This Privacy Policy describes how NTT Research, Inc. (“NTT Research”, “we”, “us”, or “our”) may access, collect, use, and/or share your personal information when you use our services (“Services”), including when you:

• visit our website at http://www.ntt-research.com (the “Site”), or any website of ours that links to this Privacy Policy; and/or
• engage with us in other related ways, including using any of our facilities, or participating in any sales, marketing, or events.

Your use of our Services, and any dispute over privacy, is subject to and any other applicable agreements between you and NTT Research, such as our Terms of Use, including any applicable limitations on damages and the resolution of disputes.

Information We Collect
How We Disclose Your Information
Cookies and Other Tracking Mechanisms
Third-Party Analytics
Do Not Track Disclosure
Third-Party Links
Security
Direct Marketing
Your California Privacy Rights
Children
Information for EU Individuals
Contact Us
Changes to this Privacy Policy

INFORMATION WE COLLECT

We collect information about you directly from you and automatically through your use of our Services. We may combine information collected from or about you from these various sources.

• Information We Collect Directly from You. We will collect any information that you provide to us through our Services, such as your name, email address, company name, phone number, your marketing preferences, and the contents of any message that you submit through our Services.
• Information We Collect Automatically Through Our Services. We automatically collect information about you through your use of our Services, including, without limitation, your Internet protocol (IP) address, the type of browser you are using, information about the device you are using, domain name, the website that led you to our Services, the website to which you go after leaving our Services, your location, and the dates and times you access our Services. Please see the section below for more information. We may combine information we collect automatically with information we collect directly from.
• Information We Collect Through Closed Circuit Television (CCTV) Monitoring. For the security of our facilities and safety of facility occupants, we perform security monitoring of internal and external spaces at our facilities, with the exception of restrooms and mother’s rooms. No expectation of privacy should be assumed while using these areas within NTT Research facilities.

HOW WE DISCLOSE YOUR INFORMATION

We may disclose your information, including personal information, as described to you at the time of collection or disclosure or as follows:

• Affiliates. We may disclose your information to current or future affiliates or subsidiaries for research, marketing, and other purposes consistent with this Privacy Policy.
• Service Providers. We may disclose your information to our vendors, service providers, agents, or others who perform functions on our behalf. For example, we may disclose your information to a service provider that helps us with our email newsletters and promotional materials.
• Business Transfers. We may disclose your information to another entity in connection with, including during negotiations of, an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer.
• Protecting Rights and Interests. We may disclose your information to protect the safety, rights, property, or security of NTT Research, the Services; to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity that NTT Research, in its sole discretion, may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; and to enforce this Privacy Policy or our Terms of Use.
• Legal compliance. We may disclose your information to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; in response to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a government official.
• Aggregate and de-identified information. We may disclose aggregate, anonymous, or de-identified information about users for marketing, advertising, research, compliance, or other purposes.

COOKIES AND OTHER TRACKING MECHANISMS

We and our service providers use cookies and other tracking mechanisms to track information about your use of our Services. We or our service providers may combine this information with other information, including personal information, we collect about you.

Cookies.

Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site, while others are used to enable a faster log-in process or to allow us to track your activities while using our Site or our Services.

Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse certain areas of the Site, but some features may not function (e.g., you may not be able to stay logged into your account). For more information about how we use cookies, please refer to our .

Clear GIFs, pixel tags, and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also referred to as web beacons, web bugs or pixel tags), in connection with our Services to, among other things, track the activities users of our Services, help us manage content, and compile statistics about usage of our Services. We and our third-party service providers may also use clear GIFs in HTML emails, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded. For more information about how we use clear GIFs and other similar technologies, please refer to our .

THIRD-PARTY ANALYTICS

We use Google Analytics as a third-party analytics company to evaluate use of our Site and Services. We use this tool to help us understand use of, and to improve, our Site and Services, performance, and user experiences. Google Analytics may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google privacy policy at https://policies.google.com/privacy.

You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

DO NOT TRACK DISCLOSURE

Our Site and Services may not respond to Do Not Track signals. For more information about Do Not Track signals, please click here. You may, however, disable certain tracking as discussed in the above (e.g., by disabling cookies).

Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members. If you are in the EU, you may opt-out of certain third party cookies that we and other websites may use for targeted advertising through the European Interactive Digital Advertising Alliance (EDAA) Your Online Choices Page or www.aboutads.info.

Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites.

THIRD-PARTY LINKS

Our Site and Services may contain links to third-party websites and applications, and to social media platforms. Any access to and use of such linked websites and applications is not governed by this Privacy Policy but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such social media platforms, third-party websites, or applications.

SECURITY

We have taken steps to help protect the personal information we collect. However, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your device and account by, among other things, choosing a robust password that nobody else knows or can easily guess and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized password activity.

