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PRIVACY STATEMENT

Introduction

This Privacy Statement is effective as of November 28, 2017. If you would like to review a previous version of this Privacy Statement, please contact us at Privacy@techdata.com.

This Privacy Statement explains how Tech Data Corporation and the companies, which Tech Data Corporation  owns or controls (“Tech Data”, “we”, “our” or “us”) are processing (e.g.: collect, use, store, process, disclose and delete) your personal information (as defined in the applicable data protection legislation). This Privacy Statement applies to information that you provide directly to us through websites or mobile apps operated by us, accessed through our social media pages as well as through email messages that we may send to you.

It also describes the choices available to you regarding our use of your personal information, the steps you can take to access this information and to request that we correct or delete it.

This Privacy Statement applies to Tech Data websites and services that link to this Privacy Statement.

From time to time, we may supplement this Privacy Statement with additional information relating to a particular interaction we have with you.

If you have questions or concerns regarding this Privacy Statement or our handling of your information collected under this Privacy Statement, contact Tech Data’s Privacy Office at Privacy@techdata.com

Personal information is information that directly identifies you or information otherwise defined as “personally identifiable” under applicable law. This includes, but is not limited to:

  • Name
  • Email address
  • Postal address (Including billing and shipping address)
  • Telephone number
  • Fax number
  • Bank information
  • Credit or debit card number

How We Collect Personal Information

Directly From You

We may collect personal information you provide directly to us via websites, mobile apps, email, EDI, and other interactions.  For example, when you register with us as a customer, place an order for product or services, participate in promotional activities, apply for a job, use an app installed on a device, post on our services, or subscribe to our notifications.

When you register with us, we will collect your registration details in order to process your or your organization’s application and to administer the relevant accounts. We will collect information relating to your application, which may include personal information such as your name, title, company or organization name, contact details (e-mail address, sold to address, shipping address), billing address and payment information (e.g. credit card details). 

You may also have the opportunity to provide further optional data (such as phone number).  In addition, you will need to choose a user name and password. We will also collect subsequent information provided when you use the account, and to keep a record of purchases or orders placed. We may also (for any visitor to our website) collect information about the domain from which you are visiting, and information regarding what pages you access.

Automatically Collected from Your Use of our Services

We may automatically collect personal information for business-related purposes, which may include providing customer service, managing the services we provide, complying with legal requirements, payment processing, and for marketing our products and services. 

When you visit our websites, we automatically receive information about which of our websites you are visiting and the browser you are using. This information will be stored anonymously, and we will use it to improve our services and to make our websites more user-friendly as well as for statistical purposes.

Further, we may use cookies to help us optimize our services for you as further outlined in the Cookie Statements on our websites.

Personal Information Collected from Other Sources

We may collect personal information from publicly available sources, including, but not limited to, public internet websites and databases, public or government sources, and news media.

Along with using fully identifiable personal information for business related purposes, we may use anonymized, or de-identified personal information for statistical purposes.

We may use your personal information to generate de-identified, statistical, summary, or aggregated information and subsequently use this de-identified information if such de-identified, statistical, summary, or aggregated information cannot be used to identify any individual.

We will obtain authorization from supervisory authorities prior to processing personal information where legally required in certain countries.   

We may also obtain personal information from third parties including other Tech Data companies that have obtained or collected information about you and that have the right to provide that personal information to us. We may also contract with third parties that are in the business of providing information to businesses such as to verify certain information about you or obtain information about you. We may use the personal information we receive from a third party outside of the website in accordance with the terms we establish with that third party.

How We Use Information We Collect

Tech Data and service providers acting on our behalf may use information about you for the following purposes:

  • To provide, maintain, protect and improve our services, develop new services, and protect the legitimate interests of Tech Data and our users;
  • To facilitate , manage, personalize and improve your online experience;
  • To respond to your inquiries and fulfill your requests, such as send you newsletters, brochures, catalogs and e-mails;
  • For our business purposes, such as data analysis, audits, fraud monitoring and prevention, enhancing, improving, or modifying our services, identifying usage trends, and operating and expanding our business activities;
  • To send you advertisements and communicate with you about products, services, offers, promotions, rewards and events we believe may be of interest to you in accordance with applicable law or based on your consent thereto; and
  • If Tech Data transfers ownership or control of any portion of Tech Data to a third party, whether in the context of an acquisition, merger, reorganization, or other disposition of all or any portion of our business, assets, or stock ( including in connection with any bankruptcy or similar proceedings), we may transfer your  personal information to that third party, provided that the use of your  personal information by that third party remains subject to applicable law.

