PRIVACY POLICY
SANMINA CORPORATION PRIVACY POLICY
SANMINA CORPORATION PRIVACY POLICY
Effective Date: January 1, 2020
This Privacy Policy (the “Policy”) sets forth the privacy principles that Sanmina Corporation and its subsidiaries (collectively, “Sanmina”) follow with respect to the processing of Personal Information (as defined below) of its potential, current and former customers, suppliers, vendors, business partners, record stockholders, website visitors, visitors to our facilities, marketing booths and events, job applicants and independent contractors. Sanmina collects, stores, processes and discloses Personal Information as permitted by applicable laws, including the General Data Protection Regulation of the European Union. This Policy describes how we collect, use, disclose and otherwise process Personal Information about you when, among other things, you visit our facilities, marketing booths and events, visit our websites or social media pages (collectively “Sites”), submit Personal Information directly to us on the Sites, inquire about our products or services, or apply for employment or provide independent contractor, temporary staffing or other services to us. We collectively refer to these activities, together with the operation of our Sites, as “Services”. In this Privacy Policy, “us”, “we” and “our” refers to Sanmina and “you” refers to persons covered by this Policy.
I. PERSONAL INFORMATION SANMINA MAY COLLECT AND HOW IT IS USED
“Personal Information” means any information relating to or that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with an identified or identifiable individual. Sanmina collects, stores and processes the following Personal Information concerning its potential, current and former customers, suppliers, vendors, business partners, record stockholders, visitors to our Sites, facilities, marketing booths and events, job applicants and independent contractors using the Services for the purposes described below, to the extent permitted by applicable law. Type of Personal Information Collected, Processed and/or Disclosed Purpose of Such Collection, Processing and/or Disclosure Potential, current and former customers, suppliers, vendors, business partners, record stockholders, visitors to our Sites, facilities, marketing booths and events Contact details (e.g., name, street address, email address, phone number, employer, job title) To provide you with the Services, including by allowing you to create and manage your account, providing you with Type of Personal Information Collected, Processed and/or Disclosed Purpose of Such Collection, Processing and/or Disclosure information about our products and Services; to communicate with you and respond to your inquiries, comments and requests; to solicit business or present potential business opportunities; marketing calls; sending you marketing communications; and advertise to you on other websites; to understand and analyze the usage trends and preferences of users of our Services; to improve the Sites; to comply with law and legal process; to maintain our contractual relationships with our customers, vendors and business partners Government issued identification, country of citizenship, photos, video images For facility security measures, including issuance of visitor passes and access to our facilities; legal and regulatory compliance; promotional purposes, with consent Voicemails To communicate with you and respond to your inquiries, comments and requests Recordings of calls and/or meetings To conduct business with our customers, suppliers and business partners, with consent IP address, browser type, device ID, OS (operating system) type, information on actions taken on our Sites, dates and times of actions To analyze the effectiveness of our communications, including marketing campaigns; to tailor our Services, content and communications to you; to create and publish content relevant to you; to understand and analyze the usage trends and preferences of users of our Services; to improve the Sites and the Services, such as by assessing how many users access or use our Services, which content, products and features of our Services most interest our visitors, what types of offers our customers like to see and how our Services perform; to improve our products and services; network and/or Type of Personal Information Collected, Processed and/or Disclosed Purpose of Such Collection, Processing and/or Disclosure data security; to enforce legal rights and comply with law and legal process; to advertise to you Personal Information directly related to accessing or using the Services (e.g., confirming whether an email recipient opened an email or whether a Sites’ visitor clicked on a link), where permitted by law To analyze the effectiveness of our communications, including marketing campaigns Personal information generated by us as you use our Services or interact with us, such as name, title, company, address, phone, email address, role (if provided by you) device information, usage and performance information, location information, and inferences about your preferences and interests Purpose of processing inferences/generated/derived data, e.g., to provide and personalize the Services and tailor offers presented to you Health conditions of visitors to our facilities (e.g., conducting and/or self,reporting of body temperature checks and/or illness symptoms) To protect health and safety at our workplace, where and as permitted or required by applicable law and/or recommended by national, state or local authorities or agencies; where necessary for substantial public interest in the area of public health (e.g., epidemic and pandemic containment and/or mitigation) Job Applicants Name and contact information (e.g., name, street address, town/city, state/province, country, email address and phone numbers) Process applications for employment; contacting past applicants about employment positions they may be interested in Identification information (e.g., social security number, taxpayer identification number, national identification number and passport and driver’s license information, including birth date and place); legal residency information, work Verification of right to work in a given jurisdiction Type of Personal Information Collected, Processed and/or Disclosed Purpose of Such Collection, Processing and/or Disclosure permit and visa information Gender Government reporting and where no other identifying details are provided Nationality and ethnic origin Government reporting and compliance Veteran or military status Determining compliance with government programs and preferences relating to