Last modified: October 1, 2023
If you are resident of California or in the growing number of US states that have enacted privacy laws (and a natural person, i.e., a "consumer"), please also see the Supplemental Privacy Statement for Consumers in California and Certain Other US States below.
If you are in the European Economic Area (“EEA”), the United Kingdom (UK) or Switzerland, please see the Supplemental Privacy Statement for EEA, UK and Swiss residents below.
B. WHAT PERSONAL INFORMATION/DATA WE COLLECT, HOW WE USE IT AND TO WHOM WE PROVIDE IT
We collect various types of personal information from the sources indicated below with respect to your interaction with Sites and our Products (which may include Products of our affiliates, BOSS, Drum Workshop and v-moda) and related offerings. Most of the personal information we collect from you is obtained in the following ways: (1) personal information that you provide to us during registration for certain areas of the Sites, or in connection with your subsequent activities related to the Sites, such as when you choose to subscribe to newsletters or magazines, purchase products or parts, seek customer support or enter contests; (2) personal information we get from certain services such as Google Analytics and for Google Analytics Advertiser Features/Display Advertising to enhance the Sites experience and possibly for promotional purposes. More specifically, we collect the following personal information from the sources listed below for the purposes stated, and disclose it to the third parties listed below:
a. Blog and Community Newsletter; Trade Shows. If you choose to subscribe to our Blog or to our Community Newsletter, we merely ask for your email address, which sends notifications of new Blog posts, and the Newsletter, to you by email. In addition, you may choose to provide us with certain personal information at a trade show or event such as name, email and telephone number, which we may digitize. The personal information described above is stored on WordPress, Shopify, and/or CRM servers which manage this content, and which send email notifications and communications to you. The basis for collection of any personal information for marketing or promotional use would be your opt-in consent if you are resident in the European Economic Area.
b. Community Forums. On the Community pages of the Sites, you may choose to participate in message boards or forums, you may post questions to the Community directly and choose to include some personal information that identifies you, or someone may provide personal information in responding. We do not moderate the message board posts, and merely provide this as a user-friendly service to you; it is operated by Zendesk, our support system provider which may make limited promotional use of personal information that you provide. If we choose to require a login for access, then such personal login information would be disclosed to Zendesk, which powers the Community webpages.
c. User Account; Product Registration. If you choose to create an account on the Sites via Backstage, our customer/support portal for users of Roland, BOSS and Drum Workshop Products we collect your first and last name and email address, so that you can create an encrypted password-controlled account on our system. This enables you to register a Product and it also facilitates our providing you with customer and Product support as well as information about Roland, BOSS and Drum Workshop Products you may own or are thinking about purchasing. Once you are registered, we may collect additional personal information to facilitate certain activities that you choose, as follows: your rebate redemption (requires your shipping address for rebate check); repair/order status (your phone number for issuing RA/repair authorization and support ticketing); contest entry forms and surveys (additional personal information including age and gender). In addition, if you establish an account with Roland via SSO (single sign-on) for Roland, BOSS or Drum Workshop Products, which only requires your email address, the same account can be used to log into various applications, services or websites as you choose. We generally have a contractual basis (especially if you have purchased and need support for existing products) and/or legitimate interests basis for collecting this personal data. A contest or survey could be a promotional use requiring opt-in. This information is not disclosed to any third parties.
d. Online Store Purchases. In order to complete a purchase via one of the Sites, you may, depending on the Site, need to login to an account in order to be able to proceed to checkout, and you would need to provide at least your email address to access the account. Other purchase information you may be asked to provide, such as credit card information is not collected by or accessible to Roland; provided, however, that we may collect and store your shipping information as necessary to fulfill your order. We do not collect or hold credit card information, which you provide to a secure payment processor via our third-party services providers, such as Shopify. We are not responsible for the practices of such third parties, and encourage you to review their privacy policies before supplying them with information.
e. GPS Data. We may use geo-location/GPS information for identifying out-of-country visitors (via IP address detection), which is generally used to route you to the appropriate Roland national or language website, and to facilitate your use of our Dealer Locator and Service Center Locator pages), but we do not store this information and it is not required from you. Moreover, often it consists of nothing more than your zip code or your location, and we cannot identify you from such information. To the extent such GPS or zip code information alone could be considered personal information, there is a legitimate interest in routing you to the appropriate country-specific Roland website in response to your request for the appropriate dealer or service center, and Roland complies with all privacy requirements applicable in such country (e.g., all GDPR requirements if the country indicated by its flag icon is in the European Union), as well as in fulfilling your request to find a Dealer or Service Center near you.
