EPC Privacy and Data Protection Policy

Your privacy is important to Executive Personal Computers (EPC), Inc., and its global affiliates (collectively “EPC” or “we” or “our”). This Policy explains what Personal Data we collect from you, why we collect and process your personal data, when and with whom your personal data is shared, and your rights with respect to your Personal Data.

In this Policy the term “Personal Data” means data that identifies or may be used to identify an individual person, including, but not limited to, a person’s name, date of birth, job title, address, email, phone number, or employer. In order to provide outstanding service, we must collect, maintain and process certain Personal Data about our customers, suppliers and other business contacts. We recognize and respect your privacy concerns and expectations about how we use this information. We want you to know about our privacy policies and practices, and what we do to protect your Personal Data.

Personal Data We Collect on our Website
In general, you can visit EPC websites without telling us who you are and without giving any personal data about yourself. There are times, however, when we may need information from you. When you select the “Contact EPC” button, we will ask you to read and agree to this Privacy Policy before you submit your Personal Data to us.

If you apply for a job through our websites, we may collect and process Personal Data you submit to us such as name, address, references, and employment history in order to evaluate your qualifications for a job and contact your references. We will retain your information until the position is filled and for up to six months after the position is filled in case other positions become available.

In all cases in which you submit personal information over our websites, you may tell us that you do not want us to use this information to make further contact with you beyond fulfilling your requests, and we will respect your wishes. If you give us personal information about someone else, such as a spouse, a reference, or a work colleague, we will assume that you have that person’s permission to do so. In any case, we will only retain your personal data for as long as we have a legitimate and lawful reason to do so.

When you visit our websites, EPC may collect certain non-personal data by various means, one of which is “cookies.” Cookies tell website operators to recognize your computer when you revisit a site. Cookies help to improve the use of the website. Cookies also allow Web sites to analyze aggregate traffic on the site, in order to streamline navigation and keep the content fresh for all visitors. You can configure your browser to reject cookies. Cookies do not contain personal data, nor can they read or transmit any data on your computer’s hard drive. Regardless of cookies, all web-browsers transmit the IP address of the computer on which they are running. For most users accessing our websites from an Internet Service Provider (ISP), the IP address will be different every time you log on. IP addresses may be used for various purposes, including to: (1) diagnose service or technology problems reported by our users or engineers that are associated with the IP addresses controlled by a specific Web company or ISP, (2) develop the most appropriate advertising based on geographic area or information derived from IP addresses, (3) estimate the total number of users visiting EPC from specific countries or regions of the world, (4) assist EPC to track visits to our Web site, and (5) help determine which users have access privileges to certain EPC Web site content.

Personal Data We Collect from Customers and Suppliers
In order to carry out our business and to fulfill our contractual obligations, EPC must collect and process Personal Data of prospective and existing customers or suppliers. Examples of the types of Personal Data that EPC may collect from its customers, suppliers and other business contacts are:

• Name, title, address, email, and telephone number
• Proof of address such as copies of utility bills
• Copies of passports or other government issued identification
• Tax identification numbers
• Signatures on legal contracts
• Payment information
• Financial statements or other financial information

Why We Collect Personal Data
EPC only collects Personal Data for lawful purposes. These include:

• To provide customers with IT Asset Disposition products or services
• To facilitate the approval of transactions
• To obtain financing in connection with our products or services
• To respond to requests from the customer, financier, or supplier
• To detect or prevent fraud
• To assess or manage risk
• To perform internal audits
• To comply with anti-terrorism, anti-bribery, or anti-money laundering laws or other laws
• To comply with legal process, subpoenas, or other requests from government bodies
• As part of a sale, merger, acquisition, or similar change of control
• To ensure data security

Specific Rights regarding Personal Data of European Citizens
If you are a citizen of Europe residing within the European Economic Area, you may have the following rights under the General Data Protection Regulation:

• to be informed of this Policy and how EPC uses and processes your Personal Data;
• to request a copy of the Personal Data we have collected;
• to request that we correct any Personal Data that is inaccurate or incomplete;
• to request that we to delete or transfer to your possession such Personal Data for which we no longer have lawful reason to keep;
• to object to the processing of your Personal Data and to lodge a complaint with the relevant data protection authority.

Specific Rights regarding Personal Data of Residents of California
If you are a resident of the state of California you may have the following rights under the California Consumer Privacy Act “CCPA”:

• to be informed of your rights under the CCPA and how EPC uses and processes your Personal Data;
• to request a copy of the Personal Data we have collected;
• to request disclosure of Personal Data processed for a business purpose;
• to request that we delete or transfer to your possession such Personal Data for which we no longer have lawful reason to keep;
• and to be free of discrimination for exercising your rights under the CCPA.

