Data Protection //

1. Data Protection Overview 


General Information 
The data protection details provide an understanding of how your personal data is processed when you visit and use this website, initiate and conclude a contract with us, and use our services or context of marketing measures by SIMPAC America Co. Ltd. and its affiliated companies in accordance with the EU General Data Protection Regulation (GDPR). Personal data is all data for which you can be personally identified. Detailed information on the subject of data protection can be found within our Data Protection Declaration listed below this text. Definitions of the terms used (e.g., "personal data" or "processing") can be found in Art. 4 GDPR. 

Website Data Recording 
Who is the responsible party for the recording of data on this website (i.e., the “controller”)? 
The data on this website is processed by the operator of the website, whose contact information is available within the section “Information Required by Law” on this website. 

How do we record your data? 
We collect your data as a result of your agreement to share your data with us. This may, for instance, be information you entered into our contact form. 
Our IT systems automatically record other data when you visit our website. This data comprises technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically once you access our website. 

What are the purposes of data collection? 
A portion of the information is generated to guarantee the error-free provision of the website. Other data may be used to analyze your user patterns. 

What rights do you have as far as your information is concerned? 
In accordance with the GDPR, you have the right to obtain information about the origin, recipient, and purpose of your stored personal data at any time and at no cost. You also have the right to request the correction, blocking, or deletion of this data. You can contact us at any time at the address provided within the Imprint regarding your information or other questions relating to data protection. Furthermore, you have the right to appeal to the competent supervisory authority. 
You also have the right, under certain circumstances, to request that your personal data be restricted. Details on this can be found within the data protection declaration under "Right to Restriction of Processing." 
If you assert your rights against us, then we will process your personal data collected in order to respond to your inquiry. Your personal data is processed to fulfill a legal obligation on the basis of Art. 6 Sect. 1c GDPR. 

Analysis Tools & Tools Provided by Third Parties 
There is a possibility that your browsing patterns will be statistically analyzed when you visit our website. Such analyses are performed primarily with cookies and with what we refer to as analysis programs. As a rule, the analyses of your browsing patterns are conducted anonymously (i.e., the browsing patterns cannot be traced back to you). You have the option to object to such analyses or you can prevent the performance by not using certain tools. For detailed information about this, please consult our Data Protection Declaration below.

2. General & Mandatory Information 


Data Protection 
The operators of this website and its pages take the protection of your personal data very seriously. As such, we handle your personal data as confidential information and in compliance with the statutory Data Protection Regulations and Data Protection Declaration. 
Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes of this data collection. It also explains how, and for what purpose, the information is collected. 
We hereby inform you that the transmission of data via the Internet (i.e., through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third party access. 

Information About Responsible Party (“Controller”) 
The data processing controller on this website is: 
SIMPAC America Co. Ltd.
850 Stephenson Hwy, Ste 305
Troy, MI 48083

President, North American Operations
Yonghwan Kim

Telephone: +1 248-607-3998
E-mail: yhkim@simpac.com 

The controller is the natural person or legal entity that single-handedly, or jointly with others, makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.). 

Revocation of Your Data Processing Consent 
A wide range of data processing transactions are possible only through your consent. You can also revoke any consent you have already given us at any time. To do so, all you are required to do is send us an informal notification via e-mail. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation. 

Right to Object to Data Collection in Special Cases/Right to Object to Direct Advertising (Art. 21 GDPR) 
In the event that data is processed on the basis of Art. 6 Sect. 1 lit. e or f GDPR, you have the right to object to the processing of your personal data based on grounds arising from your unique situation at any time. This also applies to any profiling based on these provisions. To determine the legal basis, on which any processing of data is based, please consult this Data Protection Declaration. If you log an objection, then we will no longer process your affected personal data, unless we are in a position to present compelling protection worthy grounds for the processing of your data that outweigh your interests, rights, and freedoms, or if the purpose of the processing is the claiming, exercising, or defense of legal entitlements (objection pursuant to Art. 21 Sect. 1 GDPR). 
If your personal data is being processed in order to engage in direct advertising, then you have the right to object to the processing of your affected personal data for the purposes of such advertising at any time. This also applies to profiling to the extent that it is affiliated with such direct advertising. If you object, then your personal data will subsequently no longer be used for direct advertising purposes (objection pursuant to Art. 21 Sect. 2 GDPR). 

