- What Personal Information We Collect
- How We Collect Personal Information
- How We Use Information We Collect
- Marketing Purposes
- Who We Share Information With
- Cross Border Data Transfer
- General Principles for Processing of Personal Information
- Cookies and Other Similar Technology
- Third Party Tracking and Online Advertising
- Social Media Features
- Security of Personal Information
- Access to Personal Information
- The Right To Object
- Retention Period
- Additional Provisions
- Compliance with Local Laws
- Sensitive Information
This Privacy Statement is effective as of April 1, 2020. If you would like to review a previous version of this Privacy Statement, please contact us at firstname.lastname@example.org.
This Privacy Statement explains how DLT, a Tech Data company ("DLT") is 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 personal information that we collect about you.
This Privacy Statement also describes the choices available to you regarding DLT’s use of your personal information, the steps you can take to access your information and to request that we correct or delete your personal information.
This Privacy Statement applies to DLT websites, applications and services that link to this Privacy Statement (collectively, the "Services").
If you have questions or concerns regarding this Privacy Statement or our handling of your information collected under this Privacy Statement, contact DLT's Privacy Office at email@example.com.
What Personal Information We Collect
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:
- Full Name
- Email address
- Postal address (Including billing and shipping address)
- Telephone number
- Fax number
- Bank information
- Payment card number
- User name and password
- Video recordings (CCTV at our offices and warehouses)
How We Collect Personal Information
Directly From You
DLT may collect personal information you provide directly to us via websites, mobile applications, email, EDI, and other interactions. For example, DLT may collect personal information 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 application installed on a device, post on our Services, or subscribe to notifications.
When you register with DLT, 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, 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 will need to choose a user name and password to administer your account and place online orders. We keep a record of purchases or orders placed on your account. 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
DLT may automatically collect personal information for business-related purposes, such as 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.
Personal Information Collected from Other Sources
DLT 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 for statistical purposes.
If required, we will obtain authorization from the applicable data protection authorities prior to processing personal information in accordance with applicable law. We may 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. For example, we may receive information about you from others within your organization, or from our business partners or affiliates we work with to provide our products and services.
DLT may contract with third parties who provide information to businesses to verify certain information about you or obtain information about you. We may use the personal information received from a third party in accordance with the terms established between Tech Data and the third party.
We may also obtain your personal data from the CCTV cameras located in the offices and warehouses of the Tech Data companies. Such video recordings are stored for a maximum of 30 days. The purpose of the video recordings is the protection of our property, prevention and detection of criminal activity and the protection of health and life of our employees/clients.
How We Use Information We Collect
DLT 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 perform a contract;
- To comply with a legal obligation to which DLT is subject;
- To facilitate, manage, personalize and improve your online experience;
- To respond to your inquiries and fulfill your requests;
- 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 about our products, Services, and events we believe may be of interest to you in accordance with applicable law or based on your consent thereto; and
- If ownership or control of any portion of DLT is made 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 are a user from the United States, DLT may use your personal information for direct marketing purposes. You may unsubscribe from marketing emails by following the unsubscribe instructions contained in such emails, or you may contact us at firstname.lastname@example.org if you do not want your personal information to be used for these purposes. You may also unsubscribe to an email communication by filling out this form.
If you are a user from outside of the United States, DLT may contact you, for example by email or by telephone to inform you about our range of products or Services similar to what you ordered from us so far or based on your explicit consent. You reserve the right at any time to refuse to allow your personal information (email address, telephone number) to be used for this purpose (object to processing) or withdraw your consent if applicable and we will emphasize this option every time you are contacted for marketing purposes. If you do not want your personal information to be used for this purpose, please update the preferences options made available to you, if any, or submit your request to us at email@example.com.
Who We Share Information With
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;
- As necessary with our affiliates, business partners and other third parties as needed to fulfill your transaction or request, to satisfy a contractual obligation, to provide our services, or for other operational or business purposes;
- If you agree, with our subsidiaries, affiliates, business partners, and other third parties for their own business purposes, which could include marketing to you, consistent with applicable laws and your preferences or instructions. 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 DLT engages third-party service providers, the disclosure of personal information to such providers is necessary, for example, to provide our Services to you. DLT 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. If the service provider is located in a country other than your country of residence, we warrant that appropriate safeguards are in place to ensure lawful and secure transfer of your personal information.
To receive an export of your data, please fill out the form on the Data Export Request page.
To be forgotten, please fill out the form on the Right to Erasure page.
Cross Border Data Transfer
Transfer of your personal information to third parties may take place 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 law. For example, if personal information is transferred from a member state of the European Economic Area/European Union or Switzerland to another country deemed to not provide an adequate level of protection according to European Commission, we implement appropriate contractual safeguards, such as Model Clauses, with such third parties or apply other appropriate safeguards as approved by the European Commission. Further, if such third parties engage sub-processors in support of our agreement with them, the third party will be required to implement the same standards and safeguards with their sub-contractors.
General Principles for Processing of Personal Information
Personal information will be collected, stored, processed and transmitted in accordance with DLT’s established policies and applicable laws.
The principles of DLT 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 as up to date as is reasonably 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 will provide notice of these changes, the purposes for which the personal information will be used, and the recipients of personal information.
Cookies and Other Similar Technology
We, and our third-party partners, may automatically collect certain types of usage information when you visit our Services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, flash objects, web beacons and similar technology (collectively, “tracking technologies”). For example, we collect information about your device and its software, such as your IP address, browser type, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your user account, and other such information. Depending on your browser or device settings, we may collect your location data, including GPS coordinates or we may approximate your device’s location based on other information, such as an IP address. We also collect information about the way you use our Services, for example, the site from which you came and the site to which you are going when you leave our Services, the pages you visit, the links you click, how frequently you access the Services, whether you open emails or click the links contained in emails, whether you access the Services from multiple devices, and other actions you take on the Services. We may collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.
