Effective May 25, 2018
I. Corporate Commitment to Privacy
II. GDPR Compliance
III. Data Protection Contact Points
The data controller for the processing activities described herein is:Vishay Intertechnology, Inc.
63 Lancaster Avenue
Malvern, Pennsylvania, 19355
You may contact the data protection officer of Vishay Intertechnology, Inc. under the above address c/o Data Protection Officer, or by e-mail to firstname.lastname@example.org.
The representative in Europe of Vishay Intertechnology, Inc. is:Vishay Electronic GmbH
Dr. Felix-Zandman-Platz 1
You may contact the data protection officer of Vishay Electronic GmbH under the above address c/o Data Protection Officer, or by e-mail to email@example.com.
IV. Definition of Personal Information
Personal information refers to any information relating to an identified or identifiable natural person, such as an identification number, physical, physiological, mental, economic, cultural, or social identifiers.
Personal Information may include the following: name, address, date of birth, gender and contact data (i.e. e-mail address, telephone number and employer name).
V. Definition of Non-Personal Information
We may also collect information that is related to you but that does not personally identify you (“Non-personal Information”). Non-personal Information also includes information that could personally identify you in its original form, but that we have modified (for instance, by aggregating, anonymizing or de-identifying such information) in order to remove any link to Personal Information.
(ii) prospective and current customers using Vishay hosting and information technology services;
(iii) users of any mobile-device applications that it offers (such as its iOS and Android applications);
(iv) service providers and business partners;
(v) job applicants;
(vi) tradeshow interactions;
(vii) subscriptions to one or more Vishay blogs or user groups; and
(viii) other third-parties that it interacts with.
VIII. (No) Collection of Information from Children
The Company recognizes the importance of protecting the privacy and safety of children. Our website and services are primarily directed towards the general audience and are not directed towards children. We do not knowingly collect information about children under the age of 13 however there are some instances where we may collect information, but we will make sure parental consent is achieved beforehand. A parent or guardian of a child may contact us at firstname.lastname@example.org to request that we delete such information.
I. Data Explicitly Provided by You
Vishay collects personal information about you in connection with many of our services. When working with or using our company, you may be prompted to make an account which may hold personal information such as your name, mailing address, email address, or credit card information. The legal basis for such processing depends on the specific purposes for which we process the data. See Section C below for details.
II. Information Collected Automatically
Vishay may also collect Technical Information about you when you use Vishay's mobile-device applications, contact Vishay or otherwise interact with Vishay. This concerns in particular data which your web browser automatically sends whenever you visit a website on the Internet. "Technical Information" is information that does not, by itself, identify a specific individual but which could be used to indirectly identify you. Our servers automatically record this information, which may include your Internet Protocol ("IP") address, browser type, browser language, and the date and time of your request. Gathering your information helps us ensure our websites and other services work correctly and support out customer analytic efforts.
Information that is collected automatically may include but is not limited to:
We use pixel tags and cookies in our marketing emails so that we can track your interaction with those messages, such as when you open the email or click a URL link that is embedded within them. When recipients click on one of those URLs, they pass through a separate web server before arriving at the destination page on a company website. We use tools like pixel tags and cookies so that we can determine interest in particular topics and measure and improve the effectiveness of our communications.
When you download or use our mobile-device applications, or access one of our mobile-optimized websites, we may receive information about your mobile device, including a unique identifier for your device.
Some of our mobile services use your device's location information. You can adjust the settings of your mobile device at any time to control whether your device communicates this location information. We may also offer additional controls on our use of your mobile location information.
Cookies and Similar Technologies
We may collect information about your use of the websites through cookies and similar technology. A "cookie" is a unique numeric code that we transfer to your computer so that we can keep track of your interests and/or preferences and recognize you as a return visitor to the websites. For example, we may use these technologies to collect information about the ways visitors use our websites, to support the features and functionality of our websites, and to personalize your experience when you use our websites.