f. Content Management and Metrics. Certain content management and measurement software/services that we use, such as Kentico, Adobe Analytics, AudienceX, Active Campaign, Storyblok, Shopify, Quivers, Hubspot, ZenDesk, and various Google services aimed at usage monitoring and tracking, advertising and retargeting activities, collect device identifiers (such as IP address), date and time of Site access by users and mobile network information including phone number, which enables us to gather aggregate, anonymized and/or de-identified demographic information about our users, and in certain cases to provide us with more detailed demographics about Site users. We also use this information to perform statistical analysis of user behavior in order to measure interest in various areas of our Sites and to ensure a better user experience on the Sites and with Roland. Much of this anonymized and aggregated data is used to generate reports for various business purposes. Collection of this information when aggregated, anonymized and/or de-identified, generally has a legitimate interests basis.
g. Tracking. Some of the tracking and retargeting described in the prior paragraph is used by our Site content management software to make you aware of products, promotions and issues that may be of interest to you. Services such as Podium, AudienceX and Google Analytics Advertiser Features/Display Advertising may be used to communicate with and/or to serve tailored ads to users, and enable features such as Remarketing with Google Analytics, Google Display Network Impression Reporting, DoubleClick Campaign Manager integration and Google Analytics Demographics and Interest Reporting. We may have a legitimate interest in why we provide this information to you, as it may relate to purchases you have made, otherwise this may be a promotional use and may require your opt-in consent, depending on applicable law in your location.
h. Underage Users. We and the Site focus upon the sale of musical and audio products, and we are not aimed at, nor do we knowingly collect, personal information from users under the age of 16. While consumers under 16 must opt-in to any sale or sharing of their personal information under the CCPA, we do not sell or disclose personal information.
Minors under 18 years of age may have the personal information that they have provide to Roland through the Site deleted by sending an email to firstname.lastname@example.org requesting deletion. Please note that, while we make reasonable efforts to comply with such requests, deletion of your personal information does not ensure complete and comprehensive removal of that data from all systems.
C. ADDITIONAL INFORMATION ON HOW WE USE YOUR PERSONAL INFORMATION/DATA
Spare Parts; Locating Dealers and Service Centers. We use your personal information to fulfill certain spare parts and Product orders (although most Products are not available for purchase through the Sites), help you locate Dealers and Service Centers in order to make Product purchases and receive customer and technical support, optimize the Sites and the Products that we offer, provide you with information that you request and/or that relates to Product purchases you have made, encourage sales of our Products and improve the overall Site experience.
We Collect No Sensitive Personal Information. In connection with the Sites, we do not collect any “sensitive personal information” or “sensitive personal data” as defined by applicable law, such as credit card, financial or health information about individuals. For example, if you choose to purchase certain spare or other Products via the Sites, when you provide credit or debit card information, we cannot access such information, nor do we see it or store it; such information is provided to our third-party payment processor via the applicable Site’s credit card portal. With respect to human resources data, we only have employees in the United States.
Targeted Information. Services engaged by us to provide targeted ads or information will not associate a cookie or anonymous identifier with sensitive personal categories, such as those based on race, religion, health or sexual orientation. In addition, without your consent/opt-in, we will not permit personal information to be merged with non-personally identifiable information collected from Display Advertising features.
Compliance and Safety. We may use your personal information as necessary to comply with our legal and contractual obligations and reserve the right to use it if necessary to protect other Site users, employees and legal interests, such as in the event of a complaint or dispute. In this regard, we may use personal information as necessary to comply with court orders, legal process, judicial or arbitral proceedings and as requested by government agencies or as necessary to protect our rights and public safety.
D. OTHER POSSIBLE DISCLOSURE OF PERSONAL INFORMATION
Roland will not disclose your personal data to third parties, except in the following circumstances and in accordance with applicable laws:
With your consent in connection with any use of your personal information for advertising purposes or for use of non-essential cookies if you are resident in the EEA, the UK or Switzerland (see Supplemental Privacy Statement for EEA, UK and Swiss Residents below).
To Roland’s service providers, who act on Roland’s behalf and instructions pursuant to Data Processing Agreements as necessary to fulfill Product orders, pre- and post-sales requirements, put you in touch with Dealers and Service Centers, and fulfill the other purposes set forth above (an example would be that credit card information goes to our payment processor).
To or between Roland and Roland’s parent corporation (Roland Corporation) and Roland’s other affiliates (BOSS, Drum Workshop and v-moda) for the purposes of coordinating our global enterprise's provision and development of Products and services, single sign-on account creation, product registration for certain Products as well as customer and technical support for such Products, and to coordinate recordkeeping and efficiency with respect to our employees and service providers.
As required by applicable law, including, without limitation, in response to any government or regulatory agency request, to cooperate with law enforcement and/or investigations, to meet national security requirements or upon receipt of any court order.
