Privacy Policy (Brother Industries, Ltd. Industrial Equipment Business)

3 October 2025

This Privacy Policy explains how Brother Industries, Ltd. (Address: 15-1, Naeshiro-cho, Mizuho-ku, Nagoya 467-8561, Japan; hereinafter referred to as ‘we’, ‘us’, or ‘our’) collects and processes Personal Data of individuals located in the EEA and the UK in relation to our Industrial Equipment Business (hereinafter referred to as "the Business"), how Personal Data is used and protected, and the rights of data subjects regarding their Personal Data. In this Privacy Policy, “Personal Data” refers to information relating to an identified or identifiable natural person.

Please note that we operate globally and have subsidiaries in Japan and other regions worldwide (hereinafter referred to as “Brother Group Companies”). Each Brother Group Company has its own privacy policy, and when Brother Group Companies collect or handle Personal Data, their respective privacy policies will apply.

Contact details for our EU representative is as follows:

EU Representative
  • Name: Brother Italia S.r.l.
  • Address: Segreen Business Park, Via San Bovio 3, 20054 San Felice di Segrate, Milan, Italy
  • Email: data.protection@brother.co.jp

1. Personal Data We Collected

We may need to collect Personal Data based on applicable laws or contractual relationships with you. If you do not provide the requested Personal Data, we may not be able to fulfill certain obligations (such as providing products or services).

1.1 Personal Data We Collected Directly from You

Personal Data collected directly from you may include:

  1. Personal details (e.g., name, date of birth, employer, job title);
  2. Contact details (e.g., phone number, email address, postal address, mobile phone number);
  3. Details and status of your inquiries, requests, and consideration of the Business’s products and services;
  4. Payment and transaction details;
  5. If you are a customer, serial numbers of the Business’s products and services (which may be used to identify you if you register a product, open an account, or purchase a service from any Brother Group Company);
  6. IP address and MAC identifiers (when accessing the Business's website or other online services).

1.2 Personal Data We Collected from Other Sources

Personal Data collected from lawful sources other than you (such as business directories, telephone books, or credit information agencies) may include:

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

2. Purposes of Processing Personal Data

We process Personal Data for the following purposes:

2.1 If you are a customer, we process your Personal Data to:

  1. ensure the accuracy of records of your Personal Data and other information held by us;
  2. comply with and fulfill legal obligations to you or third parties (e.g., tax authorities);
  3. check and maintain the quality of the Business’s products and services;
  4. improve and develop the Business’s products and services, conduct market analysis,
    inventory analysis, inspection, and confirmation, and ensure proper logistics functions;
  5. take steps prior to entering into a contract and fulfill contractual obligations, including;
    • provide materials and information at your request;
    • provide you with customer service, after-sales support (including provision of support information and content), and software updates;
    • provide educational content related to the Business’s products;
    • deliver products to you.
  6. recall products;
  7. operate and manage exhibitions, seminars, and campaigns related to the Business’s products and services;
  8. conduct marketing research, data measurement, and analysis to deliver appropriate advertising
  9. respond to your inquiries and requests.

2.2 If you are a business partner representative (including new, existing, and former partners), we process your Personal Data to;

  1. conduct credit checks prior to transactions;
  2. ensure the accuracy of records of information, including Personal Data, related to transactions;
  3. improve and develop the Business’s products and services, conduct market analysis, inventory analysis, inspection, and confirmation, and ensure proper logistics functions;
  4. verify your identity when you visit us;
  5. take steps prior to entering into a contract and fulfill contractual obligations to business partners, including;
    • Provide materials and information at the request of business partners
    • Process payments for invoices;
    • Allow business partners to access the Business’s premises upon contractual request.
  6. comply with and fulfill legal obligations to business partners or third parties (e.g., tax authorities);
  7. manage and operate exhibitions, seminars, and campaigns related to the Business’s products and services;
  8. conduct marketing research, data measurement, and analysis to deliver appropriate advertising;
  9. respond to inquiries, requests, and appointments.

2.3 For Direct Marketing

With your explicit consent, or where permitted by applicable law, we may use Personal Data to provide personalized offers relating to the Business’s products and services (“Direct Marketing”). Direct Marketing may include:

  1. Newsletters and email magazines regarding the Business’s products and services;
  2. Information on events, exhibitions, and seminars hosted by the Business or its distributors and dealers;
  3. Requests for feedback on the Business’s products and services;
  4. Information on products or services provided by third parties related to the Business’s products or services that may be of interest to you.

In principle, we shall not use Personal Data for purposes other than those described in this Privacy Policy. If it becomes necessary to use Personal Data for purposes not described herein, we shall provide prior notice and seek your consent. Personal Data collected shall not be used for automated decision-making, including profiling.

2.4 For legal compliance, legal proceedings, and establishment, exercise, or defense of legal claims

We may process Personal Data to comply with applicable laws, respond to court orders and legal proceedings, or establish, exercise, or defend legal claims.

