Privacy Policy

Purpose
What Does This Privacy Policy Cover?
What Information Does CPI Collect and How is the Information Used?
Types of Personal Information We Collect
How We Use Your Information – Commercial
How We Use Your Data – Human Resources
How We Use Your Data – Other Uses
Onward Transfer — How CPI May Disclose Your Information
Opt-out (Right to Restrict Processing)
Right of Access, Rectification, Erasure and Restriction
Data Retention
Security of Your Information
International Users
Children's Privacy
Redress/Compliance and Accountability
Other Rights and Important Information
Revision History

PURPOSE

This Privacy Policy is incorporated by reference into the CPI Terms of Service (the “Terms”). The terms “CPI,” “we,” and “us” include Communications & Power Industries LLC and our affiliates and subsidiaries. This Privacy Policy 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.

WHAT DOES THIS PRIVACY POLICY COVER?

CPI's privacy policy applies to personal information that CPI collects, organizes, stores, alters, retrieves or discloses (“Process” or “Processing”) in the course of our business, including on CPI 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, the “Services”). Personal information is any information relating to an identified or identifiable natural person, such as your name, address, email address, phone number and fax number (“Personal Information”). All individuals whose responsibilities include the Processing of Personal Information on behalf of CPI are expected to protect that data by adherence to this Privacy Policy. This Privacy Policy is intended to meet requirements globally, including those in North America, Europe, APAC, and other jurisdictions.

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

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

The types of Personal Information we may collect (directly from you or from third-party sources) and our privacy practices depend on the nature of the relationship you have with CPI and the requirements of applicable law. Some of the ways that CPI may collect Personal Information include:
  • When you provide Personal Information directly to CPI through interacting with the Services, transacting with us, participating in surveys, during events, and requesting products or information.

  • As you use the Sites and Apps, we may automatically collect information about your visit, including through cookies and similar technologies as described below.
We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.

Types of personal information we collect


CPI 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, we may collect information from you as follows:

       
  • Purchasing Our Products. When you or your employer purchases or offers to purchase CPI products, we collect the Personal Information of the customer representative(s) in order to fulfill the transaction and customer service.
  • Registering for an Account. You may create an account for certain Services, including Apps that CPI 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.
  • Automatic Data Collection. In general, you can visit CPI’s Sites and use our Apps without registering for an account. However, we may collect certain information automatically, such as 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, 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 uses this information to track statistical information about use of the Sites and Apps and to improve the Services.

  • Information Submitted Via the Services. You agree that CPI 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 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 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 information and accounts;
  • Respond to questions, comments, and other requests;
  • Provide access to certain areas, functionalities, and features of CPI’s Services;
  • Contact you to answer requests for customer support or technical support;
  • Allow you to register for events.
Administrative Purposes. CPI may use Personal Information about you for its administrative purposes, including to:
  • Measure interest in CPI’s Services;
  • Develop new products and Services;
  • Ensure internal quality control;
  • Verify Individual identity;
  • Communicate about Individual accounts and activities on CPI’s Services and systems, and, in CPI’s discretion, changes to any CPI 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;
  • Prevent potentially prohibited or illegal activities;
  • Enforce our Terms of Service.
Marketing CPI Products and Services. CPI may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. CPI may provide you with these materials by phone, postal mail, facsimile, or email, 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’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions the “Opt Out” section below.

Anonymous and Aggregated Information Use. CPI may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access CPI’s Services, or other analyses we create. Anonymized 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. Anonymized or aggregated information is not Personal Information, and CPI may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within CPI and with third parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

Cookies, pixel tags/web beacons and analytics information

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.

  • 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 Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.

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 shopping carts, 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;

  • 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.

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 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.

The News & Events portion of CPI's website is hosted by Dianum LLC (a direct and wholly owned subsidiary of Nasdaq Corporate Solutions LLC). CPI has been informed that it will not use or share the personal information collected on the News & Events portion of CPI's website except to make it available to CPI.

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 app.

How we use your data – Human Resources

CPI collects Personal Information from current, prospective, and former employees, including temporary, permanent, prospective or former employees, directors, contractors, workers, or retirees of CPI or its subsidiaries worldwide (“Employees”). CPI also collects their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin or immigration status; and optional demographic information such as race (“Sensitive Human Resources Data”), which helps us achieve our diversity goals.

