Last Updated: November 2019

Key Tronic Corporation, its subsidiaries, and affiliated companies (“Keytronic,” “we” or “us”) value the importance of protecting your privacy and personal information. This Privacy Notice applies to information we collect when you use our websites, mobile applications, and other online products and services (collectively, the “Services”) or when you otherwise interact with us, including through phone communications, email communications, and at events.

We may change this Privacy Notice from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification).

For details regarding any choices we offer in connection with our information practices, please see the “Your Choices” section, below.

Collection of Information

Information You Provide to Us

We may collect data, including personal information, that you provide directly to us. For example, we collect information when you fill out a form, apply for a job, or otherwise communicate with us. The types of information we may collect include your name, position, email address, postal address, phone number, fax number, and any other information you choose to provide.

Information We Collect Automatically When You Use Our Services

When you access or use our Services, we automatically collect information about you, including:

• Log Information: We collect log information about your Internet use, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to our Services.
• Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
• Information Collected by Cookies and Other Tracking Technologies: We and our service providers use various technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, determine which areas and features of our Services are popular, and count visits. Web beacons are electronic images that may be used in our Services or emails to help deliver cookies, count visits, and understand usage and campaign effectiveness.

Use of Information

We may combine the information we collect about you and use this information for various purposes, including to:

• Deliver the services you request;
• Provide, maintain, and improve our services;
• Send you technical notices, updates, security alerts, and support and administrative messages;
• Respond to your comments, questions, and requests;
• Communicate with you about services, offers, and events offered by Keytronic and others, and provide news and information we think will be of interest to you;
• Monitor and analyze trends, usage, and activities in connection with our services;
• Detect, investigate, and prevent fraudulent transactions and other illegal activities and protect the rights and property of Keytronic and others;
• Personalize and improve the Services and provide advertisements, content, or features that match user profiles or interests; and,
• Carry out any other purpose described to you at the time the information was collected.

Sharing of Information

We may share information about you as follows or as otherwise described in this Privacy Notice:

• With vendors, consultants, and other service providers who need access to such information to carry out work on our behalf in support of the purposes described above;
• In response to a request for information, if we believe disclosure is in accordance with, or required by, any applicable law, regulation, or legal process, including in connection with lawful requests by law enforcement, national security, or other public authorities;
• If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property, and safety of Keytronic or others;
• In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company;
• With third parties in anonymized, aggregated, pseudonymized, or de-identified form which cannot reasonably be used to identify you;
• Between and among Keytronic and our current and future parents, affiliates, subsidiaries, and other companies worldwide under common control and ownership; and,
• With your consent or at your direction.

Advertising and Analytics Services Provided by Others

We may allow others to provide analytics services and serve advertisements on our behalf across the Internet and in applications. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by Keytronic to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices. Your device may also include a feature that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes.

Security

Keytronic takes reasonable physical, technical, and administrative measures and contractually requires our suppliers to help protect information about you from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. Since the Internet can never be completely secure, we cannot warrant or ensure the security of any personal information you provide.

Consent to Transfer

Keytronic is a global company and may transfer, process, and store your personal information with its affiliates, subsidiaries, or with its third parties and business partners in locations worldwide. Where applicable by law, by providing us with your personal information and by using our Services, you are consenting to the transfer, processing, and storage of such information outside the country of your residence.

EU-U.S. Privacy Shield Framework

For purposes of this section of the privacy notice regarding the EU-U.S. Privacy Shield Framework, “Keytronic” refers only to Key Tronic Corporation, the Keytronic entity that may receive in the U.S. and process personal data from the EU.

Keytronic adheres in its processing of personal data received in the U.S. from the EU (“EU Data”) to the EU-U.S. Privacy Shield Framework Principles designed by the U.S. Department of Commerce and the European Commission (the “Principles”). For more information about the Principles, please visit the Department of Commerce’s Privacy Shield Website.

Your Choices

Access Rights

If you are a resident of a country that provides you with the right to request a copy of the personal data Keytronic holds about you and/or to correct any inaccuracies within such data, and Keytronic is required by applicable laws to respond to such requests, then you may address such requests to the contact information provided in the “Contact Us” section below. Keytronic will use reasonable efforts to supply, correct, or delete information that we hold about you or to advise you if we are not required by applicable laws to comply with such requests.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Removing or rejecting browser cookies does not necessarily affect third-party flash cookies used in connection with our Services. To delete or disable flash cookies, please visit http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html for more information. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

California Privacy Rights

Residents of the State of California, under certain provisions of the California Civil Code, have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed certain personally identifiable information, as defined under California law, during the preceding year for third-party direct-marketing purposes. The law also provides that if the company has a privacy notice that gives either an opt-out or opt-in choice for use of your personal information by third parties (such as advertisers) for marketing purposes, the company may instead provide you with information on how to exercise your disclosure choice options. Since Keytronic is, via this privacy notice, providing you with details on how to either opt out or opt in to use of your personal information by third parties, Keytronic qualifies for the latter option and is therefore not required to disclose a list of the third parties that received your personal information for marketing purpose during the preceding year.

You may learn more about your rights under California’s privacy laws at

https://oag.ca.gov/privacy/privacy-laws.t