Privacy Policy

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, and the methods used by Ricoh Futures Europe EMEA (“RFE” or “We”) for handling your personal data in “RICOH360” (“Services”), which are provided by RFE and the related websites managed by RFE (“Websites”).
RICOH360 Services include “RICOH360 Application” (“RICOH360 Application Service”) and “RICOH360 Cloud” (“RICOH360 Cloud Service”) (together, the “Services”).
The terms User and You include:

• potential customers of the Services (“Potential Users”), and
• users of applications created by third parties other than RFE (“App Creator”) that enable access to the Services (“Third Party Apps”) (“End Users”).

Additional information on our personal data practices may be provided in other notices given 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 precedence.
“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”) 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”).
Some terms of this Policy are applicable to users of RICOH360 Application Service only (“Application Users”) and users of RICOH360 Cloud Service only (“Cloud Users”), respectively.
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For residents of the State of California, additional disclosures and rights apply as described in the “Appendix ‒ California Privacy Rights Notice (CPRA)” attached hereto.

2. Management of Personal Data

Ricoh Futures Europe EMEA (“RFE”) has stipulated that Personal Data used for business operations will be handled by RFE, as data controller, under appropriate protection in accordance with applicable laws and regulations, the Ricoh Group Code of Conduct, and the Ricoh Group Personal Information Protection Basic Regulations, which are part of the Ricoh Group Standards.
RFE implements appropriate safety management measures in line with laws, regulations, guidelines, and internal policies, to prevent leaking, loss, destruction, alteration, or unauthorized access of Personal Data, and works to protect Personal Data retained by RFE.
RFE also trains its employees on appropriate handling of Personal Data and works to ensure full protection of such information.

3. Acquisition and Purposes of Use of Personal Data

Ricoh Futures Europe EMEA (“RFE” or “We”) will acquire your Personal Data when you provide such Personal Data to us, automatically through the Services and Websites, or through Third Party Apps and third parties such as our distributors and use your Personal Data within the necessary scope for the purposes stated below.
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List of Types of Acquired Information and Purposes of Use
RFE will process your Personal Data as data controller 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, as well as the applicable legal basis where this information is required.

(1) (only for Potential Users)
Type of acquired information:
RFE collects your email address, name, company name, phone number and other personal information when you inquire about the Services or contact RFE.
Purpose of use:
The email address, name, company name, phone number and other personal information is needed to provide information and proposals related to the services provided by RFE (including but not limited to the Services, collectively, “RICOH360 Cloud Services”), contact for business negotiations and meetings, and responding to your inquiries.
Legal Basis (only for European Users):
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 commercial relationship entered into or, in the absence of a contract, for a maximum period of 3 years from the last exchangebetween the Potential User and RFE.
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 RFE.

(2) (Users except End Users)
Type of acquired information:
RFE 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 information is needed to identify and allocate users to specific Service accounts.
Legal Basis (only for European Users):
Art. 6(1)(b) GDPR ‒ necessary for performance of the contract.
Duration:
Personal Data processed for the duration of the contractual relationship between you and RFE. Unless you object in accordance with the explanations in Chapter 5 below, RFE may retain your Personal Data for a maximum period of 3 years after the end of the contractual relationship, for the purpose of proposing you products or services similar to those covered by the contractual relationship.

(3)
Type of acquired information:
RFE collects email address, name, address, phone number and other personal information shared on RICOH360 Application Service.
Purpose of use:
Such data is required to share content with other users of the RICOH360 Application Service.
Legal Basis (only for European Users):
Art. 6(1)(b) GDPR ‒ necessary for performance of the contract
Duration:
Personal Data processed for the duration of the contractual relationship between you and RFE.

(4)
Type of acquired information:
RFE 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 may further process your User Name in connection with your shared 360-degree photos or videos to display it as your User Account, if such sharing functionality is enabled. It is necessary to provide the RICOH360 Cloud Service.
Legal Basis (only for European Users):
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 RFE.

(5)
Type of acquired information:
RFE automatically collects your IP Address, device profile and other Personal Data when using the Services and Websites.
Purpose of use:
Such information is required to provide and administer the Websites and the Services, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
Legal Basis (only for European Users):
Art. 6(1)(b) GDPR ‒ necessary for performance of the contract.
Duration:
Personal Data will be processed for the duration of the contractual relationship between you and RFE.(Only for End Users) Notwithstanding the foregoing, Personal Data will be processed for the duration of the contractual relationship between App Creator and RFE with respect to the Third-Party Apps you use.