III. Information Collected from Social Media Applications and Networking Websites
Links to Social Media Websites
Our websites do not use any social media plugins. The links on our websites are static links to our subpages on various social networks (Linkedin, YouTube, Facebook, Twitter, Google+, etc.). These links do not transfer any data to the operators of the social networks simply by visiting our websites. Only if you follow one of these links by clicking on it will you reach the pages of the respective social network. In this case the provider of the social network can collect data from you which is done according to the respective data protection regulations of the provider over which we have no influence or control.
Data Processing in the Context of our Social Media Pages
In addition to our websites, we are also represented on online platforms and social networks. If you visit these websites and communicate with us, the social media’s terms and conditions and data protection guidelines (see below) as well as this data protection declaration apply. In this respect, we may be jointly responsible with the provider under data protection law.
Your data can be processed for analysis and advertising purposes. This is done, for example, by creating usage profiles based on your usage behavior and the resulting interests. Cookies are usually used to create the user profiles, which make it possible to analyze your usage behavior and your interests. Normally, the user profiles serve to enable advertisements to be placed with the respective provider or elsewhere on the Internet that correspond to your interests. In addition, other data may be stored in addition to the user profiles, especially if you are a registered user of the platform of the respective provider and are logged in to the platform. For a detailed description of the respective provider’s processing and the possibilities of objection (opt-out), please refer to the information of the providers linked below.
If you visit our social media pages and communicate via these social media pages, the data processing takes place on the basis of your consent (Article 6 paragraph 1 sentence 1 letter a) GDPR) if you have granted this. Otherwise, data processing, in particular communication with us, is based on legitimate interests (Article 6 paragraph 1 sentence 1 letter f) GDPR). In this respect, our interest is to provide you with the most informative, customized and appealing social media pages possible.
We will delete your data (in particular the contents of our communication) as soon as they are no longer required for the respective purpose and as far as we are able to do so. You have the rights listed under "Your Rights as a Data Subject" (see below) vis-?vis us and the social media provider. Since the respective provider only has access to all of your data, you should in any case also assert your rights against the provider.
Facebook (Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (www.facebook.com) and Facebook Ireland Limited, Hanover Reach, 5-7 Hanover Quay, Dublin 2, Ireland (www.facebook.de) enables us to receive your anonymized data on so-called fan pages using the Facebook Insight function, which is available as an irrevocable part of the user relationship. This data is collected by using cookies, each of which contains a unique user code. The user code can be linked to your Facebook login information if you are registered on Facebook and is collected and processed when you visit the fan page.
Information on data protection on Facebook can be found here https://www.facebook.com/about/privacy/
If you would like to object to the data collection by Facebook in the future, you can do so here: https://www.facebook.com/settings?tab=ads
If data are processed outside the EEA, where no data protection level according to the European standard exists, this is done on the basis of the EU-US Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC
Information on data protection at Google (Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) can be found here: https://policies.google.com/privacy
If you wish to object collection of data by Google in the future, you can do so here: http://www.google.com/ads/preferences
If data are processed outside the EEA, where no data protection level according to the European standard exists, this is done on the basis of the EU-US Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AA
Information on data protection at Instagram (Instagram LLC., 1601 Willow Road, Menlo Park, CA 94025, USA) and an opportunity to object can be found here: http://instagram.com/about/legal/privacy/
If data are processed outside the EEA, where no data protection level according to the European standard exists, this is done on the basis of the EU-US Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0
Information on data protection on Twitter (Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA) can be found here: https://www.twitter.com/privacy
If you wish to object to the collection of data via Twitter in the future, you can set an opt-out cookie here: https://twitter.com/personalization
If data are processed outside the EEA, where no data protection level according to the European standard exists, this is done on the basis of the EU-US Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO
IV. Information Collected from Other Sources
Vishay may also collect information about you from other sources to help us correct or supplement our records, improve the quality or personalization of our services to you, and prevent or detect fraud. Information that is collected from other sources may include but is not limited to:
Some company websites or services may be co-branded and offered in conjunction with another company. If you use such websites or services, both Vishay and the other company may receive the Personal Information that’s collected via that co-branded website or service
I. Vishay's Business Operations
Vishay uses your personal information to provide you products and services, such as to fulfill your requests for products or to help us personalize our offerings to you. We also use your personal information to support our business functions, such as fraud prevention, marketing, and legal functions. To do this, we combine personal and non-personal information, collected online and offline, including information from third party sources.
