Beta Test Privacy Notice

## Beta Test Privacy Notice (Version 1.0)

### 1. Who we are

Sonicware Co., Ltd. (data controller)
Address: 2-26-17 Higashi-Ikebukuro, Toshima-ku, Tokyo 170-0013, JAPAN
Contact: https://sonicware.jp/pages/support
Requests to access, correct or delete your data go through the same form. Please start your message with "Beta Test".

### 2. What we collect

| Data | Source |
|---|---|
| Name | Registration form |
| Email address | Registration form |
| Serial number of the target product | Registration form; report form (optional) |
| Date and version of the terms you agreed to | Registration form submission record |
| Defect reports (firmware version, symptom, steps to reproduce, operating environment, power source, reference URLs, etc.) | Report form |
| Contact email address, where it differs from the one used at registration | Report form (optional) |
| Newsletter preference | Registration form |

We do not collect special categories of personal data (racial or ethnic origin, health, beliefs, criminal history and similar).

### 3. Why we use it

1. to manage Program participants and to contact you;
2. to investigate and reproduce defects, and to improve our products and firmware;
3. to determine whether a defect relates to a particular production lot;
4. to compile statistics about the Program; and
5. to send you our newsletter, if you asked for it.

### 4. Legal basis (for residents of the EU/EEA and the UK)

| Processing | Basis |
|---|---|
| Purposes 1–4 | Performance of a contract, and our legitimate interest in improving product quality |
| Purpose 5 (newsletter) | Your consent, which you may withdraw at any time |

### 5. Who we share it with

We do not share your personal data with third parties except where required by law.

We use the following service provider, which processes data only on our instructions:

- Microsoft Corporation (Microsoft 365: forms, lists, email and notifications)

### 6. How long we keep it

| Data | Retention |
|---|---|
| Name, email address, serial number, consent record | 2 years after the end of your most recent beta test |
| Defect reports | No fixed period. After the above period we sever the link to your name, email address and serial number so the report no longer identifies you |
| Newsletter recipient data | Until you unsubscribe |

### 7. International transfers

Your data is controlled by Sonicware in Japan. Transfers of personal data from the EEA and the UK to Japan take place under the adequacy decisions adopted by the European Commission and the UK government, so no additional safeguards are required.

Our cloud service provider processes the data primarily in data centres in Japan, in line with our tenant configuration. Some services may process data in other regions; those transfers are covered by the provider's own data protection terms, which include the EU Standard Contractual Clauses.

### 8. Your rights

You may ask us to:

- tell you what we hold and give you a copy;
- correct, add to or delete it;
- stop using it, erase it, or stop disclosing it to third parties;
- restrict our processing, or object to it (EU/EEA and UK residents);
- provide it in a portable format (EU/EEA and UK residents);
- stop sending you the newsletter.

Contact us at the address in Section 1. We will verify your identity and respond as required by law.

If you live in the EU/EEA or the UK, you also have the right to complain to your national data protection authority.

### 9. Security

Access to your data is limited to staff who need it, and access is logged. Data is transmitted over encrypted connections and stored in access-controlled cloud services.

### 10. Changes

If we change this notice we will publish the new version on our website, and will email participants about significant changes.