veteran or military status Personal information contained in cover letters, resumes and employment applications, including employment related and salary information Making employment decisions Current employment status Verification of information contained in employment application Current or past salary, where permitted by applicable law Formulating employment offers Consumer, credit, criminal and other personal background information (when permitted by law and with applicant consent when required) Assessing suitability for employment in certain positions Disability information Assessment of ability to offer reasonable accommodation Results of drug testing when requested and obtained in accordance with applicable law Assessing suitability for certain positions in the Company (e.g., truck drivers and heavy equipment operators) Health conditions of job applicants who visit our facilities (e.g., conducting and/or self-reporting of body temperature checks and/or illness symptoms) To protect health and safety at our workplace, where and as permitted or required by applicable law and/or recommended by national, state or local authorities or agencies; where necessary for substantial public interest in the area of public health (e.g., epidemic and pandemic containment and/or mitigation) Temporary Workers (employed by Type of Personal Information Collected, Processed and/or Disclosed Purpose of Such Collection, Processing and/or Disclosure staffing agencies or other third parties) Name and image, job title/job code, plant, department, location, supervisor, temporary employee identification number/badge number; home address, birth date, phone number, emergency contact details, medical practitioner contact details (i.e. name, address, phone number), next of kin and preemployment health questionnaire Facility access (i.e. badges) Contact information (e.g., name, street address, town/city, state/province, country, email address and phone numbers); identification information (e.g., social security number, taxpayer identification number, national identification number and passport and driver’s license information, including birth date); legal residency information, work permit, visa information; date of hire; gender; temporary employee identification number; job information (e.g., job code, job title, job grade, location, supervisor) Authentication and access to Sanmina IT systems and applications, such as email Health conditions of temporary workers assigned to work at our facilities (e.g., conducting and/or self-reporting of body temperature checks and/or illness symptoms) To protect health and safety at our workplace, where and as permitted or required by applicable law and/or recommended by national, state or local authorities or agencies; where necessary for substantial public interest in the area of public health (e.g., epidemics and pandemic containment and/or mitigation) Independent Contractors Name and image; contact information (e.g., name, street address, town/city, state/province, country, email address and phone numbers); identification information (e.g., social security number, taxpayer identification number, national Facilities access; payment of fees for services; preparation and delivery of income tax documents; authentication and access to Sanmina IT systems and applications, such as email Type of Personal Information Collected, Processed and/or Disclosed Purpose of Such Collection, Processing and/or Disclosure identification number and passport and driver’s license information, including birth date); legal residency information Bank account details (e.g., account number); Financial/credit information/insurance information Payment of fees for services; confirming compliance with Sanmina policies for independent contractors Work permit, visa information; date of hire; gender; job information (e.g., job code, job title, job grade, location, supervisor) Authentication and access to Sanmina IT systems and applications, such as email Health conditions of independent contractors who visit our facilities (e.g., conducting and/or self-reporting of body temperature checks and/or illness symptoms) To protect health and safety at our workplace, where and as permitted or required by applicable law and/or recommended by national, state or local authorities or agencies; where necessary for substantial public interest in the area of public health (e.g., epidemics and pandemic containment and/or mitigation) Note: Sanmina does not necessarily collect all of the above-listed information from any particular individual using the Services or covered by this Policy. In case we use Personal Information for reasons other than those listed above, we will provide you notice of such uses or obtain your consent, in each case if required by applicable law.
II. SOURCES OF PERSONAL INFORMATION THAT SANMINA MAY COLLECT
The above-listed Personal Information may be provided directly by you to us in person, by email or in online submission fields that you complete on our Sites (including our Sites’ Partner Connect portal) or on the websites of third parties we direct you to or in employment applications and documents you complete and return to us. In addition, we may receive Personal Information about you from third party marketing partners and databases or service providers, and we may combine this information with other Personal Information we maintain about you, if permitted by applicable law and, if required by applicable law, with your consent. Finally, we may also receive Personal Information about you from other sources such as employers, business partners, third party referrals, social media, public databases, consumer reporting agencies, direct marketers, public internet sites and other commercially and publicly available sources. One way we collect Personal Information on the Sites is through use of cookies and similar technologies. You may set your browsers to provide notice before they receive a cookie, giving you the opportunity to decide whether to accept the cookie. You can also set your browsers to turn off cookies. If you do so, however, some areas of the Sites may not function properly. We may also use analytics providers such as Google Analytics, which use cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. These services may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
III. HOW SANMINA MAY USE PERSONAL INFORMATION
Sanmina may use your Personal Information for the following purposes:
- To provide you with the Services, including by creating and managing your account, providing you with information at your request, and creating and publishing content relevant to you.
