PURPOSE

This Privacy Policy applies to CPI International, Inc. (doing business as CPI Electron Device Business) and our affiliates and subsidiaries (“CPI EDB,” “we,” “our,” and “us”) and explains our online and offline information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can opt-out of a use or correct or change such information. CPI EDB is the controller for the personal information we Process, unless otherwise stated. This Privacy Policy is incorporated by reference into the CPI EDB Terms of Service (the “Terms”). For information on how to contact us, please refer to the Contact Us section below.

WHAT DOES THIS PRIVACY POLICY COVER?

CPI EDB’s privacy policy applies to personal information that CPI EDB collects, organizes, stores, alters, retrieves or discloses (“Process” or “Processing”) in the course of our business, including on CPI EDB websites (each a “Site”), mobile applications (“Apps”), and other online or offline offerings (together with any and all future online and offline offerings operated by or on behalf of CPI EDB, the “Services”). Personal information is any information relating to an identified or identifiable natural person (“Personal Information”). This Privacy Policy is intended to meet requirements globally, including those in North America, Europe, Asia, and other jurisdictions.

This privacy policy does not apply to companies that CPI EDB does not own or control, or to people that CPI EDB does not employ or manage. CPI EDB’s website has links to sites of other companies. CPI EDB is not responsible for those companies’ privacy practices and encourages you to learn about the privacy policies of those companies.

WHAT INFORMATION DOES CPI EDB COLLECT AND HOW IS THE INFORMATION USED?

Types of personal information we collect

CPI EDB collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, guests, and employees (collectively “Individuals”).

Information You Provide Directly to Us.

When you use the Services or engage with CPI EDB, we may collect information from you as follows:

• Purchasing Our Products. When you or your employer purchases or offers to purchase CPI EDB products, we collect the Personal Information of the customer representative(s) in order to fulfill the transaction and customer service, which may include your name, business contact information, job title, and company. We may also collect payment information to process your purchases, such as your payment card information, billing address, and signature.
• Registering for an Account. You may create an account for certain Services, including Apps that CPI EDB provides. When you create an account, we collect your name, email address and company name, and we may also collect your phone number and country if you choose to provide it.
• Communications with Us. We may collect Personal Information from you, such as email address, phone number, or mailing address, when you choose to request information about our Services, register for a newsletter that we may offer from time to time, request to receive customer or technical support, or otherwise communicate with us.
• Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
• Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend conferences, trade shows, and other events.
• Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
• Job Applications. We may post job openings and opportunities on our Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use your information to assess your qualifications and use your data as described in our Applicant and Worker Privacy Notice.

Information Collected Automatically.

In general, you can visit CPI EDB’s Sites and use our Apps without registering for an account. However, we may collect certain information automatically from these interactions, including:

• Device Information. We may collect your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information (including approximate location derived from IP address), hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences. CPI EDB uses this information to track statistical information about use of the Sites and Apps and to improve the Services.
• Cookies, Pixel Tags/Web Beacons. We, as well as third parties that provide analytics services on our Sites and Apps, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through Sites and Apps. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “device”) that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools, and to recognize you across devices.
• Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page.

Our uses of such Technologies fall into the following general categories:

• Operationally Necessary. We may use Technologies that are necessary to the operation of our Sites, Services, and Apps. This includes technologies that allow you access to our Services; that are required to identify irregular behavior on our Sites and Apps, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as submitting or requesting information, saved search, or similar functions;
• Performance Related. We may use Technologies to assess the performance of our Sites and Apps, including as part of our analytic practices to help us understand how our visitors use our Sites and Apps, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our Services; and
• Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Sites and Apps. This may include identifying you when you sign into our Sites and Apps or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our sites.

If you would like to opt-out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits. Please see the Your Privacy Choices and Rights section below for more information on your choices regarding these Technologies.

• Analytics. We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services and to develop website content. This analytics data is not tied to any Personal Information. For more information about how Google uses your personal information (including for its own purposes, e.g., for profiling or linking it to other data), please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.
• Information Submitted Via the Services. You agree that CPI EDB is free to use the content of any communications submitted by you to us, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. CPI EDB will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.

