ComponentSource DPF Privacy Policy

ComponentSource, Inc. (U.S.) Data Privacy Framework (DPF) Privacy Policy

ComponentSource, Inc. and ComponentSource Holding Corporation, (together “ComponentSource”), complies with the EU-U.S. Data Privacy Framework and the UK Extension to the EU-U.S. Data Privacy Framework (together DPF) as set forth by the U.S. Department of Commerce. ComponentSource has certified to the U.S. Department of Commerce that it adheres to the DPF Principles with regard to the processing of personal data received from the United Kingdom and European Union member countries in reliance on the DPF. If there is any conflict between the policies in this Privacy Policy and the DPF Principles, the DPF Principles will govern. To learn more about the Data Privacy Framework program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

In compliance with the DPF ComponentSource commits to cooperate and comply with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) (DPF Panel) with regard to unresolved complaints concerning our handling of non-human resources data received in reliance on the DPF.

Definitions

“Data Subject” means the individual to whom any given Personal Data covered by this Privacy Policy refers.

“Personal Data” means any information relating to an individual residing in the United Kingdom or the European Union that can be used to identify that individual either on its own or in combination with other readily available data.

Personal Data of individual customers or vendors or service providers and of individuals working for customers or vendors or service providers is used solely for the purposes of delivering and improving ComponentSource products and services and the management of its business.

“Sensitive Personal Data” means Personal Data regarding an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, physical or mental health, or sexual life.

Scope and Responsibility

This Privacy Policy applies to Personal Data transferred from the United Kingdom or European Union member countries to ComponentSource companies in the U.S. in reliance on the DPF and does not apply to Personal Data transferred under Standard Contractual Clauses or any approved derogation from either the EU GDPR or the UK GDPR.

Some types of Personal Data may be subject to other privacy-related requirements and policies. For example:

  • Some ComponentSource websites have their own privacy policies.
  • Personal Data regarding and/or received from a customer, vendor or licensee is also subject to any specific agreement with, or notice to, the customer, vendor or licensee, as well as additional applicable laws.

All employees of ComponentSource that have access in the U.S. to Personal Data covered by this Privacy Policy are responsible for conducting themselves in accordance with this Privacy Policy. Adherence by ComponentSource to this Privacy Policy may be limited to the extent required to meet legal, regulatory, governmental, or national security obligations, but Personal Data covered by this Privacy Policy will not be collected, used, or disclosed in a manner contrary to this Privacy Policy without the prior written permission of the ComponentSource Data Protection Manager.

ComponentSource employees responsible for engaging third parties to which Personal Data covered by this Privacy Policy will be transferred are responsible for obtaining appropriate assurances that such third parties have an obligation to conduct themselves in accordance with the applicable provisions of the DPF Principles, including any applicable contractual assurances required under the DPF Principles.

DPF Principles

ComponentSource commits to subject to the DPF Principles all Personal Data received by ComponentSource in the U.S. from the United Kingdom or European Union member countries in reliance on the DPF.

1. Notice

ComponentSource notifies Data Subjects covered by this Privacy Policy about its data practices regarding Personal Data received by ComponentSource in the U.S. from the United Kingdom or European Union member countries in reliance on the DPF, including the types of Personal Data it collects about them, the purposes for which it collects and uses such Personal Data, the types or identities of third parties to which it discloses such Personal Data and the purposes for which it does so (for example, software publishers for purposes of license registrations and to facilitate receipt of software updates and support, financial organisations for the purpose of payment processing, and authorities responsible for export compliance checks), the rights of Data Subjects to access their Personal Data, the choices and means that ComponentSource offers for limiting its use and disclosure of such Personal Data, how ComponentSource obligations under the DPF are enforced, and how Data Subjects can contact ComponentSource with any inquiries or complaints.

2. Choice

If Personal Data covered by this Privacy Policy is to be used for a new purpose that is materially different from that for which the Personal Data was originally collected or subsequently authorized, or is to be disclosed to a non-agent third party, ComponentSource will provide Data Subjects with an opportunity to choose whether to have their Personal Data so used or disclosed. Requests to opt out of such uses or disclosures of Personal Data should be sent to dpm@componentsource.com If Sensitive Personal Data covered by this Privacy Policy is to be used for a new purpose that is different from that for which the Personal Data was originally collected or subsequently authorized, or is to be disclosed to a third party, ComponentSource will obtain the Data Subject’s explicit consent prior to such use or disclosure.

