Política de Privacidade

Last Updated: November 17, 2025

At SENKO Advanced Components, Inc. (SENKO), we are committed to protecting your privacy and handling your personal data with care. This Privacy Policy explains what information we collect and how we collect, use, store, and share such information when you interact with us, whether through our websites, products, services, or business activities.

SENKO acts as a data controller when we collect and process personal data directly – for example, when you visit our websites, use our products and services, or communicate with us. In this role, we decide how and why personal information is processed, including to provide our products and solutions, support our customers, and improve our offerings. When you visit our websites, use our products and services, or communicate with us, you agree to the terms of this Privacy Policy. Therefore, we recommend you read it carefully.

This Privacy Policy applies to all personal data we handle in connection with our business. It describes what information we collect, the purposes for which we use it, and the rights you may have under applicable privacy laws.

We review and update this Privacy Policy from time to time to reflect changes in our business practices, services, or legal requirements. When we make material changes, we’ll notify you by posting a notice on our website or, when appropriate, by sending you a direct communication (for example, via email).

This Privacy Policy should be read together with our Termos de uso. The Terms of Use set out the rules for using our website, while this Privacy Policy explains how we handle your personal data.

I. Who We Are

SENKO is a global leader in designing, testing, manufacturing, and distributing precision fiber optic interconnect products. With over 30 years of industry expertise, SENKO’s mission is to deliver reliable, high-performance solutions tailored for telecom, datacom, hyperscale data centers, AI infrastructure, automotive and industrial manufacturers, and a wide array of optical connectivity needs.

Our offerings include over 1,000 different fiber optic interconnect components such as connectors, splitters, cleaning tools, inspection scopes, and specialized accessories, all engineered to meet both standard and custom requirements.

SENKO is a Massachusetts corporation founded in 1997 with its U.S. corporate headquarters located at 2 Cabot Road, Suite 103, Hudson, Massachusetts 01749, U.S.A.

II. What Personal Data We Collect and How We Do So

The information we collect depends on how you choose to engage with SENKO. In the course of doing business, we may handle the following categories of personal data:

Information You Provide to Us

When you interact with us through our websites, at trade shows, by contacting our representatives, or when requesting products, services, or support, we may collect personal data directly from you. This typically includes your name, job title, company/employer details, contact information (including telephone number(s) and email address(es)), and any other information you choose to share.

Information From Business Interactions

If you purchase products or services from us, or if you are a supplier, distributor, or other partner, we may collect relevant business contact information (including telephone number(s) and email address(es)), order history, invoicing records, financial and banking information, and payment details necessary to manage the relationship.

Information From Events and Meetings

When you attend a SENKO exhibition, training session, or webinar, we collect the details you provide during registration such as your name, company, and contact information (including telephone number(s) and email address(es)).

Information Collected Automatically

When you visit our websites or use our online services, certain data is collected automatically. This information does not directly identify you but may include technical details like your IP address, browser type, device identifiers and operating system, and browsing behavior such as pages or screens viewed, time spent and activity on a page or screen, and the websites (if any) you visited before coming to our sites. We also use cookies and similar technologies to understand how visitors interact with our sites and to improve your experience. Please see our dedicated Política de Biscoitos for more information.

Information From Other Sources

We may receive information about you from our global network of distributors, resellers, event partners, or from publicly available sources such as professional directories. This helps us keep our records accurate and relevant.

Recruitment Information

If you apply for a role with SENKO, we will collect the details you provide in your application, such as CVs, cover letters, and professional qualifications, as well as any information gathered during the recruitment process. This information may include your name, contact information (including telephone number(s) and email address(es)), educational background, professional experience, and business affiliations and certifications.

Sensitive Personal Data

We do not collect or process sensitive personal data (such as information about your health, political opinions, religious beliefs, or genetic and biometric data) in the ordinary course of business.

If at any time we do need to collect such information, we will first ask for your explicit consent and process sensitive information only as described in this Privacy Policy. You may withdraw your consent at any time by contacting us using the details provided in the Contate-nos section below.

III. Why We Collect and Use Personal Data

At SENKO, we believe that strong business relationships are built on trust. Part of that trust comes from being clear about why we collect personal data and how we use it. We only ask for information that helps us deliver our products, support our customers, and improve the services we provide. Specifically, we use the information collected or received for the following purposes:

To Deliver Products and Services

We collect personal data first and foremost to deliver our products and solutions to you. Whether it’s processing an order or request, arranging a shipment, or providing technical support, we need certain details to make sure everything runs smoothly and efficiently and to keep our records accurate. Without this information, we wouldn’t be able to meet our commitments or maintain the level of service our customers expect.

