CALIFORNIA PRIVACY NOTICES
Advantest America, Inc. California Consumer Privacy Act (CCPA) Personnel Privacy Statement
Revision Date: July 1, 2023
Advantest America, Inc., together with its direct and indirect subsidiaries, including Advantest Test Solutions, Inc., Essai, Inc. and R&D Altanova, Inc. (collectively, “AAI”), provides this Advantest America, Inc. Personnel Privacy Statement (“Statement”) in compliance with the California Consumer Privacy Act (“CCPA”) to make you aware of our privacy practices and our commitment to strong and meaningful privacy protection for the personal information we may collect in connection with your employment or engagement with AAI.
This Statement applies to all AAI entities and their respective officers, employees, contractors and temporary or contingent workers (“Personnel”). At AAI, our goal is to collect, use and transfer personal information lawfully and honestly.
“Personal information” is any information that either directly or indirectly: i) identifies, relates to, or describes you or your household; or ii) is reasonably capable of being associated with or could reasonably be linked to you or your household.
AAI notifies its Personnel from whom personal information is collected at the point where the personal information is collected or otherwise by notice to individuals as to what personal information is collected, how it is used, and how to contact AAI.
How long we keep your Personal Information.
The retention periods for personal information (including sensitive personal information) is as set forth below. Unless a time period is specified herein, your personal information is only stored and retained for as long as necessary for the purposes set out in this Statement. In determining the appropriate retention period, we consider the nature and duration of our relationship with you, the type of services provided, and the impact on our services if certain information is deleted. In all cases, AAI may retain personal information for additional time as required by applicable law; to establish, exercise or defend our legal rights; or, for other legitimate business purposes, including archiving and historical purposes. We will maintain such information in an anonymized form where practical.
What information AAI collects from or about its Personnel.
In connection with your employment or engagement with AAI, we may collect the following personal information about you:
| Category | Examples | Retention Period |
|---|---|---|
| Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. | During the employment or other relationship term + 7 years. |
| Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). |
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. |
During the employment or other relationship term + 7 years. |
| Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | During the employment or other relationship term + 7 years. |
| Professional or employment-related information. | Current or past job history or performance evaluations. | During the employment or other relationship term + 7 years. |
| Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | During the employment or other relationship term + 7 years. |
Sensitive Personal Information
Among the above-mentioned categories of personal information which we will collect, certain categories are considered “sensitive personal information” under the CCPA, which we will retain for the below retention periods.
| Category | Examples | Retention Period |
|---|---|---|
| Government identifiers | Social Security number, driver's license, state identification card, and passport and visa information, and immigration status and documentation. | During the employment or other relationship term + 7 years. |
| Complete account access credentials | User names, account numbers, or card numbers combined with required access/security code or password. | During the employment or other relationship term + 7 years. |
| Precise geolocation | Physical access to a Company office location recorded by the badging system or security cameras. | 1 year for badging system; 6 months for security cameras. |
| Racial or ethnic origin | During the employment or other relationship term + 7 years. | |
| Mail, email, or text messages contents not directed to the Company | 10 years. | |
| Health information, including job restrictions and workplace illness and injury information | During the employment or other relationship term + 7 years. |
We obtain the categories of personal information (including sensitive personal information) listed above from the following categories of sources:
- Directly from you, through direct interactions and forms.
- Third-parties, such as AAI’s service providers.
- Observations from monitoring behavior, such as AAI security camera systems.
Purpose and Usage of Personal Information of Personnel.
AAI collects and processes personal information to manage and provide compensation and benefits to AAI Personnel, to conduct its business and to comply with applicable laws and regulations. AAI may use the personal information that you have provided for the following purposes:
- Developing and maintaining employee personnel and related records;
- Ranking and review process;
- Compensation and benefit administration;
- Training and training administration;
- Transfers, relocations, terminations and other changes of employment status;
- Immigration related applications and processing (e.g., H1B, L1, visas, permanent residency, etc.);
- IT services management;
- Headcount planning and reporting;
- Expense management;
- Travel and fleet related services;
- Accounting for personnel-related compensation and expenses;
- Compliance with AAI’s legal or regulatory obligations;
- Protection of the vital interests of Advantest or Advantest Personnel;
- Advantest stock option plan; and
- Work-related injury tracking and reporting
None of your personal information that is collected in connection with your employment is “sold” or “shared” (as such terms are defined by the CCPA).
