SIMCO Electronics Privacy Policy

Last updated: July 14, 2021

SIMCO Electronics, and its subsidiaries, affiliates, and (“SIMCO Electronics”, “we”, “us” or “our”) are committed to protecting your privacy and ensuring you have a positive experience when you use our services, software products, instrument repair, visit our webpages, interact with us on social media, or attend a SIMCO Electronics sponsored event (collectively, the “Services”).

This Policy explains SIMCO Electronics’ practices when we process personal data as a “controller”, “business”, or other similar concept under applicable data protection and/or privacy laws. “Personal data” is information that relates to an identified or identifiable individual. “Process” or “processing” means any use of personal data including, transferring, collecting, recording, storing, using, analyzing, combining, disclosing, or deleting it.

Updates to this Policy and Supplemental Notices

This Policy may be updated periodically in our sole discretion. If we make any material changes to this Policy, we will notify you by posting an updated version of this Policy on our website and/or we may also send you other communications. It’s important that you review the Policy whenever we update it or you use the Services. You understand and agree that you will be deemed to have accepted the updated Policy if you continue to use our Services after the new Privacy Policy takes effect.

We may supplement this Policy with “just-in-time” notices, or other disclosures contained within or in connection with the provision of the Services, which may describe in more detail our personal data collection, use and sharing practices. Unless we say otherwise, such supplemental privacy notices will also govern how we may process the personal data in the context of that specific product or service.

What this Policy Covers

As mentioned above, this Policy applies to the personal data we process as a controller (the party that determines what personal data to collect and why). The personal data we collect depends on the context of your interactions with SIMCO Electronics and the choices you make, including the products and features you use. You may provide some of this personal data directly to us. In addition, we may automatically collect personal data as a result of your interactions and experiences with the Services. We may also obtain personal data about you from third parties.

This Policy does not apply to any of the personal data that we process on behalf of Simco Electronics’ customers (“Customer Data”). Our customers’ respective privacy policies govern the collection and use of Customer Data. Our processing of Customer Data is governed by the contracts that we have in place with our customers, not this Policy. For example, when you use SIMCO Electronics’ Services through a SIMCO Electronics service management software account holder, such as your employer, the processing of Customer Data is determined and administered by that account holder under its privacy policies. If you have questions about how and why Customer Data is collected, the legal basis for processing, or requests regarding Customer Data, please refer to our customer’s privacy statement and direct your inquiries to the relevant customer.

Personal Data We Process & How We Use It

Some of the personal data we collect and our uses for personal data are set forth in the table below:

Types of Personal Data Use Case Legal Basis (as applicable for data subjects whose personal data is subject to data protection laws of the European Economic Area, Switzerland, and/or the United Kingdom)
Personal data related to website visitors including, but not limited to:
Browser Type
Cookie Information
Geolocation Information
IP Address
Network Interaction History
Website History
  • Analyze how our website is used so we can improve your experience.
  • As set forth below in “Additional Uses of Personal Data”
  • Performance of a contract or steps taken at the request of the data subject prior to entering into a contract
  • The processing is necessary for the purposes of our organization’s legitimate interests
  • Consent (as applicable)
Personal data related to customers and prospects including, but not limited to:
In-Session Information
Purchasing Tendencies
Contact Details
Personal Email
Work Phone Numbers
Work Email
Business Unit Division
Company Entity
Contract Type
Job Title Role
Line Reporting Manager
Office Location
Insurance Information
Full Name
Signature
Audio Information
Electronic Information
Visual Information
Email Activity
Outreach and Inbound Activity
Website Activity
Social Media Account
Social Media Contact
Social Media History
  • Providing tailored information about our Services
  • Marketing activities
  • Sending marketing communications
  • Training
  • As set forth below in “Additional Uses of Personal Data”
  • Performance of a contract or steps taken at the request of the data subject prior to entering into a contract
  • The processing is necessary for the purposes of our organization’s legitimate interests
  • Consent (as applicable)
Personal data related to paid account holders including, but not limited to:
User ID
Team
Line Reporting Manager
Work Email
Purchase Order
Account Password
Account Number
Account Age
Contract Type
Credit Card Number
Bank Account Number
Bank Account Information
  • Manage leads/opportunities
  • Manage customers and accounts
  • Develop and manage sales proposals, bids, and quotes
  • Manage sales orders
  • As set forth below in “Additional Uses of Personal Data”
  • Performance of a contract or steps taken at the request of the data subject prior to entering into a contract
  • The processing is necessary for the purposes of our organization’s legitimate interests
  • The processing is necessary for compliance with a legal obligation
  • Consent (as applicable)
Personal data collected in connection with our marketing efforts including, but not limited to:
Data enrichment services (only in connection with Marketing Pages)
Email marketing lists (where permitted under applicable law)
Online Advertising Data
Name
Email address
Employer (if applicable)
Job Title (if applicable)
  • Marketing activities
  • Sending marketing communications
  • Providing tailored information about our Services
  • As set forth below in “Additional Uses of Personal Data”
  • Performance of a contract or steps taken at the request of the data subject prior to entering into a contract
  • The processing is necessary for the purposes of our organization’s legitimate interests
  • Consent (as applicable)
Personal data processed when you communicate with us
  • As set forth below in “Additional Uses of Personal Data”
  • Performance of a contract or steps taken at the request of the data subject prior to entering into a contract
  • The processing is necessary for the purposes of our organization’s legitimate interests
  • Consent (as applicable)
Personal data processed in connection with surveys we administer
  • As set forth below in “Additional Uses of Personal Data”
  • The processing is necessary for the purposes of our organization’s legitimate interests
Personal data processed in connection with our interactive features including, but not limited to personal data that is processed via:
Messaging and chat features
Commenting functionalities
Forums
Blogs
Social media pages
  • The processing is necessary for the purposes of our organization’s legitimate interests
  • Performance of a contract or steps taken at the request of the data subject prior to entering into a contract
  • The processing is necessary for the purposes of our organization’s legitimate interests
Personal data processed in connection with SIMCO Electronics’ sponsored or co-sponsored events, conferences, trade shows, and other events including, but not limited to:
Event title & details
Name
Email address
Employer (if applicable)
Job Title (if applicable)
  • Communicate with you about the event
  • Run promotional activities
  • Provide you with information and offers from us or event co-sponsors
  • As set forth below in “Additional Uses of Personal Data”
  • Performance of a contract or steps taken at the request of the data subject prior to entering into a contract
  • The processing is necessary for the purposes of our organization’s legitimate interests
  • Consent (as applicable)
Personal data processed when you apply for or inquire about a job with SIMCO Electronics including, but not limited to:
Application
Resume/CV
Cover letter
Other related information
  • To assess your qualifications and otherwise process your application
  • As set forth below in “Additional Uses of Personal Data”
  • Performance of a contract or steps taken at the request of the data subject prior to entering into a contract
  • It is necessary for the purposes of our organization’s legitimate interests

