DYNABOOK CANADA INC. PRIVACY POLICY STATEMENT

This Privacy Policy Statement (“Privacy Statement”) applies solely to the online information gathering and data sharing practices of Dynabook Canada Inc. (as follows, "Dynabook", "we", "us" or “our”) for this Web Site, service and/or application (“Dynabook Online”) and does not apply to other Dynabook affiliates or our parent company, and such entities may have their own privacy policies.

We are proud to demonstrate our commitment to your privacy, by complying with the laws and regulations under applicable privacy laws in Canada, including the Personal Information Protection and Electronic Documents Act.

From time to time, we may make changes to this Privacy Statement. The Privacy Statement is current as of the "last revised" date which appears at the top of this page. We will treat Personal Information in a manner consistent with the Privacy Statement under which it was collected and our Privacy Policy, unless we have your consent to treat it differently. This Privacy Statement applies to any information we collect or receive about you, from any source.

By using Dynabook Online, you agree to the terms provided in this Privacy Statement, which are as follows:

1. To which companies does this Privacy Statement apply?

This Privacy Statement applies to the collections, uses and disclosures of Personal Information by Dynabook Canada Inc.

2. What is Personal Information?

“Personal Information” is information about an identifiable individual. This information may include but is not limited to your name, mailing address, phone number, email address, domain name, client IP address, facsimile number, credit card number, household income, banking information, creditor information, and other personally identifiable information about you.

3. How do we collect your Personal Information?

We may collect Personal Information and the products or services you purchase or obtain from us. This information is collected, in general, from information you provide to us through Dynabook Online when you complete a product registration or initial setup, through your survey responses or rebate forms, and/or through your filling out and submitting forms through Dynabook Online requesting information from Dynabook, as well as when you register your product for warranties and/or speak to a Dynabook representative. We may also collect Personal Information in other circumstances when we have obtained your consent to do so or as otherwise permitted or required by law. With your consent, we may also collect your precise geographic location information via Dynabook Online.

4. What about "cookies"?

Dynabook may collect information during your website visit through use of a "cookie" to track how our visitors use this site and understand trends and patterns. These cookies provide anonymous traffic insights that are used to assess site efficiency and allow us to enhance your future online experiences with Dynabook.

We may engage third parties to collect non-personal information using "cookies" and/or other industry standard technologies (e.g., clear GIFS, web beacons, pixel tags, javascript tag) to generate statistics or measure and analyze website activity (including page usage and paths followed during visits through our sites and/or the items you view or place in your shopping bag) in order to improve Dynabook Online functionality, deliver content specific to you and/or targeted for your interests while using Dynabook Online and/or a third party web site, and to better manage advertising of our products. The collected data also helps us determine which product, service or support information may be appropriate for you and to help us maintain an efficient shopping experience for you.

You can set your browser to notify you before you receive a "cookie" or to turn off "cookies" completely. If you do so, however, some areas of our site may not function properly.

5. Where do we use and store your Personal Information?

We will keep the Personal Information that we collect primarily at our offices or on our servers (or those of our affiliates or service providers). While our affiliates and service providers may, from time to time, also hold your Personal Information in connection with purposes for which you provided your consent or as otherwise permitted or required by law, we remain responsible, and remain the contacts for, such information.

We generally identify the purposes for which we use your Personal Information at the time we collect such information from you. We generally use your Personal Information for the following purposes (the “Purposes”): (i) to provide the products, services or information you have requested; (ii) to complete your service requests; (iii) to assist you with technical support; (iv) to gather your opinion and feedback through surveys; (v) to enrol you in our contests or promotional programs; (vi) to include you on our mailing list; and (vii) to process your application for employment. We may use your Personal Information for other purposes with your consent or as permitted or required by law.

6. To whom do we provide your Personal Information?

We may disclose your Personal Information to third party service providers with whom we have contractual agreements that include appropriate privacy standards, where such third parties are assisting us with certain services (i.e. third parties may be used for registration of a training event). We may also disclose Personal Information to a potential or actual acquirer in connection with a transaction involving the sale of the business of Dynabook or its assets or as otherwise permitted or required by law. In addition, we may send Personal Information outside of Canada, including to the United States, for the purposes set out above, including for process and storage by service providers in connection with such purposes, and you should note that while such information is out of the country, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.

