in the context of the CCPA. In providing the Services, we collect the following categories of personal information: an individual consumer’s name, postal or mailing address, Internet Protocol (IP) address, unique personal identifier or online identifier, email address, account name, telephone number, bank account number, credit card number, debit card number, or other financial account information provided. The criteria we use to determine the retention period for each of the above categories of personal information are found in Section 12 of this Policy.
As explained above, we collect personal information from consumers themselves, directly via our website, interactions with our company personnel, and through social media, and, in some cases, from service providers such as payment processors.
As explained in greater detail above in Section 6, we use personal information collected for a wide variety of business purposes:
• to provide and manage the Services, ensure the quality and security of the Services, communicate with consumers about our Services, and fulfill any contractual obligations we have with consumers;
• to facilitate the establishment and use of consumer’s individual Wacom accounts they create for themselves. personal information to verify your identity and manage access to your Wacom account;
• to facilitate your participation on our online forums such as user groups and bulletin boards or in live or online events such as training seminars or conferences;
• for analytics purposes and to operate, maintain and improve the Services;
• to market the Services and gather additional information regarding the Services;
• to create new products and services;
• to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity on or relating to our Services; and
• when necessary, to meet legal requirements, such as legally mandated reporting, subpoenas, court orders, or other legal process requirements.
We disclose your personal information only for a business purpose or purposes to the following categories of third parties:
• Service providers, as explained in Sections 4, 5, 6, and 8, above, and with Affiliates.
Under the CCPA, “sell,” “selling,” “sale,” or “sold,’’ means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for monetary or other valuable consideration. We do not sell your personal information.
Under the CCPA “share,” “shared,” or “sharing” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged. We share your personal information with the companies that provide cookies and similar technologies used in our website to help present targeted ads on other websites based on your activity on our sites and third party sites.
To notify us of your desire for us not share your personal information, click the link below and adjust your cookie preferences:
DO NOT SHARE MY PERSONAL INFORMATION
You can also adjust your cookie preferences on our website by clicking on the “COOKIE PREFERENCES” link at the bottom of the homepage. You can also disable the use of cookies via your browser, but please note that our website may no longer work properly if you disable cookies. For more information on our use of cookies, please review our Cookie Notice at https://www.wacom.com/en-us/cookie-notice.
If you believe you have questions about your request through this webform or want to make a request that you believe the webform does not address, please contact us and submit your request by emailing us at privacy-wtc@wacom.com or calling toll free at 1-855-669-2266.
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
i. Access to Specific Information.
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. Once we receive and confirm your verifiable consumer request (see Exercising Consumer Rights, below), 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 (if applicable) selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you.
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
o sales, identifying the personal information categories that each category of recipient purchased; and
o disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Under the CCPA, you also may request that we disclose certain information to you about our collection and use of your personal information beyond the past 12 months. Wacom, however, may decline to provide you that information if doing so would require a disproportionate effort on our part.
ii. Deletion and Correction Request Rights
You have the right to request that we delete or correct any of your personal information that we collected from you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Consumer Rights, below), we will delete (and direct our service providers to delete) or correct your personal information from our records, unless an exception applies.
In the absence of a verifiable consumer request from you, we will retain your personal information in accordance with the criteria in Section 12 of this Policy before automatically deleting (and directing our service providers to delete) it.
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, 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.
iii. The Right to Opt-Out – The Right to Opt Out of Sharing of Personal Information
You have the right to opt out of any sharing of your information to a third party, i.e., to prevent a transfer of information to a third party that is not restricted in certain ways from making use of the information. As we explained above, some of the companies that provide cookies and similar technology might use Usage Information for targeted advertising information based on individual internet activity and interests, including potentially the sharing of information with others. You can exercise your right to opt out of the sharing of your information by clicking on the link below and adjusting your cooking preferences.
DO NOT SHARE MY PERSONAL INFORMATION
iv. Exercising Consumer Rights
To exercise the rights described above, please submit a verifiable consumer request to us by one of the following methods:
• Emailing us at privacy-wtc@wacom.com;
• Calling us toll free at 1-855-669-2266; or
• Submitting a request through our webform accessible here.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
To verify the identity of an individual making a request, a two-step process will need to be completed. A verifiable consumer request must:
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
• Separately provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
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.
Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
iv. Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, 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.
Unless otherwise, requested, any disclosures we provide will cover only the 12-month period preceding the verifiable consumer request’s receipt. 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.
We will not discriminate against you for exercising your CCPA rights. Unless permitted by the CCPA, we will not:
• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. However, we do not currently provide any financial incentives.
We have not shared any personal information with other companies for their direct marketing use within the immediately preceding calendar year. Accordingly, California’s “Shine the Light” law, Cal. Civil Code § 1798.83 to § 1798.84, does not apply to us and we have not established any mechanism for you to request information on our sharing of information for third parties’ marketing purposes.
15. Use by Children
16. Changes to this Policy