Ingram Micro Privacy Statement and Notice at Collection for Recruitment and Hiring

Last Updated: September 1, 2026

This Ingram Micro Recruitment and Hiring Privacy Statement (this “Recruitment Privacy Statement” or “Statement”) explains how Ingram Micro Inc., ("we", "us", "our," or “Ingram Micro”), a Delaware corporation, and companies that we own or control (“Affiliates”) collect, use, store, process, disclose, and delete your Personal Data that we receive from or about you in the context of employment recruiting and hiring. This Recruitment Privacy Statement also outlines your rights in respect of your Personal Data. If you are offered and accept a position with the company, this information will also be governed according to our human resources and employment privacy policies.

This Statement includes information regarding the categories of California Applicant Personal Information collected, the purposes for which the categories of California Applicant Personal Information are collected or used, whether the California Applicant Personal Information is sold or shared, and how long the California Applicant Personal Information is retained. You can find those details by clicking on the above links.

Personal Data collected from you

The types of Personal Data we may, depending on the relevant Ingram Micro country of incorporation, collect and process directly from you when you apply for a role with Ingram Micro and/or if you are hired for the respective role, include (but is not limited to):

• Identification data and contact details – including your name, address, email address, phone number and other contact information, gender, date of birth, nationality/ies, government identifiers (such as national ID/passport, Social Security number(s));
• Employment history – such as previous employers and job titles/positions;
• Background information – such as academic/professional qualifications, job qualifications, education, details included in your CV/résumé, transcripts and employment references;
• Details of your nominated references (including their name, contact details, employer and job role);
• Recordings of your interviews – in some cases, we may ask for your permission to make an audio and video recording of your interview;
• Details of your immigration status;
• Previous applications/roles (information relating to previous applications you have made to Ingram Micro and/or any previous employment history with Ingram Micro);
• Other information you voluntarily provide throughout the process, including through assessment centers, exercises, and interviews;
• Pre-employment background screening information, which varies depending on jurisdiction and applicable legal requirements, but may include information gathered from publicly available sources, your former employers or colleagues, schools you have attended, credit reporting agencies, and criminal records databases; and
• Information generated or inferred from other information we collect.

Personal Data collected automatically

We may collect or receive Personal Data automatically and indirectly through cookies and similar technologies. Our third-party providers of these technologies may also collect, receive, or record your Personal Data. See the “Cookies and Other Website Usage Information” section of the Ingram Micro Privacy Statement and Notice at Collection for more information.

Personal Data collected from third parties and other sources

The types of Personal Data we may, depending on the relevant Ingram Micro country of incorporation, collect and process from other sources when you apply for a role with Ingram Micro include (but is not limited to):

• Information provided by applicants, such as contact details for references;
• Information provided by references;
• Other background information provided or confirmed by academic institutions and training or certification providers;
• Criminal records data obtained through criminal records checks;
• Information provided by recruitment or executive search agencies; and
• Information collected from publicly available sources, including any social media platforms you use or other information available online.

As a general matter, Ingram Micro may use your Personal Data when we have an appropriate legal basis. We may process the information we collect from you for the following purposes:

• For our legitimate interests, consistent with your rights and appropriate to the context, including to:
• Assess your suitability for employment for the role for which you are applying, as well as future roles that may become available;
• Perform administrative functions (e.g., schedule interviews, reimburse you for interview-related expenses);
• Perform analysis of our applicant pool to better understand who is applying to positions at Ingram Micro and how to attract talent;
• In some cases, record your online interview for review by additional recruiters and hiring managers where you expressly consent to be recorded if required under applicable law;
• Communicate and market to you in accordance with your communication preference settings, such as by sending emails and mailings about Ingram Micro positions and recruiting events or to notify you of positions that may be of interest to you;
• Evaluate and improve the recruiting and hiring process;
• Verify your identity, including in relation to any requests you make under this Recruitment Privacy Statement;
• Create deidentified or aggregate data;
• Perform activities associated with an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all assets, including as part of bankruptcy, liquidation, or similar proceeding;
• Perform other activities and fulfill other purposes that we may disclose; and

1. To the extent you provide your consent.
2. To comply with applicable legal requirements, which may include performing any legally required reporting and responding to legal process.