We do not sell your Personal Information. We may use your personal information to contact you about products you have purchased, inform you of product and service opportunities that may be of interest to you, to conduct market research regarding Dynabook products or services, to customize the content of Dynabook Online for you, to support and enhance our communications with you, or for other business purposes. We may share your personal information within the Dynabook family of companies for business purposes and with other companies who provide marketing or other services on our behalf and at our direction, but we do not permit them to use such personal information that we have shared for their own direct marketing purposes. We may share your personal information outside of the Dynabook family with companies in connection with your trial, purchase or registration of products or services provided by such companies and with companies that perform marketing or other services on our behalf and at our direction. We may also share your personal information in connection with law enforcement, fraud prevention, and other legal action, or if Dynabook reasonably believes it is appropriate to do so to protect Dynabook, its customers or the public.

7. When and how do we obtain your consent?

We obtain your consent prior to collecting, using or disclosing your Personal Information, except where collection, use or disclosure of Personal Information without consent is permitted or required by law. Consent for the collection, use or disclosure of Personal Information may be express or implied, or may be obtained through opt-out methods. You may provide your consent to us either orally, electronically or in writing. You may withdraw your consent to our collection, use or disclosure of Personal Information at any time subject to contractual and legal restrictions. However, if you withdraw your consent to certain collections, uses or disclosures of your Personal Information, we may no longer be able to provide certain products or services.

8. Third Party Web Sites

Dynabook Online may contain links to other third party web sites that are not operated by us. We are not responsible for the privacy practices or the content of such third party web sites. The information practices of those third party web sites are not covered by this Privacy Statement. Other Dynabook co-branded web sites may also operate under their own privacy and security policies. You are responsible for reviewing third party and co-branded privacy policies, as applicable, to determine the handling of your information.

9. How do we ensure the privacy of your Personal Information when dealing with our affiliates and other third parties?

We take reasonable steps to ensure that all affiliates and other third parties that are retained to perform services on our behalf and are provided with Personal Information are contractually required to observe the intent of this Privacy Statement and our Privacy Policy and practices.

10. How long will we utilize, disclose or retain your Personal Information?

We may keep a record of your Personal Information, correspondence or comments in a file specific to you. We will utilize, disclose or retain your Personal Information for as long as necessary to fulfill the purposes for which that Personal Information was collected and as permitted or required by law.

11. How can you review your Personal Information that we have collected, utilized or disclosed?

If you make a written request to review any Personal Information about you that we have collected, utilized or disclosed, we will provide you with any such Personal Information to the extent required by law. We will make such Personal Information available to you in a form that is generally understandable, and will explain any abbreviations or codes.

12. How do you know that the Personal Information we have on you is accurate?

We will ensure that your Personal Information is kept as accurate, complete and up-to-date as necessary for the purposes for which we intend to use it. We will not routinely update your Personal Information, unless such a process is necessary. We expect you, from time to time, to supply us with written updates to your Personal Information, when required.

13. What if the Personal Information we have on you is inaccurate?

At any time, you can challenge the accuracy or completeness of your Personal Information in our records. If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information.

14. How fast will we respond to your written requests?

We will attempt to respond to each of your written requests not later than thirty (30) days after receipt of such requests. We will advise you in writing if we cannot meet your requests within this time limit. You have the right to make a complaint to the federal Privacy Commissioner in respect of this time limit.

15. Are there any costs to you for requesting information about your Personal Information or our Privacy Policy or practices?

We will not charge any costs for you to access your Personal Information in our records or to access our Privacy Policy or practices without first providing you with an estimate of the approximate costs, if any. You may withdraw your requests for access to information by notifying us within the thirty (30) day notice period disclosed on the estimate. If you do not notify us within such thirty (30) day period, we will send you a further notice indicating that you will be deemed to have withdrawn your request for access unless you advise us otherwise within thirty (30) days. If, after the expiry of this second thirty (30) day period, you have not so advised us, we will deem your request to have been withdrawn and provide you with written notice to that effect.

