I. Safe Harbor
The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (the "Safe Harbor Principles") to enable US companies to satisfy the requirement under European Union law that adequate protection be given to Personal information transferred from the EU to the United States. The EEA also has recognized the US Safe Harbor as providing adequate data protection (OJ L 45, 15.2.2001, p.47). Consistent with its commitment to protect Personal privacy, Sanmina-SCI Corporation adheres to the Safe Harbor Principles.
Sanmina-SCI Corporation has designated Michael Delgado, Director of Corporate Compliance, the Person responsible for Sanmina-SCI’s compliance with and enforcement of this Policy. Sanmina-SCI Corporation also has designated Manesh Patel, VP Enterprise Services, in ensuring compliance with this Policy and data security issues. With the cooperation and assistance of appropriate staff and operating people, he will administrate the company’s data protection program, including supporting policies, direct the monitoring and reporting system and provide regular reports, as appropriate to management. Sanmina-SCI Corporation educates its employees concerning compliance with this Policy and has self-assessment procedures in place to assure compliance. The Corporate Legal Team is available to any of its valued employees, customers, vendors, business partners or others who may have questions concerning this Policy or data security practices. Relevant contact information is provided herein.
Personal information collected by Sanmina-SCI Corporation from prospective customers, consumers, vendors, business partners and others may be maintained at its corporate offices in San Jose, California or at other Sanmina-SCI Corporation facilities. Sanmina-SCI Corporation collects Personal information for, among other things, legitimate business reasons such as customer service, product, warranty and claims administration, meeting governmental reporting and records requirements, maintenance of accurate accounts payable and receivable records, internal marketing research, safety and performance management; financial and sales data, and contact information. All Personal information collected by Sanmina-SCI Corporation will be used for legitimate business purposes consistent with this Policy.
For purposes of this Policy, the following definitions shall apply:
IV. Privacy Principles
The privacy principles in this Policy are based on the seven Safe Harbor Principles.
1. NOTICE: Where Sanmina-SCI Corporation collects Personal information directly from individuals, it will inform them about the purposes for which it collects and uses Personal information about them, the types of non-agent third parties to which Sanmina-SCI Corporation discloses that information, and the choices and means, if any, Sanmina-SCI Corporation offers individuals for limiting the use and disclosure of their Personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal information to Sanmina-SCI Corporation, or as soon as practicable thereafter, and in any event before Sanmina-SCI Corporation uses the information for a purpose other than that for which it was originally collected. Sanmina-SCI Corporation may disclose Personal information if required to do so by law or to protect and defend the rights or property of Sanmina-SCI Corporation.
2. CHOICE: Sanmina-SCI Corporation will offer individuals the opportunity to choose (opt-out) whether their Personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For sensitive Personal information, Sanmina-SCI Corporation will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Sanmina-SCI Corporation will provide individuals with reasonable mechanisms to exercise their choices should requisite circumstances arise.
3. DATA INTEGRITY: Sanmina-SCI Corporation will use Personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Sanmina-SCI Corporation will take reasonable steps to ensure that Personal information is relevant accurate, complete and current, to its intended use.
4. TRANSFERS TO AGENTS: Sanmina-SCI Corporation will obtain assurances from its Agents that they will safeguard Personal information consistently with this Policy. Examples of appropriate assurances that may be provided by Agents include: a contract obligating the Agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), Safe Harbor certification by the Agent, or being subject to another European Commission adequacy finding (e.g., companies located in Hungary and Switzerland). Where Sanmina-SCI Corporation has knowledge that an Agent is using or disclosing Personal information in a manner contrary to this Policy, Sanmina-SCI Corporation will take reasonable steps to prevent or stop the use or disclosure. Sanmina-SCI Corporation holds it Agents accountable for maintaining the trust our employees and customers place in the company.
5. ACCESS AND CORRECTION: Upon request, Sanmina-SCI Corporation will grant individuals reasonable access to Personal information that it holds about them. In addition, Sanmina-SCI Corporation will take reasonable steps to permit individuals to correct, amend or delete information that is demonstrated to be inaccurate or incomplete. Any employees that desire to review or update their Personal information can do so by contacting their local Human Resources Representative.