To Manage Our Relationship with You

We also use personal data to communicate with you in a meaningful way. If you reach out to us with a question, register for a webinar, or attend a trade show where SENKO is present, we use the details you share to respond to your request, provide relevant follow-up, and ensure you have the information you need. We also use this information to organize and manage events, communicate with you regarding events, and improve future events.

To Comply with Legal and Contractual Obligations

Another important reason why we collect personal data is to comply with our legal and contractual obligations. Like all global businesses, we need to maintain accurate records for billing and invoicing, satisfy legal and regulatory compliance requirements, and fulfil our obligations under contracts with customers, suppliers, and partners. We may also need to defend against legal claims and disputes and respond to legal inquiries, including those of governmental and regulatory agencies.

To Market and Promote Our Business

From time to time, we may also use your information to share updates about SENKO, such as new product releases, technical insights, or event invitations. We only do this where it is permitted, and you always have the choice to opt out of receiving marketing communications.

You can opt out of receiving any marketing communications by following the opt-out instructions in each marketing communication or at any time by contacting us using the details provided in the Contact Us section of this Privacy Policy

To Monitor, Improve, Personalize and Protect our Websites and Services

Collecting certain technical and usage information helps us improve our websites and services. By understanding how visitors interact with our content and tools, we can make them more useful, relevant, and reliable and ensure that your experience with SENKO continues to meet the high standards we set for ourselves. We can also use the information we learn to better protect the security of our websites, online platforms and other systems, and detect and prevent security threats.

То Facilitate Corporate Transactions

Finally, we may use your personal data when it is in our legitimate business interests to pursue and consummate business transactions involving the sale of all or substantially all of our business or assets, including mergers, financings, acquisitions and bankruptcy proceedings.

For more detail about the purposes for which we use personal data, the types of data involved, and the lawful bases on which we rely, please see Annex 1 – How Your Information Will Be Used at the end of this Privacy Policy.

IV. How We Share Personal Data

At SENKO, we value your privacy and are committed to sharing data only when it’s necessary, legal, and consistent with the purposes you expect:

Sharing Within the SENKO Group

Your information may be shared internally within SENKO and with affiliates in the SENKO Group, but only when needed to fulfil an order, support your service experience, or manage our business relationship.

Working with Our Partners

In some cases, we rely on third-party service providers such as logistics companies, customer support platforms, and marketing vendors to help deliver our products and services. When sharing information with these partners, we impose contractual safeguards to ensure they use the data solely for the agreed purpose.

Legal and Safety Obligations

We may share personal data if required to comply with laws or a court order. We may also disclose data to attorneys, accountants and auditors, as well as regulatory authorities or other official bodies, if it’s necessary to protect SENKO’s legal interests or the users of its products and services, or comply with applicable laws and regulations. We may also share information to prevent fraud or for risk management purposes.

With Your Consent

Occasionally, we might ask for your permission before sharing your data such as distributing a testimonial or collaborating with a co-hosted event. In such cases, we’ll ask for your explicit consent and honor your choice if you prefer not to participate.

Prospective Sellers or Buyers

We may share personal data, if required in connection with any business transaction involving the sale of our business, with a prospective buyer or seller.

What We Do Not Do

We do not sell your personal data, nor do we share it with unrelated third parties for marketing or unrelated commercial purposes.

V. International Data Transfers

Transfers Within the SENKO Group

To support our global operations, we may transfer personal data to SENKO affiliates located in different countries. These transfers are made solely for the purposes described in this Privacy Policy and always subject to appropriate safeguards. These transfers are carried out under SENKO’s Intra-Group Data Processing Agreement, which ensures that personal data is handled consistently and securely throughout the SENKO Group.

This Privacy Policy applies equally, regardless of where your personal data is processed. We have implemented safeguards to ensure that your data remains protected when transferred internationally, including reliance on Standard Contractual Clauses approved by the European Commission and, where relevant, the UK Addendum and Swiss-approved frameworks. Additional technical and organizational measures such as encryption, access controls, and strict internal policies help maintain the confidentiality and integrity of personal data across borders.

Transfers to Third Parties

In some cases, we may share personal data with third-party service providers or partners located outside your home country – for example, logistics companies, IT support providers, and event organizers. Where such transfers involve personal data from the European Economic Area (EEA), the United Kingdom, or Switzerland, SENKO relies on legally recognized safeguards such as Standard Contractual Clauses or other applicable mechanisms to ensure your rights are protected.