Right to Log a Complaint with the Competent Supervisory Agency 
In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular to the member state for which they usually maintain their domicile, place of work, or the place where the alleged violation occurred. The right to log a complaint is in effect, regardless of any other administrative or court proceedings available, as legal recourse. 

Right to Data Portability 
You have the right to demand that we hand over any data we automatically process, on the basis of your consent, or a machine-readable contract that a third party commonly used. If you should demand the direct transfer of the data to another controller, then this will only be done if it is technically feasible. 

SSL/TLS Encryption 
This website uses either an SSL or a TLS encryption program for security purposes in order to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator. You can recognize an encrypted connection by the address line of the browser as it switches from “http://” to “https://,” or by the appearance of the lock icon within the browser. 
If the SSL or TLS encryption is activated, then the data you transmit to us cannot be read by third parties. 

Information About Blockage, Rectification, and Eradication of Data 
Within the scope of the applicable statutory provisions, you have the right to demand information about your archived personal data, its source and recipients, and its purpose at any time. You can also have your data rectified, blocked, or eradicated. If you have questions about this subject matter or any other questions about personal data, then please do not hesitate to contact us at any time at the address provided within the section “Information Required by Law.” 

Right to Demand Processing Restrictions 
You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time at the address provided within the section “Information Required by Law.” The right to demand restriction of processing applies in the following cases: 
  • In the event that you should dispute the correctness of your data archived by us, we will typically need some time to verify this claim. During the time of this investigation, you have the right to demand that we restrict the processing of your personal data. 
  • If the processing of your personal data was/is conducted in an unlawful manner, then you have the option to demand the restriction of the processing of your data in lieu of demanding the eradication of this data. 
  • If we do not need your personal data any longer and you need it to exercise, defend, or claim legal entitlements, then you have the right to demand the restriction of the processing of your personal data instead of its eradication. 
  • If you have raised an objection pursuant to Art. 21 Sect. 1 GDPR, then your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data. 
  • If you have restricted the processing of your personal data, then the data – with the exception of its archive – may be processed only via your consent or to claim, exercise, or defend legal entitlements, protect the rights of other natural persons or legal entities, or for important public interest reasons cited by the European Union or a member state of the EU. 

Rejection of Unsolicited E-mails 
We hereby object to the use of contact information published in conjunction with mandatory information, to be provided within the section “Information Required by Law,” as a means to send us promotional and informational material that we have not expressly requested. The operators of this website and its pages reserve the right to take legal action in the event of any unsolicited sending of promotional information such as SPAM messages.

3. Data Protection Officer 


Designation of a Data Protection Officer as Mandated by Law 
We have appointed a data protection officer for our company: 
SIMPAC America Co. Ltd.
850 Stephenson Hwy, Ste 305
Troy, MI 48083

General Manager/VP of Sales & Operations
Stephan Robertson
 
Telephone: +1 248-607-3998
E-mail: s.robertson@simpac.com


4. Recording of Data on Our Website 


Cookies 
In some instances, our website and its pages use cookies. Cookies do not cause any damage to your computer and do not contain viruses. The purpose of cookies is to make our website more user-friendly, effective, and secure. Cookies are small text files that are placed on your computer and stored by your browser. 
Most of the cookies we use are “session cookies.” They are automatically deleted after you leave our site. Other cookies will remain archived on your device until you delete them. These cookies enable us to recognize your browser the next time you visit our website. 
You can adjust the settings of your browser to make sure that you are notified every time cookies are placed. You can enable the acceptance or exclusion of cookies for specific purposes, or in general, and you can also activate the automatic deletion of cookies once you close your browser. If you deactivate cookies, then the functions of this website may be limited. 
Cookies that are required for the performance of electronic communication transactions, or to provide certain functions you want to use (e.g., the shopping cart function), are stored on the basis of Art. 6 Sect. 1 lit. f GDPR. The website operator has a legitimate interest in storing cookies to ensure the technically error-free and optimized provision of services. If other cookies (e.g., cookies for the analysis of your browsing patterns) should be stored, then they are addressed separately within this Data Protection Declaration. 

Server Log Files 
The provider of this website and its pages automatically collects and stores information via server log files, for which your browser communicates to us automatically. The information comprises: 
  • The type and version of browser used. 
  • The used operating system. 
  • Referrer URL. 
  • The hostname of the accessing computer. 
  • The time of the server inquiry. 
  • The IP address. 
This data is not merged with other data sources. 
This data is recorded on the basis of Art. 6 Sect. 1 lit. f GDPR. The operator of the website has a legitimate interest in the technically error-free depiction and optimization of the website. In order to achieve this, server log files must be recorded. 

