ÌìÃÀ´«Ã½

1.???? Introduction & Purpose

ÌìÃÀ´«Ã½ Semiconductor, Inc., and its subsidiaries and affiliates (the ¡°Company¡±, ¡°ÌìÃÀ´«Ã½,¡± ¡°we,¡± ¡°us,¡± or ¡°our¡±) is committed to protecting the privacy, confidentiality, and integrity of the Candidate Data collected and processed throughout the recruitment and hiring process. This Privacy Notice (¡°Notice¡±) applies to all applicants and candidates (¡°Candidates¡±) and describes:

• The categories of Candidate Data we may collect;
• The purposes and lawful bases for Processing;
• The sources of collection of Candidate Data
• The categories of recipients with whom we may share Candidate Data;
• The measures we take to secure Candidate Data;
• The retention policy; and
• The Data Subject rights available to you.

Unless stated otherwise, ¡°Candidate¡± or ¡°you¡± refers to both current and former individuals in the categories listed above. Former Candidates should note that their rights under applicable data protection laws may continue after their engagement with ÌìÃÀ´«Ã½ ends.

2.???? Scope and Jurisdiction-Specific Annexes

This Notice applies to Candidate Data processed by ÌìÃÀ´«Ã½ in connection with a prospective employment relationship, including: recruitment, hiring, and onboarding. Jurisdiction-specific annexes (each, an ¡°Annex¡±) supplement this Notice and take precedence where they impose stricter or additional requirements.

• Annex A ¨C Americas
• Annex B ¨C European Economic Area (EEA) & United Kingdom (UK)
• Annex C ¨C Israel
• Annex D ¨C China
• Annex E ¨C Singapore
• Annex F ¨C APAC

ÌìÃÀ´«Ã½ is committed to respecting and protecting Candidate Data across all jurisdictions. While specific legal requirements may vary, we apply consistent principles of transparency, fairness, and accountability in our data practices.

For Candidates located in a state, country, or region not specifically listed in Annexes, you may have Data Subject rights similar to those described in this Notice.

We strive to ensure that all Candidates feel confident that their personal information is handled with care and integrity.

3.???? Contact Information

Questions about this Notice, the Annexes, or your rights may be directed to ÌìÃÀ´«Ã½¡¯s Privacy Team.

Email: privacy@marvell.com

Address (Corporate Headquarters)

5488 ÌìÃÀ´«Ã½ Lane, Santa Clara, California, 95054, USA

When exercising your privacy rights, we will verify your identity before fulfilling your request and respond within applicable legal timelines. Some requests may be partially fulfilled or denied where permitted by law (e.g., to protect the rights of others or comply with legal obligations).

4.???? Categories of Candidate Data Collected

ÌìÃÀ´«Ã½ collects certain Candidate Data to comply with legal and regulatory obligations and conduct our business. ÌìÃÀ´«Ã½ limits data collection to what is necessary and reasonable. Candidate Data collected may include any of the following (Table 1):

Table 1.

5.???? Sources of Candidate Data

ÌìÃÀ´«Ã½ may collect Candidate Data through the following means:

• Directly from you: via applications, interviews, assessments, and communications.
• Automatically: through recruitment platforms, ATS systems, and ÌìÃÀ´«Ã½ IT tools.
• Third Parties and the Public Domain: recruiters, background check vendors, references, public sources (e.g., LinkedIn), and government agencies.
• Online Website Technologies: cookies, web beacons, and google analytics.

6.???? Purposes & Legal Bases for Processing

ÌìÃÀ´«Ã½ Processes Candidate Data only when we have a valid legal basis under applicable law. Common purposes and bases include, but are not limited to the following (Table 2):

Table 2.

7.???? Processing of Sensitive Candidate Data

ÌìÃÀ´«Ã½ Processes Sensitive Candidate Data (as defined above) only when permitted by law.

Where local law requires, ÌìÃÀ´«Ã½ will obtain your explicit consent or provide you with the opportunity to object to the Processing of Sensitive Candidate Data.

8.???? Use of Artificial Intelligence Tools and Systems

ÌìÃÀ´«Ã½ is committed to a human-led and equitable recruiting process. We may use certain artificial intelligence (AI) and machine learning tools to assist our recruiters in processing applications and evaluating candidates in compliance with applicable regulations. The use of AI supports an efficient and secure recruiting process.