Customer Content

Customer content is the “in-session” information you give us directly through your use of the Services, such as files, emails, logs, history, and any other information uploaded while using the Services.

We do not control the actions of anyone with whom you or any other Service user may choose to share information. Therefore, we cannot and do not guarantee that any customer content you or any user provides to the Services will not be viewed by unauthorized persons. Nor can SIMCO Electronics control the information a user may choose to share while using our Services. Although SIMCO Electronics account holders can set privacy options that limit access to certain areas of the Services, please be aware that no security measures are perfect or impenetrable and that we are not responsible for circumvention of any security measures contained on the Services. You should be cautious about the access you provide to others when using the Services, and the information you choose to share when using the Services.

Personal Data We Collect Automatically

We may collect personal data automatically when your use our Services:

Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location  information (including approximate location derived from IP address ), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.

Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services.

  • Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

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

  • Strictly Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality.
  • Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below).
  • Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

  • We may use Technologies and other third-party tools to process analytics data on our Services. Some of our analytics partners include:
  • Google Analytics. For more information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your personal data, please click here.
  • LinkedIn Analytics. For more information, please visit LinkedIn Analytics’ Privacy Policy. To learn more about how to opt-out of LinkedIn’s use of your personal data, please click here.

Personal Data Collected from Other Sources

We may obtain personal data about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as a third-party login service, we may collect information about you from that third-party application that you have made available via your privacy settings.

Additional Uses of Personal Data

Provide our Services. We use your personal data to fulfil our contract with you and provide you with our Services, such as:

  • Managing your information and accounts;
  • Providing access to certain areas, functionalities, and features of our Services;
  • Answering requests for customer or technical support;
  • Communicating with you about your account, activities on our Services, and policy changes; and
  • Processing your financial information and other payment methods for products or Services purchased.

Administrative Purposes. We use your personal data for various administrative purposes, such as:

  • Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
  • Measuring interest and engagement in our Services;
  • Improving, upgrading or enhancing our Services;
  • Developing new products and services;
  • Ensuring internal quality control and safety;
  • Authenticating and verifying individual identities, including requests to exercise your rights under this Policy;
  • Debugging to identify and repair errors with our Services;
  • Auditing relating to interactions, transactions and other compliance activities;
  • Enforcing our agreements and policies; and
  • Complying with our legal obligations.

Marketing our Products and Services. We may use personal data to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

If you have any questions about our marketing practices, you may contact us at any time as set forth in “How to Contact Us” below.

Consent. We may use personal data for other purposes that are clearly disclosed to you at the time you provide personal data or with your consent.

De-Identified and/or Aggregated Data. We may use personal data and other data about you to create de-identified and/or aggregated data, such as de-identified demographic data, de-identified location data, data about the device from which you access our Services, or other analyses we create.