Vishay uses your personal information for the following purposes:
To fulfill your requests for products and services and communicate with you about those requests. Such processing is lawful as it is necessary for the performance of a contract with you or to take preparatory steps upon your request prior to entering into a contract, cf. Art. 6 para. 1 lit. b GDPR;
Understand Customer Behavior
To better understand customer behavior so that we may improve our marketing and advertising efforts and to improve the distribution of our products and services. This is based on a balancing of interests taking into account Vishay's interest in promoting its own business, cf. Art. 6 para. 1 lit. f GDPR;
To help us personalize our service offerings, websites, mobile services, and advertising. This is based on a balancing of interests taking into account Vishay's interest in adapting its products and services to the needs of its customers, cf. Art. 6 para. 1 lit. f GDPR;
Vishay may use personal information such as name, date of birth, mailing address, or social security number to verify the identity of their customers and to prevent fraudulent activities such as the fraudulent purchase of products/services. Data processing for fraud protection purposes is based on a balancing of interests taking into account Vishay's interest in protecting its own business and avoiding/reducing losses from fraudulent behavior, cf. Art. 6 para. 1 lit. f GDPR;
Credit Card Information
Credit card information may be used to check the financial qualifications or collect payment from customers regarding orders of products and services. Such data processing is permissible as it is necessary for the performance of a contract with you or to take preparatory steps upon your request prior to entering into a contract, cf. Art. 6 para. 1 lit. b GDPR;
To protect the security and integrity of our websites, mobile services, and our business. Data processing for this purposes is based on a balancing of interests taking into account Vishay's interest in protecting the availability, security and integrity of its services, cf. Art. 6 para. 1 lit. f GDPR;
To comply with legal and/or regulatory requirements. This processing is based on the fact that it is necessary to comply with legal obligations to which Vishay is subject (cf. Art. 6 para. 1 lit. c GDPR for obligations arising from European law, otherwise processing is based on Vishay's interest in compliance with applicable laws, cf. Art. 6 para. 1 lit. f GDPR);
Responding to Customer
To respond to reviews, comments, or other feedback you provide us. Data processing for this purposes is based on a balancing of interests taking into account Vishay's interest in responding to such customer communication and protecting Vishay's reputation, cf. Art. 6 para. 1 lit. f GDPR;
For industry benchmarking and analysis consistent with our legitimate business purpose. Data processing for this purposes is based on a balancing of interests taking into account Vishay's interest in promoting its own business, cf. Art. 6 para. 1 lit. f GDPR;
In connection with a job application or inquiry, you may provide us with data about yourself, including your educational background or resume and other information, including your ethnicity where required or permitted by law.
II. Personalization and Tracking of Website Use
Ability to Disable Technologies
Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your computer, tablet or mobile device. Although you are not required to accept cookies, if you block or reject them, you may not have access to all features available through our services.
Consequences of Disabling Technologies
Please note that if you disable your web browser's cookies and other technologies, certain features of our website and services will be disabled and you will limit the functionality we can provide when you visit our site.
III. Promotional Messaging or Advertising
Promotional Messaging by E-Mail
Vishay uses your contact information to recommend products and services that might be of interest to you, to send you marketing and advertising messages such as newsletters, announcements, or special offers or to notify you about our upcoming events. Such data processing is based on your consent, cf. Art. 6 para. 1 lit. a GDPR.
Promotional Messaging or Advertising on our Website
Vishay allows you to opt-in to receive advertisements on our Website based on your interests. If you do not opt-in, you will still receive advertisements but they will not be tailored to your interests.
