LAST UPDATED [May 21, 2020]
PRIVACY & SECURITY
WHAT PERSONAL INFORMATION DO WE COLLECT
a) When You Register on the Site or Order Products
When you register by creating an account on the Site or order products available on the Site, we collect the following identifiers that may, alone or in combination with other information, constitute Personal Information:
- Phone number;
- Shipping and billing address; and
- Your newsletter subscription or choice of marketing communication.
We do not collect payment card information in connection with product purchases. Payment card information is processed by a third party vendor. You have no obligation to provide the Personal Information described above, but if you don’t provide such Personal Information, we may not be able to create an account, process your order, or send a newsletter to you. Please note that you have the right to opt out of receiving electronic direct marketing communications, such as newsletters, from us. All electronic direct marketing communications that you may receive from us, such as e-mail messages, give you an option of not receiving such communications from us in the future. If you have any additional questions about electronic direct marketing received from us, please contact us at email@example.com.
b) When You Communicate With Us
When you communicate with us on and through the Site, e-mail us, or otherwise communicate with us, we collect the following identifiers that may, alone or in combination with other information, constitute Personal Information:
- Phone number;
- Contact information such as email address and a street address; and
- Content of communications sent to us.
You have no obligation to provide the Personal Information described above, but if you don’t provide such Personal Information, we will not be able to respond to your communications to us.
c) When You Submit an Application for an Open Position
When you visit the “Careers” page on the Site, we use a third-party vendor to collect the following identifiers and professional information that may, alone or in combination with other information, constitute Personal Information:
- Contact information such as e-mail address;
- The content of your resume/CV;
- Publicly available professional social media (e.g. LinkedIn) profile information included available through links submitted in connection with your application; and
- Any other information you choose to submit with your application.
You have no obligation to provide the Personal Information described above, but if you don’t provide such Personal Information, we may not be able to respond to your requests.
d) Assistance Over The Phone
You may call our customer service line for information about our products. If you do so, we may collect the following identifiers that may, alone or in combination with other information, constitute Personal Information:
- Contact information such as email address, postal address, and phone number; and
- If you choose to make a purchase, your payment card information.
You have no obligation to provide the Personal Information described above, but if you don’t provide such Personal Information, we may not be able to provide you the assistance that you request.
e) Internet Activity Information
Software used on the Site collects Internet or other electronic network activity information that may, alone or in combination with other information, constitute Personal Information:
- The domain from which you access the Site;
- The type of browser and operating system used in the device you use to access the Site;
- Internet Protocol (IP) address;
- Imprecise geolocation;
- The date and time you visited the Site (time stamp);
- The pages browsed on the Site;
- The website used to link to the Site from;
- Any search terms used to navigate the Site;
- Products purchased and viewed on the Site;
- A browsing session ID; and
- Whether you are a first time visitor to the Site.
For additional information about cookies used on the Site, please review Section XI below.
Google Analytics is an element of the Site. By using cookies, Google Analytics collects and stores data such as time of visit, pages visited, time spent on each page of the Site, the Internet Protocol address, and the type of operating system used in the devices used to access the Site. By using a browser plugin available at http://www.google.com/ads/preferences/plugin/ provided by Google, you can opt out of Google Analytics.
THE SOURCES OF PERSONAL INFORMATION
In the last 12 months, we have collected Personal Information from the following categories of sources:
- You: When you voluntarily provide Personal Information to us;
- Software: Information automatically collected via cookies, web logs, web beacons, and other software-based analytics tools;
- Commercial partners: Information obtained from our commercial partners, including social networks and sponsored content hosts.
WHY WE COLLECT PERSONAL INFORMATION ABOUT YOU
We use Personal Information about you for the following purposes:
- To operate and improve our Site, including through analytics to help us understand how you use the Site, so that we can present content in the best manner;
- To provide the products to you;
- To provide customer service;
- To provide you with any information that you request from us;
- To notify you about changes to the Site;
- To facilitate our participation in ad networks;
- To enable us to issue a notice, administrative, or corrective action to you in relation to the Site, if required;
- To send you direct marketing messages that you have consented to receive;
- To protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities;
- To comply with applicable legal requirements, industry standards, and our own policies;
- Where permitted by law, to provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about and we feel may interest you.