6. SECURITY: Sanmina-SCI Corporation will take reasonable precautions to protect Personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. Sanmina-SCI Corporation protects data in many ways. Physical security is designed to prevent unauthorized access to database equipment and hard copies of sensitive Personal information. Electronic security measures continuously monitor access to our servers and provide protection from hacking or other unauthorized access from remote locations. This protection includes the use of firewalls, restricted access and encryption technology. Sanmina-SCI Corporation limits access to Personal information and data to those persons in Sanmina-SCI's organization, or as Agents of Sanmina-SCI, that have a specific business purpose for maintaining and processing such Personal information and data. Individuals who have been granted access to Personal information will be made aware of their responsibilities to protect the security, confidentiality and integrity of that information and have been provided training and instruction on how to do so.
7. ENFORCEMENT: Sanmina-SCI Corporation will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy and the US Department of Commerce Safe Harbor Principles. Any employee that Sanmina-SCI Corporation determines is in violation of this Policy will be subject to disciplinary action up to and including termination of employment.
V. Dispute Resolution
Any questions or concerns regarding the use or disclosure of Personal information should be directed to the Sanmina-SCI Corporation Privacy Office at the address given below. Sanmina-SCI Corporation will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between Sanmina-SCI Corporation and the complainant, Sanmina-SCI Corporation has agreed to participate in the dispute resolution procedures of the panel established by the European data protection authorities to resolve disputes pursuant to the Safe Harbor Principles.
VI. Internet Privacy
Sanmina-SCI Corporation sees the Internet, intranets and the use of other technologies as valuable tools for communicating and interacting with consumers, employees, vendors, business partners and others. Sanmina-SCI Corporation recognizes the importance of maintaining the privacy of Personal information collected through websites that it operates. Sanmina-SCI's sole purpose for operating its websites is to provide information concerning products and services to its customers and employees. In general, visitors can reach Sanmina-SCI Corporation on the Web without revealing any Personal information. Visitors on the Web may elect to voluntarily provide Personal information via Sanmina-SCI Corporation websites but are not required to do so. Sanmina-SCI Corporation collects information from visitors to the websites who voluntarily provide Personal information by filling out and submitting online questionnaires concerning feedback on the website, requesting information on products or services, or seeking employment. The Personal information voluntarily provided by website users is contact information limited to the user's name, home and/or business address, phone numbers and email address. Sanmina-SCI Corporation collects this information so it may answer questions and forward requested information. Sanmina-SCI Corporation does not sell or share this information with non-agent third parties. For purposes of improved security and authentication, Sanmina-SCI may enter into mutual agreements with customers or partners to utilize protocols and technology that may require the collection of additional information.
Sanmina-SCI Corporation may also collect anonymous information concerning website users through the use of "cookies" in order to provide better customer service. "Cookies" are files that websites place on users’ computers to identify the user and enhance the website experience. None of this information is reviewed at an individual level. Visitors may set their browsers to provide notice before they receive a cookie, giving the opportunity to decide whether to accept the cookie. Visitors can also set their browsers to turn off cookies. If visitors do so, however, some areas of Sanmina-SCI Corporation websites may not function properly.
Sanmina-SCI Corporation website users have the option to request that Sanmina-SCI Corporation not use information previously provided, correct information previously provided, or remove information previously provided to Sanmina-SCI. Those that would like to correct or suppress information they have provided to Sanmina-SCI Corporation should forward such inquiries to:
C/O Safe Harbor Compliance
2700 North First Street, Bldg 1
San Jose, CA 95134
FAX: (408) 964.3799
The inquiries should include the individual's name, address, and other relevant contact information (phone number, email address). Sanmina-SCI Corporation will use all reasonable efforts to honor such requests as quickly as possible. Sanmina-SCI Corporation websites may contain links to other " non-Sanmina-SCI" websites. Sanmina-SCI Corporation assumes no responsibility for the content or the privacy policies and practices on those websites. Sanmina-SCI Corporation encourages all users to read the privacy statements of those sites; their privacy practices may differ from those of Sanmina-SCI.
The practices described in this Policy are current Personal data protection policies as of September 1, 2010. Sanmina-SCI Corporation reserves the right to modify or amend this Policy at any time consistent with the requirements of the Safe Harbor Principles. Appropriate public notice will be given concerning such amendments.