We may use artificial intelligence, machine learning, algorithms, or similar technologies, including those provided by third-party service providers, to facilitate the personal data uses described above.

We may disclose your Personal Data to the following categories of recipients:

• Our Affiliates;
• Authorized personnel at our service providers whose platforms help us operate our recruiting and hiring functions, including:
• Service providers and third parties that support our business and organization, including Workday, which provides HR systems and services, service providers that provide or support artificial intelligence, machine learning, algorithms, or similar technologies;
• Online recruitment and job websites, including LinkedIn;
• Companies contracted to perform background screenings, where applicable;
• Government officials where legal reporting requirements may exist, or law enforcement agencies or private litigants in response to valid law enforcement process (warrant, subpoena, or court order);
• Third parties as necessary to comply with applicable legal requirements, including performing any legally required reporting and responding to legal process;
• Third parties to establish, exercise or defend against potential, threatened or actual legal claims;
• Third parties where necessary to protect your vital interests or those of another person;
• Third parties to perform other activities and fulfill other purposes as you may authorize or that we may disclose;
• Third parties in connection with an actual or potential business transaction, such as a business or asset sale, merger, acquisition, investment, round of funding, or other transaction, including as part of a bankruptcy or similar proceeding or a business reorganization;
• Third parties as you may authorize or that we may disclose; or
• Third parties for any of the purposes described in the “How will Ingram Micro use your Personal Data?” section above.

We and our Affiliates listed here (“US Affiliates”) comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  Ingram Micro has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom (and Gibraltar) in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.  Ingram Micro and our US Affiliates have certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the UK Extension to the EU-US DPF Principles, and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Ingram Micro and our US Affiliates commit to subject the EU-U.S. DPF Principles to all personal data received from the European Union, the United Kingdom (and Gibraltar if applicable) in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Ingram Micro and our US Affiliates commit to subject the Swiss-U.S. DPF Principles to all personal data received from Switzerland in reliance on the Swiss-U.S. DPF.

For job applicants, in compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Ingram Micro and our US Affiliates commit to cooperate and comply with the advice of the panel established by the EU data protection authorities (DPAs), the UK Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of job applicant data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF in the context of job applications and related human resources activities. Individuals have the possibility, under certain conditions, to invoke binding arbitration for complaints regarding DPF compliance that are not resolved by any of the other DPF mechanisms. For additional information about the arbitration process please see Annex I of the Principles: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.

The Federal Trade Commission (FTC) has jurisdiction over Ingram Micro and our US Affiliates’ compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. In certain situations, Ingram Micro and our US Affiliates may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In certain circumstances, Ingram Micro and our US Affiliates may transfer personal data received from the European Union, the United Kingdom (and Gibraltar if applicable), or Switzerland in reliance on the EU-U.S. DPF to third parties, such as our service providers. Ingram Micro and our US Affiliates maintain contracts with these parties that restrict their access, use, and disclosure of personal data and that require them to provide at least the same level of protection as required by the DPF Principles. Ingram Micro and our US Affiliates are responsible for these parties’ compliance with these obligations, and may be liable under the Principles if they process such personal data in a manner inconsistent with the Principles, unless Ingram Micro or our US Affiliate proves that it is not responsible for the event giving rise to any damages.

Cookies and Interest-Based Advertising. You can choose to accept or decline cookies on our websites. Many of our websites include cookie banners that allow you to proactively choose the types of cookies you prefer. Additionally, most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. 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 any cookies. However, please be aware that if you disable or reject cookies, some features and services on our websites may not work properly because we may not be able to recognize and associate you with your account(s). In addition, any offerings we provide when you visit us may not be as relevant to you or tailored to your interests.