Our Data Protection Principles:
EPC will treat your Personal Data as confidential. We respect your right to privacy. In all cases in which we collect your Personal Data according to this Policy, we will abide by the following principles:

• We will only collect your Personal Data with your full knowledge
• We will only collect and keep your Personal Data for a lawful purpose
• We will only keep that Personal Data which is necessary for the lawful purpose
• We will only keep your Personal Data for as long as the lawful purpose exists
• We will keep your Personal Data accurate to the extent it is reasonably practicable to do so
• We will store your Personal Data securely to prevent unauthorized or unnecessary disclosure
• We will process your Personal Data in accordance with your rights under the relevant data protection laws
• We will not transfer your Personal Data outside of its country of origin unless adequate protections are in place

Transfer or Sharing of Your Personal Data
Subject to the above Data Protection Principles and the terms of any valid and fully-executed non-disclosure agreement, EPC may transfer or share your personal data in the following circumstances:

1. Among our affiliates, including our sole shareholder, CSI Leasing, Inc. and it’s sole shareholder, Tokyo Century Corporation for the lawful purposes described in this Policy;
2. To third parties such as our banks, financiers, couriers and suppliers in order to deliver our services or to fulfill or enforce a contract;
3. To our attorneys, auditors, IT professionals or other third party service providers for the lawful purposes described in this Policy;
4. To government, regulatory, judicial or law enforcement bodies in response to official requests.

EPC may also utilize cloud based customer relationship management or IT service providers to store and process personal data. In all cases EPC will take reasonable steps to ensure that adequate technical and organizational measures are in place so that the transfer and storage of your personal data is secure from unauthorized disclosure, alteration or deletion.
EPC does not sell, rent, or share Personal Data we collect directly from you or about you from third parties with third party Advertisers for their own marketing purposes.

Case Studies
EPC websites may contain “case studies” describing scenarios when EPC customers benefited from EPC’s services and expertise. Because no two customers are alike, these case studies should only serve as examples of other customers’ experiences, and thus may differ from your experience.

Anti-Spam Policy
EPC does not tolerate spam and is committed to proper Web practices and full compliance with the CANSPAM Act of 2003 (15 U.S.C. §7701.) We do not sell or rent e-mail addresses to any unauthorized third party. This does not mean that we can prevent all spam from happening on the internet. If you believe that you have received an unsolicited e-mail from us, please contact EPC at privacy@epcusa.com and we will investigate.

Children
EPC websites are not intended for visitors under 18 years of age. We do not knowingly solicit or collect personal data from or about children, nor do we knowingly market our products or services to children.

Notices and Revisions
EPC may revise this privacy policy from time to time. You should periodically check the revision date at the top of this Web page to learn of any revisions.

Privacy Shield
Please visit www.csileasing.com for the Privacy Shield Policy for CSI Leasing, Inc. and its subsidiaries, which include EPC, Inc.

Contact EPC, Inc.
To “opt out” or make other choices about your Personal Data or to exercise your rights, please email privacy@epcusa.com.

Website Terms of Use

EPC, INC. WEB SITE TERMS OF USE.

Effective date: January 1, 2021.

INTRODUCTION

EPC, Inc. (“EPC” or “we” or “us”) operates this Web site (“Site”) to provide online access to information about EPC and the services and opportunities we provide (“Services”). By accessing and using this Site, you agree to each of the terms and conditions set forth herein (“Terms of Use”). If you do not agree to be legally bound by the Terms of Use, you should exit this Site immediately. Additional terms and conditions applicable to specific areas of this Site or to particular content or transactions are also posted in particular areas of the Site and, together with these Terms of Use, govern your use of those areas, content or transactions. These Terms of Use, together with applicable additional terms and conditions, are referred to as this “Agreement.”  EPC reserves the right to amend this Agreement at any time and will notify you of any such changes by posting the revised Agreement on the Site. You should check this Agreement periodically for changes. All changes shall be effective upon posting. Your continued use of the Site after any change to this Agreement constitutes your agreement to be bound by any such changes. EPC may terminate, suspend, change, or restrict access to all or any part of this Site without notice or liability.