- To communicate with you and respond to your inquiries.
- To tailor our Services, content and communications to you in order to provide you with a better experience.
- To place marketing calls, send you marketing communications, and advertise to you on other websites, such as LinkedIn. For example, we may send you an email to alert you about product upgrades, special offers, updated information and other new products and services. Our marketing may be tailored to you, based on information such as your interests and preferences (which we may deduct from your interactions with our Sites and email campaigns).
- To operate, evaluate and improve our business and develop new products and services.
- To understand and analyze the usage trends and preferences of users of our Services, to improve the Sites, and to develop new products, services, features, and functionality (including anonymization of Personal Information).
- To enforce legal rights and comply with the law.
- To comply with an order from a government entity or other competent authority (including, but not limited to, public health agencies).
- To prevent or address potential or actual injury or interference with our rights, property, operations, users or others who may be harmed or may suffer loss or damage.
- To protect our rights, prevent fraud and/or comply with judicial proceeding, court order, or legal process.
- For health and safety purposes.
- To manage our customer, vendor and partner relationships.
- For other purposes for which we provide specific notice at the time of the collection of the information.
IV. SANMINA’S GROUNDS TO PROCESS PERSONAL INFORMATION
Sanmina processes Personal Information on the following grounds:
- You have consented to the processing of your Personal Information. For example, we may seek to obtain your consent for our use of cookies and similar technologies or to send you marketing communications.
- We need your Personal Information to provide you with the services and products requested by you, or to respond to your inquiries.
- The processing is necessary for compliance with a legal obligation.
- The processing is necessary for the performance of a contract with you.
- We, or a third party, have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information for the purposes set forth in the table above.
V. HOW SANMINA MAY DISCLOSE PERSONAL INFORMATION
Sanmina may disclose the Personal Information we process about you to its own employees who have an appropriate business need to access such information, to third parties retained by Sanmina to assist us in providing our Services or, when required or appropriate to our auditors, attorneys and other, professional advisors, insurance companies and brokers and financial institutions, in all cases only as needed to fulfill the purposes described in this Policy or otherwise disclosed to you at the time of collection. The items disclosed in the table above under “Type of Personal Information Collected, Processed and/or Disclosed” are the only Personal Information shared with authorized employees and such third parties. When required by applicable law and as appropriate, we enter into data processing agreements or similar agreements with the third parties to maintain the privacy and security of the Personal Information that is processed. If Sanmina is involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of Sanmina assets or transition of service to another provider, Personal Information may be disclosed or transferred as part of such a transaction, as permitted by law or contract. Sanmina may also disclose Personal Information in order to comply with the law or legal process and to enforce legal rights. Additional privacy information for California residents can be found in Appendix 1 to this Policy.
VI. HOW SANMINA PROTECTS PERSONAL INFORMATION
Sanmina maintains administrative, technical and physical safeguards that Sanmina believes are appropriate to protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in Sanmina’s possession. Sanmina completes periodic reviews of its databases, and has established specific time limits for data deletion, taking into account the type of data and its uses, mandatory retention periods and the statute of limitations.
VII. RIGHTS AND CHOICES
a. Potential, current and former customers, suppliers, vendors, business partners, visitors to our Sites, facilities, marketing booths and events You may choose not to use the Services, in which case no Personal Information about you will be collected or processed. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the Sites. If you receive an email from us, you may opt out from receiving electronic marketing communications by clicking on the unsubscribe link provided within the electronic communication or by request in the event of an email message directly from an individual sales representative.
b. Job Applicants and Independent Contractors Job applicants may choose not to provide Personal Information to Sanmina. However, to the extent it is not supplied, Sanmina would not be able to assess the suitability of such persons for employment and therefore to employ such persons. Similarly, we would not be able to enter into agreements with independent contractors who do not provide us with the Personal Information needed in order to retain them and pay them for their services.