DIRECT MARKETING

We may send periodic promotional emails to you. You may opt out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt out of receiving emails about recommendations or other information that we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, under California Civil Code § 1798.83, you may request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us at the contact information provided below. In your request, please attest to the fact that you are a California resident and provide a current California address for your response.

California Job Applicant Personal Data. In addition to the categories above, we may collect the following categories of information about California resident job applicants:

• Personal information categories listed in California Civil Code § 1798.80(e). Job applicants may provide a name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
• Protected classification characteristics under California or federal law. Job applicants may provide age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
• Professional or employment-related information. Job applicants may provide current or past job history or performance evaluations.
• Non-public education information (per the Family Educational Rights and Privacy Act, 20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Job applicants may provide education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
• Inferences drawn from other personal information. Job applicants may provide profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

CHILDREN

Our Services are not targeted to children under 13 years of age, and we do not knowingly collect personal information from children under 13. If we discover that a child under 13 has provided us with personal information, we will promptly delete such personal information from our systems.

INFORMATION FOR EU INDIVIDUALS

The following disclosures apply only to NTT Research’s processing of personal data about EU residents.

The Data Controller of the information collect through the Site and Services is NTT Research, Inc., which is headquartered in the United States at 940 Stewart Drive, Sunnyvale, California 94085. To exercise any rights that you may have regarding your personal data, you may contact us at the following address and email:

940 Stewart Drive

Sunnyvale, California 94085

privacy@ntt-research.com

The legal bases for using your personal Information. We collect your information as a Data Controller when we have a legal basis to do so. The following legal bases pertain to our collection of data:

• Our use of your personal data is necessary to perform a contract or take steps to enter into a contract with you.
• Our use of your personal data is in our legitimate interest as a commercial organization to make improvements to our Site and to provide you with access to the Services as you request.
• Our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have in particular, where we are required to disclose personal information to a court or regulatory body in the event of an investigation.
• Our use of your personal information is in accordance with your consent.

If you would like to find out more about the legal bases on which we process personal information, please contact us at privacy@ntt-research.com.

Your legal rights. Subject to certain exemptions, and dependent upon the processing activity we are undertaking, European Union individuals have certain rights in relation to personal information:

Right to access, correct, and delete your personal information: You have the right to request access to the personal information that we hold about you and: (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred. You also have the right to request that we correct any inaccuracies or delete your information. We are not required to comply with your request to erase personal information if the processing of your personal information is necessary for compliance with a legal obligation or for the establishment, exercise, or defense of legal claims.

Right to restrict the processing of your personal information: You have the right to restrict the use of your personal information when (i) you contest the accuracy of the data; (ii) the use is unlawful but you do not want us to erase the data; (iii) we no longer need the personal information for the relevant purposes, but we require it for the establishment, exercise, or defense of legal claims; or (iv) you have objected to our personal information use justified on our legitimate interests verification as to whether we have a compelling interest to continue to use your data. We can continue to use your personal information following a request for restriction, where: (a) we have your consent; or (b) to establish, exercise or defend legal claims; or (c) to protect the rights of another natural or legal person.

Right to data portability: To the extent that we process your information (i) based on your consent or under a contract; and (ii) through automated means, you have the right to receive such personal information in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller.

Right to object to the processing of your personal information: You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

Right to lodge a complaint with your local supervisory authority: You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

How to exercise your rights. If you would like to exercise any of the rights described above, please send us a request to privacy@ntt-research.com. In your message, please indicate the right you would like to exercise and the information to which it relates.

We may ask you for additional information to confirm your identity and for security purposes before disclosing the personal information requested to you.

Cross-border transfer of information. We maintain servers and systems in the United States hosted by third-party service providers. As a result, where the personal information that we collect through or in connection with the Site or the Services is processed in the United States, we will take steps to ensure that the information receives the same level of protection as if it remained within the European Union. You may have a right receive details of any safeguards that we have where your data is transferred outside the European Union, (e.g., to request a copy where the safeguard is documented, which may be redacted to ensure confidentiality).

Retention of personal data and access. We will keep your information accurate, complete and up to date. We will retain your personal data for the period necessary to fulfil the different purposes outlined in this Privacy Policy, and in particular, we will keep data for as long as it takes to respond to a query. Where we are required to do so to meet legal, regulatory, tax or accounting requirements, we will retain your personal data for longer periods of time, but only where permitted to do so, including so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a possibility of legal action relating to your personal data or dealings.

Right to non-discrimination for your exercising your rights. We will not provide a different level or quality of services just because you exercised your rights. However, if you refuse to provide your personal information, or ask it to delete or stop selling your personal information, and that personal information or sale is necessary for us to provide you with services, we may not be able to complete that transaction.

CONTACT US

If you have questions about this Privacy Policy or the privacy aspects of our Services, please contact us at privacy@ntt-research.com.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is current as of the “last updated” date set forth above. We may change this Privacy Policy from time to time, so please be sure to review this policy periodically at www.ntt-research.com/privacy.