LICENSE AND OWNERSHIP

Any and all intellectual property rights (“Intellectual Property”) associated with this Site and its contents (the “Content”) are the sole property of EPC, its affiliates or third parties. The Content is protected by copyright and other laws in both the United States and other countries. Elements of the Site are also protected by trade dress, trade secret, unfair competition, and other laws and may not be copied or imitated in whole or in part. All custom graphics, icons, and other items that appear on the Site are trademarks, service marks or trade dress (“Marks”) of EPC, its affiliates or other entities that have granted EPC the right and license to use such Marks and may not be used or interfered with in any manner without the express written consent of EPC. Except as otherwise expressly authorized by these Terms of Use, you may not copy, reproduce, modify, lease, loan, sell, create derivative works from, upload, transmit, or distribute the Intellectual Property of the Site in any way without EPC’s or the appropriate third party’s prior written permission. Except as expressly provided herein, EPC does not grant to you any express or implied rights to EPC’s or any third party’s Intellectual Property.

EPC grants you a limited, personal, nontransferable, nonsublicensable, revocable license to (a) access and use only the Site and Content only in the manner presented by EPC, and (b) access and use the EPC computer and network services offered within the Site (“EPC Systems”) only in the manner expressly permitted by EPC. Except for this limited license, EPC does not convey any interest in or to the EPC Systems, information or data available via the EPC Systems (the “Information”), Content, Services, Site or any other EPC property by permitting you to access the Site.  Except to the extent required by law or as expressly provided herein, none of the Content and/or Information found or accessed via the Site may be reverse engineered, modified, reproduced, republished, translated into any language or computer language, retransmitted in any form or by any means, resold or redistributed without the prior written consent of EPC. You may not make, sell, offer for sale, modify, reproduce, display, publicly perform, import, distribute, retransmit or otherwise use the Content in any way, unless expressly permitted to do so by EPC.

RESTRICTIONS ON THE USE OF THE SITE

In addition to other restrictions set forth in these Terms of Use, you agree that:

(a) You shall not disguise the origin of information transmitted through the Site.

(b) You will not place false or misleading information on the Site.

(c) You will not use or access any service, information, application or software available via the Site in a manner not expressly permitted by EPC.

(d) You will not input or upload to the Site any information which contains viruses, Trojan horses, worms, time bombs or other computer programming routines that are intended to damage, interfere with, intercept or expropriate any system, the Site or that infringes the Intellectual Property rights of another.

(e) You may not use or access the Site in any way that, in EPC’s judgment, adversely affects the performance or function of the Site, or interferes with the ability of authorized parties to access the EPC Systems, Services or the Site.

DOWNLOADING FILES

Any software available for download via the Site is the copyrighted work of EPC and/or its licensors. Use of such software is governed by the terms of the end user license agreement that accompanies or is included with the software. Downloading, installing, and/or using any such software indicates your acceptance of the terms of the end user license agreement. EPC cannot and does not guarantee or warrant that files available for downloading through the Site will be free of infection by software viruses or other harmful computer code, files or programs.

CASE STUDIES

The Site may contain “case studies” describing scenarios where EPC customers benefitted from EPC’s services and expertise.  Because no two customers are alike, these case studies should only serve as examples of other customers’ experiences, and thus may differ from your experience.

COPYRIGHT COMPLAINTS

If you believe, in good faith, that any materials on the Site infringe your copyrights, notifications of claimed copyright infringement should be sent, in accordance with Title 17, United States Code, Section 512(c)(2) (under the “Digital Millennium Copyright Act”) to EPC’s designated agent. Notification should include:

  1. an electronic or physical signature of the person authorized to act on behalf of the owner of the copyright interest;
  2. a description of the copyrighted work that you claim has been infringed;
  3. a description of where the material you claim is infringing is located on the Site;
  4. a statement by you that you have a good faith belief that the disputed use is not authorized by the copyright owner, its agent or the law; and
  5. a statement by you, made under penalty of perjury, that the above information in your notice is accurate and that you are the copyright owner or duly authorized to act on the copyright owner’s behalf.

EPC’s agent for notification of claimed copyright infringement is: Ms. Joan Kersting, 314-997-7010, fax: 314-997-7844, Joan.Kersting@csileasing.com.

NO WARRANTY

EPC MAKES NO REPRESENTATIONS ABOUT THE RESULTS TO BE OBTAINED FROM USING THIS SITE, EPC SYSTEMS, SERVICES, OR CONTENT.  THE USE OF SAME IS AT YOUR OWN RISK. THE SITE, SERVICES AND CONTENT ARE PROVIDED ON AN “AS IS” BASIS.  EPC AND ITS LICENSORS, TO THE FULLEST EXTENT PERMITTED BY LAW, DISCLAIM ALL WARRANTIES, EITHER EXPRESS OR IMPLIED, STATUTORY OR OTHERWISE, INCLUDING BUT NOT LIMITED TO THE IMPLIED WARRANTIES OF MERCHANTABILITY, NON-INFRINGEMENT OF THIRD PARTIES’ RIGHTS, AND FITNESS FOR A PARTICULAR PURPOSE.  EPC AND ITS AFFILIATES, LICENSORS AND SUPPLIERS MAKE NO REPRESENTATIONS OR WARRANTIES ABOUT THE ACCURACY, COMPLETENESS, SECURITY OR TIMELINESS OF THE CONTENT, INFORMATION OR SERVICES PROVIDED ON OR THROUGH THE USE OF THE SITE.  NO INFORMATION OBTAINED BY YOU FROM THE SITE SHALL CREATE ANY WARRANTY NOT EXPRESSLY STATED BY EPC IN THESE TERMS OF USE.

