Privacy and Cookies Policy

This Policy is effective as of May 25, 2018 and amended as of March 6, 2023.

This Privacy and Cookies Policy (“Policy”) describes how Wolfspeed, Inc., located at 4600 Silicon Drive Durham, North Carolina, 27703 (hereinafter, “Wolfspeed,” "Company," “we,” “us,” or “our”) collect, use, share, and otherwise process information about identified or identifiable visitors to this Site (defined below) and business contacts of our customers, prospects, distributors, resellers, vendors, end users and suppliers ("Personal Data"). This Policy applies to Personal Data that we collect through our websites, mobile apps, or other online applications that link to this Policy (individually and collectively, our "Site"), as well as offline through contact forms or other communications with Wolfspeed. We may update this Policy from time to time as our services and privacy practices change, or as required by law. The effective date of our Policy is posted above. We will post any updated version of the Policy on our Site.

For California residents who are visitors to the Site and/or business contacts, please see our California Privacy Policy that applies to California residents.

Summary of Key Points

1. Collection of Personal Data

We collect the following categories of Personal Data to the extent permitted by applicable data protection law:

• Basic Data. Name, title, company, job responsibilities, professional and educational qualifications, phone number, mailing address, email address, and other contact details needed for shipping purposes.
• Commercial Data. Purchasing history, warranty assistance, and browsing history.
• Registration Data. Newsletter requests, webinar browsing history, downloads, and username/passwords.
• Device Data. Computer Internet Protocol (IP) address, unique device identifier (UDID), cookies and other data linked to a device, data about your usage of our Site and communications, the websites you visited immediately prior to and upon exiting the Site, and the browser software you are using to access the Site.
• Marketing Data. Data about individual credentials, associations, services you are interested in, and other preferences.
• Compliance Data. Government identifiers, including passport number, and other trade compliance and due diligence data, to the extent required and permitted by applicable law.
• Sensitive Data. In limited circumstances, certain Compliance Data that we collect may be considered “sensitive” within the meaning of applicable laws, such as government identifiers.

Wolfspeed does not seek information from persons who are under 16 years of age and no information should be submitted to Wolfspeed by anyone who is under 16 years of age.

2. Use of Personal Data

We use the above categories of Personal Data for the following purposes:

3. Disclosure of Personal Data

We disclose Personal Data to the following categories of recipients to the extent permitted by applicable law:

• Affiliates.  We disclose Personal Data to our affiliated companies (see list in Appendix A) for the purposes identified above.
• Customers, distributors, and business partners. We disclose Personal Data to customers, distributors, and business partners as data controllers in order to provide the services you requested, respond to your inquiries, and carry out the purposes identified above.
• Service providers. We disclose Personal Data to service providers acting as our data processors to enable such parties to perform functions on our behalf and under our instructions in order to carry out the purposes identified above, such as marketing and web hosting. We require service providers by contract to provide reasonable security for Personal Data and to use and process such Personal Data only on our behalf.
• Auditors and advisors. We disclose Personal Data to auditors for the performance of audit functions and advisors for the provision of legal and other advice.
• Business reorganization. We disclose Personal Data to any corporate purchaser or prospect to the extent permitted by law as part of any merger, acquisition, sale of company assets, or transition of service to another provider, as well as in the event of insolvency, bankruptcy, or receivership in which Personal Data would be transferred as an asset of Wolfspeed.
• Mandatory disclosures and legal rights. We disclose Personal Data in order to comply with any subpoena, court order or other legal process, or other governmental request, as allowed by applicable laws.  We also share Personal Data to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims.

If you have questions about our disclosures of Personal Data, please contact us as specified below.

4. Marketing Choices

You have control regarding our use of your Personal Data for directing marketing. To the extent consent is required, we obtain consent from you. If you no longer wish to receive any marketing communications, remain on a mailing list to which you previously subscribed, or receive any other marketing communication, you can choose to not receive such communications at any time. Please follow the unsubscribe link in the relevant communication or contact us as detailed below. In addition, information about your control over Cookies follows below.

5. Data Subject Rights

Where required by applicable law, you have the right to obtain confirmation that we maintain certain Personal Data relating to you, to verify its content, origin, and accuracy, as well as the right to access, review, port, delete, or to block or withdraw consent to the processing of certain Personal Data (without affecting the lawfulness of processing based on consent before its withdrawal), by contacting us as detailed below.