To a prospective or actual purchaser or seller with respect to Roland’s business or that of a Roland affiliate or unit in the context of a merger, acquisition or other reorganization or sale of Roland’s business or assets or a Roland affiliate, unit or line of business. Roland would seek appropriate protection for information in these types of transactions, and would attempt to notify you by email and/or a prominent notice on the applicable Site of any change in ownership and the choices you may have regarding your personal information, once it is legally permissible to do so.
To courts and public authorities to protect you, Roland or third parties from harm, including fraud or instances where someone’s safety is at risk.
E. OPTING OUT
To contact us for any reason, you can use the Contact Information set forth in Section M below. You may have additional rights under the CCPA, other state privacy laws or GDPR, depending on where you are resident.
In addition, with respect to email newsletter sent to our users about products, services, clinic schedules or other news using email addresses provided at registration or otherwise: upon your request, we will remove your personal information from our database or permit you to opt-out of further communication of this nature if you simply send an email to email@example.com, and place the word “remove” in the subject field.
To change or update any personal information that we hold about you, please send a “remove” email as explained in the bullet point immediately above, and re-register with the new information.
In addition, you can opt out of Google Analytics Advertiser Features through Google Ads Settings, Google Ads Settings for mobile apps, or any other available means (such as the Network Advertising Initiative opt-out).
F. SECURITY MEASURES AND STANDARD OF CARE THAT WE APPLY REGARDING PERSONAL INFORMATION
Roland takes reasonable and appropriate precautions — including administrative, technical, organizational and physical measures — to safeguard your personal information against loss, theft, and misuse, as well as against unauthorized access, disclosure, alteration, and destruction.
Service providers acting on Roland's behalf are obligated to adhere to security and confidentiality requirements no less protective than those set forth herein and will only receive access to your personal data as necessary to perform their functions.
However, no data transmission over the Internet can be guaranteed to be 100% secure. In the event that we believe that there has been a security breach involving your personal data, we would endeavor to notify you promptly in accordance with applicable law. In the event such notification is appropriate under the circumstances, we would first try to notify you at the latest email address we have for you on record, subject to legal requirements.
We also perform statistical analyses of the users of the Sites and Products to improve the content, design and navigation of the Sites and to further improve our Products and offerings. In these cases, we use aggregate anonymized or de-identified data, or statistical data that cannot be used to identify you.
G. THIRD-PARTY AND EXTERNAL WEBSITES
H. COOKIES AND SIMILAR TECHNOLOGIES
A cookie is a small piece of data sent from a website and stored in a user’s web browser while the user is visiting a website. When the user loads the website, the browser sends the cookie back to the server to notify the website of the user’s previous activity. Third-party cookies are used to compile records of users’ browsing history.
We use first-party cookies (such as Kentico, Storyblok, Shopify, Quivers, Hubspot, Adobe Analytics and Google Analytics cookies) and third-party cookies (such as DoubleClick and AudienceX cookies) to report how ad impressions, our use of ad services, and interactions by users with these ad impressions and ad services are related to Site visits.
With respect to cookies and similar technologies that are not strictly necessary for our provision of the Sites, Products and related services, if you are a user resident in the EEA, UK or Switzerland, we will try to redirect you to the appropriate European website at the outset, where the corresponding Roland group company seeks consent from users of the Service using a One Trust cookie management tool.
I. RESPONSE TO “DO NOT TRACK” SIGNALS
Some Internet browsers include the ability to transmit “Do Not Track” signals. Since uniform standards for “Do Not Track” signals have not yet been adopted, Roland does not process or respond to “Do Not Track” signals.
J. INTEGRITY AND RETENTION OF PERSONAL INFORMATION
K. ACCESS TO PERSONAL INFORMATION
You can help ensure that your contact information and preferences are accurate, complete, and up-to-date by contacting us using the information below. For other personal information, we make good faith efforts to provide you with access so you can request that we correct the data if it is inaccurate or delete the data if Roland is not required to retain it by law or for legitimate business purposes. We will attempt to respond to your request within 30 days or sooner where required by law. As permitted by applicable law, we may decline to process requests where the data is required to be retained by law, required for legitimate business purposes, or jeopardizes the privacy of others.
We encourage you to periodically review this page for the latest information on our privacy practices.
M. GOVERNING LAW
Roland is headquartered in California, and most of the servers that we use are also U.S.-based. By accessing or using the Site, or any of Roland’s services, or by undertaking the activities and/or options on the Site enumerated above, you agree that your use of the Site is governed by the laws applicable in the State of California, and you expressly consent to the processing of personal information/data in, and transfer of your personal information/data to, the United States (and any other countries where Roland may in the future hold such data, subject to the security representations set forth in this Policy).
However, if you are resident and located in the EEA, UK or Switzerland the Supplemental Privacy Statement for EEA, UK and Swiss Residents has been provided in addition (or in substitution for certain provisions of this Policy as required by applicable law) with respect to your use of the Site.