9.???? Disclosures of Candidate Data (Categories of Recipients)

ÌìÃÀ´«Ã½ may disclose Candidate Data to third parties for the purposes listed in this Notice and in accordance with applicable laws.

Candidate Data may be shared with one or more of the recipient categories below:

• ÌìÃÀ´«Ã½ subsidiaries and affiliates: For centralized recruitment and talent-management functions.
• Service providers / Processors: Applicant tracking systems (ATS), background check vendors, etc. that are bound by written contracts with appropriate data protection provisions.
• Government and regulatory bodies: Such as Immigration authorities.
• Professional advisors and counterparties: Such as auditors/investigators, lawyers, and their advisors (subject to confidentiality terms).

ÌìÃÀ´«Ã½ never leases or sells Candidate Data for monetary consideration.

10.?? International Data Transfers

ÌìÃÀ´«Ã½ is headquartered in the United States and operates globally. Candidate Data may therefore be transferred to, and Processed in, countries that may not provide the same level of data protection as your home jurisdiction. Where required, we implement appropriate safeguards, such as:

• Data Processing Agreements (DPAs), including Standard Contractual Clauses (SCCs) or other approved transfer mechanisms;
• Intragroup agreements;
• Technical and organizational security measures (e.g., encryption, access controls)

You may request more information about the safeguards that we have put in place to protect your Candidate Data and your privacy rights when we make cross-border transfers of your data.

11.?? Data Security

ÌìÃÀ´«Ã½ maintains organizational, technical, and physical safeguards designed to protect Candidate Data against accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure or access, in line with industry standards (e.g., NIST, ISO27001), including measures like encryption, access controls, and regular audits.

12.?? Data Retention

Candidate Data is retained only for as long as necessary to fulfill the purposes described above to comply with employment, legal, tax, accounting or reporting requirements, or to defend or assert legal claims. Retention schedules differ by data category and jurisdiction and are catalogued in internal policies and procedures. Upon expiry of the retention period, data is securely deleted or anonymized.

13.?? Your Privacy Rights

Depending on your jurisdiction, you may have Data Subject rights, similar to those listed below (see Annex for your region). ?

• Access, correct, or update your Candidate Data;
• Request erasure/deletion;
• Restrict or object to Processing;
• Receive a portable copy of certain data;
• Withdraw consent where Processing is based on consent;
• Lodge a complaint with a supervisory authority;
• Appeal automated or partially automated decisions.

ÌìÃÀ´«Ã½ recognizes and upholds applicable Candidate Data Subject rights; however, certain requests may be subject to lawful or operational limitations. Requests may be partially or fully denied if fulfillment would interfere with ÌìÃÀ´«Ã½¡¯s legal, tax, audit, or employment obligations; compromise the rights or freedoms of others; disrupt the integrity or security of ÌìÃÀ´«Ã½ systems; or expose proprietary algorithms or privileged communications.

14.?? Updates to this Notice

ÌìÃÀ´«Ã½ may update this Notice or its Annexes to reflect changes in our practices, technology, or legal requirements. The latest version is available on our website.

15.?? Definitions

The following section explains key terms used in this Notice and the Annexes so you can better understand how we handle your information. If a term is defined by privacy laws, we use the meaning given in those laws.

• Candidate Data: In this Notice, this term refers to all personal information we collect during the recruiting process. This includes what privacy laws call Personal Data, Personal Information, or Personally Identifiable Information (PII).
• Controller: ÌìÃÀ´«Ã½ is the organization responsible for deciding how Candidate Data is used, as required by laws like the EU General Data Protection Regulation (GDPR), Israel¡¯s Protection of Privacy Law, and the California Consumer Privacy Act (CCPA/CPRA).
• Personal Data: Any information that relates to an identified or identifiable person.
• Process (includes Processing, Processes, Processed): Any action we take with Candidate Data, such as collecting, storing, sharing, or deleting it.
• Sensitive Candidate Data: A special type of Candidate Data that has extra legal protections. This includes what privacy laws call ¡°Sensitive,¡± ¡°High Risk,¡± or ¡°Special Category¡± data.

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Annex A ¨C Americas

This Annex supplements the ÌìÃÀ´«Ã½ Global Applicant and Candidate Privacy Notice (the ¡°Notice¡±).