We use or may use the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit our Services; (b) provide custom, personalized content and information, including targeted content and advertising; (c) recognize and contact you across multiple devices; (d) provide and monitor the effectiveness of our Services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Services; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our Services.
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Services, as some features on our Services may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies, you may not be able to block non-cookie technologies or the changes to your settings may have no effect. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it.
Third Party Tracking and Online Advertising
Interest Based Advertising. We participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on your browsing history. We may share, or we may permit third-party online advertising networks, social media companies and other third-party services, to collect, information about your use of our Services over time so that they may play or display ads on our Services, on other devices you may use, and on other websites, apps or Services. These third parties may collect information such as click stream information, browser type, time and date you visited the Services, mobile device identifiers, your use of third-party applications, and/or precise geolocation data and other information. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related Services such as reporting, attribution, analytics and market research.
Cookies. Most browsers allow you to adjust your browser settings to: (i) notify you when you receive a cookie, which lets you choose whether to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Blocking or deleting cookies may negatively impact your experience using the Services, as some features and services on our Services may not work properly.
Interest-based advertising. To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at https://www.aboutads.info/choices.
Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use. Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.
Mobile advertising. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting "limit ad tracking" (iOS) or "opt-out of interest based ads" (Android). You may also be able to opt-out of some — but not all — interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
Social Media Advertising. We may display targeted advertising to you through social media platforms, such as Facebook, LinkedIn and others. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our Services while those users are on the social media platform, or to groups of other users who share similar traits, such as commercial interests and demographics. These advertisements are governed by the privacy policies of the social media companies that provide them and you can control your advertising preferences directly on those platforms.
Google Analytics and Advertising. We use Google Analytics to recognize you and link the devices you use when you visit our Services on your browser or mobile device, login to a user account on our Services, or otherwise engage with us. Google Analytics allows us to better understand how our users interact with our Services and to tailor our advertisements and content to you. We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics and Demographic and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Double-click advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Services. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's site “How Google uses data when you use our partners' sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On, here: https://tools.google.com/dlpage/gaoptout/. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by visiting NAI's online resources at http://www.networkadvertising.org/choices.
Social Media Features
DLT provides social media features that enable you to share information with your social networks and to interact with Tech Data on various social media sites. These providers may recognize you and collect information about your visit to our Services, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies. We encourage you to review the privacy policies and settings on the social media sites you use to interact to make sure you understand the information that may be collected, used, and shared by those sites. You may disable these features at any time.
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 laws) 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, unless prohibited by applicable law.
Access to Personal Information
In accordance with the applicable data privacy law, you may be entitled to request certain information about the personal data we have stored about you; to request certain access to, correction, deletion, portability or blocking of such data, and 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 firstname.lastname@example.org.
If you need to update or change your personal information changes, you may log into your account or you may contact us at email@example.com.
DLT 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 verify your identity by requiring sufficient information to allow it to confirm the identity of the party making the request before granting access or making corrections.
The Right To Object
According to the Article 21 of the General Data Protection Regulation No. 2016/679 you have, among others, the right to object to the processing of the personal data if we process your personal data on the basis of a legitimate interest, including the processing for the purposes of direct marketing. The objection can be filed at the e-mail address: firstname.lastname@example.org. In case that you object to the processing for direct marketing purposes, the personal data shall no longer be processed in this scope.
More information about this right can be found particularly in the Article 21 of the General Data Protection Regulation No. 2016/679.
We retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Statement or otherwise upon collection of your personal data, unless a longer retention period is required or allowed by law or to otherwise fulfill a legal obligation.
We do not knowingly collect information from children as defined by local law, and do not target our websites to children.
Your Consent and Changes
You have a right to withdraw your consent with processing of your personal data (if given) at any time at the e-mail address: email@example.com. Please note that the withdrawal of your consent does not affect the lawfulness of the processing based on your consent given before its withdrawal. The withdrawal of your consent also does not affect the processing of your personal data which is being done by us on another legal basis than your consent (e.g., in particular if the processing is necessary for the performance of a contract, fulfillment of a legal obligation or due to other reasons stated in the valid legal regulation).
DLT may supplement this Privacy Statement with additional information relating to a particular interaction you may have with us.
DLT 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.
California Privacy Rights
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 unsubscribing from such material or sending an email to firstname.lastname@example.org.
Compliance with Local Laws
This Privacy Statement is meant to guide DLT with respect to personal information collected from or about you. While this Policy 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.
Unless we specifically request or invite you to provide sensitive personal information to us as defined by applicable law, we ask that you not send us such information. In cases where we may request or invite you to provide sensitive personal information, we will only process sensitive personal information you provide with your express consent.
DLT uses 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, raise your concerns by contacting us at email@example.com.
If you have any questions or concerns about this Privacy Statement, the privacy practices of DLT, our collection or use of your personal information, or you wish to access your personal information, please contact us. If we need or are required to contact you concerning any issue or event that involves this Privacy Statement, then we will do so using the email address, telephone number, or physical mailing address we have on file for you.
Updates to This Privacy Statement
We will update this Privacy Statement from time to time. When we make changes to this Privacy Statement, we will change the effective date in the "Introduction" section of this Privacy Statement. If we make material changes to this Privacy Statement, we will notify you by emailing the email address we have on file for you, by prominent posting on this website or our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.
If you have any questions or requests in connection with this Privacy Statement or other privacy-related matters, please send an email to firstname.lastname@example.org.
Alternatively, inquiries may be addressed to:
DLT, a Tech Data Company
2411 Dulles Corner Park
Herndon, VA 20171
This Privacy Statement was last amended on April 1, 2020.