Additional Safeguards and Compliance

We use physical, technical and administrative measures to safeguard the information in our possession against loss, theft and unauthorized use, disclosure or modification. Please note, however, that in no case is the collection, storage or transmission of personal data guaranteed as 100% secure. Consequently, while we are committed to ensuring the security of the information in our possession, we cannot guarantee the total security of any information provided or collected.

SENKO reviews its international transfer practices regularly to ensure they remain compliant with evolving privacy regulations. We also apply additional industry-standard safeguards, including secure data transfer protocols, contractual restrictions, and internal monitoring, to protect personal data in transit and at rest.

If you would like more information about the specific legal mechanisms SENKO relies on for cross-border transfers, you may contact us using the details provided in the Contate-nos section of this Privacy Policy.

Transfer Tools & Frameworks

To make sure your personal data remains protected when it moves across borders, SENKO relies on a set of recognized legal and contractual safeguards. These tools ensure that data enjoys a consistent level of protection, even when processed in countries with different privacy laws.

• Intra-Group Data Processing Agreement (IGDPA)
  Personal data shared between SENKO affiliates around the world is protected by our IGDPA. This agreement applies uniform privacy and security standards across all SENKO offices and affiliates, ensuring that your information is handled consistently no matter where it is processed.
• Standard Contractual Clauses (SCCs)
  For transfers from the European Economic Area (EEA) to countries without an adequacy decision from the European Commission, we use SCCs. These clauses are legally binding commitments that require the recipient to safeguard personal data in line with EU standards.
• UK Addendum to the SCCs
  For transfers originating in the United Kingdom, we implement the UK Addendum to the SCCs as approved by the UK Information Commissioner’s Office (ICO). This ensures equivalent protection for personal data moving from the United Kingdom to third countries.
• Swiss Adaptations of the SCCs
  For transfers of personal data from Switzerland, we apply the SCCs with adjustments required under the Swiss Federal Data Protection Act, including recognition of the Federal Data Protection and Information Commissioner as the competent authority.

Together, these tools form the backbone of SENKO’s international transfer approach. They reflect our commitment to handling personal data responsibly, transparently, and consistent with global privacy expectations.

VI. How We Protect and Store Personal Data

At SENKO, we understand that the personal data you entrust to us deserves strong protection both in how it is safeguarded and how it is stored:

Here’s how we do it:

Secure Data Storage

We retain personal data in secure environments, using servers located in regions like the United Kingdom, European Union, and other necessary locations to support compliance with applicable data retention guidelines.

Technical and Organizational Security Measures

To safeguard your data from unauthorized access, loss, or misuse, we’ve implemented a range of robust security protocols. These include industry-standard encryption, access controls, firewall protections, and ongoing security monitoring.

Minimizing Access, Maximizing Control

Access to personal data is restricted to team members who have a legitimate need for it in order to perform their roles. We train our staff regularly to uphold our privacy standards and ensure you can trust us with your information.

Data Backups and Resilience

We maintain data backups and resilient systems to guard against unintended loss or corruption. Whether due to technical faults or external threats, our controls ensure your information remains safe, recoverable, and intact.

Clear Retention and Disposal Practices

We have established clear retention and disposal policies and procedures, which are communicated to those who have access to personal data, and follow them as a critical part of our data protection policy.

VII. How Long We Keep Personal Data

SENKO keeps personal data only for as long as necessary to fulfil the purposes for which it was collected, to meet our contractual and legal obligations, or to resolve disputes. We follow the GDPR principle of storage limitation and regularly review the personal data we hold to ensure it is still needed for these purposes.

The exact retention periods vary depending on the type of data and the context in which it was collected. These periods are defined in SENKO’s Data Retention Policy, which sets out how long different categories of data are kept and the criteria used to determine those timelines.

If you would like more information about how long your personal data will be kept, or a copy of our Data Retention Policy, you can contact us using the details provided in the Contact Us section of this Privacy Policy.

VIII. Your Privacy Rights and Choices

At SENKO, we believe in transparency and respect for your rights. Depending on your location and applicable law, you have specific rights over your personal data, and we aim to make exercising them as easy as possible.

