Semiconductor Club for Business Privacy Statement

This Semiconductor Club For Business Privacy Statement was updated on April 1, 2021.

In the course of providing Semiconductor Club for Business (“UFB”) services and related services to its corporate, non-profit organization and governmental customers (“Customers”), Semiconductor Club will receive and have access to personal data of individual users to whom customers grant access (“Users”). For the purposes of this privacy statement, Customers are data controllers and Semiconductor Club is a data processor. Semiconductor Club’s processing of User data and the security measures implemented to protect such data are detailed in and governed by a written agreement between Semiconductor Club and each of its Customers.

As a data processor, Semiconductor Club will access, store and use the personal data of individual Users solely for the purpose of providing the UFB services to its Customers and will process the data as instructed by its Customers.

As data controllers, Customers decide which of their employees or other authorized personnel are given access to the UFB services. They do this by designating one or more UFB account administrators or group administrators (“Administrator”) who act on behalf of the Customer and have the ability to customize the Customer account, manage individual User accounts, access the UFB Insights tool and related reporting features, access the UFB Administrator tools, and populate the Customer account with Customer-provided content. Customers are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, relating to the collection of personal information relating to individual Users selected by Customers for accessing the UFB services. Semiconductor Club has no direct relationship with individual Users, who should contact Customers (their employer) for assistance with any requests or questions relating to the processing of their personal information.

For avoidance of doubt, this Privacy Statement does not apply to:

any processing of data for the purpose of marketing the UFB service to enterprise and corporate prospects;

any other offerings available at Semiconductor Club.com separate from the UFB services, for which the Semiconductor Club Privacy Policy is applicable. A User may already have an account with Semiconductor Club to access Semiconductor Club’s marketplace educational content, and data processed as a result of the use of the Semiconductor Club marketplace from a User account is governed by the Semiconductor Club Privacy Policy.

In the event where Semiconductor Club makes any material changes to the manner in which it processes User data to provide its services to Customers, it will notify Customers.

Semiconductor Club for Business Privacy Statement

Information about Users collected and stored by Semiconductor Club

Purpose of User Data Processing and Retention Period

Cookies and other Tracking Technologies

Sharing User Information

Processing of User Data outside of the EEA

General

1. Information about Users collected and stored by Semiconductor Club

When a User is given access to the UFB services by the Administrator, a User may set up an individual User account and Semiconductor Club will collect information provided by the User or the Administrator. The Customer can customize the type of data requested to create an account, which may include the following:

first name, last name, and email address required

photo, areas of interest, job skills, goals, and role (optionally provided by User or Customer)

other personal data, as allowed by the Customer

A unique identifying number is assigned by Semiconductor Club upon the creation of a User account.

Individual User account information may be set to private or public, as selected by Users. If set to public, the information is searchable via search engines and viewable by anyone, including by other Users and the Customer.

Administrators may assign a User to a group membership.

Customers may select to integrate with UFB a Single Sign On (SSO) identity provider to enable Users to log in to UFB User accounts without the need to disclose passwords to Semiconductor Club. Users may log in by providing their individual SSO credentials to the SSO identity provider, which will authenticate them and allow or deny access to the Customer account. SSO identity providers share with Semiconductor Club a unique cookie ID and authentication “token” information to recognize the User as an authorized user of Customer.

At the option of the Customer, the UFB service may enable Administrators and Users to interact with others, including with instructors, teaching assistants, other students, and the Customer, by posting reviews about educational content, sending messages to or chatting with others, posting questions or answers, or posting other content. Posted content is stored by Semiconductor Club and may be publicly available or viewable by others, including Administrators, Users, or instructors and teaching assistants, depending on where the content is posted.

At the option of the Customer, Administrators may enable the ability to “Share to Slack.” This optional feature allows Users to manually or automatically post a message to the Customer’s own instance of the Slack messaging service. To enable this optional functionality, Customer’s Slack administrators must grant Semiconductor Club the ability to read the full list of public channels, private channels, and users in the Customer’s Slack instance. These lists may include individuals in Customer’s Slack instance who are not UFB Users. Slack user lists and channels are briefly cached before being automatically purged from Semiconductor Club’s systems.

Semiconductor Club stores information relating to the activities of Users as they use and interact with the UFB services, such as content viewed or accessed (and information relating to that content); interactions with instructors, teaching assistants, Administrators, and other Users; as well as answers, essays, and other items submitted by Users to satisfy the educational content requirements. This information is linked to a User’s unique account ID and is shared with Customers via the Customer Account reporting tools or upon request of the Customer.

The UFB service enables Users to contact the Semiconductor Club Support Team for assistance or to report a problem, concern, potential abuse or other issues regarding the UFB services or other users. Semiconductor Club may collect and store the User’s name, email address, location, operating system, IP address as well as the User’s activity on the Semiconductor Club platform and communications with the Semiconductor Club help desk team. Semiconductor Club may request additional information from Users in order to resolve any issue reported by a User or by another user.

When a User uses the UFB services, Semiconductor Club collects and stores certain information by automated means: (a) technical information about the User’s computer or wireless device, such as IP address, operating system type and version, unique device ID, browser, browser language, domain, and other operating systems or platform information. This information is collected through the use of server log files and tracking technologies, such as: (i) cookies, which are small files that websites send to a computer or wireless device to uniquely identify a browser or mobile device or to store information in a browser setting; and (ii) other tracking technologies (see below for more detailed information).