We do not use or disclose sensitive personal information for purposes other than those specified in section 7027(m) of the CCPA.
Your Data Rights
As a resident of California, you have the following rights under California law:
- Right to know: You have the right to know what personal information we have collected about you no more than twice in a 12-month period, including: (1) the specific pieces of personal information we have collected about you; (2) the categories of personal information collected; (3) the categories of sources from which the personal information is collected; (4) the purposes for which we collected, sold or shared your personal information; (5) the categories of third parties to whom we have disclosed personal information about you; (6) a list of the categories of personal information disclosed for a business purpose in the prior 12 months and, for each, the categories of recipients, or that no disclosure occurred; and (7) a list of the categories of personal information sold or shared about you in the prior 12 months and, for each, the categories of recipients, or that no sale/sharing occurred.
- Right to delete: You have the right to request deletion of the personal information that we have collected directly from you. After we confirm that your deletion request is a Verifiable Consumer Request, we will either (i) permanently erase your personal information on our existing systems with the exception of archived or back-up systems, (ii) deidentify your personal information, or (iii) aggregate your personal information with other information (i.e., such that it no longer constitutes personal information). In our response to your request to delete, we will tell you the method for deleting your personal information. However, the law provides certain exceptions that allow us to retain the information even if you have requested that it be deleted, in which case we will tell you which ones apply and limit retention to the permitted purpose(s).
- Right to correct inaccurate personal information: You have the right to request that we correct any inaccurate personal information that we have collected from you.
- Right to opt-out of sale/sharing (opt-in for minors): You have the right to direct a business to not “sell” or “share” your personal information as those terms are defined in the CCPA. For minors under sixteen years of age, businesses are legally prohibited from selling their information unless the minor or the parents of the minor (if under 13) consent to the sale. Because we do not sell/share and have not sold/shared your personal information, we do not offer an express “Do Not Sell/Share” option. For more information about how we disclose personal information in the context of marketing and advertising, and how to exercise choice with respect to cookies, please visit the Cookies section of our Privacy Policy at https://www.advantest.com/privacy-policy.html
- Right against discrimination: You have the right to not be discriminated against because you have exercised any of your above rights conferred by the CCPA, including an employee’s, job applicant’s, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights. Discrimination includes, but is not limited to, denying goods or services, charging different prices or rates for goods or services, providing a different level or quality of goods or services. Businesses however are allowed to charge you a different price or rate, provide a different level or quality of goods or services, or offer financial incentives if the difference is reasonably related to the value provided to the business by your data and that the financial incentive practices are not unjust, unreasonable, coercive, or usurious in nature. We do not currently offer any financial incentive or price or service differences.
How to Exercise Your Rights/Submit a Request:
If you are a California resident, you can exercise your right to know, right to delete or right to correct as set forth in this section. Only you, or someone legally authorized to act on your behalf (an “authorized agent”), may make a request to know, delete, or correct related to your personal information. To designate an authorized agent, please provide us with your contact information, the contact information of your authorized agent, and a description of how and when your authorized agent will be reaching out to us (to the extent known).
To make a request to know, delete or correct, please submit your request to us by either:
- Emailing us at AAI_privacy.officer@advantest.com
- Call us at 844-943-1783
Contact Information
Advantest’s Information Security Committee, in conjunction with the Human Resources Department, is responsible for addressing employee and personnel privacy incidents, inquiries, complaints, and AAI will investigate all complaints or disputes regarding personal information promptly. The AAI Regional Information Security Officer will designate individuals who will be responsible for investigating and resolving such matters, as well as ensuring that this Statement is observed and enforced.
The AAI Regional Information Security Officer can be reached via email at:
AAI_Privacy@advantest.com.
We strive to respond to access requests within a reasonable timeframe.
Changes to the Statement
We reserve the right to change the Statement including as may be required by applicable laws or regulations. All material changes to the Advantest America, Inc. Personnel Privacy Statement will be posted in or linked to the Advantest America, Inc. Employee Handbook, an electronic copy of which can be found on the AAI Intranet here.
Hardcopies of the Advantest America, Inc. Employee Handbook can be requested from and are accessible with the Advantest America, Inc. Human Resources Department.
The revision date shown at top of this Statement page will be updated accordingly.