c. Temporary Workers (employed by staffing agencies or other third parties) Sanmina collects only limited personal information from temporary workers who are employed by staffing agencies or other third parties and who are assigned by such third parties to work at our facilities. Should such persons not provide such information to Sanmina, we would not be able to permit them to work at our facilities or to access our IT systems.
d. Consent Where required by law, we obtain your consent for the processing of sensitive Personal Information. If we rely on consent for the processing of your Personal Information, you have the right to withdraw it at any time and free of charge. When ou do so, this will not affect the lawfulness of the processing before your consent withdrawal.
e. Privacy Rights In certain jurisdictions, you may have the right to
(1) request access and receive information about the Personal Information Sanmina maintains about you,
(2) update and correct inaccuracies in your Personal Information,
(3) restrict or object to the processing of your Personal Information,
(4) have the information blocked, anonymized or deleted, as appropriate,
(5) transfer or receive a copy of your Personal Information,
(6) opt-out of certain sharing with third parties, and
(7) lodge a complaint with the relevant data protection authority in the country in which you are located, if applicable. Those rights may be limited in some circumstances by local law requirements. For example, we may need to retain or share certain personal information for business purposes, to complete transactions you have requested, to comply with our legal obligations, and for other purposes as required or permitted by law. You may exercise the rights specified in this section by contacting us as specified below.
VIII. DATA TRANSFERS
Personal Information that Sanmina collects may be stored, processed or transferred to any of Sanmina’s or third-party vendors’ locations or computer systems, wherever located. Personal Information may be transferred to countries that do not have the same data protection laws as the country in which the data was originally collected. Regardless of where Sanmina stores, processes or transfers Personal Information, it will protect that information as described in this Policy. If you are located in the European Economic Area, we comply with applicable legal requirements to provide adequate safeguards for the transfer of Personal Information to countries other than the country where you are located. We may transfer Personal Information to countries for which adequacy decisions have been issued, use contractual protections for the transfer of Personal Information, such as the European Commission’s Standard Contractual Clauses, or rely on third parties’ certification to the EU-U.S. or Swiss-U.S. Privacy Shield Frameworks, where applicable. You can obtain a copy by contacting us as provided in the “Contact Us” section below.
IX. LINKS TO OTHER SITES
This Privacy Policy covers the privacy practices of Sanmina and it does not cover the privacy practices of third parties on their websites and other features. Any information you provide on third-party sites or services is provided directly to the operators of such sites or services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Services. To the extent any features or linked websites you visit are not owned or operated by Sanmina, we are not responsible for the privacy policies or practices of those third-parties.
X. CHANGES TO THIS POLICY
From time to time, Sanmina may amend this Policy. When we do, we will post an updated version of the Policy with the revised effective date. If we make material changes to this Policy, we will notify you here.
XI. CONTACT US
If you have any questions, comments, or concerns about this Policy, or if you would like to exercise your rights in relation to your Personal Information, please contact us using the following contact information: Sanmina Corporation Email: privacy@sanmina.com C/O Human Resources Department 2700 North First Street, Building 1 San Jose, CA 95134 United States California residents who wish to exercise their California privacy rights may also contact us by calling 833-527-0013 (toll free within the United States). For security purposes, we may request additional information from you to verify your identity when you request to exercise your privacy rights.
APPENDIX 1
Effective Date: January 1, 2020 Additional California Privacy Information (California residents only)* Categories of Personal Information Disclosed by Sanmina to Third Parties For a Business Purpose in Accordance with Sanmina’s Privacy Policy In the Preceding 12 Months Categories of Personal Information we disclose for a business purpose Categories of third parties to whom we disclose Personal Information to for a business purpose Identifiers (such as name, street address, email address, IP address, telephone number, government issued identification, or other similar identifiers) Service providers** Electronic, or visual information (such as photos or video images) Service providers** Internet or other electronic network or device activity information (such as browser type, device ID, operating system type, usage and performance information, information regarding a consumer’s actions taken on our Sites) Service providers** Professional or employmentrelated information (such as employer, job title) Service providers** * Sanmina does not sell Personal Information of California consumers, and has not sold any such Personal Information in the twelve months prior to the Effective Date of this Appendix. ** For purposes of this disclosure, service providers are third parties retained by Sanmina to assist us in providing Services and, when required or appropriate, our auditors, attorneys and other professional advisors, insurance companies and brokers and financial institutions, in all cases only as needed to fulfill the purposes described in the Privacy Policy or otherwise disclosed to you at the time of collection. Sanmina will not discriminate against any California consumer for exercising their rights under the California Consumer Privacy Act.