When you visit our websites or online services, we and third-party cookie providers may place and use cookies and similar tracking technologies on your device to collect information about your web-browsing activities over time and across different websites, for the purpose of serving you ads or other content personalized to your interests. You can opt out of being tracked online for interest-based advertising purposes by going to https://optout.aboutads.info or https://optout.networkadvertising.org, or by changing your settings in our Cookie Options link available in the footer of our websites. Choices you make are device-specific and browser-specific. If you use different browsers on your computer, or multiple devices, you will need to opt out of interest-based advertising from each browser on each of the devices that you use.

Marketing Communications. You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “Questions and Contact information” heading below or access our preference center.

Do Not Track. Certain web browsers and other devices you may use to access the websites and online services may permit you to indicate your preference that you do not wish to be “tracked” online. At this time, the websites do not respond to “Do Not Track” signals. We do not modify your experience on our websites or modify the personal data we collect from you through the websites, based on whether such a preference is indicated.

Preference Center. Many of our subsidiaries utilize a preference center that allow you to opt out of receiving messages and communications from us. You can select or unselect your communication preferences at any time through the web form provided by that affiliate.

Privacy Rights Under Applicable Law. Your rights regarding Personal Data processed in the recruitment and hiring context will depend on the laws of the jurisdiction in which you reside or are located, the nature of the Personal Data at issue, and our processing of that Personal Data. Depending on those factors, you may have the right to request we:

• Confirm whether we process your Personal Data;
• Access your Personal Data;
• Rectify your Personal Data;
• Delete, anonymize, block, or erase certain Personal Data;
• Object to or restrict processing of Personal Data;
• Withdraw your consent with respect to Personal Data processing we undertake based on your consent; or
• Lodge a complaint with applicable regulatory or supervisory authorities.

As the rights described above would be provided by law, there may be limitations or exceptions that apply to your request in accordance with applicable legal requirements. We have described these rights generally, without noting all applicable or potentially applicable limitations or exceptions. When you make a request, we may provide more detailed information regarding any legal requirements applicable to your request and whether any exception or limitation applies.

Eligible individuals can request to exercise the below-described privacy rights online by completing our webform available at by clicking on Data Subject Request Form

Personal Data collected in the recruiting and hiring context will be stored in accordance with applicable laws and kept as needed to carry out the purposes described in this Recruitment Privacy Statement or as otherwise required by applicable law.

Ingram Micro employs organizational, technical, and physical security measures designed to protect your Personal Data from loss or misuse.

This section applies only to personal information that we collect about or from individuals who reside in California acting as a job applicant (“California Applicant Personal Information”). California Applicant Personal Information does not include, and this section does not apply to, information that is not subject to the California Consumer Privacy Act of 2018 as amended from time to time (“CCPA”), such as deidentified information. This section also may not apply to California Applicant Personal Information we process for purposes of compliance with federal, state, or local laws or court orders or subpoenas.

We may collect, and may have collected in the preceding 12 months, the below categories of California Applicant Personal Information. Certain data elements appear in multiple categories in accordance with CCPA descriptions of those categories and data elements.

• Identifiers.
• Unique and online identifiers.
• Demographic data, including characteristics of protected classifications under California or federal law, such as race, ethnic origin, marital status, disability, and veteran or military status.
• Professional and employment-related information.
• Education information.
• Other categories of personal data as described in California law.
• Geolocation data, such as approximate location as derived from your IP address.
• Sensory or surveillance information, such as videoconference recordings.
• Inferences and profiles based on other California Applicant Personal Information.
• California Applicant Personal Information defined as “sensitive” under the CCPA, such as information revealing Social Security, passport, and other government identification numbers and racial or ethnic origin.

We may use, disclose, or otherwise process California Applicant Personal Information for the purposes described in the “How will Ingram Micro use your Personal Data?” section above.

Notwithstanding the foregoing, we do not intend to use, disclose, or otherwise process California Applicant Personal Information defined as “sensitive” under the CCPA for the purposes of inferring characteristics about you.

Sources of California Applicant Personal Information

We may collect or receive California Applicant Personal Information directly from you, automatically, or from third parties and other sources as described in the “What Personal Data will Ingram Micro collect?” section above.