N. CONTACT US
Roland Corporation U.S.
Attention: Website Privacy Questions
PO Box 910921
Los Angeles, CA 90091-0921
Or via email at firstname.lastname@example.org.
SUPPLEMENTAL PRIVACY STATEMENT FOR CONSUMERS IN CALIFORNIA AND CERTAIN OTHER US STATES (as applicable).
“State Privacy Laws” means all U.S. privacy and data protection laws and regulations applicable to Roland’s processing of customer personal information in the provision of services to the customer, including, as applicable, (a) the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq., as amended by the California Privacy Rights Act, and its implementing regulations (“CCPA”); (b) Colorado Privacy Act, Colorado Rev. Stat. §§ 6-1-1301 to 6-1-1313 (“ColoPA”); (c) Connecticut Personal Data Privacy and Online Monitoring Act, Public Act No. 22-15) (“CPOMA”); ; (d) Utah Consumer Privacy Act (Utah Code Ann. §§ 13-61-101 to 13-61-404) (“UCPA”); and (e) Virginia Consumer Data Protection Act, Virginia Code Ann. §§ 59.1-575 to 59.1-585 (“VCDPA”). California, Colorado, Connecticut, Virginia and Utah shall be referred to collectively as the “States.”
Please bear in mind that the State Privacy Laws of individual states may not apply to Roland and consequently may not give you certain rights even if you are a resident of a state listed above, because generally such laws apply only to businesses that meet certain thresholds based on the amount of processing of personal information of consumers resident in such state during a calendar year. In a growing number of states, the relevant threshold is generally that Roland has processed the personal information of 100,000 consumers in such state in a calendar year, which Roland may not meet. Nonetheless, Roland strives to apply high privacy standards, and so on a case-by-case basis may comply with consumer requests related to the privacy standards set forth below even if a given consumer has no legal right to make such request.
Your State Privacy Rights. If you are a resident of one of the States, State Privacy Laws may provide you with the following rights with respect to your personal information:
The right to know what personal information we have collected, used or disclosed about you.
The right to request that we delete any personal information we have collected about you.
The right to request that we correct any inaccurate personal information we have collected about you.
Submitting Requests. You may submit requests to delete, correct and/or to know personal information we have collected about you by contacting us at email@example.com or by contacting our toll-free telephone number at 1-877-339-5494 ext. 3900.
We will respond to your request in compliance with the requirements of the State Privacy Law or other applicable law.
Verification of Your Identity. When you exercise these rights and submit a request to us, we or our partners will verify your identity by asking you to authenticate your identity via standard authentication procedures. For example, we may ask for your email address, order numbers of previous orders of our products and services, or the date of your last purchase from us. We also may use a third-party verification provider to verify your identity.
Authorized Agents. You may permit an authorized agent to submit a request to know, delete or correct your personal information. If we receive a request on your behalf, we will ask that person to give us proof that you gave that person written permission to make a request for you. If that person does not provide us with written proof, we will deny their request so that we can protect your personal information.
California Business Contact Information. If you are a California resident and we receive your personal information in the form of contact details from business events, for example as part of a business appointment (e.g., by exchanging business cards) or as part of any other form of collaboration, we may use your contact and business details to maintain our business contacts. For this purpose, we may transfer your contact details to our internal database. Pursuant to the CCPA, you have the privacy rights under State Privacy Laws with respect to your business contact personal information described above. The processing activity may include the following data categories:
Your contact information (e.g., name, title, form of address or salutation, address, gender, telephone numbers, email address); and
Details on your profession (e.g., job title, position, personnel number, place of work, branch office, department, qualifications).
This data processing is based on our legitimate business interests. We have a legitimate economic interest in maintaining contacts beyond the initial context and in using them to establish and develop a business relationship and to remain in contact with the parties concerned.
Such business contacts could also be easily processed in our email communications with you and then kept in typical business software, either centrally or on the electronic devices of our employees.
No Sale of Personal Information. Roland DOES NOT SELL your personal information, as that term is defined under the CCPA.
Cross-Context Behavioral Advertising. We will not share your personal information for cross-context behavioral advertising, as those terms are defined under the CCPA.
Non-Discrimination. If you make a request under a State Privacy Law, we will not discriminate against you in any way. For example, we will not deny you goods or services, charge you different prices or rates for goods or services, deny you discounts or other benefits or impose penalties on you, or provide you with or suggest that you will receive a different level or quality of goods or services.
Automated Decision-Making. We generally do not use automated decision-making technology, as that term is defined by the U.S. Privacy Laws. If we make use of automated decision-making technology, you will be informed through a separate privacy notice.