HOW WE DISCLOSE PERSONAL INFORMATION
In the past twelve (12) months we have disclosed the following categories of Personal Information with the following categories of third parties for business purposes:
|Category of Personal Information||Category of Third Party|
Internet activity information
|Our affiliates (such as subsidiaries that we own)|
Internet activity information
|Service providers: We use services providers such as website hosting and management companies, recruiting software providers, data storage and data analysis companies and marketing technology companies. Such service providers can only use Personal Information for the specific business purpose of providing such services to us and for no other purpose.|
Internet activity information
|Parties to a corporate transaction or proceeding: In the event of a corporate sale, merger, reorganization, bankruptcy, dissolution or similar event, Personal Information may be part of the transferred assets.|
|Public authorities and legal proceedings: Flex may disclose Personal Information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Site; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.|
|Internet activity information||Our advertising partners|
CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits the users of the Site who 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 contact us at firstname.lastname@example.org.
If you are a California resident you may also have the right:
- To request disclosure of the categories and specific pieces of Personal Information collected about you;
- To request the disclosure of the business purpose for collecting or selling Personal Information; the categories of third parties with whom it is shared, and the categories of sources from which Personal Information is collected;
- To request the deletion of Personal Information, subject to the limitations set forth in California Civil Code Section 1798.105(d); and
- Not to be discriminated against for exercising the rights guaranteed by California Civil Code Section 1798.100 et seq.
For a list of categories of Personal Information collected and the purposes for the processing of that Personal Information, please refer to Sections II and IV above.
b) Requests to Know
You have the right to request that we disclose:
- The categories of Personal Information we collect;
- The categories of Personal Information we have sold or disclosed for a business purpose;
- The categories of sources from which we collect Personal Information about you;
- Our business or commercial purpose for selling or collecting Personal Information;
- The categories of Personal Information sold or shared about you, as well as the categories of third parties to whom the Personal Information was sold, by category of Personal Information for each party to whom information was sold;
- The specific pieces of Personal Information collected about you.
Delivery may take place electronically or by mail. We are not required to respond to requests relating to Personal Information more than twice in a 12-month period.
c) Requests to Delete
With certain exceptions, you have the right to request that we delete any Personal Information we have collected about you. Upon receiving a verified request to delete Personal Information about you, we will do so unless otherwise authorized by law.
d) Verifiable Requests
We will acknowledge the receipt of requests to know or requests to delete Personal Information free of charge, within ten (10) business days. In order to protect your privacy and the security of Personal Information, we may verify your request by asking you to provide additional Personal Information for us to verify your identity. We will respond to your request within 45 calendar days of receipt, provided that we have been able to successfully verify your identity.
You may submit a request to know or a request to delete Personal Information via email@example.com.
e) Sale of Personal Information
In the last 12 months, we have not sold Personal Information collected in and through the Site or Personal Information relating to our customers. Consequently, we do not have an opt-out functionality on the Site.
f) The Right to Non-Discrimination
You have a right not to receive discriminatory treatment for the exercise of your California privacy rights.
g) Notice of Financial Incentive
If you allow us to collect your email address or phone number (SMS), we will provide you with access to select special product offers, discounts, and deals, (“the Program”). If you participate in the Program, we will retain the following categories of your Personal Information:
- Your email address
- Your phone number
You may opt-in to the Program here.
You have the right to withdraw from the Program at any time, and may exercise that right by responding STOP, END, CANCEL, UNSUBSCRIBE, or QUIT to a text message or clicking the Unsubscribe link in an email. You may also contact us directly by email at firstname.lastname@example.org or toll-free at (800) 931-0882 to opt out.
We provide select special product offers, discounts, and deals to consumers who voluntarily provide their contact information to us, because we can use that information to communicate to potential consumers about products or services that they may be interested in.
h) Authorized Agents
You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney pursuant to Probate Code sections 4000-4465 may submit a request on your behalf.
SECURITY OF PERSONAL INFORMATION
We take reasonable and appropriate measures to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. Despite these efforts to store Personal Information collected on and through the Site and otherwise by us in a secure operating environment that is not available to the public, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Information, we cannot guarantee that our security measures will prevent third-parties such as so-called hackers from illegally obtaining access to Personal Information. We do not warrant or represent that Personal Information about you will be protected against, loss, misuse, or alteration by third parties.