(6)
Type of acquired information:
RFE 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:
This information is necessary to provide the Services, including uploading and sharing with other users. Each piece of content contains its own Universally Unique Identifier (UUID) used to locate that content through URLs.
Please note: Due to the nature of URL composition, third parties may theoretically identify photos/videos by testing UUID patterns.
Legal Basis (only for European Users):
Art. 6(1)(b) GDPR ‒ necessary for performance of the contract.
Duration:
Personal Data will be processed during the contractual relationship between you and RFE.
When you delete your 360-degree photos or videos, RFE will no longer process such content.
(Only for End Users) Notwithstanding the foregoing, Personal Data will be processed for the duration of the contractual relationship between App Creator and RFE with respect to the Third-Party Apps you use.

(7) (Users except End Users)
Type of acquired information:
RFE collects your contact form contents, chat history, email address and other Personal Data when you send a support request.
Purpose of use:
Collected to administer the Services and Websites under your terms and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
Legal Basis (only for European Users):
Art. 6(1)(b) GDPR ‒ performance of the contract
Art. 6(1)(f) GDPR ‒ legitimate interests (improvement of the Services)
Duration:
Personal Data processed during the contractual relationship between you and RFE.

(8) (Users except End Users)
Type of acquired information:
RFE collects your email address, name, company name, phone number, subscription type, subscription change history, access time and other personal information when you subscribe to the Services.
Purpose of use:
To administer the Services and Websites under your terms and for internal operations, including marketing and promotions related to your use of RFEʼs Services.
Legal Basis (only for European Users):
Art. 6(1)(b) GDPR ‒ performance of the contract
Art. 6(1)(f) GDPR ‒ legitimate interests (improvement of Services and functionality)
Art. 6(1)(f) GDPR ‒ legitimate interests (marketing and promotional activities as Users are using the Service on behalf of the company they belong to)
Duration:
Personal Data will be processed for the duration of the contractual relationship between you and RFE, augmented for a duration of 3 years for marketing and promotional activities except in case of objection from the data subject pursuant Chapter 5.

(9) (Users except End Users)
Type of acquired information:
RFE collects your amounts of payments, payment statuses and related information necessary to administer payments (excluding your full credit card details and card brand information).
Purpose of use:
To administer the Services and Websites under your terms and for internal operations.
Legal Basis (only for European Users):
Art. 6(1)(b) GDPR ‒ performance of the contract
Art. 6(1)(f) GDPR ‒ legitimate interests (improvement of Services and functionality)
Duration:
Personal Data will be processed for the duration of the contractual relationship between you and RFE.

(10) (Users except End Users)
Type of acquired information:
RFE collects name, address, phone number and other personal information as delivery address information when you order goods.
Purpose of use:
To deliver ordered goods to you.
Legal Basis (only for European Users):
Art. 6(1)(b) GDPR ‒ performance of the contract
Duration:
Personal Data will be processed for the duration of the contractual relationship between you and RFE.

Legal Grounds for Our Processing of Your Personal Data
RFE processes Personal Data under one or more of the following bases:
1. Consent where legally required
（withdrawal explained later）
2. Contract necessity
Processing necessary to perform a contract or pre-contract steps (Art. 6(1)(b) GDPR)
3. Legal obligation
Processing necessary for compliance with law (Art. 6(1)(c) GDPR)
4. Legitimate interests
Pursued by RFE or a third party, unless overridden by your fundamental rights (Art. 6(1)(f) GDPR)
Additionally, processing is conducted when permitted under applicable laws of each country.