SUPPLEMENTAL PRIVACY STATEMENT FOR RESIDENTS OF THE EEA, UK AND SWITZERLAND [GDPR]
If you are accessing the Sites from a member state of the EEA, the UK or Switzerland, this Supplemental Privacy Statement applies to you. The following data protection/privacy laws and regulations are applicable to Roland’s Processing of Personal Data in the provision of the Products and related services to you if you are domiciled in the EEA, UK and Switzerland, including, as applicable: (a) the EU General Data Protection Regulation 2016/679 (“GDPR”); (b) any legislation which implements or supplements the GDPR; (c) any legislation which implements the European Community’s Directive 2002/58/EC; (d) UK GDPR and Data Protection Act of 2018 (UK); (e) the Federal Data Protection Act of 19 June 1992 (Switzerland).
1. Preliminary Information
1.1 Roland has appointed Roland Central Europe N.V., a company registered in Belgium under company number 0422.585.547 whose registered office is Klaus-Michael Kuehnelaan 13, 2440 Geel, Belgium, as its EU representative under GDPR Art. 27, and Roland Europe Group Limited whose registered office is at Hive 2, 1530 Arlington Business Park, Theale, Reading, Berkshire RG7 4SA United Kingdom as its UK representative under UK-GDPR Art. 27.
1.2 We can be contacted via our representative and Data Protection Officer at REG-DPO@roland.com.
1.3 We also disclose your Personal Data as defined in clause 2.1 below with other companies in the Roland group of companies, as described below in clause 8 for the purposes set forth in Section D. above. You can access their privacy policies on the Roland website found at www.roland.com/global.
2. Data Protection
2.1 References in this Supplemental Statement to:
“Data Controller” means: the organization responsible for processing your Personal Data and complying with Privacy and Data Protection Requirements;
“Privacy and Data Protection Requirements” means the applicable laws applying to the processing of your Personal Data, including the EU’s General Data Protection Regulation (GDPR) and UK-GDPR; and
“Personal Data” means any information that can be used to identify you or that we can link to you and which we have in our possession or control.
2.2 For the purposes of applicable Privacy and Data Protection Requirements, we are Data Controllers and therefore responsible for the processing of your Personal Data in accordance with applicable Privacy and Data Protection Requirements.
3. Information we may Collect about You
3.1 When you use our Sites and/or when you otherwise deal with us, as explained more fully above, we may collect the following information about you:
Personal and contact information including first and last name, email address, shipping address, telephone number, age (or date of birth);
Technical or statistical/analytics information including IP address, operating system, browser type and related information regarding the device you used to visit our Sites, geolocation information, the length of your visit and your interactions with our Sites;
Information obtained through our correspondence and monitoring in accordance with clause 3.2 below; and/or
details of any inquiries made by you through our Sites and any offline channels, together with details relating to subsequent correspondence (if applicable).
3.2 We may monitor your use of our Sites through ‘cookies’ and similar tracking technologies. We may also monitor traffic, location and other data and information about users of our Sites. Such data and information, to the extent that you are individually identifiable from it, shall constitute Personal Data as defined above. With respect to web cookies and similar technologies that are not strictly necessary for our collection of Personal Data, such as cookies for marketing purposes, Roland seeks consent from users of the Sites who are subject to GDPR. In addition, some of the data collected will be aggregated, deidentified and/or statistical, which means that we will not be able to identify you individually.
3.3 Occasionally we may receive Personal Data about you from other sources, for example authorized Roland dealers or service centers, third-party media partners, repair technicians you connect with through our Sites, competition or contest entries, online/offline events or from any third-party websites and applications that integrate or communicate with our Sites in relation to you. If so, we will add this information to the Personal Data we already hold about you in order to help us carry out the activities listed below.
4. How long we keep your Personal Data
4.1 Subject to clause 4.2, we will keep your Personal Data only for the purposes set out in clause 5.2 below as follows: Roland keeps Personal Data for as long as required to meet our obligations to you, often contractual requirements, and to comply with applicable law. For example, if you register with Roland on one of the Sites, we retain your Personal Data for as long as you have an account with us and thereafter for as long as required for us to comply with applicable law, fulfill our contractual obligations to you or defend our legal interests in connection with any claim or action we might face before a dispute resolution body. We take commercially reasonable measures to ensure that Personal Data is deleted, erased or anonymized as soon as possible once the purposes for which such data was collected have been fulfilled.
4.2 If required, we will be entitled to hold your Personal Data for longer periods in order to comply with our legal or regulatory obligations.
5. Legal basis for processing your Personal Data
5.1 Under applicable Privacy and Data Protection Requirements we may only process your Personal Data if we have a “legal basis” (i.e. a legally permitted reason) for doing so. For the purposes of this Supplemental Statement, our legal bases for processing your Personal Data are set out in the table below.
