SugarCRM (CONTACTS) Privacy Notice

Introduction

AVX Corporation and all the members of AVX Group (“AVX” or “We”) respect your right to privacy. This privacy notice only applies to the collection and processing of personal information through SugarCRM, a contact relationship platform. AVX uses SugarCRM to maintain customer accounts and business relationships.

If you prefer your personal information not be processed, please inform us. In such a case, we will return or destroy the relevant information which you do not want to be processed, and we will inform you about the potential negative consequences of failure to provide such information.

Under the General Data Protection Regulation (“GDPR”) and other data privacy laws, you have certain rights in relation to your personal information, including how it will be used and stored. If you have any questions or concerns about the use of your personal data, please contact us using the contact details provided at the bottom of this Policy.

What Personal Data Do We Collect?

AVX’s implementation of SugarCRM allows AVX to maintain customer contact information and business relationships. When we use the term “customers,” we refer to current, past, and potential individuals or businesses interested in conducting business with AVX. For the purposes of this Policy, all individuals working for or on behalf of customers are referred to as “Contacts.”

Because AVX is committed to protecting your personal data; the SugarCRM administrative team has limited the information that can be collected and stored to the following:

• Name
• Mobile Phone Number
• Work Address
• Job Title
• Department or Division
• Work Phone Number
• Work Email Address

Information That You Provide Voluntarily

It is common for a Contact to voluntarily provide certain personal information via email or business card to members of AVX in the normal course of business relations. Contacts can be established during the ordinary course of business – such as emails, business cards, or general interest. When it is provided, AVX is the “collector” of such information. Such collection is not limited to Users of SugarCRM; personal data could be collected by any AVX employee or a third party, acting on behalf of AVX to develop customer relationships. For example, it is also possible for sales, engineering, and marketing teams to collect data during various trade shows₁. It is important to understand that only the information you provide will be stored in SugarCRM.

Purpose and Manner of Personal Data Processing

AVX may process your personal information connected with legitimate interests in carrying on, managing, and administering our respective businesses effectively and accurately. Personal information will not be processed on this basis if AVX’s interests are overridden by the individual’s own interests, fundamental rights, and freedoms.

Only AVX employees and sales representatives₂ have access to your information stored in SugarCRM. The application provider does not use your name, email address, or any information collected in any way other than to provide AVX with the software platform.

Once personal information is entered into SugarCRM, it is used to promote the business relationship with your company. AVX employees and representatives will initiate contacts in the course of that relationship to discuss sales opportunities, promote existing and new products, respond to inquiries, provide information, and other similar activities. The information will never be used for other purposes or provided to third parties other than as discussed above.

Consent to Process Your Data

Your personal data is processed only based on your approval – free and expressed consent to process your personal data for the purposed of maintaining business relationships. Your consent for the collection and processing of your personal data for the given purpose shall be confirmed when you provide information to representatives of AVX.

AVX requires two forms of consent when processing Contact information. First, when Contacts offer their personal information to employees of AVX in the inherent understanding of entering into business. In other instances, when consent is not obvious, such as trade shows and contracts with manufacturing representatives, the Policy is provided, and signed consent is required.

In order for your information to be processed through SugarCRM, you must explicitly agree.

It is in your and AVX’s interest that valid and willing consent is given. As such, a second confirmation of consent will be sent directly from the SugarCRM application when your information is added there (this is sometimes called “double consent”). In this email, you are required to confirm that you consent to the processing of your personal information through SugarCRM. If you do not confirm your consent, your personal data will not be processed. Instead, it will be deleted₃, and no further communication from AVX will occur. In the instance you do not respond to the email, AVX will assume no consent is given, and processing of data will cease. In these instances, no personal information will remain.

Your consent can be withdrawn at any time. Further, AVX reserves the right to delete some or all of your personal information if you change jobs or for any other reason.

How Do We Protect Your Personal Data?

AVX uses appropriate technical and organizational measures to protect your personal information, which we collect and process. These measures are designed to provide a level of security appropriate to the risk of processing personal information. In particular, AVX has implemented cybersecurity protocols to protect your personal information from the intrusion of unauthorized third parties and only allows access to your information by authorized employees bound by confidentiality provisions.

Additionally, SugarCRM guarantees appropriate technical and organizational measures have been taken through their services to safeguard personal information against loss, theft, and unauthorized use, access, and modifications.

Your Data Protection Rights

AVX wishes to be as open as we reasonably can about the personal information we process. If you would like to obtain specific information, please do not hesitate to contact our Data Protection Officer (“DPO”).

To ensure you are fully aware of all your data protection rights, each customer contact is entitled to the following:

• The right to access- You have the right to request copies of your personal data. You have the right to obtain information about why your personal data is being processed.
• The right to rectification- You have the right to request AVX to complete information you believe is inaccurate or incomplete.
• The right to erasure- You have the right to request that AVX erase your personal data.
• The right to restrict processing- You have the right to request that AVX restrict the processing of your personal data under certain conditions.
• The right to object to processing- You have the right to object to AVX’s processing of your personal data under certain conditions.
• The right to data portability- You have the right to request that AVX transfer the data we have collected to another organization, or directly to you, under certain conditions.

We respond to all requests we receive from individuals wishing to exercise their data protection rights within one week. If you would like to exercise any of these rights, please provide appropriate notice, addressed to the contact identified at the bottom of this notice.

International Transfers of Personal Data

Your personal data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country (and, in some cases, may not be as protective). All entities in the AVX Group have executed agreements, including the standard contractual clauses, and AVX has a contract in place with the entity hosting SugarCRM that also includes the standard contractual clauses.

Contacts can include any natural person wishing to do business with AVX, and thus can be in any location where AVX engages in business practices. This includes North and Central America, Europe, the Middle East, and Asia. Because our website servers may be located in the United States, this means that when we collect your personal data, we may process it in any of these countries.

Retention of Personal Data

Because AVX uses SugarCRM to maintain not only your contact information, your personal data will be retained as long as a legitimate business relationship exists, may exist, or is archived within the system or until you withdraw your consent. In general, if you withdraw consent, your personal data will be deleted within one month.

Update to This Policy

We may update this notice from time to time in response to changing legal, technical, or business developments. When we do, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material changes if appropriate or if required by law.

You can see when this Policy was last updated by checking the “last revised” date displayed at the end of this Policy.

How to Contact Us

If you have any questions about how your personal information is stored, handled, or processed in SugarCRM, you may contact the AVX SugarCRM support team at sugar.support@kyocera-avx.com.

If you have any questions related to this Policy and the protection of your data, you may contact the AVX Data Protection Officer at dpo.avx@kyocera-avx.com.

1. For trade shows, event attendees who show interest in AVX’s business model have the opportunity to read and sign a separate privacy notice to indicate they understand and consent to the use of their data. This notice can be obtained from the Corporate DPO or the DPO with responsibility for an employee’s facility.
2. AVX uses some independent representatives in the course of its sales effort. All such representatives are bound by contracts that include the standard contractual clauses as promulgated in the EU.
3. AVX will retain your name solely to track those persons who have not given consent so they will not be contacted again.