Disclosures of California Applicant Personal Information for a Business Purpose

In the preceding 12 months, we may have disclosed the categories of California Applicant Personal Information listed below to the categories of third parties identified below for a business purpose:

• Identifiers—to our Affiliates, service providers, and other third parties as described in the “With whom we share your Personal Data” section above.
• Unique and online identifiers—to our Affiliates, service providers, and other third parties as described in the “With whom we share your Personal Data” section above.
• Demographic data, including characteristics of protected classifications under California or federal law, such as race, ethnic origin, marital status, disability, and veteran or military status—to our Affiliates, service providers, and other third parties as described in the “With whom we share your Personal Data” section above.
• Professional and employment-related information—to our Affiliates, service providers, and other third parties as described in the “With whom we share your Personal Data” section above.
• Education information—to our Affiliates, service providers, and other third parties as described in the “With whom we share your Personal Data” section above.
• Other categories of personal data as described in California law—to our Affiliates, service providers, and other third parties as described in the “With whom we share your Personal Data” section above.
• Geolocation data, such as approximate location as derived from your IP address—to our Affiliates, service providers, and other third parties as described in the “With whom we share your Personal Data” section above.
• Sensory or surveillance information, such as videoconference recordings—to our Affiliates, service providers, and other third parties as described in the “With whom we share your Personal Data” section above.
• Inferences and profiles based on other California Applicant Personal Information—to our Affiliates, service providers, and other third parties as described in the “With whom we share your Personal Data” section above.
• California Applicant Personal Information defined as “sensitive” under the CCPA, such as information revealing Social Security, passport, and other government identification numbers and racial or ethnic origin—to our Affiliates, service providers, and other third parties as described in the “With whom we share your Personal Data” section above.

In the preceding 12 months, we have not sold California Applicant Personal Information or shared California Applicant Personal Information for cross-context behavioral advertising. We do not sell California Applicant Personal Information or share California Applicant Personal Information for cross-context behavioral advertising, and we do not have actual knowledge that we sell California Applicant Personal Information of consumers under 16 years of age.

California Applicant Personal Information Rights and Choices

The CCPA provides consumers with specific rights regarding their California Applicant Personal Information. This section describes those rights and explains how to exercise them.

• Right to Access to Specific Information. You have the right to request that we disclose certain information to you about our collection, use, and disclosure of your California Applicant Personal Information during the applicable time period for your request. If we receive a request from you pursuant to the “Exercising Your Rights” section below and confirm the request, we will disclose to you, depending on the scope of the request:
• The categories of California Applicant Personal Information we collected about you.
• The categories of sources for the California Applicant Personal Information we collected about you.
• Our business or commercial purpose for collecting California Applicant Personal Information about you.
• The categories of third parties to whom we disclose your California Applicant Personal Information.
• The specific pieces of California Applicant Personal Information we collected about you.
• If we disclosed your California Applicant Personal Information for a business purpose, a list of the categories of third parties to whom we disclosed your California Applicant Personal Information for a business purpose during the applicable time period for your request.
• Right to Data Portability. You may request to obtain a copy of your California Applicant Personal Information in a portable and, if technically feasible, readily-usable format that allows you to transmit the California Applicant Personal Information to another person or entity without hindrance.
• Right to Deletion. You may request that we delete your California Applicant Personal Information, subject to certain exceptions.
• Right to Correction. You may request that we correct California Applicant Personal Information about you that is inaccurate. We will take into account the nature of the California Applicant Personal Information and the purposes of our processing when we address your request.

We may update this Recruitment Privacy Statement from time to time in response to changing legal, technical or business developments. When we do, we will update the “last updated” date displayed at the top of this Recruitment Privacy Statement. We encourage you to periodically review this Recruitment Privacy Statement for the latest information on our privacy practices.

If you have any questions or concerns about this Recruitment Privacy Statement, the privacy practices of Ingram Micro, or our collection or use of your Personal Data, please contact us by mail at:

Ingram Micro Global HQ

ATTN: Recruitment Privacy Statement
3351 Michelson Drive, Suite 100
Irvine, CA 92612-0697
USA