In particular, if you reside in the European Union (“EU”) or the United Kingdom (“UK”), you generally have the following rights under data protection regulations:

• Access. Subject to certain exceptions, you have the right to obtain from us confirmation as to whether or not Personal Data concerning you is processed, and, where that is the case, to request access to the Personal Data as well as further information. You may have the right to request a copy of the Personal Data we are processing about you, which we will provide to you in electronic form. We may require you to prove your identity before providing the requested information.
• Rectification. You have the right to require that any incomplete or inaccurate Personal Data that we process about you is amended. 
• Deletion. You have the right to request that we delete Personal Data that we process about you, unless we are required to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
• Restriction. You have the right to request that we restrict our processing of your Personal Data where, e.g.: (i) you believe such data to be inaccurate; (ii) our processing is unlawful and you oppose to the erasure of the Personal Data and request the restriction instead; or (iii) we no longer need to process such data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims.
• Portability. You have the right to request that we transmit the Personal Data we hold with respect to you to another data controller, where this is: (i) Personal Data which you have provided to us; and (ii) we are processing that data on the basis of your consent or in order to perform our obligations under contract to you (such as to provide legal services).
• Withdrawing Consent.  If you have consented to our processing of your Personal Data, you have the right to withdraw your consent at any time, free of charge, without affecting the lawfulness of processing based on consent before its withdrawal.  This includes cases where you wish to opt out from marketing messages that you receive from us.
• Contacting authorities.  You have the right to lodge a complaint with a data protection authority if you believe that we have not complied with applicable data protection laws. For details about the competent supervisory authority in your jurisdiction, see https://edpb.europa.eu/about-edpb/board/members_en.

Objection
Direct marketing. You have the right to object to our use of Personal Data for direct marketing and in certain other situations at any time and without justification. Please note that we may need to retain certain Personal Data as required or permitted by applicable law.
Right of Objection. Where the legal justification for our processing of your Personal Data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation.  We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defense of a legal claim.

6. Data Security

We maintain appropriate technical and organizational measures to protect the security of Personal Data. However, no security measure can guarantee against compromise. You also have an important role in protecting your Personal Data. You should not share your username and password with anyone, and you should not re-use passwords across more than one website. If you have any reason to believe that your username or password has been compromised, please contact us as detailed below.

7. Cross-Border Data Transfers

We transfer Personal Data to various jurisdictions as necessary for the purposes described above, including to jurisdictions that may not provide the same level of data protection as your home country. Please see below for a list of jurisdictions in which Wolfspeed has operations and receives personal data. We provide appropriate protections for cross-border transfers as required by law for international data transfers. With respect to transfers originating from the EU and UK, we implement standard contractual clauses approved by the European Commission, and other appropriate solutions to address cross-border transfers as required by applicable law. Where required by such laws, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed below.

8. Other Information

(i) What is the legal basis of processing?
We have several different legal grounds on which we collect and process Personal Data, as indicated in the table above in Section 2. Use of Personal Data, including: (a) as necessary to perform a contract (such as in order to provide the services you requested); (b) as necessary to comply with a legal obligation (such as when we use Personal Data for record keeping to substantiate tax liability); (c) consent (where you have provided consent as appropriate under applicable law, such as for direct marketing or certain cookies); and (d) necessary for legitimate interests (such as when we act to maintain our business generally, including maintaining the safety and security of the Site). With respect to legitimate interests, given that we are a B2B company, we typically collect and process limited Personal Data about customer contacts and other individuals acting in their business capacities, as part of our overall effort to reduce the privacy impact on individuals. Our legitimate interests could in particular be group-wide information sharing, prevention of fraud, misuse of IT systems, or money laundering, physical security, IT and network security, internal investigations, or potential merger and acquisition activities (more information on the balancing test is available upon request). To the extent that any of our collection and processing activities relate to sensitive or special categories of data, such as Compliance Data, we perform such activities as necessary to comply with legal obligations and/or to establish, exercise, or defend legal claims.

(ii) What are the consequences of not providing Personal Data?
You are not required to provide all Personal Data identified in this Policy to use our Site or to interact with us offline, but certain functionalities will not be available if you do not provide certain Personal Data. In Section 2. Use of Personal Data above, when legal basis is contract performance or compliance with law, providing of data is mandatory and if you do not provide certain Personal Data, we may not be able to respond to your request, perform a transaction with you, provide our products or services. When legal basis is legitimate interest, providing of data is functional to these activities and denial may jeopardize the same. For the processing purposes based on consent (i.e. marketing, cookies), providing of data is optional and not providing data will not have any consequence.