If you contact us, we may store any written/email correspondence between you and us. We use this information to respond to your queries, to provide our services and to improve our future services.

In the above cases the legal basis for the collection and processing of personal data is that it is necessary for the purposes of the legitimate interests pursued by us or by a third party. Such legitimate interests can be the offering and operation of the services in a cost-efficient and state-of-the art way as well as the high quality fulfillment of your orders.

The provision of your personal data is a requirement necessary to enter into a contract with us.  If you fail to provide information (which are not marked as optional), you will not be able to open a user account and/or use our services.

Marketing Purposes

If you are a user from the United States, we may use your personal information for direct marketing purposes. If you are a user from outside of the United States, we may contact you, for example by email or by telephone to inform you about our range of products or services similar to what you have previously ordered from us. You reserve the right at any time to refuse to allow your personal data (email address, telephone number) to be used for this purpose or withdraw your consent if applicable and we will emphasize this fact every time you are contacted for marketing purposes. If you do not want your personal information to be used for this purpose, please contact Privacy@techdata.com. 

How We Share Information

Our agents, vendors, consultants, marketing service providers, and other service providers including other Tech Data companies may receive, or be given access to your information, including personal information and usage information, in connection with their work on our behalf.

We may also share information about you as follows:

  • As necessary to (a) comply with legal process; (b) to respond to requests from public and government authorities, (c) to enforce our contractual rights ; (d) to protect our operations and protect our rights, privacy, safety or property, and /or that of you or others; and (e ) to allow us to pursue available remedies or limit the damages that we may sustain;
  • As necessary with other Tech Data companies for internal business purposes. For example , processing your orders, fulfilling your requests, providing customer service, and improving our products;
  • If you agree, with our subsidiaries, affiliates, business partners, and other third parties for their own business purposes. For example, improving their products and services; and
  • To a third party in connection with or during negotiations of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock ( including in connection with any bankruptcy or similar proceedings).

When Tech Data engages third-party service providers, the disclosure of personal information to such providers is necessary, for example, to provision our services to you. Tech Data ensures that such providers protect personal information in a manner consistent with this Privacy Statement and with applicable data protection laws.  These service providers may be located in countries other than your country of residence and may be prohibited from using your personal information for any other purpose other than to provide assistance.

Additionally, we may be required by law to provide certain data to authorities, in such case the legal basis for the transfer is that it is necessary for compliance with a legal obligation to which we are subject.

Cross Border Data Transfer

Transfer of your personal information may take place to third parties including to Tech Data companies in a territory where the laws do not offer a level of protection for personal information equivalent to the laws applied in your region.  In order to ensure an adequate level of data protection at those recipients of personal information, we implement appropriate measures for the transfer in line with applicable legislation. If for example personal information is transferred from European Economic Area/European Union or Switzerland to another geographic area not providing for an adequate level of data protection according to European Commission, we conclude Model Clauses with such recipients or apply other appropriate safeguards as approved by the European Commission.  Further, if such recipients engage sub-processors in line with our agreement with them, they will be obliged to make sure that such sub-processors comply with the same level of data protection. 

Sweepstakes, Contests, and Promotions

If you voluntarily choose to enter a promotion, your personal information may be disclosed to third parties as further described in the terms of that promotion for administrative purposes and as required by law. By entering a promotion, you may be asked to explicitly consent to, except where prohibited by applicable law, allow us, the sponsor and/or other parties as described in the terms of use to use your name, voice and/or likeness in advertising or marketing materials.

General Principles for Processing of Personal Information

Personal information will be collected, stored, processed and transmitted in accordance with Tech Data’s established policies and applicable federal, state, local and foreign laws, rules and regulations.

The principles of Tech Data with regard to the processing of personal information are as follows:

  • Personal information will be processed fairly and lawfully;
  • Personal information will be collected for specified, explicit, and legitimate purposes and not further processed for incompatible purposes;
  • Personal information collected by Tech Data will be adequate, relevant, and not excessive in relation to the purposes for which it is collected;
  • Personal information collected by Tech Data will be accurate and, where necessary, kept up to date as reasonable possible ; and
  • Personal information collected by Tech Data will be retained as identifiable data for no longer than necessary to serve the purposes for which the personal information was collected.