How We Share Personal Data

We may share personal data in order to operate our business, including with companies, organizations, or individuals outside of SIMCO Electronics when one of the following circumstances applies:

With Vendors and Service Providers

We may share personal data with vendors and service providers that help us provide the Services and for SIMCO Electronics’ business purposes. Examples include public cloud vendors, carriers, billing, payment processor, and service providers for managing customer support tickets.

With Consent

We may share personal data with companies, organizations, individuals outside of SIMCO Electronics and others when we have consent from an individual (as applicable).

With Third Parties You Share or Interact With

Your personal data may be disclosed to third parties that you share or interact with using our Services.

With SIMCO Electronics’ Affiliates

We may share your personal data with our company affiliates.

With Advertising Partners

We may share your personal data with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”

With SIMCO Electronics Partners

We may also share your personal data with business partners to provide you with a product or service you have requested or with business partners with whom we jointly offer products or services.

In Connection with Corporate Transactions

We may share personal data with actual or prospective acquirers, their representatives, and other relevant participants in, or during negotiations of, any sale, merger, acquisition, restructuring, or change in control involving all or a portion of SIMCO Electronics’ business or assets, including in connection with bankruptcy or similar proceedings.

To Protect SIMCO Electronics or Others

We may access, preserve, and disclose any data we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

Your Privacy Choices and Rights

Your Privacy Choices

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. 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 us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our agreements or this Policy).

We process requests to be placed on do-not-mail, do-not-phone, and do-not-contact lists as required by applicable law.

Text Messages. You may opt out of receiving text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us.

“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. 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 and by clicking on Cookie Settings on the global site footer. 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 Data about you, including: (i) confirming whether we are processing your personal data; (ii) obtaining access to or a copy of your personal data; and (iii) receiving an electronic copy of personal data that you have provided to us, or asking us to send that data to another company in a structured, commonly used, and machine readable format (the “right of data portability”);
  • Request Correction of your personal data where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal data;
  • Request Deletion of your personal data;
  • Request Restriction of or Object to our processing of your personal data; and
  • Withdraw your Consent to our processing of your personal data.

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

International Transfers

SIMCO Electronics operates globally, which means personal data may be stored and processed (for example stored in a data center) in any country where we or our service providers have facilities or hold events. You acknowledge that your personal data may be transferred to or stored in the United States or in other countries around the world. Such countries may have data protection rules that are different and less protective than those of your country. We endeavor to safeguard your information consistent with the requirements of applicable laws.

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth below.

Verification. 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 confirming the email address associated with any personal information we have about you.

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

Supplemental Notice for California Residents

This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information SIMCO Electronics has collected about them and whether SIMCO Electronics disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below :

The categories of sources from which we collect personal information and our business and commercial purposes for using and disclosing personal information are set forth above under the section titled “Personal Data We Process & How We Use It”

Additional Privacy Rights for California Residents

“Sales” of Personal Information under the CCPA. For purposes of the CCPA, SIMCO Electronics does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age. We do, however, use advertising services that tailor content to your interests based on information collected via cookies and similar technologies about your online activity. This is called targeted advertising. You can get more information and opt-out of the use of cookies on our sites for targeted advertising purposes by clicking on Cookie Settings on the global site footer and setting your preferences. You will need to set your preferences from each device and each web browser from which you wish to opt-out. This feature uses a cookie to remember your preference, so if you clear all cookies from your browser, you will need to re-set your settings. If you want to ask a question about how to opt out, please see the “How to Contact Us” section below.

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth below.

Verification. 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 confirming the email address associated with any personal information we have about you.

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

Supplemental Notice for Nevada Residents

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth below.

Retention

We will retain personal data for as long 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. The criteria used to determine our retention periods may include:

  • The length of time we have an ongoing relationship with you and provide our Services to you (for example, for as long as you have an account with us or keep using our Services).
  • Whether we have a legal obligation to keep the data (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them); and/or
  • Whether retention is advisable considering our legal position (such as regarding applicable statutes of limitations, litigation, or regulatory investigations).

Security

SIMCO Electronics takes steps in an effort to ensure that your personal data is treated securely and in accordance with this Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any personal data we process under this Policy. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our Services 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 our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.

Children’s Information

The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal data from children.

If you are a parent or guardian and believe your child has uploaded personal data to our Services without your consent, you may contact us as described in “How to Contact Us” below. If we become aware that a child has provided us with personal data in violation of applicable law, we will delete any personal data we have collected, unless we have a legal obligation to keep it, and terminate the child’s account, if applicable.

Third-Party Websites/Applications

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each 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. Providing personal data to third-party websites or applications is at your own risk.

Supervisory Authority

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

How to Contact Us

If you have any privacy-related questions or comments related to this Policy, or to exercise your rights as detailed in this Policy, please send an email to privacy@simco.com.

You can also contact us by writing to this address:

SIMCO Electronics
Attention: Data Privacy Officer
3131 Jay Street
Suite 100
Santa Clara, CA 95054

Data Protection Officer

BaoTin Nguyen is our Data Protection Officer and he can also be contacted at privacy@simco.com or by calling 1-866-973-1323