(iii) Do we engage in automated decision-making without human intervention?
We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.

(iv) How long do we retain Personal Data?
We typically retain Personal Data related to marketing activities for as long as you accept marketing communications from us, and upon request we will securely delete such data in accordance with applicable law. For Personal Data that we collect and process for other purposes described above, we typically retain such Personal Data for no longer than for the period necessary to fulfill the purposes outlined in this Policy and as otherwise needed to address tax, corporate, compliance, litigation, and other legal rights and obligations. For Personal Data collected through cookies, please see below Section 9. Cookie Policy.

(v) Are third-party websites governed by this Policy?
This Site contains links and references to other websites administered by unaffiliated third parties. This Policy does not apply to such third party websites. When you click a link to visit a third party websites, you will be subject to that website's privacy practices. We encourage you to familiarize yourself with the privacy and security practices of the linked third party websites before providing any Personal Data on that website. In particular, like many companies, this Site allows you to connect and share data on Vimeo, LinkedIn and other social media sites (“Social Media”). Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on the Site and our Social Media pages any comments or content that you post on our Social Media pages. Your use of Social Media is governed by the privacy policies and terms of the third parties that own and operate those websites and not by this Policy.

9. Cookie Policy

This Cookie Policy explains how Wolfspeed uses cookies and similar technologies to recognize you when you visit our Site. In particular, we use and allow certain trusted partners to use cookies, web beacons, pixels, tags, and similar tracking technologies (collectively, "Cookies") on our Site.

What are Cookies?
Cookies are small amounts of data or other technologies that are stored on or otherwise interact with your browser, device, communication, or the page you are viewing. Cookies placed by us are called “first party cookies” whereas cookies from third parties are called “third party cookies” as explained below. Some cookies are deleted once you close your browser, while other cookies are retained even after you close your browser so that you can be recognized when you return to a websites. More information about cookies including for example names, purposes, duration and how they work is available at our Cookie Management Preferences Center.

Why do we use Cookies?
Cookies do a lot of different jobs, such as navigating between pages efficiently, remembering your preferences and generally improving the user experience. They can also help to ensure that the advertisements you see online are more relevant to you and your interests. In addition, cookies can help us to analyze the use of our websites and online content (analytical cookies) and they can also facilitate/track the interaction on our websites and online content with social media (e.g. links to social media sites, like buttons, etc.).

How do we use Cookies?
We use Cookies to provide the Site and our services, gather information about your usage patterns when you navigate this Site in order to enhance your personalized experience, and to understand usage patterns to improve our Site and services. We also allow certain trusted partners to place Cookies on our Site in order to collect information about your online activities on our Site over time and across different websites you visit. This information is used to provide advertising tailored to your interests on websites you visit, also known as interest based advertising, and to analyze the effectiveness of such advertising.

Cookies on our Site are generally divided into the following categories:

• Strictly Necessary Cookies. These are required for the operation of our Site. They include, for example, Cookies that enable you to log into secure areas. Some of these cookies will be removed when you quit your browser, as they are session cookies, others allow for the functionality that persists after quit, such as downloading documentation after presenting an email address on first download.
  
  Strictly necessary Cookies do not require your consent. The legal basis is the necessity of storage of and access to information on your end user device for us being able to provide the telemedia service expressly requested by you. The legal basis for the collection and further processing of Personal Data through the use of strictly necessary cookies is contract performance (if we concluded a contract on the use of the Site with you) or legitimate interests of us or third parties, such as the provision of a functioning Site. More information on the balancing test is available upon request.
  
  You can set your browser to block or alert you about these cookies, but some parts of the Site will then not work.
• Functional & Analytics Cookies. These improve the functional performance of our Site and make it easier for you to use. For example, these Cookies are used to remember that you have previously visited the Site and asked to remain logged into it. These Cookies qualify as persistent, because they remain on your device for us to use during a next visit to our Site. You can delete many of these Cookies via your browser settings, or see below for further details on our Cookie Management Preferences center.
  
  These Cookies enable the Site to provide enhanced functionality and personalization. The legal basis for the storage of and access to information on your end user device is your consent. The legal basis for the collection and further processing of Personal Data by Functional & Analytics Cookies is your consent.
  
  If you do not allow these Cookies then some or all of these services may not function properly.
• Targeting Cookies. These Cookies record your visit to our Site, the pages you have visited and the links you have followed to recognize you as a previous visitor and to track your activity on the Site and other websites you visit. These Cookies qualify as persistent, because they remain on your device for us to use during a next visit to our Site. You can delete many of these Cookies via your browser settings, or see below for further details on our Cookie Management Preferences center.
  