5.2 Purpose and Legal Basis Table:
Purpose for Processing
Legal basis for processing your Personal Data
To provide services to you in accordance with a Product or warranty that you have registered with us. These services may include but are not limited to after sales support, version updates, hints & tips or repair of Products.
This is necessary for the performance of the contract between us, such as completing your purchase, or is based on our legitimate interests of providing Products or services to you.
For managing or performing a contract we have with you
This is necessary for the performance of the contract between us or necessary for our legitimate interests of providing a Products or services to you, such as support
To conduct questionnaires, surveys, contests and research into customer satisfaction.
This is carried out in accordance with our legitimate business interests of providing services and Products to you and ensuring that we continue to monitor and improve those services and products.
To operate, administer, maintain, provide, analyze and enhance our Sites and the services available through our Sites.
This is carried out in accordance with our legitimate business interests of providing services and Products to you and ensuring that we continue to monitor and improve those services and Products.
To investigate and address any comments, questions or complaints made by you regarding our Sites or any of our Products or services, and any similar or related comments, questions or complaints from other users.
This carried out in accordance with our legitimate business interests for the purpose of processing your comments, questions or complaints and in the event that follow-up questions arise.
To ensure that content from our Sites is presented in the most effective manner for you and for your device.
This is carried out in accordance with our legitimate business interests of providing services and Products to you and ensuring that we continue to monitor and improve those services and Products.
To allow you to participate in interactive features of our Sites, including inputting information and providing feedback.
This is carried out in accordance with our legitimate business interests of providing services and Products to you and ensuring that we continue to monitor and improve those services and Products.
To notify you about changes to our Sites or any Product warranty.
This is carried out in accordance with our legitimate business interests of providing services and Products to you and ensuring that we continue to monitor, support and improve those services and Products.
To disclose your information to selected third parties as described in clause 7.4 below.
This is carried out under consent.
Where we receive your Personal Data from a third party in order to continue the provision of a service or Product to you (see clause 3.3 above)
This is carried out in accordance with our legitimate business interests, contractual obligations and/or consent you may have provided us with.
To contact you for marketing purposes (see 'Marketing and opting out' in clause 7 below).
This is carried out under the following circumstances:
(i) you have given your consent; or
(ii) you have previously bought Products and/or services from us and we are contacting you to let you know about similar Products and/or services that we offer.
Where required by (but not limited to) any request or order from law enforcement agencies and/or tax authority in connection with any investigation to help prevent unlawful activity.
This is necessary for compliance with a legal obligation.
We may monitor communications with you (such as emails) for the purposes of provision of services and Products, quality assurance, training, fraud prevention and compliance purposes. Any information that we receive through such monitoring and communication will be added to the information we already hold about you.
This is necessary for compliance with a legal obligation and/or for our legitimate business interests of providing services and products to you and ensuring that we continue to monitor and improve those services and Products.
6. Your Consent to Processing
6.1 As noted above, you will be required to give consent to certain processing activities before we can process your Personal Data as set out in this Supplemental Statement. Where required, we will seek this consent from you when you first submit Personal Data to or through our Sites.
6.2 If you have previously given consent you may freely withdraw such consent at any time. You can do this through your account(s) on our Sites or by notifying us in writing using the contact details provided in this Supplemental Statement.
6.3 If you choose to withdraw your consent, and there is no other legal basis for processing your Personal Data (see clause 5 above), we will stop processing your Personal Data. If we do have another legal basis for processing your Personal Data, then we may continue to do so subject to your legal rights (see clause 14 below).
6.4 Please note that if we need to process your Personal Data in order to operate our Sites and/or provide our services, and you object or do not consent to us processing your Personal Data, our Sites and/or those services provided may not be fully available to you.
7. Marketing and Opting Out
7.1 Where you have previously ordered Products or services from us, we may contact you by telephone, email and/or regular mail about similar or related Products, services, promotions and special offers that may be of interest to you. We will inform you (during the sales process) if we intend to use your data for such purposes and give you the opportunity to opt-out of receiving such information from us.
7.2 In addition, and where you have given your consent, we may also contact you by telephone and email about our other Products, services, promotions and special offers that may be of interest to you. We will inform you (before collecting your data) and seek your permission if we intend to use your data for such additional marketing purposes. If you prefer not to receive any direct marketing communications from us, or you no longer wish to receive them, you can opt out at any time (see below).
7.3 If you have given consent, we may contact you by mail, telephone and/or email to provide information about Products, services, promotions, special offers and other information we think may be of interest to you. We will inform you (before collecting your data) if we intend to use your Personal Data for such purposes. If you would rather not receive such marketing information from us, or you no longer wish to receive it, you can opt out at any time (see below).