Data Retention
RFE retains Personal Data only for as long as required for the purposes for which it was collected, except where  continued storage is necessary for:

• compliance with legal obligations
  
• additional legitimate and lawful purposes

Merger / Business Transfer
If Personal Data is transferred to RFE through merger, split-up, business transfer, etc.,RFE will use Personal Data:

• within the scope of original consent, or
• within the scope necessary for the notified purposes prior to the business transfer
  

4. Provision of Personal Data to a Third Party

RFE 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]
‍Provision to our sub-contractors and suppliers with appropriate supervision from RFE tofulfill a purpose of use:

• RFE transfers Personal Data to its processor and hosting provider, Amazon WebServices, Inc., in the United States of America. This is necessary for the provision ofthe platform and, thus, for the fulfillment of the Terms of Use, Art. 6 (1) (b) GDPR.
• International transfers of Personal Data to Amazon Web Services, Inc. in the UnitedStates of America are made in compliance with GDPR Chapter V through theEuropean Commissionʼs Standard Contractual Clauses (“SCCs”), together with supplementary measures as required under GDPR Art. 46 to ensure an adequate level of protection for Personal Data.
• RFE transfers Personal Data to its processors providing mailing or text messaging services in the United States of America on behalf of RFE.
• RFE transfers Personal Data to support service providers in the United States of America or the United Kingdom on behalf of RFE.
• RFE transfers Personal Data to analysis service providers in the United States of America on behalf of RFE.
• RFE transfers Personal Data to data integration service providers in the United States of America on behalf of RFE.
• RFE transfers Personal Data to payment service providers in the United States ofAmerica and Canada on behalf of RFE.
  
• RFE transfers Personal Data to indirect tax payment service providers in Europe and Japan on behalf of RFE.
  
• RFE transfers Personal Data to delivery service providers in Japan (if applicable) for delivering products to you on behalf of RFE.
  

International transfers of Personal Data to mailing service providers, support service providers, analysis service providers, data integration service providers, and payment service providers located in the United States of America are made in compliance with GDPR Chapter V through the European Commissionʼs Standard Contractual Clauses (“SCCs”), together with supplementary measures as required under GDPR Art. 46 to ensure an adequate level of protection for Personal Data. A copy of the safeguards governing these international transfers can be made available to you upon written request to the contact information set forth in Chapter 7 hereof.
International transfers of Personal Data to support service providers located in United Kingdom, payment service providers located in Canada, and indirect tax payment service providers and delivery service providers located in Japan are made under European Commission adequacy decisions.

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(2b) [for Users except European Users]
Provision to our business partners, including sub-contractors and suppliers with appropriatesupervision from RFE to fulfill a purpose of use.You hereby consent to international transfers for the following uses:‍‍

• RFE transfers Personal Data to Amazon Web Services, Inc., in the United States ofAmerica.
• RFE transfers Personal Data to mailing and text messaging service providers in the United States of America on behalf of RFE.
• RFE transfers Personal Data to support service providers in the United States ofAmerica or the United Kingdom on behalf of RFE.
• RFE transfers Personal Data to analysis service providers in the United States ofAmerica on behalf of RFE.
• RFE transfers Personal Data to data integration service providers in the United Statesof America on behalf of RFE.
• RFE transfers Personal Data to payment service providers in the United States ofAmerica and Canada on behalf of RFE.
• RFE transfers Personal Data to indirect tax payment service providers in Europe andJapan on behalf of RFE.
• RFE transfers Personal Data to delivery service providers in Japan (if applicable) fordelivering products to you on behalf of RFE.

(3) When Personal Data is required to protect human life, limb, or property and obtainingconsent is difficult.
(4) When it is particularly necessary to improve public health or promote the sounddevelopment of children and obtaining consent is difficult.
(5) When it is necessary to cooperate with a national agency, local public entity, or a personentrusted thereof with carrying out affairs prescribed by laws and obtaining consent mayinterfere with those affairs.
(6) When a judicial or administrative organization demands provision of Personal Dataaccording to laws and regulations.
(7) When the recipient third party is an academic research institution and the processing isnecessary for academic research purposes (including a case where part of the purpose involvesacademic research but excluding cases where such processing may unfairly infringe yourrights and interests).
(8) When RFE provides Personal Data to other parties because of a merger, split-up, businesstransfer, etc.
(9) Sharing with Affiliates
‍RFE may share Personal Data with its subsidiaries, joint ventures, or other companies undercommon control (“Affiliates”).Shared Personal Data includes necessary information such as:

• name, company name, address, phone number, email address, contract information,purchase history, payment information, IP address, etc.

Affiliates are required to honor this Policy and Ricoh Group standards, and the data ismanaged responsibly by the representative set forth in this Policy.