  These Cookies may be set through our Site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. The legal basis for the storage of and access to information on your end user device is consent. The legal basis for the collection and further processing of Personal Data by targeting Cookies is your consent.

Managing Cookie Preferences

You can change your Cookie preferences any time by visiting our Cookie Management Preferences Center below. This will let you revisit the Cookie consent banner and change your preferences or completely and immediately withdraw your consent for Functional & Analytics Cookies and Targeting Cookies. Essential Cookies are necessary to enable basic functionality and cannot be changed. Please note that our Cookie Management Preferences Center is deployed to each of our Sites individually. Due to practical limitations, if you visit more than one of our Sites, you will need to express your Cookie preferences separately on each Site.

Can I turn off Cookies on my browser?
You can review your Internet browser settings, typically under the sections "Help" or "Internet Options," to exercise choices you have for certain Cookies. If you disable or delete certain Cookies in your Internet browser settings, you might not be able to access or use important functions or features of this Site, and you may be required to re-enter your log-in details. Listed below are the links to the support documents on how to manage and delete cookies from the major web browsers.

Chrome | Safari | Firefox | Microsoft Edge

To learn more about the use of Cookies for Google Analytics and to exercise choice regarding such cookies, please visit https://tools.google.com/dlpage/gaoptout.

To learn more about certain Cookies used for interest based advertising by third parties, including through cross-device tracking, and to exercise certain choices regarding such cookies, please visit the Digital Advertising Alliance, Network Advertising Initiative, Digital Advertising Alliance-Canada, European Interactive Digital Advertising Alliance or your device settings.

10. Contact

If you have questions or comments regarding this Policy or our privacy practices, to enforce your privacy rights, for information on data transfers and legitimate interest balancing, please contact us: Wolfspeed Inc., 4600 Silicon Drive Durham, North Carolina, 27703, email: privacy@wolfspeed.com.

Appendix A

Wolfspeed, Inc. Subsidiaries (including Affiliates, Branch and Representative Offices) and Locations

California Privacy Policy

This California Privacy Policy explains how Wolfspeed, Inc. (“Wolfspeed,” "Company," “we,” “us,” or “our”) collects and processes identified or reasonably identifiable information about California residents who are business contacts of our customers, prospects, distributors, resellers, vendors, end users and suppliers ("California Personal Information"). This California Privacy Policy applies to California Personal Information that we collect through our website, mobile apps, or other online applications that link to this Policy (individually and collectively, our "Site"), as well as offline through contact forms or other communications with Wolfspeed.

California Personal Information. Depending on your online and offline interactions with us, Wolfspeed may collect and process the following categories of personal information (“California Personal Information”):

• Identifiers, including contact details such as name, address, telephone number, and email address;
• Commercial information, including purchasing history;
• Professional or employment-related information, including relevant experience and organization information;
• Educational information, including professional qualifications;
• Internet or other electronic network activity information, including your interactions with our Site;
• Audio, electronic, visual or similar information, including CCTV images in connection with secure use of company systems and facilities; 
• Geolocation data, including general mobile network information;
• Inferences drawn from the information collected; and
• Other, including warranty assistance information as information about you that is linked to the California Personal Information above, such as inquiry and communication information when you contact us.

Certain California Personal Information that Wolfspeed collects about you may be considered Sensitive Personal Information within the meaning of the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“California Privacy Law”), including: Government identifiers that we collect for trade compliance and related legal purposes. We only use and disclose such data for purposes of compliance with Federal and other laws, and as otherwise permitted by California Privacy Law.

Sources. Wolfspeed generally sources the categories of California Personal Information identified above directly from you (for instance, when you provide information as part of a business transaction or otherwise), third party reference agencies, distributors and intermediaries, data analytics providers, and social media networks.