7.4 If you have given consent, we may disclose your Personal Data with carefully selected third-party organizations and business partners and they may contact you directly (unless you have asked them not to do so) by mail, telephone and email about Products, services, promotions and special offers that may be of interest to you. We will inform you (before collecting your Personal Data) and seek your permission if we intend to disclose your Personal Data to third parties for such purposes. If you prefer not to receive direct marketing communications from our business partners, or you no longer wish to receive them, you can opt out at any time (see below).
7.5 If you have given consent, we may use your email address to deliver personalized marketing and advertising to you on social media platforms and advertising platforms, such as Facebook, Twitter, TikTok, LinkedIn, Instagram and Google. We may also use your email address, or information about you from the Facebook cookie/pixel on our websites, or if you follow our pages on social media, to enable social media and advertising platforms to find other users who share similar interests to you based on the information those platforms hold on you. If you prefer not to receive any direct marketing communications from us, or you no longer wish to receive them, you can opt out at any time (see below).
7.6 You have the right at any time to ask us, or any third party, to stop processing your Personal Data for direct marketing purposes. If you wish to exercise this right, you should contact us by sending an email to REG-DPO@roland.com or contact the relevant third party using their given contact details, giving us or them enough information to identify you and deal with your request. Alternatively, you can follow the unsubscribe instructions in emails you receive from us or them.
8. Disclosure of your Personal Data
8.1 We may disclose your Personal Data:
To other companies within our group of companies some of which are located outside of the EEA, (please see clause 11 for more information on how we transfer data overseas);
To our business partners, service providers or third-party contractors to enable them to undertake services and processing as necessary for us and/or on our behalf (and we will ensure they have appropriate measures in place to protect your Personal Data);
To any prospective buyer or seller (and their representatives) in the event that we sell or buy any business or assets;
If we are under a duty to disclose Personal Data in order to comply with any legal obligation, including (but not limited to) any request or order from law enforcement agencies and/or tax authorities in connection with any investigation to help prevent unlawful activity; and
To other third parties if you have specifically consented to us doing so.
8.2 We may disclose aggregated, anonymized and deidentified information (i.e. information from which you cannot be personally identified), or insights based on such anonymized information, to selected third parties, including (without limitation) analytics and search engine providers to assist us in the enhancement and optimization of our Sites. In such circumstances we do not disclose any information which can identify you personally.
9. Keeping your Personal Data Secure
9.1 We will use technical and organizational measures in accordance with good industry practice to safeguard your Personal Data, including the use of data encryption.
9.2 While we will use all reasonable efforts to safeguard your Personal Data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot entirely guarantee the security or integrity of any Personal Data that is transferred from you or to you via the internet.
10.1 We may monitor communications with you (such as emails) for the purposes of provision of services, quality assurance, training, fraud prevention and compliance purposes. Any Personal Data that we receive through such monitoring and communication will be added to the Personal Data we already hold about you and may also be used for the purposes listed in clause 5 above.
11. Personal data transfers outside of EEA/UK/Switzerland
11.1 From time to time we may need to transfer your Personal Data to countries outside of the UK, Switzerland or the European Economic Area (which comprises the EU member states plus Norway, Iceland and Liechtenstein (“EEA”)). Other countries where we may need to transfer your Personal Data include:
Japan, because our Roland group headquarters is based there; Japan received the first adequacy decision under the GDPR, so Personal Data transfers to Japan from the EEA/UK need no further data transfer mechanisms.
The United States as certain servers are located there; while the U.S. has no adequacy decision from the European Commission, most Personal Data transferred is located in Amazon Web Services data centers, subject to a high degree of security and protection. Other Personal Data is maintained by well-known service providers such as ActiveCampaign for CRM and Zendesk for customer support purposes. Roland attempts to provide an adequate degree of protection as required by GDPR, including where appropriate: entering into appropriate data transfer agreements based on language approved by the European Commission pursuant to GDPR Art. 46(5), such as the Standard Contractual Clauses, and implementing appropriate physical, technical and organizational security measures to protect Personal Data against accidental or unlawful destruction, alteration, loss, unauthorized disclosure or access.
Other countries as may be required for the purposes set out in clause 6. Such countries may not have similar protections in place regarding protection and use of your data as those set out in this Supplemental Statement. If we do transfer your Personal Data to countries outside the UK, Switzerland or the EEA, we will take reasonable steps to ensure adequate protections are in place to ensure the security of your Personal Data, including the use of approved standard contractual clauses.
12. Personal Data about other Individuals
If you provide us with the Personal Data of a third party, you confirm that the third party has appointed you to act on their behalf and has agreed that you can: give consent on their behalf to the processing of their Personal Data; receive on their behalf any Data Protection notices; and give consent to the transfer of their Personal Data abroad (if applicable).
13. Your Rights
If you are an individual, this section sets out your legal rights in respect of any of your Personal Data that we are holding and/or processing. If you wish to exercise any of your legal rights, you should put your request in writing to us (using our contact details in clause 19 below) giving us enough information to identify you and respond to your request.