Payment Processing Information
For online payments, RFE uses the payment services of Stripe, directly or through Affiliates.RFE and its Affiliates do not process, record, or store credit card details or other relatedfinancial information necessary to complete your payments.
For details regarding Stripeʼs data security and privacy handling, please refer to:
https://stripe.com/us/privacy‍

5. Inquiries and Procedures Relating to Enforcement of the Data Subjectʼs Rights

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

• The right to require free of charge
  (i) disclosure of the Personal Data concerned (in addition, you may request access tothird 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 of your PersonalData;
• Where legally applicable, the right to request deletion of your Personal Data;
• Where legally applicable, the right to request restriction of the processing of yourPersonal Data without impact to data processing activities that have taken placebefore such restriction;
• Where legally applicable, in case processing of your Personal Data is either based onyour consent or necessary for the performance of a contract with you and processingis carried out by automated means, the right to receive the Personal Data concerningyou in a structured, commonly used and machine-readable format or to have yourPersonal 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 yourconsent, the right to withdraw your consent at any time without impact to dataprocessing activities that have taken place before such withdrawal or to any otherexisting legal justification of the processing activity in question;
• The right not to be subject to any automatic individual decisions which produce legaleffects on you or similarly significantly affect you; and
• The right to take legal actions in relation to any breach of your rights regarding theprocessing 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 areprocessing Personal Data relating to you on the basis of legitimate interests.
[Only for European Users]
As far as RFE processes Personal Data on the basis of RFEʼs legitimate interest (Art. 6 (1) lit.f GDPR), you have the right to object to processing (Art. 21 (1) GDPR) at any time. You mayfind a detailed description of RFEʼs processing activities and the legal basis in Chapter 3 ofthis Policy. If you object to such processing, RFE asks you to state the grounds of yourobjection in order for RFE to examine the processing of your Personal Data and decidewhether to adjust the processing accordingly, without impact to data processing activities thathave taken place before such objection.
[Only for European Users (except End Users)]
Processing of Personal Data may involve direct marketing activities as described above. AsRFE processes your data in the framework of a professional relationship with the companyyou belong to, such marketing activities are made under RFEʼs legitimate interest. If you donot want to have your activity on the Services processed for direct marketing activities, youcan 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 theServices, please contact the contact information set forth in Chapter 7 hereof. Persons makinginquiries may be asked to confirm that they are the data subject or a legitimate agent of thedata subject. Notwithstanding the above section, we may ask you to bear a reasonable fee forrequests for disclosure, etc. For details, please contact the inquiry window described inChapter 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 ofthe 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 rightsor interests of yours or another individual.
• If disclosure, deletion, or cessation of use of Personal Data is likely to seriously impedethe proper execution of our business.
• If disclosure of Personal Data held by RFE violates 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 RFEif, 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 orMember State law to which RFE is subject or for the performance of a task carried outin the public interest or in the exercise of official authority vested in RFE;
  • for reasons of public interest in the area of public health;
  • for archiving purposes in the public interest, scientific or historical researchpurposes or statistical purposes in so far as the right for deletion is likely to renderimpossible 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 ourviolation.
• If it is difficult to suspend the use of Personal Data held by us and your rights andinterests can be protected by alternative means; or RFE is otherwise permitted underapplicable laws to refuse your request.
• If your request for deletion or cessation of use of Personal Data is not based on ourviolation.• If it is difficult to suspend the use of Personal Data held by us and your rights andinterests can be protected by alternative means; or RFE is otherwise permitted underapplicable laws to refuse your request.
• If your request for deletion or cessation of use of Personal Data is not based on ourviolation.• If it is difficult to suspend the use of Personal Data held by us and your rights andinterests can be protected by alternative means; or RFE is otherwise permitted underapplicable laws to refuse your request.
• If your request for deletion or cessation of use of Personal Data is not based on ourviolation.• If it is difficult to suspend the use of Personal Data held by us and your rights andinterests can be protected by alternative means; or RFE is otherwise permitted underapplicable laws to refuse your request.

6. Handling of Access Log Information on the Service and Websites

(1) SSL
Encryption technologies using SSL (Secure Sockets Layer) are used to prevent informationtheft etc. by a third-party during communication when you provide highly confidentialinformation such as Personal Data via this Service and Websites.
It may not be possible to use these technologies depending on your devices (including, butnot limited to computer or mobile phone). In this case, please be aware that you may not usethis Services and Websites.