How we use your information – Commercial

We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:

To Provide Products, Services, or Information Requested. CPI EDB may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:

• Generally manage Individual’s information and accounts;
• Respond to questions, comments, and other requests;
• Provide access to certain areas, functionalities, and features of CPI EDB’s Services;
• Contact you to answer requests for customer support or technical support;
• Process applications if you apply for a job we post on our Services;
• Allow you to register for events.

Administrative Purposes. CPI EDB may use Personal Information about you for its administrative purposes, including to:

• Measure interest in CPI EDB’s Services;
• Develop new products and Services;
• Ensure internal quality control;
• Verify Individual identity;
• Communicate about Individual accounts and activities on CPI EDB’s Services and systems, and, in CPI EDB’s discretion, changes to any CPI EDB policy;
• Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
• Process payment for products or services purchased;
• Process applications and transactions;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity;
• Debug to identify and repair errors with our Services;
• Conduct audits relating to interactions, transactions, and other compliance activities;
• Prevent potentially prohibited or illegal activities; or
• Enforce our Terms of Service.

Marketing CPI EDB Products and Services. CPI EDB may use Personal Information for our legitimate interests including to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. CPI EDB may provide you with these materials by phone, postal mail, facsimile, email, or through online platforms, including social media as permitted by applicable law. Such uses include:

• To tailor content, advertisements, and offers;
• To notify you about offers, products, services, and events that may be of interest to you;
• To provide Services to you;
• For other purposes disclosed at the time that Individuals provide Personal Information; or
• Otherwise with your consent.

You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described below.

Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from third parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on CPI EDB’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. If you would like to opt-out of these communications, please refer to the section titled Your Privacy Choices and Rights below.

De-identified and Aggregated Information Use. CPI EDB may use Personal Information and other information about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access CPI EDB’s Services, or other analyses we create. De-identified and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. De-identified or aggregated information is not Personal Information, and CPI EDB may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.

How we use your data – Human Resources

CPI EDB collects Personal Information from current, prospective, and former employees, including temporary, permanent, prospective or former employees, directors, contractors, workers, or retirees of CPI EDB or its subsidiaries worldwide (“Employees”). For more information about our Processing of Employee Personal Information, please see our Applicant and Worker Privacy Notice.

How we use your data – Other Uses

In addition to the commercial and human resources data uses described above, CPI EDB may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, employee monitoring for safety/management purposes or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

ONWARD TRANSFER—HOW CPI EDB MAY DISCLOSE YOUR INFORMATION

Information we share

We may share your information as described in this Privacy Policy (e.g., with our third-party service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission.

• Service Providers. We may share any information we receive with our third-party service providers. The types of service providers (processors) to whom we entrust Personal Information may include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Sites.
• Business Partners. We may share Personal Information with our business partners, to provide you with a product or service that you have requested. We may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear along with ours.
• Affiliates. We may share your personal information with our company affiliates for our administrative purposes, including activities such as IT management, for them to provide services to you or support and supplement the Services we provide.
• APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in the Contact Us section below.
• Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) to establish or exercise our legal rights or defend against claims; (iii) respond to your requests; (iv) protect yours’, ours’ or others’ rights, property, or safety; (v) to enforce CPI EDB policies or contracts; (vi) to collect amounts owed to CPI EDB; (vii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; (viii) when investigating or filing claims with an insurer; or (ix) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
• In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
• Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.

YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

Email and Telephone Communications

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding CPI EDB and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).

We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.

Mobile Devices

If you use a CPI EDB App and consent to receive push notifications through your App settings, CPI EDB may occasionally send you push notifications. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. CPI EDB may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.

Do Not Track

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Cookies and Interest-Based Advertising

You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance and the Digital Advertising Alliance of Canada.

Please note you must separately opt out in each browser and on each device.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

• Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information;
• Request Correction of your personal information where it is inaccurate, incomplete or outdated. In some cases, we may provide self-service tools that enable you to update your personal information;
• Request Deletion, Anonymization or Blocking of your personal information when processing is based on your consent or when processing is unnecessary, excessive or noncompliant;
• Request Restriction of or Object to our processing of your personal information where the processing of your personal information is based on our legitimate interest or for direct marketing purposes, including (i) the right to opt-out of the sharing of personal information for certain cross-contextual or targeted advertising, (ii) object to or restrict our use of or your sensitive personal information, including the right to opt-out of the sharing of sensitive personal information, in some circumstances, and (iii) opt out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
• Withdraw your Consent to our processing of your personal information. If you refrain from providing personal information or withdraw your consent to processing, some features of our Service may not be available;
• Request data portability and receive an electronic copy of personal information that you have provided to us;
• Request to be informed about third parties with which your personal information has been shared; and
• Request the review of decisions taken exclusively based on automated processing if that could affect data subject rights.