SOME JURISDICTIONS DO NOT ALLOW LIMITATIONS ON IMPLIED WARRANTY, SO THE LIMITATIONS AND EXCLUSIONS IN THIS SECTION MAY NOT APPLY TO YOU.  IF YOU ARE DEALING AS A CONSUMER, YOUR STATUTORY RIGHTS THAT CANNOT BE WAIVED, IF ANY, ARE NOT AFFECTED BY THESE PROVISIONS.  YOU AGREE AND ACKNOWLEDGE THAT THE LIMITATIONS AND EXCLUSIONS OF LIABILITY AND WARRANTY PROVIDED IN THESE TERMS OF USE ARE FAIR AND REASONABLE.

LIMITATION OF LIABILITY

TO THE EXTENT PERMITTED BY APPLICABLE LAW AND TO THE EXTENT THAT EPC IS OTHERWISE FOUND RESPONSIBLE FOR ANY DAMAGES, EPC IS RESPONSIBLE FOR ACTUAL DAMAGES ONLY.  TO THE EXTENT PERMITTED BY LAW, IN NO EVENT SHALL EPC, ITS AFFILIATES, ITS LICENSORS, ITS SUPPLIERS OR ANY THIRD PARTIES MENTIONED ON THE SITE BE LIABLE FOR ANY INCIDENTAL, INDIRECT, EXEMPLARY, PUNITIVE AND CONSEQUENTIAL DAMAGES, LOST PROFITS, OR DAMAGES RESULTING FROM LOST DATA OR BUSINESS INTERRUPTION RESULTING FROM THE USE OF OR INABILITY TO USE THE SITE, EPC SYSTEMS, INFORMATION, SERVICES OR CONTENT WHETHER BASED ON WARRANTY, CONTRACT, TORT, DELICT, OR ANY OTHER LEGAL THEORY, AND WHETHER OR NOT EPC IS ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. TO THE EXTENT PERMITTED BY LAW, THE REMEDIES STATED FOR YOU IN THESE TERMS OF USE ARE EXCLUSIVE AND ARE LIMITED TO THOSE EXPRESSLY PROVIDED FOR IN THESE TERMS OF USE.

SUBMISSIONS TO THE SITE

Any and all submissions communicated to EPC through this Site (collectively, “Submissions”) will be deemed and remain the property of EPC, and EPC is entitled to use any Submission for any purpose, without restriction or compensation to the individual who has provided the Submission. Nothing herein contained shall be construed as limiting EPC’s responsibilities and obligations under its Privacy Policy.

INDEMNIFICATION

You agree to indemnify and hold harmless EPC from and against any and all claims, losses, expenses, or demands or liabilities, including attorneys’ fees and costs, incurred by EPC in connection with any claim by a third party (including any intellectual property claim) arising out of (i) Submissions that you communicate, submit, post to or transmit through the Site, or (ii) your use of the Site in violation of this Agreement or in violation of any applicable law. You further agree that you will cooperate as reasonably required in the defense of any such claims. EPC reserves the right, at its own expense, to assume the exclusive defense and control of any matter otherwise subject to indemnification by you, and you shall not in any event settle any such claim or matter without the written consent of EPC. You further agree to indemnify and hold harmless EPC from any claim arising from a third party’s use of information or materials of any kind that you post on the Site.