13.1 You have the right to request access to your Personal Data that we may hold and/or process about you.
13.2 You have the right to have any inaccurate Personal Data that we may hold about you corrected and/or updated. If any of the Personal Data that you have provided changes, or if you become aware of any inaccuracies with your Personal Data, please let us know in writing, providing us with enough information to make the required change(s) and/or correction(s).
13.3 You have the right in certain circumstances to request that we delete all Personal Data we hold about you (the ‘right of erasure’). Please note that this right of erasure is not available in all circumstances, for example where we need to retain the Personal Data for legal compliance purposes. If this is the case, we will let you know.
13.4 You have the right in certain circumstances to request that we restrict the processing of your Personal Data, for example where the Personal Data is inaccurate or where you have objected to the processing (see clause 13.6 below).
13.5 You have the right to request a copy of the Personal Data we hold about you and to have it provided in a structured format suitable for you to be able to transfer it to a different data controller (the ‘right to data portability’). Please note that the right to data portability is only available in some circumstances, for example where the processing is carried out by automated means. If you request the right to data portability and it is not available to you, we will let you know.
13.6 You have the right in certain circumstances to object to the processing of your Personal Data. If so, we shall stop processing your Personal Data unless we can demonstrate a sufficient and compelling legitimate basis for continuing the processing If, as a result of your circumstances, you do not have the right to object to such processing then we will let you know.
13.7 You have the right in certain circumstances not to be subject to a decision based solely on automated processing, for example where a computer algorithm (rather than a person) makes decisions which affect your contractual rights. Please note that this right is not available in all circumstances. If you request this right and it is not available to you, we will let you know.
13.8 You have the right to object to direct marketing, for which see clause 8.5 above.
13.9 Profiling. Roland does not use in connection with the Sites or the services we offer automated decision-making in a way that produces legal effects concerning you or which significantly affects you.
13.10 Procedure: We will not charge a fee for your exercise of the rights enumerated above, provided the request is not excessive or unreasonable. In addition, you have the right to data portability, which allows you to receive from us Personal Data about you which you have provided to us in a structured, commonly used and machine-readable format, such as a CSV file. We will do this free of charge. If it is technically feasible, you can request that we transmit the Personal Data directly to another organization, rather than to you. We will respond to the request within 30 days, unless the request is complex or you send us multiple requests, in which case we can extend our response by another 2 months upon notice to you. You can exercise such rights by accessing the information in your account and/or by emailing us at firstname.lastname@example.org. Please note that these rights may be subject to limitations and conditions under the GDPR or applicable national data protection laws.
We may choose not to fulfill any request that we determine is illegal or incorrect, where we need to maintain the Personal Data because of our contractual or legal obligations (e.g., Personal Data in case files), where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy, or where the rights of persons other than the individual would be violated, but our intention is to comply with opt-out requests, and other requests that seek to correct, update or delete your Personal Data, as fully as possible in accordance with applicable law. You will also be given notice should we use your Personal Data for a purpose other than that for which it was originally collected or processed. We do not ask for, collect or knowingly receive sensitive Personal Data, i.e., Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious beliefs, or information relating to sex life.
If our collection of Personal Data from you has been based on obtaining your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. You have the right to lodge a complaint with a supervisory authority in the EEA.
If you have any concerns about how we collect or process your Personal Data, you have the right to lodge a complaint with a supervisory authority in your country of residence. You can find the relevant supervisory authority name and contact details under https://edpb.europa.eu/about-edpb/about-edpb/members_en.
If you have any questions about reporting concerns or about the competent supervisory authority, please contact our Data Protection Officer by e-mail at REG-DPO@roland.com.
15. Changes to this Supplemental Statement
15.1 We may change this Statement from time to time as necessary. If we change this Supplemental Statement, we will post the changes on this page, and place notices on other pages of our Site as applicable, so that you may be aware of the Personal Data we collect and how we use it at all times. You are responsible for ensuring that you are aware of the most recent version of this Supplemental Statement as it will apply each time you access the Site.
16. Links to other Sites
17.1 Our Sites may contain links to other websites. This Supplemental Statement only applies to our Sites. If you access links to other websites any Personal Data, you provide to them will be subject to the privacy policies of those other websites.
16.2 We have no control over third party websites or systems and accept no legal responsibility for any content, material or information contained in them. Your use of third-party sites or systems will be governed by the terms and conditions of that third party. It is your responsibility to ensure you are happy with such third-party terms and conditions.
17. Contact Us
We welcome your feedback and questions on this Supplemental Statement. If you wish to contact us, please contact our Data Protection Officer at REG-DPO@roland.com. You may find it more efficient to contact us directly at email@example.com