If You Are in the EEA or the UK (GDPR / UK GDPR)

Under the GDPR and UK GDPR, you may have the following rights:

• Right to Access – You can request a copy of personal data we hold about you and understand how it’s used.
• Right to Correction – You may ask us to update inaccurate or incomplete data.
• Right to Erasure (“Right to be Forgotten”) – You can request deletion of your personal data in certain cases, such as when the data is no longer necessary, or if consent is withdrawn.
• Right to Restrict Processing – You can ask us to limit how we use your data – for example, during a dispute over accuracy.
• Right to Data Portability – You may request a machine-readable copy of your data for use elsewhere.
• Right to Object – You can object to processing based on legitimate interests, including profiling and direct marketing.
• Right to Withdraw Consent: Where data processing is based on your consent, you can withdraw it at any time without impacting prior legality.

If You Are in California (CCPA / CPRA)

Under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), California residents have these rights:

• Know what personal data we collect, use, disclose, and share.
• Delete personal data, subject to certain legal exceptions.
• Opt out of the “sale” or “sharing” of personal data (SENKO does not sell your personal data).
• Correct inaccurate personal data we hold about you.
• Limit the use of sensitive personal data (SENKO does not process sensitive personal data in the ordinary course of business).
• Non-discrimination for exercising any of your CCPA/CPRA rights.

For more information about how SENKO handles personal data under the CCPA and CPRA, please see Annex 2 – California Residents (CCPA/CPRA Disclosure).

How to Exercise Your Rights

To submit a request under GDPR/UK GDPR or CCPA/CPRA, simply contact us through the details provided in the Contate-nos section of this Privacy Policy. Please let us know:

• Which right you wish to exercise (e.g., “right to access” or “delete my data”);
• The relevant personal data or context (e.g., “event registration from May 2025”); and
• Any supporting information to help us locate your data.

We may ask for verification to confirm your identity before responding to protect your data privacy.

If you remain dissatisfied, you have the right to apply directly to your local Data Protection Regulator. You can find their contact details on the following link: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en

IX. Cookies and Similar Technologies

When you visit SENKO websites, we may use cookies and similar technologies to make your experience smoother, understand how our sites are used, and improve the services and experience we provide.

What are cookies?

Cookies are small text files that are stored on your device when you browse our websites. They allow us to recognize your browser, remember your preferences, and provide features that make navigation easier.

Types of cookies we use

• Essential cookies – required for the website to function properly (for example, enabling navigation or access to secure areas);
• Analytics cookies – help us understand how visitors use our sites so we can improve content and usability;
• Functional cookies – remember your choices, such as preferred language or region, to provide a more personalized experience; and
• Marketing cookies – in limited cases, we may use cookies to deliver relevant content or communications, always in line with applicable consent requirements.

Other tracking technologies

In addition to cookies, we may use web beacons, pixels, and similar technologies to measure the effectiveness of campaigns, monitor site performance, and gather aggregated usage data.

Your choices

You can control or disable cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of our websites. Where required by law (such as under GDPR/UK GDPR, Privacy and Electronic Communications Regulation or the ePrivacy Directive), we request your consent before placing non-essential cookies on your device.

For more information about how we use cookies, please see our dedicated Política de Biscoitos

X. Children’s Privacy

SENKO does not knowingly collect personal data from minors. Our products, services, and communications are designed for business-to-business contexts such as optical connectivity solutions, supply chain operations, and professional events. Therefore, we expect our audience to be adults acting in their professional capacity.

• If we learn or have reason to believe that we’ve unintentionally collected personal data from someone under the age of 16, we will act promptly to delete that information from our systems.
• If you become aware that your minor child has shared personal data with us without your consent, please contact us immediately using the details in the “Contate-nos” section. We will take appropriate steps to delete the data without undue delay.

XI. Links to Third-Party Sites

SENKO websites may contain links to third-party websites, applications, or services. These links are provided for convenience and to give you access to additional information. Please note that SENKO is not responsible for the privacy practices, content, or security of those third-party sites.

When you follow a link to another website, the collection and use of your personal data will be governed by that site’s own privacy policy, not this one. We encourage you to review the privacy policies of any third-party websites you visit to understand how your information may be handled.

XII. Changes to This Privacy Policy

SENKO may update this Privacy Policy at any time as needed to reflect changes in our products, services, legal obligations, or privacy practices.

When we make material changes, we’ll notify you by posting a notice on our website or when appropriate by sending you a direct communication (for example, via email).

The revised policy will take effect either on the date specified in the notice or immediately upon being published on our website. We encourage you to periodically revisit this page to stay informed of any updates.

By continuing to access our websites and use our products and services, you accept the terms of the Privacy Policy as revised.