3. Accountability for Onward Transfer

In the event we transfer Personal Data covered by this Privacy Policy to a third party acting as a data controller, we will do so consistent with any notice provided to Data Subjects and any consent they have given, and only if the third party has given us contractual assurances that it will (i) process the Personal Data for limited and specified purposes consistent with any consent provided by the Data Subjects, (ii) provide at least the same level of protection as is required by the DPF Principles and notify us if it makes a determination that it cannot do so; and (iii) cease processing of the Personal Data or take other reasonable and appropriate steps to remediate if it makes such a determination. If ComponentSource has knowledge that a third party acting as a data controller is processing Personal Data covered by this Privacy Policy in a way that is contrary to the DPF Principles, ComponentSource will take reasonable steps to prevent or stop such processing.

With respect to third party transferees, we will transfer only the Personal Data covered by this Privacy Policy needed for a third party to deliver to ComponentSource the requested product or service. Furthermore, we will (i) permit the third party to process such Personal Data only for limited and specified purposes; (ii) require the third party to provide at least the same level of privacy protection as is required by the DPF Principles; (iii) take reasonable and appropriate steps to ensure that the third party effectively processes the Personal Data transferred in a manner consistent with ComponentSource obligations under the DPF Principles; and (iv) require the third party to notify ComponentSource if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the DPF Principles. Upon receiving notice from a third party that it can no longer meet its obligation to provide the same level of protection as is required by the DPF Principles, we will take reasonable and appropriate steps to stop and remediate unauthorized processing.

ComponentSource remains liable under the DPF Principles if a third party processes Personal Data covered by this Privacy Policy in a manner inconsistent with the DPF Principles, except where ComponentSource is not responsible for the event giving rise to the damage.

4. Security

ComponentSource takes reasonable and appropriate measures to protect Personal Data covered by this Privacy Policy from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the processing and the nature of the Personal Data.

5. Data Integrity and Purpose Limitation

ComponentSource limits the collection of Personal Data covered by this Privacy Policy to information that is relevant for the purposes of processing. ComponentSource does not process such Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the Data Subject.

ComponentSource takes reasonable steps to ensure that such Personal Data is reliable for its intended use, accurate, complete, and current. ComponentSource takes reasonable and appropriate measures to comply with the requirement under the DPF to retain Personal Data in identifiable form only for as long as it serves a purpose of processing or ComponentSource business purposes unless a longer retention period is permitted by law, and it adheres to the DPF Principles for as long as it retains such Personal Data.

6. Access

Data Subjects whose Personal Data is covered by this Privacy Policy have the right to access such Personal Data and to correct, amend, or delete such Personal Data if it is inaccurate or has been processed in violation of the DPF Principles (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the Data Subject’s privacy, or where the rights of persons other than the Data Subject would be violated). Requests for access, correction, amendment, or deletion should be sent to dpm@componentsource.com

7. Recourse, Enforcement, and Liability

ComponentSource participation in the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF is subject to the regulatory enforcement of the U.S. Federal Trade Commission.

In compliance with the DPF Principles, ComponentSource commits to resolve complaints about your privacy and our collection or use of your Personal Data. Data Subjects with inquiries or complaints regarding this Privacy Policy should first contact ComponentSource at dpm@componentsource.com

ComponentSource has further committed to refer unresolved privacy complaints under the DPF Principles to an independent dispute resolution mechanism, either the DPAs or the ICO as applicable. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://ico.org.uk for more information and to file a complaint.

Under certain conditions detailed in the DPF, Data Subjects may be able to invoke binding arbitration before the DPF Panel.

ComponentSource agrees to periodically review and verify its compliance with the DPF Principles, and to remedy any issues arising out of failure to comply with the DPF Principles.

ComponentSource acknowledges and advises that its failure to provide an annual self-certification to the U.S. Department of Commerce will cause it to be removed from the Department’s official list of DPF participants.

Changes to this DPF Privacy Policy

This Privacy Policy may be amended from time to time consistent with the requirements of the DPF. Appropriate notice regarding such amendments will be given.

CS DPF Privacy Policy 09/2023