IV. (No) Automated Decision Making
Vishay does not carry out any automated decision making in the sense of Art. 22 GDPR.
I. Disclosure of Personal Information to Third Parties
Vishay will not rent or sell your Personal Information to others but may disclose personal information with third-party vendors and service providers that work with Vishay. We will only share Personal Information to these vendors and service providers to help us provide a product or service to you. Such vendors and service providers will be bound by data processing agreements ensuring the protection of your personal data.
II. Disclosure of Personal Information for Legal and Safety Reasons
Vishay may be required to disclose personal information to the authorities, law enforcement agencies, government agencies, or legal entities. We may disclose information by law, litigation, or as a matter of national security to comply with valid legal process including subpoenas, court orders or search warrants, and as otherwise authorized by law. We may also need to disclose personal information in the event of an emergency that threatens an individual's life, health, or security. This processing is based on the fact that it is necessary to comply with legal obligations to which Vishay is subject (cf. Art. 6 para. 1 lit. c GDPR for obligations arising from European law, otherwise processing is based on Vishay's interest in compliance with applicable laws, cf. Art. 6 para. 1 lit. f GDPR)
III. Disclosure of Personal Information Via Links to Third-Party Websites, Services, and Applications
IV. Onward Transfer Liability
In cases of onward transfer to third parties of your personal data, Vishay is potentially liable. In particular, Vishay remains responsible and liable under GDPR if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with its principles, unless Vishay proves that it is not responsible for the event giving rise to the damage.
I. Security Measures Taken to Protect Personal Information by Vishay (Including Data Breach Notification)
Security of all information is of the utmost importance for Vishay. Vishay uses technical and physical safeguards to protect the security of your personal information from unauthorized disclosure. We use encryption technology to keep information secure when commercially appropriate. We also make all attempts to ensure that only necessary people and third parties have access to personal information. Nevertheless, such security measures cannot prevent all loss, misuse or alteration of personal information and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. In the case of a data breach, we will notify you without delay of any loss, misuse or alteration of personal information that may affect you. We will notify relevant regulatory bodies within 72 hours of becoming aware of a breach.
II. Security Measures to Protect Personal Information by Third Parties
We require that our third party service providers and channel partners agree to keep all confidential information we share with them and to use the information only to perform their obligations in the agreements we have in place with them. These third party service providers and channel partners are expected to maintain privacy and security protections that are consistent with Vishay’s privacy and information security policies.
III. Data Retention and Storage
Vishay retains your information for business purposes, for as long as your account is active, and/or as long as is reasonably necessary to provide you with our products and services. Vishay will also retain your information as reasonably necessary to comply with our legal obligations, resolve disputes and enforce our agreements. We may also retain cached or archived copies of your information for a reasonable period of time. As far as processing of your data is based on consent, you can withdraw consent and we will immediately stop processing your data.
I. International Transfer of Personal Information
Vishay may share customer information within our family of companies for a variety of purposes, for example to provide you with the latest information about our products and services and offer you our latest promotions. To facilitate our global operations, Vishay may transfer personal data from your home country to other Vishay locations across the world. To protect your personal information, we will only transfer data to countries who provide an "adequate" level of personal data protection. If the data is transferred to counties without 'adequate' protection as determined by the European Parliament, we will use additional safeguards to ensure your data is protected. For data transfers within the Vishay group of companies, Vishay has concluded intra-group-agreements based on the EU Standard Contractual Clauses. You may obtain a copy of these intra-group agreements and/or the respective agreements with other companies by contacting Vishay at email@example.com.
II. Location of Data Processing/Storage
Any personal information collected about EU data subjects via our websites is processed in the United States by Vishay or by a third party acting on our behalf. When you provide personal information to Vishay, you consent to the processing of your information in the United States. Our websites are hosted in the United States.