We acquire, hold, use and Process Human Resources Data for a variety of business purposes including:
  • Interviewing, hiring, and recruiting;
  • Workflow management, including assigning, managing and administering projects;
  • Human Resources administration and communication;
  • Payroll and the provision of benefits;
  • Compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs;
  • Job grading activities;
  • Performance and employee development management;
  • Organizational development and succession planning;
  • Benefits and personnel administration;
  • Absence management;
  • Helpdesk and IT support services;
  • Regulatory compliance;
  • Internal and/or external or governmental compliance investigations;
  • Internal or external audits;
  • Litigation evaluation, prosecution, and defense;
  • Diversity and inclusion initiatives;
  • Restructuring and relocation;
  • Emergency contacts and services;
  • Employee safety;
  • Compliance with statutory requirements;
  • Processing of employee expenses and travel charges; and
  • Acquisitions, divestitures, and integrations.

How we use your data – Other Uses

In addition to the commercial and human resources data uses described above, CPI 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 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.
  • We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information 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. CPI has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.

  • Business Partners. CPI may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. CPI 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 CPI. CPI requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which CPI provided them.

  • 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 its 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 policies or contracts; (vi) to collect amounts owed to CPI; (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. In such event, CPI will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Privacy Policy in effect at the time such Personal Information was collected.

Data transfers

All Personal Information collected via or by CPI may be stored anywhere in the world, including but not limited to, in Canada, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to CPI, you consent to the storage of your Personal Information in these locations.

OPT-OUT (RIGHT TO RESTRICT PROCESSING)

In General

You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to CPI’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt-out to further Processing by contacting privacy@cpii.com. Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on third-party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.

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 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 App and consent to receive push notifications through your App settings, CPI 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 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.

Human Resources Data

With regard to Personal Information that CPI receives in connection with the employment relationship, CPI will use such Personal Information only for employment-related purposes as more fully described above. If CPI intends to use this Personal Information for any other purpose, CPI will notify the Individual and provide an opportunity to opt-out of such uses.

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.

RIGHT OF ACCESS, RECTIFICATION, ERASURE AND RESTRICTION

You may inquire as to whether CPI is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate. Where otherwise permitted by applicable law, you may send an e-mail to privacy@cpii.com or use any of the methods set out in this Privacy Policy to request access to, receive (port), seek rectification, or request erasure of Personal Information held about you by CPI. Please include your full name, email address associated with your account, and a detailed description of your data request. Such requests will be processed in line with local laws.

Although CPI makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which CPI is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If CPI determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, CPI will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

DATA RETENTION

CPI 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 to designed to ensure that your information is treated securely and in accordance with this Privacy Policy. CPI 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 ensure 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 system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.

INTERNATIONAL USERS

By using the Site, CPI will transfer data to the United States and other jurisdictions, potentially including, but not limited to California. By choosing to visit the Site, utilize the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of California and the adjudication of any disputes arising in connection with CPI or the Site will be in accordance with the Terms.

If you are using or accessing CPI Services from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.

CHILDREN’S PRIVACY

The Services are not directed to children under 13 (and in certain jurisdictions under the age of 16) years of age, and CPI does not knowingly collect Personally Identifiable Information from children under 13 (and in certain jurisdictions under the age of 16) years of age. If you learn that your child has provided us with Personal Information without your consent, you may alert us at privacy@cpii.com. If we learn that we have collected any Personal Information from children under 13 (and in certain jurisdictions under the age of 16), we will promptly take steps to delete such information and terminate the child’s account.

REDRESS/COMPLIANCE AND ACCOUNTABILITY

If you have any questions about our privacy practices or this Privacy Policy, please contact CPI by email at privacy@cpii.com. We will address your concerns and attempt to resolve any privacy issues in a timely manner.

OTHER RIGHTS AND IMPORTANT INFORMATION

Can changes be made to this privacy policy?

CPI reserves the right to modify or supplement this policy from time to time.
  • Revision to the Privacy Policy. We may revise this Privacy Policy in our sole discretion, so review it periodically. If you continue to visit this Site and use the services made available to you after such changes have been made, you hereby provide your consent to the changes. If you do not agree with the changes, then you must stop using the Services.

  • Posting of Revised Privacy Policy. If there are any material changes to this Privacy Policy, CPI will notify you as required by applicable law. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective immediately when it is posted (or upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.

  • New Uses of Personal Information. Before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, CPI will endeavor to comply with the law or contract.


Revision history

Title
CPI Privacy Policy

Effective Date
May 21, 2018