(2) Use of Cookies and Web Beacons
‍RFE uses Cookies and other similar technologies (Web Beacons, Flash Cookies, etc.) in orderto enhance the experience using the Service and Websites.
Although most web browsers automatically accept Cookies, the decision of whether to acceptor not is yours. You have the choice to accept or decline Cookies by way of consent. RFE onlydrops strictly necessary Cookies (see below) without your consent. If you do not acceptCookies, RFE will not be able to produce customized Service and Website content to you andyou 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 and Website. They include, for example, Cookies that enable you to loginto secure areas of the Services and Website.
• Functionality Cookies. These are used to recognize you when you return to theServices and Website. This enables RFE to personalize its content for you, greet youby name and remember your preferences (for example, choice of language or region).
• Analytical Cookies. They allow RFE to recognize and count the number of users andto see how they move around the website when using it. This helps RFE for itslegitimate purposes to improve the way the Services and 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 and Website, thepages 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 Services and Website and make improvements.
• To make advance assessments of your use of the Services and Website on whichPersonal Data will be registered and make improvements.

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

The following list of cookies are those used on the Services and Websites which we haveidentified:
(a)
Information on the cookies: “Google Analytics”, a cookie which is used when you use the webanalytics service provided by Google Inc. (“Google”)
Purpose of the cookies: To assess usage of the Services and Websites and to makeimprovements by RFE and Google
Types of the cookies: Analytical cookies, Targeting Cookies (subject to your consent)(b)
Information on the cookies: “Stripe”, a cookie which is used when you use the payment serviceprovided by Stripe
Purpose of the cookies: To process and complete your payment by Stripe
Types of the cookies: Strictly necessary Cookies(c)
Information on the cookies: A cookie which is used when you use the Services and Websites
Purpose of the cookies: To customize your user interface
Types of the cookies: 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 Services and Websites and make improvements
Types of the cookies: Analytical cookies, Targeting Cookies (subject to your consent)(e)
Information on the cookies: “AWS”, a cookie which is used when you log in the Services andWebsites
Purpose of the cookies: To administer your log in session in the Services and Websites
Types of the cookies: Strictly necessary 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 (subject to your consent). You can setyour browser not to receive such 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 theServices and Website may not operate properly if cookies are disabled. If you only disable thirdparty cookies, you will not be prevented from using our Service and Website. If you disable allcookies, you will be unable to use our Services and Website. See below for details of how todisable 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
‍RFE uses Google Analytics, a web analytics service provided by Google Inc. (“Google”), 1600Amphitheatre Parkway Mountain View, CA 94043, USA. Google Analytics uses Cookies,which are text files placed on usersʼ devices, to help the Services and Website analyze howusers use the Services and Website. The information generated by the Cookie about the useof the Services and Websites (including your IP address) will be transmitted to and stored byGoogle on servers in the United States of America. In case of activation of the IPanonymization, Google will truncate/anonymize the last octet of the IP address. Only inexceptional 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 Services andWebsites on RFEʼs behalf, compiling reports for RFE and providing RFE with other servicesrelating to services activity and internet usage. Google will not associate your IP address withany other data held by Google. You may refuse the use of Cookies by selecting the appropriatesettings on their browser and app. However, in that case, it may not be possible to use the fullfunctionality of the Services and 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 mayprovide from time to time.

(6) Links to Websites Other than This Websites
‍Links to the websites of companies related to RFE or third-party companies (hereinafter"Websites Managed by Third Parties") are placed in some areas of the Websites to improveconvenience for you. Accessing these links may take you away from RFE's Websites. Although the RICOH or RICOH THETA logo may be displayed on some parts of the Websites Managed by Third Parties, RFE 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 onother, linked websites. Therefore, in the event that you access a Website Managed by a Third Party, RFE recommends that you read the policies of the Website Managed by a Third Partyrelating 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 browsinghistory, IP address, operating system and device information (hereafter referred to as “AccessLog 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 RFE by underage users, RFE 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 RFE that Personal Data has been providedby underage users, the information and the underage user's account will be deleted immediately.

8. Amendments

RFE 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, RFE recommends to periodically check this Policy on the Website.

9. Controlling Text

The governing language of this Policy is English. Only the original English language versionof this Policy has the effect of a policy, and any translation of the Policy has no contractual orany other effect.

© 2025 RICOH Futures Europe EMEA All rights reserved.
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Appendix ‒ California Privacy Rights Notice (CPRA)
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