Contact Form 
If you submit inquiries to us via our contact form, then the information provided within the contact form, as well as any contact information provided therein, will be stored by us in order to handle your inquiry. The data is also stored for any further questions the operator needs answered. We will not share this information without your consent. 
As such, the processing of the data entered into the contact form occurs exclusively based on your consent (Art. 6 Sect. 1 lit. a GDPR). You have the right to revoke any consent you have already given us at any time. To do so, all you are required to do is send us an informal notification via e-mail. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation. 
The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data, or update the data if the purpose for which the information is being archived no longer exists (e.g., after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions – in particular, retention periods. 

Processing Data 
We collect, process, and use personal data only to the extent necessary for the establishment, content organization, or change of the legal relationship (data inventory). These actions are taken on the basis of Art. 6 Sect. 1 lit. b GDPR, which permits the processing of data for the fulfillment of a contract or pre-contractual actions. We collect, process, and use personal data concerning the use of our website (usage data) only to the extent that is necessary to make it possible for users to utilize the services and to bill for them. 
The collected customer data shall be eradicated upon completion of the order or the termination of the business relationship. This shall be without prejudice to any statutory retention mandates. 

Category of Recipients of Your Personal Data 
We transfer your personal data to external parties in the form of order processing, as well as to third parties for which they conduct further processing. Furthermore, we transfer data within the framework of an internal company process relating to the division of labor for the preparation, implementation and, if applicable, processing of your purchase or service contract and, if applicable, for the processing and handling of your inquiries within the SIMPAC Group. The transfer is carried out on the basis of our legitimate interest in efficient internal administrative activities on the basis of Art 6 Sect. 1 lit. f GDPR.

5. Social Media 


Social Media Plug-ins with Shariff 
We do use plug-ins of social media networks on our website and its pages (e.g., Facebook, Twitter, Instagram, LinkedIn, etc.). 
As a rule, you will be able to recognize these plug-ins by their respective social media logos. To warrant the protection of data on our website, we use these plug-ins only in combination with the “Shariff” solution. This application prevents the plug-ins that have been integrated into our website from transferring data to the respective provider as soon as you enter our website. 
A direct connection to the provider's server shall not be established until you have activated the respective plug-in by clicking on the affiliated button (indicating your consent). As soon as you activate the plug-in, the respective provider receives the information that you have visited our website with your IP address. If you are simultaneously logged into your respective social media account (e.g., Facebook), then the respective provider will be able to allocate your visit to our website to your user account. 
The activation of the plug-in constitutes a declaration of consent as defined in Art. 6 Sect. 1 lit. a GDPR. You have the option to revoke this consent at any time, which shall affect all future transactions. 

Facebook Plug-ins (Like & Share Buttons) 
We have integrated Facebook plug-ins, provided by Facebook Inc., 1 Hacker Way, Menlo Park, California 94025, USA, on our website. You will be able to recognize Facebook plug-ins by the Facebook logo or the "Like" button on our website. An overview of the Facebook plug-in is available via the following link: https://developers.facebook.com/docs/plugins/. 
Whenever you visit our website and its pages, the plug-in will establish a direct connection between your browser and the Facebook server. As a result, Facebook will receive the information that you have visited our website with your plug-in. However, if you click the Facebook “Like” button while you are logged into your Facebook account, then you can link the content of our website and its pages with your Facebook profile. As a result, Facebook will be able to allocate the visit to our website and its pages to your Facebook user account. We, as the provider of the website, do not have any knowledge of the transferred data and its use by Facebook. For more detailed information, please consult the Data Privacy Declaration of Facebook at: https://www.facebook.com/privacy/explanation. 
If you do not want Facebook to be able to allocate your visit to our website and its pages to your Facebook user account, then please log out of your Facebook account while you are on our website. 
The use of the Facebook plug-in is based on Art. 6 Sect. 1 lit. f GDPR. The operator of the website has a legitimate interest in being as visible as possible on social media. 