16. How do we know that it is really you requesting your Personal Information?

We may request that you provide sufficient identification to permit us to verify your identity before granting access to, or confirming the existence, use or disclosure of your Personal Information. Any such identifying information shall be used only for this purpose.

17. What safeguards have we implemented to protect your Personal Information?

We have implemented physical, organizational, contractual and technological security measures to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification. However, you should understand that absolute security cannot be guaranteed and we cannot guarantee or warrant the security of any information you transmit to us. The only employees who are granted access to your Personal Information are those with a business ‘need-to-know’ or whose duties reasonably require such information.

18. Notifications of Changes

From time to time, we may choose to change our privacy practices and this Privacy Statement. We will notify you of material changes to the Privacy Statement by posting a revised Privacy Statement via Dynabook Online with an updated effective date. Any updates, revisions, supplements, modifications or amendments to this Privacy Statement shall be effective immediately upon its posting via Dynabook Online and will only be applicable to disputes arising, or arising out of events occurring, after such posting has been made. You agree that you will continue to be bound by this Privacy Statement, however and whenever it is updated, revised, supplemented, modified, or amended, if you continue to use Dynabook Online after, the updates, revisions, supplements, modifications or amendments have been posted. This Privacy Statement is effective as of September 1, 2019.

19. How do you contact us regarding access to your Personal Information or our Privacy Policy and practices?

All requests for access to or correction of your Personal Information, as well as any comments, questions, concerns or complaints regarding your Personal Information or our Privacy Policy and practices, should be forwarded to our Privacy Officer as follows:

In writing:
Privacy Officer
Dynabook Canada Inc.
335 Britannia Road East
Mississauga, ON L4Z 1W9

Email: DBC-PrivacyOfficer@dynabook.com

© 2019 Dynabook Canada Inc. All rights reserved.

---

Privacy Notice for Business Partners

1. About this notice

We will process your personal data in compliance with every applicable law and any laws that replace them in the future (including the European Union’s General Data Protection Regulation, Regulation (EU) 2016/679 (“GDPR”)).

In this notice, we provide information based on such laws related to processing your personal data. This notice sets out the basis on which any personal data that you provide to us, or that we obtain about you from other sources, will be processed by us. Please take the time to read and understand this notice.

2. Information about us

For the purpose of data protection law, Dynabook Canada Inc. (“we”, “us” and “our”) is a data controller in respect of your personal data. And we are committed to respecting your privacy.

1. Our main office address: 335 Britannia Road East, Mississauga, Ontario L4Z 1W9
2. Our phone number: 1-905-890-2100
3. Our inquiry email address: DBC-PrivacyOfficer@dynabook.com

3. Definitions

In this notice:

1. your “personal data” means any data which relates to you and from which you can be identified. It may include contact details, other personal information, or photographs;
2. our “affiliates” means our subsidiaries; and
3. “processing” means any activity or operation that is carried out in respect of your personal data, such as collecting, storing, using, transferring or deleting it.

4. How we collect your personal data and what personal data we collect

We will collect and process the following personal data about you (collected through communications including: writings, face-to-face discussion, phone calls, e-mails, or otherwise). Such information generally includes your name, contact data (e-mail, phone number), company name, address, position and all other personal data which is required to enter into a contract with you and to communicate with you.

In some circumstances, we may be provided such personal data relating to you by the organization you represent or the organization that otherwise employs or engages you (“Business Partners”). This information is necessary in order for (i) the relevant business we provide you or Business Partners or (ii) the relevant business services to be provided to us by Business Partners.

There may be circumstances where the provision of business services to us results in us collecting other types of personal data from you, or us being provided other types of personal data about you from Business Partners. If so, then we will protect such personal data to the same high standards explained in this policy and take any additional steps necessary to ensure we process such personal data in accordance with applicable laws.

