General EEA Safe Harbor Notice

Qualcomm Incorporated and its U.S. subsidiaries (collectively “Qualcomm US” or “we”) recognize that the European Community has established a data protection regime pursuant to Directive 95/46/EC, which applies to the European Economic Area (“EEA”) and restricts companies in the EEA in transferring personal data about individuals in the EEA to the United States, unless there is “adequate protection” for such personal data when it is received in the United States. To create such “adequate protection” and allow its subsidiaries and business partners to overcome the restriction on international data transfers established by the Directive, Qualcomm US adheres to the Safe Harbor Privacy Principles published by US Department of Commerce (“Safe Harbor Principles”) with respect to personal data about individuals in the EEA that subsidiaries, customers and other business partners in the EEA send to Qualcomm US. Qualcomm US’s Safe Harbor Certification does not extend to data that Qualcomm US receives directly through www.qualcomm.com or other websites (information on Qualcomm US’s practices regarding data received through websites is contained in the applicable website privacy statements, if any). More information on the Safe Harbor Principles and Qualcomm US’s scope of participation is available at http://www.export.gov/safeharbor/SH_Overview.asp.

Qualcomm US has issued a separate Safe Harbor Notice for Qualcomm Employees in the EEA and this Notice does not apply to employees of Qualcomm US or its subsidiaries; this Notice addresses other data subjects residing in the EEA whose data Qualcomm US may receive from one of its subsidiaries, customers, suppliers or other business partners in the EEA (“EEA Persons”), e.g., customers’ procurement managers, suppliers’ sales representatives, individual independent contractors, etc.

Qualcomm US and its subsidiaries (“Qualcomm Group”) sell products and services largely to businesses and rarely to consumers. Thus, Qualcomm US receives mostly business-related information from the EEA, occasionally connected to contact information related to individual representatives of the businesses with whom Qualcomm is dealing, including, without limitation, names, addresses, work phone numbers, work email addresses of EEA Persons (“EEA Data”). In connection with some managed services, Qualcomm US may process EEA Data on behalf of, and in accordance with instructions from, customers. Since EEA Data covered by this Notice is by definition sent to Qualcomm US by another company in the EEA (e.g., a supplier to the Qualcomm group), the categories of data sent and the purposes of processing often depend on such other company, with whom the EEA Persons typically have a closer employment or business relationship (and which therefore, can provide additional information on categories of data shared with us).

Qualcomm US collects and uses EEA Data for purposes of providing products and services to customers, communicating with corporate business partners about business matters, processing EEA Data on behalf of corporate customers, transmitting marketing emails and performing other marketing activities, and conducting related tasks for legitimate business purposes.

Qualcomm US shares EEA Data with affiliates and contractors, which process EEA Data on behalf of the Qualcomm Group. Qualcomm US also shares EEA Data with other third parties for the purposes for which Qualcomm US receives the EEA Data (e.g., performance of contractual obligations) and as required or permitted by law.

With respect to marketing emails, EEA Persons may opt-out of receiving further email marketing communications from Qualcomm US by submitting request at http://www.qualcomm.com/feedback.htm, or by following opt-out instructions that are contained in each marketing email. EEA Persons may also send an email to this address to ask to opt-out of disclosures to third parties, but such a limitation on data sharing may make it difficult or impossible for Qualcomm US to provide the requested services. Notwithstanding other statements in this Privacy Policy, Qualcomm US may disclose EEA Data where it is legally required to disclose (e.g., under statutes, contracts or otherwise) or the disclosure is permitted by law and Qualcomm US has a legitimate business interest in such disclosure.

EEA Persons whose EEA Data Qualcomm US holds may request access to, and the opportunity to update, correct or delete some or all of the EEA Data that Qualcomm holds about them. To submit such requests or raise any other questions, please contact the Qualcomm Safe Harbor Contact as described below. Qualcomm reserves the right to take appropriate steps to authenticate an applicant’s identity, charge an adequate fee before providing access and deny requests, except as required by the Safe Harbor Principles.

If you have questions, please contact our Qualcomm Safe Harbor Privacy Contact Joshua Davis at 5775 Morehouse Dr., San Diego, CA 92121 or e-mail: joshuad@qualcomm.com.
If you have a comment or concern that cannot be resolved with Qualcomm directly, you may contact the competent local data protection authority.