Twitter Plug-ins 
We have integrated functions of the social media platform Twitter on our website. These functions are provided by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. While you use Twitter and the "Re-Tweet" function, websites you visit are linked to your Twitter account and disclosed to other users. During this process, data is transferred to Twitter as well. We, the providers of the website and its pages, do not know anything about the content of the data transferred or the use of this information by Twitter. For more details, please consult Twitter’s Data Privacy Declaration at: https://twitter.com/en/privacy. 
The use of Twitter plug-ins is based on Art. 6 Sect. 1 lit. f GDPR. The operator of the website has a legitimate interest in being as visible as possible on social media. 
You have the option to reset your data protection settings on Twitter under the account settings at https://twitter.com/account/settings. 

LinkedIn Plug-ins 
Our website uses functions of the LinkedIn network. The provider is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. 
Any time you access one of our sites that contains functions of LinkedIn, a connection to LinkedIn’s servers is established. LinkedIn is notified that you have visited our websites with your IP address. If you click on LinkedIn’s "Recommend" button and are logged into your LinkedIn account at the time, LinkedIn will be in a position to allocate your visit to our website to your user account. We, as the provider of the website, do not have any knowledge of the content of the transferred data or its use by LinkedIn. 
The use of the LinkedIn plug-in is based on Art. 6 Sect. 1 lit. f GDPR. The operator of the website has a legitimate interest in being as visible as possible on social media. 
For further information on this subject, please consult LinkedIn’s Data Privacy Declaration at: https://www.linkedin.com/legal/privacy-policy.

6. Analysis Tools & Advertising 


Google Analytics 
This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. 
Google Analytics uses cookies. Cookies are text files, which are stored on your computer and enable an analysis of the use of our website by users. The information generated by cookies regarding your use of this website is usually transferred to a Google server in The United States of America, where it is stored. 
The storage of Google Analytics cookies, and the utilization of this analysis tool, is based on Art. 6 Sect. 1 lit. f GDPR. The operator of this website has a legitimate interest in the analysis of user patterns to optimize both the services offered online and the operator’s advertising activities. 

IP Anonymization 
On this website, we have activated the IP anonymization function. As a result, your IP address will be abbreviated by Google within the member states of the European Union or in other states that have ratified the Convention of the European Economic Area prior to its transmission to The United States of America. The full IP address will be transmitted to one of Google’s servers in The United States of America and abbreviated there only in exceptional cases. On behalf of the operator of this website, Google shall use this information to analyze your use of this website to generate reports on website activities and render other services to the operator of this website in relation to the use of the website and Internet. The IP address transmitted in conjunction with Google Analytics from your browser shall not be merged with other data in Google’s possession. 

Browser Plug-ins 
You do have the option to prevent the archiving of cookies by making pertinent changes to the settings of your browser software. However, we have to point out that, in this case, you may not be able to use all of the functions of this website to the fullest extent. Moreover, you have the option to prevent the recording of the data generated by the cookies and affiliated with your use of the website (including your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en. 

Objection to the Recording of Data 
You have the option to prevent Google Analytics from recording your data. This will result in the placement of an opt-out cookie, which prevents the recording of your data during future visits to this website. 
For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en. 

Contract Data Processing 
We have executed a contract in the form of a data processing agreement with Google, and we are implementing stringent provisions of North American data protection agencies when using Google Analytics. 

Demographic Parameters Provided by Google Analytics 
This website uses the function “demographic parameters,” provided by Google Analytics. It makes it possible to generate reports providing information on the age, gender, and interests of website visitors. The sources of this information are interest-related advertising by Google as well as visitor data obtained from third party providers. This data cannot be allocated to a specific individual. You have the option to deactivate this function at any time by making pertinent settings changes of advertising within your Google account, or you can generally prohibit the recording of your data by Google Analytics as explained within the section “Objection to the Recording of Data.”

7. Newsletter 


Newsletter Data 
If you would like to subscribe to the newsletter offered on this website, then we will need an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and consent to the receipt of newsletters. No further data shall be collected, unless provided voluntarily. We shall use such data only for the sending of requested information and shall not share such data with any third parties. 
The processing of the information entered into the newsletter subscription form shall occur exclusively on the basis of your consent (Art. 6 Sect. 1 lit. a GDPR). You may revoke the consent you have given to the archiving of data, the e-mail address, and the use of this information for the distribution of newsletters at any time (e.g., by clicking on the "Unsubscribe" link within the newsletter). This shall be without prejudice to the lawfulness of any data processing transactions that have taken place to date. 
The data you provide, for the purpose of the newsletter subscription, shall be archived by us until you unsubscribe from the newsletter. Once you cancel your subscription to the newsletter, the data shall be deleted. This shall not affect data we have been archiving for other purposes. 