If you would like to exercise any of these rights, please contact us as set forth in the Contact Us section below. We will process such requests in accordance with applicable laws.

DATA RETENTION

CPI EDB retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

SECURITY OF YOUR INFORMATION

We take steps designed to ensure that your information is treated securely and in accordance with this Privacy Policy. CPI EDB limits access to personal information about you to its employees or consultants that it believes reasonably need to have that information to do their jobs. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot guarantee or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security breach impacting your data, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you.

INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

CHILDREN’S PRIVACY

The Services are not directed to individuals under the age of 18, and CPI EDB does not knowingly collect Personally Identifiable Information from individuals under the age of 18. If you learn that your child has provided us with Personal Information without your consent, you may alert us at Contact Us below. If we learn that we have collected any Personal Information from a child, we will promptly take steps to delete such information, except where we are required to retain it under applicable law, and terminate the child’s account, if applicable.

SUPPLEMENTAL NOTICE FOR RESIDENTS OF CERTAIN STATES INCLUDING CALIFORNIA

This Supplemental Notice is for residents of states that have adopted comprehensive privacy legislation and others that may come into effect from time to time, including, but not limited to, California, Connecticut, Colorado, Utah, Nevada, and Virginia (collectively, “Applicable State Laws”).

The following table describes the categories of personal information CPI EDB has collected and whether CPI EDB disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months:

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in the What Information Does CPI EDB Collect and How is the Information Used? sections above.

“Sales” of Personal Information

CPI EDB does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

Additional Privacy Rights for Residents of Certain States

Non-Discrimination. Residents of certain states have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by applicable law.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in the Contact Us section below.

Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.

Appeals. In certain states, you may appeal our decision in response to your request. You can appeal our response to your request by contacting us as described in the Contact Us section below and indicating you are appealing a prior response or by utilizing additional options for appeal that we may provide in our response.

If you are a qualifying resident and would like to exercise any of your rights under applicable state law, please contact us as set forth in the Contact Us section below. We will process such requests in accordance with applicable laws.

Accessibility. This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.

SUPPLEMENTAL NOTICE FOR PERSONAL INFORMATION FROM CHINA

This Supplemental Notice for China only applies to our processing of personal information that is subject to the applicable data protection laws of China, including the Personal Information Protection Law (“PIPL”).

• Your Privacy Rights. In addition to the applicable rights listed above in the section titled Your Privacy Choices and Rights, you have the following additional data subject rights: the right to request an explanation on how your Personal Data is handled, the right to file a lawsuit, and the right to allow your next of kin to exercise any of your rights unless other arrangements have been made before your death. For purposes of the PIPL, CPI EDB Privacy Officer is your data handler, and data subject requests may be directed to the contact information provided in section titled Contact Us below.
• International Transfers. When transferring Personal Data that originates in China internationally, we will comply with the applicable requirements governing the transfer and processing of such data. Providing CPI EDB information for employment or otherwise during the Services or through the website constitutes your consent for our international transfer of your data.
• List of Entrusted Persons. If permitted under applicable law, data subjects may request a copy of our service providers (entrusted persons).

THIRD-PARTY WEBSITES

The Sites may contain links to other websites and other websites may reference or link to our Site or other Services. These other websites are not controlled by us, and CPI EDB does not endorse or make any representations about third-party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

Our Apps are available for download from either the Apple iTunes App store or from Google Play Store. Please review the privacy information policies of those services and/or their related organizations for information on how they may treat the information that they require to allow you to download the CPI EDB app.

SUPERVISORY AUTHORITY

If you are located in the European Economic Area, Switzerland, the United Kingdom, Brazil, or Virginia you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

CHANGES TO OUR PRIVACY POLICY

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

CONTACT US

If you have any questions about our privacy practices or this Privacy Policy, please contact as set forth below:
CPI Electron Device Business
150 Sohier Road
Beverly, MA 01915-5536  USA
privacy.edb@cpi-edb.com

Revision history

Effective Date June 5, 2024