We will only retain Personal Information about you for as long as necessary to fulfill the purposes Personal Information was collected for, including the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Personal Information, the purposes for which we process Personal Information and whether we can achieve those purposes through other means, and applicable legal requirements.
LINKS TO OTHER WEBSITES
The Site is not intended for children under the age of 16. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 16 years of age. We do not intentionally collect, sell, or process the Personal Information of individuals under 16 years of age.
The following sets out how we may use different categories of cookies and your options for managing cookie settings:
|Type of Cookies||Description||Managing Settings|
|Performance cookies||These cookies collect information about how you use the Site, including which pages you go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identifies you. Information is only used to improve how the Site functions and performs. From time to time, we may engage third parties to track and analyze usage and volume statistical information relating to individuals who visit the Site. We may also utilize Flash cookies for these purposes.||To learn how to opt out of performance cookies using your browser settings, click here. To learn how to manage privacy and storage settings for Flash cookies, click here.|
|Functionality cookies||Functionality cookies allow the Site to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of the Site after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. We may use local shared objects, also known as Flash cookies, to store your preferences or display content based upon what you view on the Site to personalize your visit.||To learn how to opt out of functionality cookies using your browser settings, click here. To learn how to manage privacy and storage settings for Flash cookies, click here.|
FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA, SWITZERLAND, AND THE UNITED KINGDOM
Legal Basis For Processing Personal Information
The legal bases for our processing of Personal Information about you are as follows:
- Contract: When you purchase a product from us, we collect Personal Information about that is necessary for completing that transaction and delivering the product to you;
- Consent: We obtain your consent to collect Personal Information for distinct purposes such as receiving marketing communications from us. You have the right to withdraw your consent at any time.
- Legitimate Interest: We have a legitimate interest to collect Personal Information about you for certain purposes such as data analytics and the protection and administration of the Site so that we can (i) understand our customers’ preferences and improve the product selection available on the Site; (ii) to protect the Site from information security threats and our Company in connection with legal claims and proceedings; (iii) to communicate administrative changes in connection with the use of the Site; and (iv) to comply with laws that apply to us and the Site.
You have the following rights with respect to the Personal Information we hold about you:
- The right to know what Personal Information we hold about you;
- The right to have incomplete, incorrect, outdated, or unnecessary Personal Information corrected, deleted, or updated;
- The right to request that we restrict the processing of Personal Information we hold about you in certain circumstances;
- The right to object to the processing of Personal Information we hold about you; and/or
- The right to receive any Personal Information we hold about you in a structured and commonly used machine-readable format or have such Personal Information transmitted to another company.
In connection with exercising your rights described above, we may request additional Personal Information for purposes of verifying your identity and for no other purpose.
Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Information about you. We encourage you to first reach out to us at email@example.com so we have an opportunity to address your concerns directly before you do so.
To exercise any of the rights described above, please contact us at firstname.lastname@example.org. We seek to promptly respond to your inquiry.
(d) Personal Information Transferred from the EU, UK, or Switzerland to the United
Flex complies with the EU-US Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (Privacy Shield) as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the EU and the United Kingdom and/or Switzerland, as applicable to the United States in reliance on Privacy Shield. Flex has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. A violation of our commitment to Privacy Shield may be investigated by the Federal Trade Commission and/or the United States Department of Commerce. If there is any conflict between the policies in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, to the extent available, please visit https://www.privacyshield.gov.
In compliance with the Privacy Shield Principles, Flex commits to resolve complaints about your privacy and our collection or use of Personal Information about you. Persons from the EU who have inquiries or complaints regarding this Statement should first contact us via email at: email@example.com.
Flex has committed to refer unresolved privacy complaints under the Privacy Shield Principles to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim for more information and to file a complaint.
These recourse mechanisms are available at no cost to you. Damages may be awarded in accordance with applicable law.
Under certain conditions, if you are not satisfied with the above recourse mechanism, you may be able to invoke binding arbitration.
In cases of onward transfer to third parties of Personal Information of EU individuals received pursuant to the EU-US Privacy Shield, Flex is potentially liable.
Pursuant to the Privacy Shield, Flex remains liable for the transfer of Personal Information to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.
CHANGES TO THIS NOTICE
DO NOT TRACK (‘DNT’) SETTINGS
California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently isn’t an industry or legal standard for recognizing or honoring DNT signals, we don’t respond to them at this time.