Klaviyo 
This website uses Klaviyo for the sending of newsletters. The provider is Klaviyo, 125 Summer Street, Floor 6, Boston, MA, 02111 USA. 
Klaviyo services can be used to organize and analyze the sending of newsletters among other things. The data you enter for the purpose of subscribing to the newsletter is archived on Klaviyo servers in The United States of America. 
If you do not want to permit an analysis by Klaviyo, then you must unsubscribe from the newsletter. We provide a link for you to do this within every newsletter. Moreover, you can also unsubscribe from the newsletter right on the website. 

Data Analysis by Klaviyo 
For analytical purposes, e-mails sent via Klaviyo are tagged with a “Tracking Pixel,” which connects to Klaviyo’s servers once the e-mail is opened. As a result, it is possible to determine whether a newsletter e-mail was actually opened. 
With the assistance of Klaviyo, we are also able to determine which links within the newsletter have been clicked by the recipient. All links integrated into the e-mail contain “Tracking Links” that enable us to count your clicks. 
For more details on Klaviyo’s analysis functions, please follow this link: https://www.klaviyo.com/privacy/policy. 

Legal Basis 
The data is processed based on your consent (Art. 6 Sect. 1 lit. a GDPR). You may revoke any consent you have given us at any time by unsubscribing from the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place prior to your revocation. 

Storage Period 
The data you archive with us for the purpose of the newsletter subscription shall be archived by us until you unsubscribe from the newsletter. Once you cancel your subscription to the newsletter, the data shall be deleted from our servers. This shall not affect data we have been archiving for other purposes. 
For more details, please consult Klaviyo’s Data Protection Addendum at: https://www.klaviyo.com/privacy/dpa.

8. Plug-ins & Tools 


YouTube 
Our website uses plug-ins of the YouTube platform, which is operated by Google. The website operator is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. 
If you visit a page on our website for which a YouTube plug-in has been integrated, then a connection with YouTube’s servers will be established. As a result, the YouTube server will be notified about which webpages you visited. 
Furthermore, YouTube will be able to place various cookies on your device. With the assistance of these cookies, YouTube will be able to obtain information about our website visitor. Among other things, this information will be used to generate video statistics with the aim of improving the user friendliness of the site and prevent attempts to commit fraud. These cookies will stay on your device until you delete them. 
If you are logged into your YouTube account while you visit our site, then you enable YouTube to directly allocate your browsing patterns to your personal profile. You have the option to prevent this by logging out of your YouTube account. 
The use of YouTube is based on our interest in presenting our online content in an appealing manner. Pursuant to Art. 6 Sect. 1 lit. f GDPR, this is a legitimate interest. 
For more information on how YouTube handles user data, please consult the YouTube Data Privacy Policy under: https://policies.google.com/privacy?hl=en. 

Google Web Fonts 
To ensure that fonts used on this website are uniformed, this website uses “Web Fonts” provided by Google. When you access a page on our website, your browser will load the required web fonts into your browser cache to correctly display text and fonts. 
To do this, the browser you use will have to establish a connection with Google’s servers. As a result, Google will learn that your IP address was used to access our website. The use of Google Web Fonts is based on our interest in presenting our online content in a uniformed and appealing way. According to Art. 6 Sect. 1 lit. f GDPR, this is a legitimate interest. 
If your browser should not support Web Fonts, then a standard font installed on your computer will be used. 
For more information on Google Web Fonts, please follow this link: https://developers.google.com/fonts/faq and consult Google’s Data Privacy Declaration: https://policies.google.com/privacy?hl=en. 

Google Maps 
Via an API, this website uses the mapping service Google Maps. The provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. 
To enable the use of Google Maps' features, your IP address must be stored. As a rule, this information is transferred to one of Google’s servers in The United States of America, where it is archived. The operator of this website has no control over the data transfer. 
We use Google Maps to present our online content in an appealing manner and to make the locations disclosed on our website easy to find. This constitutes a legitimate interest as defined in Art. 6 Sect. 1 lit. f GDPR. 
For more information on the handling of user data, please review Google’s Data Privacy Declaration under: https://policies.google.com/privacy?hl=en. 

Modification of this Data Protection Declaration 
The provisions of this data protection information of SIMPAC America Co. Ltd. shall apply to this current and valid version. We reserve the right to amend and change the content of this data protection information. The updated data protection information is valid per its date of validity.