3. Legal Basis for Processing Personal Data

The legal bases on which we rely for each processing purpose described above are as follows:

Section Process Lawful Basis for Processing
2.1(a) ensure the accuracy of records of your Personal Data and other information held by us Legitimate interests
2.1(b) comply with and fulfill legal obligations to you or third parties (e.g., tax authorities) Compliance with legal obligations or legitimate interests
2.1(c) check and maintain the quality of the Business’s products and services Performance of contract or legitimate interests
2.1(d) improve and develop the Business’s products and services, conduct market analysis, inventory analysis, inspection, and confirmation, and ensure proper logistics functions Performance of contract or legitimate interests
2.1(e) take steps prior to entering into a contract and fulfill contractual obligations Performance of contract
2.1(f) recall products Performance of contract, compliance with legal obligations, or legitimate interests
2.1(g) operate and manage exhibitions, seminars, and campaigns related to the Business’s products and services Legitimate interests or consent
2.1(h) conduct marketing research, data measurement, and analysis to deliver appropriate advertising Legitimate interests
2.1(i) respond to your inquiries and requests Legitimate interests or consent
2.2(a) conduct credit checks prior to transactions Legitimate interests
2.2(b) ensure the accuracy of records of information, including Personal Data, related to transactions Legitimate interests
2.2(c) improve and develop the Business’s products and services, conduct market analysis, inventory analysis, inspection, and confirmation, and ensure proper logistics functions Performance of contract or legitimate interests
2.2(d) verify your identity when you visit us Legitimate interests or consent
2.2(e) take steps prior to entering into a contract and fulfill contractual obligations to business partners Performance of contract or legitimate interests
2.3 direct marketing Legitimate interests or consent
2.4 legal compliance, legal proceedings, and establishment, exercise, or defense of legal claims Compliance with legal obligations or legitimate interests

4. Rights of Data Subjects Regarding Personal Data

Under the GDPR/UK GDPR, you have certain rights regarding your Personal Data held by us, including:

  1. The right to obtain information about the processing of your Personal Data and access your Personal Data;
  2. The right to request the correction of inaccurate or incomplete Personal Data;
  3. The right to request the erasure of your Personal Data under certain circumstances;
  4. The right to request the restriction of the processing of your Personal Data under certain circumstances;
  5. The right to object to the processing of your Personal Data by the Business;
  6. The right to receive your Personal Data in a structured, commonly used, and machine-readable format and/or to request the direct transfer of your Personal Data to another recipient where technically feasible (right to data portability);
  7. The right to withdraw your consent at any time where processing is based on consent (however, withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal);
  8. The right to file a complaint with the relevant data protection authority.

If you wish to exercise any of the rights described in this section, please contact the inquiry address listed in section 8.

5. Disclosure of Personal Data

We work closely with Brother Group Companies and may disclose Personal Data to Brother Group Companies located in the country or region of customers and business partners. In such cases, Personal Data shall be disclosed in accordance with this Privacy Policy. Brother Group Companies receiving Personal Data shall use it only within the scope of the purposes specified in this Privacy Policy, unless you provide consent.

Within the scope of the purposes specified in this Privacy Policy, we may also disclose Personal Data to the following third parties:

  1. External third parties
    • Cloud service providers
      We use cloud service providers such as Microsoft and Amazon to store data in the cloud, including Personal Data.
    • Business service providers
      We outsource the provision of information and content for after-sales support, provision of educational content, sending newsletters and marketing emails, provision of data analysis services, and processing and fulfillment of payments and orders to business service providers, and may disclose Personal Data to them as part of such outsourcing.
    • Distributors and dealers of the Business’s products and services
      We may disclose Personal Data to distributors and dealers to support customer purchases and use of the Business's products and services, respond to customer requests, and better understand how customers use the Business's products and services.
  2. Law enforcement agencies, courts, regulatory authorities, and government agencies
    We may disclose Personal Data to these parties as necessary to comply with legal or regulatory obligations or to protect the rights of us or third parties.
  3. Successors to the Business
    We may disclose your Personal Data to third parties that succeed to all or part of the Business.

6. Security and Retention Period of Personal Data

We will erase Personal Data when it is no longer necessary for the purposes of processing or when consent is withdrawn and there is no other legal basis for retaining the Personal Data. When determining the retention period for Personal Data, we consider legal obligations and retain Personal Data in accordance with its data retention policy as required or permitted by applicable law.

7. International Data Transfers

As we and the Business are located in Japan, your Personal Data will be stored and processed in Japan. Japan has been designated by the European Commission and the UK government as a country/region that ensures an adequate level of protection for the rights and freedoms of individuals with respect to Personal Data. However, when Personal Data is disclosed to Brother Group Companies or external third parties as described in section 5, Personal Data may be transferred outside the EEA or the UK. If Personal Data is transferred outside the EEA or the UK to countries or regions not designated as adequate by the European Commission or the UK government, we will ensure that the third party has entered into standard data protection clauses approved by the European Commission or the UK government with us.

For example, your Personal Data may be stored in the cloud by the Business’s cloud service providers, and such providers may store Personal Data in locations outside the EEA not designated as adequate by the European Commission or the UK government.

For details of the safeguards implemented, please contact the inquiry address listed in section 8.

8. Data Controller and Contact Information

We are the data controller for Personal Data collected and processed in relation to the Business. If you have any questions or concerns regarding the use of Personal Data, your rights, or other matters concerning the protection of Personal Data, please contact us at the email address below. Depending on the nature of your request or inquiry, we may need to verify your identity.

data.protection@brother.co.jp

9. Changes to This Privacy Policy

The Company may amend or update this Privacy Policy from time to time. You will be notified in advance of any material changes to this Privacy Policy. Please review this Privacy Policy periodically to confirm whether there have been any changes to how your Personal Data is used.