If Tech Data engages in the processing of personal information for purposes other than those specified in this Privacy Statement, Tech Data would provide notice of these changes, the purposes for which the personal information will be used, and the recipients of personal information.

Social Media Features

We may also provide social media features that enable you to share information with your social networks and to interact with Tech Data on various social media sites.  Your use of these features may result in the collection or sharing of information about you, depending on the feature.  We encourage you to review the privacy policies and settings on the social media sites with which you interact to make sure you understand the information that may be collected, used, and shared by those sites.

Security of Personal Information

We seek to comply with legal requirements and use reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.  Tech Data will notify you in the event we become aware of a security breach involving your personally identifiable information (as defined by the applicable state, federal and international regulations) stored by or for us. By disclosing your email address to us for any reason, you expressly consent to receive electronic notice from us in the event of such a security breach.

Access to Personal Information

Subject to the applicable data privacy regulation, you may be entitled to request certain information about the personal data we have stored about you and to request certain access to, correction, deletion or blocking of such data as well as to request restriction of processing or to object to the processing;  you may also have a right to lodge a complaint with the supervisory authority. For this purpose, or if you have any questions regarding the processing of your personal data, please contact Privacy @Techdata.com.

If your personal information changes, you may correct, update, or delete it through the website or by contacting us at Privacy@techdata.com.

Tech Data reserves the right to decline requests to access or delete personal information if and to the extent disclosure or deletion of the information requested is not required or permitted by applicable law.

To guard against fraudulent requests for access, Tech Data reserves the right to require sufficient information to allow it to confirm the identity of the party making the request before granting access or making corrections.

Retention Period

We retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Statement or otherwise upon collection of your personal information, unless a longer retention period is required or allowed by law or to otherwise fulfill a legal obligation.

Additional Provisions

Children

The website is intended solely for use by individuals 18 years or age and older and thus is not directed to children under 13 years of age.  Tech Data does not knowingly solicit or collect Personal information from children under 13 years of age.

Your Consent and Changes

When using our websites, you consent to the processing and use of your personal information in accordance with this policy.

Tech Data may from time to time revise this Privacy Statement with effect for the future in its sole discretion to reflect changes in our business practices. If we revise this Privacy Statement, we will notify you by posting the updated version on the applicable website.  We will notify you of the change via a reference on the website at least thirty days in advance, unless the change is reasonable and not in your disfavor. Such notice of the change will refer to the fact that changes to this Privacy Statement will become effective unless you object to it within the said thirty day period.

Your California Privacy Rights

Under California law, organizations that do business with California residents are required to provide residents of the State of California access to a privacy policy that  provides a choice in the use of certain personal information by third parties for marketing purposes.

If you are a California resident, you can opt-out of the sharing of your personal information to third parties for direct marketing purposes by sending an email to Privacy@techdata.com.

Compliance with Local Laws

This Privacy Statement is meant to guide Tech Data with respect to personal information collected from or about you on our websites. While this Privacy Statement applies to personal information generally, the local laws, rules and regulations of jurisdictions that are applicable to Tech Data (“Local Laws”) may require standards that are stricter than this Privacy Statement, and in such event, Tech Data will comply with applicable Local Laws. Specific privacy policies may be adopted to address the specific privacy requirements of particular jurisdictions.

Sensitive Information

Unless we specifically request or invite it, we ask that you not send us, and you not disclose, any sensitive personal data ( e.g. information related to racial or ethnic origin, political opinions, religion or other beliefs, health , criminal background or trade union membership) on or through this website or otherwise to us. In those cases where we may request or invite you to provide sensitive personal information, we will do so with your express consent.

Compliance

Tech Data will use a self- assessment approach to verify compliance with this Privacy Statement and periodically verify that it is accurate and comprehensive regarding the information intended to be covered.

If you believe that, your personal information has been processed or disclosed in violation of this Privacy Statement, Tech Data encourages you to raise any concerns using the contact information provide in this Privacy Statement or the applicable website notice. Tech Data will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information.

Questions

If you have any questions or concerns about this Privacy Statement, the privacy practices of Tech Data, our collection or use of your personal information, or you wish to access your personal information, please contact us at Privacy@techdata.com. If we need or are required to contact you concerning any issue or event that involves this Privacy Statement, your personal information, or the website, then we may do so using the email address, telephone number, or physical mailing address we have on file for you.

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