I. General Information
Vishay gives you choices about the ways we collect, use, and share your personal information. You can choose what contact and financial information will be stored in your account and preferences. However, if you choose not to provide certain details, some of your experiences with us may be affected. If at any point in time you wish know what data we process about you, you can request to access the information by contacting firstname.lastname@example.org.
II. Your Rights under the California Privacy Rights
California Civil Code Section 1798.83 permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to email@example.com.
III. Your Rights under the GDPR
Access to Personal Information
Vishay provides you with many opportunities to access and update your personal information. You can ensure that any account, contact, or financial information is up-to-date and can correct, update or delete inaccuracies to the information by in your MyVishay account or by emailing firstname.lastname@example.org. We will respond to your request to access within 7 business days. In some cases, however, we may limit or deny your request if the law permits or requires us to do so, infringes on the privacy of other individuals, or if we are unable to verify your identity. Please note, at any time, if you desire to obtain or transfer your information, we will provide you with your personal data in a structured and commonly used electronic format.
Right to Rectification
If any personal data is inaccurate or incomplete, you can request Vishay corrects the data. When this occurs, Vishay will notify third parties to whom the personal data have been disclosed of the change, unless this proves impossible or involves disproportionate effort. If you wish to alter your data, please contact email@example.com.
Right to Erasure
You have the right to request Vishay erases all of your personal data on a number of grounds, including if the data is no longer necessary for its original purpose, if you withdraw consent or if you object to the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate grounds for processing or you object to the processing pursuant to Art. 21 para. 2 GDPR. If Vishay receives a request, we will inform all third parties to whom the personal data have been disclosed of this request, unless this proves impossible or involves disproportionate effort. For additional information on when you can request data erasure, please contact firstname.lastname@example.org.
Right to Restrict Processing
Even if personal data is still stored by a company, now or in the future, you can request Vishay stops using or processing your data. If you wish to restrict data processing, please contact email@example.com. If Vishay receives a request to restrict processing, we will inform all third parties to whom the personal data have been disclosed of this request, unless this proves impossible or involves disproportionate effort.
Right to Data Portability
You have the right to transfer your personal data from one electronic processing system to another without being prevented from doing so by Vishay's data processor. Within one month, Vishay will respond to the request and provide you with the desired information for free in a structured and commonly used electronic format. If you wish to transfer your personal data, please contact firstname.lastname@example.org.
Right to Object
You have the right to object to your personal data being processed for profiling, direct marketing, scientific research, statistics and any other processing based on a balancing of interests (Art. 6 para. 1 lit. e GDPR). If you wish to object, please contact email@example.com.
Rights Related to Automated Decision Making (if any)
At any point in time, you can contact a Vishay representative to obtain human intervention on the part of Vishay, to express your point of view, to contest the decision, to challenge an explanation of data use, or otherwise obtain further information on automatic data processing via email at firstname.lastname@example.org.
Right to Withdraw Consent
Before collecting and using your personal data, unless processing is permitted by other legal basis, Vishay will obtain consent. At any point in time, you can revoke consent and Vishay will stop using and processing your personal data. Withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. To withdraw consent, please contact email@example.com.
Right to Lodge a Complaint to Vishay and to a Data Protection Authority
You also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.
1. Right to object on a case-by-case basis
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based Art. 6 para. 1 lit. f GDPR (data processing on the basis of a balancing of interests); this also applies to any profiling based on this provision within the meaning of Art. 4 para. 4 GDPR.
If you object, Vishay will no longer process your personal data, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or the processing serves establishment, exercise or defence of legal claims.
2. Right to object to processing of data for direct marketing purposes
In individual cases, Vishay processes your personal data for direct marketing purposes. You have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
Where you object to processing for direct marketing purposes, we shall no longer process your personal data for such purposes.
The objection may in both cases be filed informally and shall be addressed to:Vishay Intertechnology, Inc.
C/O Data Privacy Officer
63 Lancaster Avenue
Malvern, Pennsylvania, 19355
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