Privacy Policy of Brother Industries, Ltd.

1ST JANUARY 2021

This privacy notice describes how Brother Industries, Ltd. a company incorporated and located in Japan with its address in 15-1, Naeshiro-cho, Mizuho-ku, Nagoya 467-8561, Japan ('we', 'us') collects and processes personal information about you, how we use and protect this information, and your rights in relation to this information.

This privacy notice applies to all personal information we collect or process about you. Personal information is information, or a combination of pieces of information that could reasonably allow you to be identified.

Please note that we operate globally either directly or through our subsidiaries ('Brother Group companies') . The Brother Group companies have their own privacy notice and where they collect and process your personal information, their own respective privacy notice will apply.

The Italian branch office of Brother International Europe, Ltd., a company incorporated and located in United Kingdom with its address at Brother House, 1 Tame Street, Audenshaw, Manchester M34 5JE, U.K. ('BIE') , is our representative in the European Union.

We will collect personal information about you from a variety of sources, including information we collect from you directly (e.g. if you are a customer when you register your Brother products, if you are a business partner when you contact us and/or provide services to us), information we collect from Brother Group companies and information we collect about you from other sources, including commercially available sources, such as public databases (where permitted by law).

We may be required by law to collect certain personal information about you or as a consequence of any contractual relationship we have with you. Failure to provide this information may prevent or delay the fulfilment of these obligations.

The categories of information that we may collect directly from you include the following:

1. personal details (e.g. name, date of birth, job title);
2. contact details (e.g. phone number, email address, postal address or mobile number);
3. payment details and transactions;
4. if you are a customer, serial numbers of Brother products (these will identify you once you have registered your Brother product with us);
5. IP addresses and MAC identifiers (while you access our websites and other online services.

The following are examples of the categories of information we may collect from other sources:

1. personal details (e.g. name, date of birth, job title, credit information);
2. contact details (e.g. phone number, email address, postal address or mobile number);

Include generated information such as profiles, history of our relationship with you, etc.

If you are a customer we use your personal information to:

1. ensure that our records are kept accurate and up to date;
2. comply with legal obligations to which we are subject;
3. check and maintain quality control;
4. carry out analysis of our stock, ensure correct functioning of logistics and check stocks;
5. provide you with customer service, after sale support and software updates;
6. ship products to you;
7. recall products.

If you are a business partner we use your personal information to:

1. carry out background checks prior to engaging you as a business partner;
2. contact you with questions and other information regarding the services you provide;
3. ensure that our records are kept accurate and up to date where you, your employees or contractors work on our facilities;
4. pay invoices;
5. comply with legal obligations to which we are subject.

We must have a legal basis to process your personal information. In most cases the legal basis will be one of the following:

1. to fulfil our contractual obligations to you. If you are a customer our contractual obligations to you include shipping products, providing customer service, after sale support, software updates, and recalling products when necessary. If you are a business partner our contractual obligations to you include paying invoices correctly and ensuring you are able to access our premises when required;
2. to comply with our legal obligations to you, for example health and safety obligations while you are on our premises, or to a third party (e.g. the taxation authorities); and
3. to meet our legitimate interests. If you are a customer our legitimate interests, for example, are maintaining quality control and logistics, carrying out analysis for product development and market research, checking stocks and ensuring that our records are kept up to date and accurate. If you are a business partner our legitimate interest, for example, are ensuring that the services you provide are appropriate for our needs, that your services function correctly with our systems, that any complaints or concerns can be promptly relayed to you, and our records are kept up to date and accurate.

You have certain rights regarding your personal information, subject to local law. These include the following rights to:

• access your personal information;
• rectify the information we hold about you;
• erase your personal information;
• restrict our use of your personal information;
• object to our use of your personal information;
• receive your personal information in a usable electronic format and transmit it to a third party (right to data portability); and
• lodge a complaint with your local data protection authority.

We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate.

Please note that we will likely require additional information from you in order to honour your requests.

If you would like to discuss or exercise such rights, please contact us at the details below.

We may also make automated decisions about you based on your personal information in the following circumstances:

• If you are a customer to select personalized offers, discounts or recommendations to send you based on your shopping history, browsing history and/or usage of Brother products;
• Subject to local legal requirements and limitations, you can contact us to object to our use of automated decision-making.

When we adopt automated decision making involving profiling based on your personal information in providing our service, we will separately provide you with information about the logic involved and any effects of the automated decisions and seek your consent.

We may share your personal information with third parties under the following circumstances:

• Cloud service providers. We partner with cloud service providers such as Microsoft and Amazon to store your personal information in the cloud.
• Business service providers. We engage business service providers to send newsletters and marketing emails, support email and messaging services, provide data analytics services and to process secure payments and fulfil orders.
• Brother Group companies are owned by Brother Industries, Ltd, so we work closely with other businesses and companies that fall under the Brother Group family. We may share certain information about customers' using serial numbers, buying and browsing history, and customers’questions or concerns with Brother Industries, Ltd and other Brother Group companies for marketing purposes, internal reporting, and response to customers' questions or concerns.
• Law enforcement agencies, courts, regulators, government authorities. We may share your personal information with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
• Asset purchasers. We may share your personal information with any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this Privacy Note.

We implement technical and organizational measures to ensure a level of security appropriate to the risk to the personal information we process. These measures are aimed at ensuring the on-going integrity and confidentiality of personal information. We evaluate these measures on a regular basis to ensure the security of the processing.

We will keep your personal information for as long as we have a relationship with you. When deciding how long to keep your personal information after our relationship with you has ended, we take into account our legal obligations and regulators' expectations. We may also retain records to investigate or defend potential legal claims.

We will retain your personal information in accordance with our data retention policy which sets out data retention periods required or permitted by applicable law.

We use Google Analytics, a web analytics services provided by Google LLC (“Google”), to track and monitor how you use our website. In connection with use of Google Analytics, we use cookies to distinguish unique users by assigning a randomly generated client ID. It is used to monitor and calculate visitor, session and campaign data for the site analytics report.

We may also implement Google Analytics Demographics and Interest Reporting, a feature of Google Analytics Advertising, to help us understand the demographics and interests of our website users. In connection with use of Google Analytics Advertising, our website and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together.

For more information about how Google handles your information, please see https://www.google.com/policies/privacy/partners/

If you would like to prevent your data from being collected and processed by Google Analytics, you can opt-out from Google Analytics by downloading and installing the Google Analytics’ Opt-out Add-on https://tools.google.com/dlpage/gaoptout/

Please note that Brother Industries Ltd. is located in Japan and thus your personal information will be submitted to, stored, and processed in Japan and which is currently regarded as ensuring an adequate level of protection for personal information under European Union data protection law. Furthermore, we may work with third party service providers while storing or processing your personal information, for example, your personal information may be stored in the cloud by our cloud service providers and they may keep your personal information in locations outside the European Economic Area, which do not provide an adequate level of protection.

We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details below.

Brother Industries, Ltd. is the controller responsible for the personal information we collect and process.

If you have any questions or concerns regarding the way in which your personal information has been used, please contact us at the email address provided below. Please note that, depending on the nature of your request or inquiry, we may need to confirm your identity before we process it.

data.protection@brother.co.jp

You may request a digital copy of this privacy notice from us using the contact details set out above. We may modify or update this privacy notice from time to time. You will be able to see when we last updated the privacy notice because we will include a revision date. Changes and additions to this privacy notice are effective from the date on which they are posted. Please review this privacy notice from time to time to check whether we have made any changes to the way in which we use your personal information.