IP addresses received from browsers or devices of Users may be used to determine the approximate location of Users.

If a Customer makes purchases via credit card, Semiconductor Club collects certain data about the purchase (such as name and ZIP code) as necessary to process the order. Customers must provide certain payment and billing data directly to Semiconductor Club’s payment processing partners, including name, credit card information, billing address, and ZIP code. Semiconductor Club may also receive limited information, like the fact that Customers have a new card and the last four digits of that card, from payment service providers to facilitate payments. For security, Semiconductor Club does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.

2. Purpose of User Data Processing and Retention Period

Semiconductor Club processes the information collected about Users and Administrators for the purpose of providing the UFB services to its Customers, specifically:

Providing, administering, and facilitating access to the UFB services, for Customers and Users, and managing Customer or User account preferences

Fulfilling Customer’s instructions with respect to personal data of Users

Displaying and sending via email notifications to Users for:

Responding to User questions or concerns

Making notifications to Users at the request of the Customer

Sending Users administrative messages and information, including confirmation of account creation, enrollment and progress in courses and related content, and notifications of responses from instructions to User questions

Providing information to Users about available content, new UFB service features, and personalized content recommendations, which Users can opt out of at any time

Sending push notifications to User wireless devices to provide updates and other relevant messages, which can be managed from the “options” or “settings” page in the mobile application.

Enabling communications among Users and instructors or teaching assistants

Incorporating feedback into and improving the UFB services

Resolving User support requests or claims

Email Preferences

Users can individually opt out of receiving non-transactional emails by: (i) following the unsubscribe instructions provided in the email communication; or (ii) managing User account email preferences. A Customer can also instruct Semiconductor Club to configure email preference settings for all Users of a Customer.

Retention of Personal Data

Semiconductor Club will retain the data of Users for as long as instructed by the Customer and no longer than required to serve the purposes of processing. Semiconductor Club will delete certain or all personal data relating to Users upon request of the Customer. Semiconductor Club may retain aggregated or anonymized data as set forth below.

Use of aggregated data

In addition, User data is aggregated with other Semiconductor Club marketplace user data to enable Semiconductor Club to improve its products and services and develop new products and services, including:

Reviewing and analyzing User browser and wireless device technical information

Reviewing user activity across UFB and the Semiconductor Club marketplace (for example, Semiconductor Club analyzes trends and User traffic and usage information to identify popular content)

Facilitating the technical functioning of the UFB services and Semiconductor Club marketplace, including to troubleshoot and resolve issues, secure the UFB services, and prevent fraud and abuse

Developing a personalized content recommendation engine

When User data is used for the above purposes, it is aggregated and/or anonymized so that no personal data of Users is processed.

3. Cookies and other Tracking Technologies

Like many online platforms, Semiconductor Club and its analytics vendors use server log files and automated data collection tools, such as browser cookies, pixel tags, scripts, and web beacons. These tools are used for analytics purposes to enable Semiconductor Club to understand how Users interact with the UFB services. Semiconductor Club and its analytics vendors may tie the information gathered by these means to the unique account ID of Users.

Cookies are small text files placed onto a computer or device while browsing the Internet. Cookies are used to collect, store, and share bits of information about User activities. Semiconductor Club uses both session cookies and persistent cookies.

A session cookie is used to identify a particular visit to the UFB services and collect information about interaction with the UFB service. These cookies expire after a short time, or when the User closes their web browser after using the UFB service. Semiconductor Club uses these cookies to identify a User during a single browsing session, such as when you log into the UFB services. This helps Semiconductor Club improve the UFB service as well as improve the Users’ browsing experience.

A persistent cookie will remain on a User’s device for a set period of time specified in the cookie. Semiconductor Club uses these cookies to identify and recognize a specific User over a longer period of time. They allow Semiconductor Club to:

analyze the usage of the UFB services (e.g. what links Users click on) in order to improve our UFB offering,

test different versions of the UFB services to see which particular features or content Users prefer to optimize the UFB services

provide a more personalized experience to Users with more relevant and recommended content and

allow Users to more easily log in to use the UFB services. Persistent cookies include:

preferences cookies to remember information about a User’s browser and settings preferences, such as preferred language. Preference cookies make User experience more functional and customized

authentication and security cookies to enable a User to log in or stay logged in and access the UFB service, to protect User accounts against fraudulent log-ins by others, and help detect, fight, and protect against abuse or unauthorized usage of User accounts.

functional cookies to make the experience of using the UFB service better, like remembering the sound volume level selected by the User.

Semiconductor Club uses tracking technology to: (i) determine if a certain page was visited (e.g. the landing page of an advertisement for UFB services that is displayed on third party sites) or whether an email sent by Semiconductor Club was opened or clicked on by a User; and (ii) to customize the learning experience of individual Users by recommending specific courses and other content.

Cookie list

Semiconductor Club will retain the data of Users for as long as instructed by the Customer. Semiconductor Club will delete certain or all personal data relating to Users upon request of the Customer. Semiconductor Club may retain aggregated or anonymized data as set forth below.