5. Purpose and legal basis of processing personal data

We use the personal data that we hold about you for the following purposes:

Establishing and maintaining relationship with Business Partners, Marketing

The legal basis for the processing of your personal data is:

• performance of a contract or in order to take steps at the request of the data subject prior to entering into a contract in accordance with Art.6 (1)(b) GDPR; or
• where the processing of your personal data is necessary for the pursuance of our legitimate interests in accordance with Art.6 (1)(f) GDPR (e.g. establishing a business relationship, marketing and networking).

We do not process your “sensitive data” (information about your race, ethnic origin, religion, physical or mental health, political opinions, sexual life, any actual or alleged criminal offences, and genetic and biometric data).

6. Disclosure of personal data to recipients

We may share your personal data with recipients in the situations described below:

1. Internal Use for us: Employees of us or our affiliates who are authorized and need to access these data.
2. Affiliates: We share your personal data with our affiliates for internal administrative purposes and uses that are consistent with this Notice.
3. Service Providers: We share your personal data with third-party service providers who perform services, such as providing data servers, logistics services and payment services on our behalf.
4. Business Partners: We may share your personal data with business partners, such as customers or suppliers to the extent this is required for conducting and/or acquiring business with these partners (e.g., exchange of contact details).
5. Legal Process and Safety: We may disclose your personal data to legal or government regulatory authorities as required by applicable law. We may also disclose your personal data to third parties as required by applicable law in connection with claims, disputes or litigation, when otherwise required by applicable law, or if we determine its disclosure is necessary to protect the health and safety of you or others, or to enforce our legal rights or contractual commitments that you have made.
6. Business Transfers: Your personal data may be disclosed as part of a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets, and could be transferred to a third party as one of the business assets in such a transaction. It may also be disclosed in the event of insolvency, bankruptcy or receivership.

7. Purpose and legal basis of processing personal data

The personal data that we collect from you or provided by Business Partners may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us, for our affiliates or for one of our suppliers.

Where we transfer your personal data outside the EEA, we will ensure that:

1. the recipient destination has been subject to a finding from the European Commission that it ensures an adequate level of protection for the rights and freedoms that you possess in respect of your personal data; or
2. the recipient enters into standard data protection clauses with us that have been approved by the European Commission.

You can obtain more details of the protection given to your personal data when it is transferred outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us in accordance with the information about us above.

8. Storage limit of personal data

We will retain the personal data that we collect about you as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer period is demanded by applicable laws.

1. Access, rectification, erasure, restriction, data portability
   
   Subject to the statutory requirements, the fulfilment of which must be assessed on a case-by-case basis, you have the following rights:
   

   Request from us access to your personal data pursuant to Art. 15 GDPR

   
   

   You have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and certain related information.

   Request from us rectification of your personal data pursuant to Art. 16 GDPR

   
   

   You have the right to obtain from us the rectification of inaccurate personal data concerning you without undue delay, and to complete any incomplete personal data.

   Request from us erasure of your personal data pursuant to Art. 17 GDPR

   
   

   You have the right to obtain from us the erasure of personal data concerning you without undue delay, when certain legal conditions apply.

   Request from us restriction of processing pursuant to Art. 18 GDPR

   
   

   You have the right to obtain from us the restriction of processing of personal data, when certain legal conditions apply.

   Right to data portability pursuant to Art. 20 GDPR

   
   

   You have the right to receive your personal data in a structured, commonly used and machine-readable format, and have the right to transmit those data to another controller without our hindrance, when certain legal conditions apply.

2. Right to object
   
   Subject to the statutory requirements, the fulfilment of which must be assessed on a case-by-case basis, you also have the right to object to the processing of your personal data.
   
   Where personal data are processed for direct marketing purposes (see section 5 above), you have the right to object at any time to processing of personal data concerning you for such marketing pursuant to Art. 21 (2) GDPR.
3. Right to lodge a complaint
   
   If you have any complaints regarding our privacy practices in the EEA, you have the right to lodge a complaint with your national data protection authority (i.e., supervisory authority).

10. Contacts

Questions, comments and requests regarding this privacy notice are welcome. Please contact us using the information about us above.

Established:13th May 2021

Chief Privacy Officer

Dynabook Canada Inc