Purposes of use. Wolfspeed uses California Personal Information for:

Business purposes, including:

• Negotiating, concluding and performing contracts with customers;
• Managing Wolfspeed accounts and records;
• Negotiating, concluding and performing contracts with suppliers;
• Communicating with individuals that are, or who represent, customers, suppliers or users related to transactions;
• Operating the Wolfspeed Site, including the use of analytics software;
• Supporting Wolfspeed’s corporate social responsibility activities;
• Facilitating the security of Wolfspeed Site and other assets;
• Facilitating the safety of you or others;
• Legal and regulatory compliance and internal control evaluations and audits (including where conducted by Wolfspeed’s internal and external audit service providers);
• Obtaining legal advice, including for legal proceedings and litigation and also in connection with the sale, purchase or merger of a business; 
• To provide the products, information and services you request;
• For security, credit or fraud prevention purposes;
• To provide you with effective customer service;
• To provide you with a personalized experience when you use our Site;
• To contact you with information and policies related to your use of our Site;
• To improve the content, functionality and usability of our Site;
• To provide warranty assistance services;
• To ship our products;
• To improve our products and services; and
• For any other purpose identified in an applicable policy or Policy or other agreement between Wolfspeed and you.

Commercial purposes, including:

• Advertising, marketing, and public relations (including direct marketing);
• Market research and analysis;
• To display personalized advertising when you visit our Site or a third party website;
• To contact you with special offers and other information that may be of interest to you;
• To invite you to participate in surveys and provide feedback to us;
• To better understand your needs and interests; and
• To improve our marketing and promotional efforts.

Disclosure of California Personal Information.

We may disclose the categories of California Personal Information described above for the business purposes described above to:

• Customers, distributors, and business partners in connection with the performance of transactions and other business and commercial purposes;
• Third party service providers that perform data processing activities on our behalf for the business and commercial purposes, and subject to appropriate privacy and security obligations;
• Government and other authorities as required by law;
• Potential purchasers and other parties in connection with the sale, purchase or merger of a business; and
• Others to the extent necessary to comply with applicable law and as otherwise permitted under California Privacy Law.

We may disclose Identifiers, Internet or other electronic network activity information, and Geolocation data for the commercial purposes described above to:

• Business partners including social media and ad networks.

Retention of California Personal Information. We typically retain your California Personal Information related to marketing activities for as long as you accept marketing communications from us, and upon request we will securely delete such data in accordance with applicable law. For California Personal Information that we collect and process for other purposes described above, we typically retain such California Personal Information for no longer than for the period necessary to fulfill the purposes outlined in this California Privacy Policy and as otherwise needed to address tax, corporate, compliance, litigation, and other legal rights and obligations, issues related to the exercise or defense of legal claims, and legitimate business needs.

Your Rights. Subject to certain exceptions detailed in California Privacy Law, as a California resident, you have the right to request: (i) deletion of your California Personal Information; (ii) correction of inaccurate California Personal Information; (iii) the right to know/ access the categories of California Personal Information that we collect about you, including the specific pieces of California Personal Information; (iv) the categories of California Personal Information disclosed for a business purpose; and (v) information about the categories of California Personal Information about you that we have shared (as such term is defined under California Privacy Law) and the categories of third parties to whom the California Personal Information was shared.

Exercising Your Rights. If you are a California resident and wish to request the exercise of these rights as detailed above or have questions regarding the California Personal Information collected or shared with third parties, please see the “Contact us” section below, email us at privacy@wolfspeed.com or call us toll free at +1 800-533-2583. When submitting your request, please include the specific nature of your request, referencing "Your California Privacy Rights," as well as your first and last name, email address, and zip code or mailing address. Wolfspeed may apply any exceptions or other conditions available under law when responding to correction, deletion, or other requests. Wolfspeed will generally fulfill requests for access, correction, and deletion within 45 days of receiving a valid request. Wolfspeed may extend the response time by another 45 days by notifying the individual of the time extension.

Do Not Sell or Share My Information. In addition to the above, California residents have the right to opt-out of the selling or sharing of their California Personal Information, as such terms are defined under California Privacy Law. This includes the right to opt-out of analytical/performance, functional, and targeting cookies. To exercise this right, click here. In addition, we have configured our cookie management tool to honor opt-out preference signals sent by Global Privacy Control ("GPC") within the browser. Due to technical limitations, the GPC signal is only honored within the particular browser. Beyond GPC, we do not currently respond to web browser “do not track” signals or other mechanisms that indicate your preference for not having information collected over time and across different Web sites or digital apps following your visit to one of our sites. We will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon this request.

Authorized Agents. To the extent that you elect to designate an authorized agent to make a request on your behalf, they must provide appropriate documentation including written signed permission from you, proof of your identity, and verification of their identity; or a valid, designated power of attorney as defined under the California Probate Code.

Financial Incentive. We do not engage in financial incentive programs.

Contact Us

If you have questions or comments regarding this California Privacy Policy, please contact us at:

Email Wolfspeed at privacy@wolfspeed.com.