LINKS TO THIRD PARTY SITES

THIS SITE MAY CONTAIN LINKS TO SITES CONTROLLED, OWNED, AND OPERATED BY THIRD PARTIES (“THIRD PARTY SITES”). EPC CANNOT CONTROL AND HAS NO RESPONSIBILITY FOR THE ACCURACY OR AVAILABILITY OF INFORMATION PROVIDED ON THE THIRD PARTY SITES. YOU ACKNOWLEDGE THAT USE OF ANY THIRD PARTY SITES IS GOVERNED BY THE TERMS OF USE FOR THOSE WEB SITES, AND NOT BY THIS AGREEMENT. LINKS TO THIRD PARTY SITES DO NOT CONSTITUTE AN ENDORSEMENT BY EPC OF SUCH SITES OR THE CONTENT, PRODUCTS, ADVERTISING OR OTHER MATERIALS PRESENTED ON SUCH SITES, BUT ARE FOR YOUR CONVENIENCE AND YOU ACCESS THEM AT YOUR OWN RISK. EPC IS NOT RESPONSIBLE FOR THE CONTENT OF ANY THIRD PARTY WEB SITES, NOR DOES EPC MAKE ANY WARRANTIES OR REPRESENTATIONS, EXPRESS OR IMPLIED, REGARDING THE CONTENT (OR THE ACCURACY OF SUCH CONTENT) ON ANY THIRD PARTY WEB SITES, AND EPC SHALL HAVE NO LIABILITY OF ANY NATURE WHATSOEVER FOR ANY FAILURE OF PRODUCTS OR SERVICES OFFERED OR ADVERTISED AT SUCH WEB SITES OR OTHERWISE.

USE OF PERSONALLY IDENTIFIABLE INFORMATION

Please review our most current Privacy Policy, which also governs your visit.

USER CONDUCT

You agree to use the Site only for lawful purposes. You are prohibited from any use of the Site, including the Content, Services, EPC Systems, which would constitute an illegal offense, give rise to liability or otherwise violate any applicable local, state, national or international law or regulation.  EPC makes no claims concerning whether the Content may be downloaded or are appropriate for use outside of the United States. If you access this Site from outside of the United States, you are solely responsible for ensuring compliance with the laws of your specific jurisdiction.

TERMINATION

You agree that EPC, in its sole discretion, may terminate or suspend the use of the Site, EPC Systems, Services, and Content at any time and for any or no reason in its sole discretion, even if access and use continues to be allowed to others.  Upon such suspension or termination, you must immediately (a) discontinue use of the Site, and (b) destroy any copies you have made of any portion of the Site, or Content.  Accessing the Site, EPC Systems or Services after such termination, suspension or discontinuation shall constitute an act of trespass.  Further, you agree that EPC shall not be liable to you or any third party for any termination or suspension of your access to the Site, EPC Systems and/or the Services.

GENERAL PROVISIONS

Failure by EPC to enforce any provision(s) of this Agreement shall not be as a waiver thereof. THIS AGREEMENT AND ALL OTHER ASPECTS OF YOUR USE OF THE SITE SHALL BE GOVERNED BY AND CONSTRUED IN ACCORDANCE WITH THE LAWS OF THE STATE OF MISSOURI, WITHOUT REGARD TO ITS CONFLICT OF LAWS RULES. All claims and disputes arising out of this Agreement, and applicable federal law or your use of the Site, other than actions for specific performance or injunctive relief brought by EPC, shall be exclusively brought in the federal, state, or local courts located in the State of Missouri, and, with regard to such claims and disputes, you hereby irrevocably (i) submit to the exercise of personal jurisdiction over you by those courts and (ii) waive any jurisdictional, venue, or inconvenient forum objections to such courts. Any cause of action you may have with respect to the Content, Services, EPC Systems and its Information, Site or this Agreement must be commenced within one (1) year after the claim or cause of action arose, or be barred. If any provision of this Agreement is found to be invalid or unenforceable, the remaining provisions shall be enforced to the fullest extent possible, and the remaining provisions of the Agreement shall remain in full force and effect. This Agreement will be binding on, inure to the benefit of, and be enforceable against the parties and their respective successors and assigns. Neither the course of conduct between parties nor trade practice shall act to modify any provision of the Agreement. All rights not expressly granted herein are hereby reserved.

CONTACT EPC

If you have questions regarding the Agreement or the practices of EPC, please contact us by e-mail, telephone or postal mail:

EPC, INC.
3941 Harry S. Truman Blvd.
St. Charles, Missouri 63301

Tel: 800-235-1046

contactepc@epcusa.com

EPC’s Environmental Policy

EPC’s Environmental Policy

EPC is committed to the prevention of pollution, promoting worker health and safety, protecting workers rights to a workplace free of harassment and discrimination, maintaining a workplace free from harmful pollutants and hazardous conditions, compliance with environmental legislation and accountability for all hazardous e-waste and recycling per the Basel Convention. In addition, EPC takes a strong stance on social accountability, including a prohibition of forced and child labor, engages in a moratorium on prison labor and proactively consults with clients concerning their data security. Through programs emphasizing ongoing training and awareness, EPC sustains continual improvement as well as conformance to the requirements of our environmental management system.