XIII. How to Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way SENKO handles your personal data, please contact our Data Protection Officer at:

GDPR Local Ltd
Adam Brogden
dpo.support@gdprlocal.com
Tel + 441 772 217 800
GDPR Local Ltd
1st Floor Front Suite 27-29 North Street, Brighton England BN1 1EB

SENKO Advanced Components, Inc.

If you are located in the European Economic Area (EEA) or the United Kingdom, you may also contact our Data Protection Officer (DPO) or EU/UK representative using the same details above, clearly stating that your request relates to GDPR/UK GDPR rights.

Address: Unit 2, Rankine Road, Daneshill Basingstoke,
Hampshire RG24 8PP, United Kingdom
Email: dataprotection@senko.com
Phone: + 1 508 8040211

Annex 1 – How Your Information Will Be Used

This annex provides more detail on how SENKO uses personal data, the types of data involved, and the lawful basis for processing. It should be read together with the sections “Why We Collect and Use Personal Data” and “Your Privacy Rights and Choices” in this Privacy Policy.

Purpose / Activity	Type of Data	Lawful Basis for Processing
To register you as a new customer, supplier, or partner	Identity, Contact, Financial (for reference and credit checks)	Performance of a contract or steps taken at your request before entering into a contract
To process and deliver products and services (including managing payments, fees and charges, and credit control)	Identity, Contact, Financial, Transaction	(a) Performance of a contract, (b) Legitimate interests in recovering debts and operating our business
To manage our ongoing relationship (including updates to terms, services, or this Privacy Policy)	Identity, Contact, Profile, Marketing & Communications	(a) Performance of a contract, (b) Compliance with legal obligations, (c) Legitimate interests in keeping records accurate, (d) Consent where required
When you visit our website (forms, cookies, or support requests)	Identity, Contact, Profile, Usage, Technical, Marketing & Communications	(a) Performance of a contract (if linked to a service), (b) Compliance with legal obligations, (c) Legitimate interests in improving our services, (d) Consent for non-essential cookies and marketing
To administer and protect our business and websites (troubleshooting, IT support, network security, hosting, reporting)	Identity, Contact, Technical	(a) Legitimate interests in running our business securely and efficiently, (b) Compliance with legal obligations
To deliver relevant content, marketing, and advertising (including social media campaigns)	To deliver relevant content, marketing, and advertising (including social media campaigns) Identity, Contact, Profile, Usage, Marketing & Communications, Technical	Legitimate interests in developing our services, growing our business, and targeting communications appropriately
To use data analytics to improve websites, products, services, and customer experience	Technical, Usage	Legitimate interests in keeping services relevant, competitive, and user-friendly
To provide product or service recommendations that may interest you	Identity, Contact, Technical, Usage, Profile	Legitimate interests in developing our services and customer engagement
To send you information about promotions, offers, and updates (according to your preferences)	Identity, Contact, Marketing & Communications	Consent (where legally required) and/or Legitimate interests in promoting our business

Annex 2 – California Residents (CCPA/CPRA Disclosure)

If you are a California resident, this annex provides the additional information required under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA). It should be read together with the sections “What Personal Data We Collect and How Do We Do So” and “Why We Collect and Use Personal Data” in this Privacy Policy.

The table below explains the categories of personal data SENKO may collect, the purposes for which the data is used, and whether it is “sold” or “shared” as defined under CCPA/CPRA. SENKO does not sell personal data.

Category of Personal Data	Exemplos	Purpose of Collection	Sold or Shared?
Identifiers	Name, email address, phone number, mailing address, account details	To register you as a customer, manage accounts, deliver products and services, and communicate with you	Not sold (may be shared with service providers to deliver services and support)
Commercial Information	Records of products or services purchased, order history, payment details	To process orders, manage customer relationships, billing, and support	Not sold (may be shared with payment processors and service providers under contractual safeguards)
Internet or Other Electronic Network Activity	IP address, browser type, device identifiers, browsing history on our websites, interactions with online forms	To improve our websites, ensure security, and understand usage patterns	Not sold (may be shared with analytics providers under contractual safeguards)
Geolocation Data	General location derived from IP address	To provide relevant content, monitor system integrity, and detect fraud	Not sold (may be shared with analytics or security providers under contractual safeguards)
Inferences	Preferences or interests derived from website usage and marketing interactions	To improve products, tailor communications, and develop marketing strategies	Not sold (may be shared with marketing service providers under contractual safeguards)