This Annex outlines additional rights, obligations, and practices under applicable local law beyond those described in the Notice. If there is any conflict between this Annex and the Notice, the provisions of this Annex shall take precedence for Candidates in the covered region.

United States ¨C California

• Applicable Laws. California Consumer Privacy Act (¡°CCPA¡±) and the California Privacy Rights Act (¡°CPRA¡±), as they may be amended or superseded from time to time.
• Candidate Data Subject Rights. California-based Candidates have the following rights:
  • Right to Know: request information about the categories and specific pieces of personal information collected.
  • Right to Access: obtain a copy of your personal information.
  • Right to Correct: request correction of inaccurate personal information.
  • Right to Delete: request deletion of personal information, subject to certain exceptions.
  • Right to Opt-Out of Sale or Sharing.
    • Note that ÌìÃÀ´«Ã½ does not sell or share Candidate Data as defined under the CCPA/CPRA.
  • Right to Limit Use of Sensitive Personal Information: restrict the use of Sensitive Personal Information to necessary business purposes.
  • Right to Non-Retaliation: protection from retaliation for exercising your privacy rights.

United States ¨C Minnesota

• Applicable Laws. Minnesota Consumer Data Privacy Act (¡°MCDPA¡±) as it may be amended or superseded from time to time.
• Candidate Data Subject Rights. Minnesota-based Candidates have the following rights:
  • Right to List: request a list of third parties to whom your data was sold.
    • Note that ÌìÃÀ´«Ã½ does not sell Candidate Data as defined under the MCDPA.
  • Right to Opt-Out: restrict sale of data, or restrict profiling, or using targeted advertising.
  • Right to Copy: obtain a copy of your data.
  • Right to Know: request information about what data has been collected.
  • Right to Edit: request correction of inaccuracies.
  • Right to Delete: request deletion personal and sensitive information.
  • Right to Question: request information on profiling and automated decision making.

United States ¨C Texas

• Applicable Laws. Texas Data Privacy and Security Act (¡°TDPSA¡±) as it may be amended or superseded from time to time.
• Candidate Data Subject Rights. Texas-based Candidates have the following rights:
  • Right to Know: request information about the categories and specific pieces of personal information collected.
  • Right to Access: obtain a copy of your personal information.
  • Right to Correct: request correction of inaccurate personal information.
  • Right to Delete: request deletion of personal information, subject to certain exceptions.
  • Right to Opt-Out: restrict sale of data, or restrict profiling, or using targeted advertising.
    • Note that ÌìÃÀ´«Ã½ does not sell or share Candidate Data as defined under the TDPSA.
  • Right to Exercise Data Subject Rights without an account
  • Right to Non-Penalization for exercising privacy rights.

Argentina

• Applicable Laws. Argentina¡¯s Personal Data Protection Law (Law No. 25,326) (¡°PDPL¡±) and proposed amendments (Bill 1948-D-2025), as they may be amended or superseded from time to time.
• Candidate Data Subject Rights. Argentina-based Candidates have the following rights:
  • Right to access: obtain a copy of your personal information.
  • Right to rectification (update/correct): request correction of inaccurate personal information.
  • Right to delete: request deletion of personal information, subject to certain exceptions
  • Right to object to certain types of processing, including automated decision-making.
  • Right to be informed about data transfers

Canada

• Applicable Laws. °ä²¹²Ô²¹»å²¹¡¯²õ Personal Information Protection and Electronic Documents Act (¡°PIPEDA¡±) and anticipated updates under the Consumer Privacy Protection Act (¡°CPPA¡±), as they may be amended or superseded from time to time.
• Candidate Data Subject Rights. Canada-based Candidates have the following rights:
  • Right to access: obtain a copy of your personal information.
  • Right to rectification (update/correct): request correction of inaccurate personal information.
  • Right to delete: request deletion of personal information, subject to certain exceptions.
  • Right to data portability: obtain and reuse your data.

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Contact Information

If you have questions about your privacy rights, this Annex, or the Applicant and Candidate Privacy Notice, please contact the ÌìÃÀ´«Ã½ Privacy Team privacy@marvell.com.

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Annex B ¨C European Economic Area (EEA) & United Kingdom (UK)

This Annex supplements the ÌìÃÀ´«Ã½ Global Applicant and Candidate Privacy Notice (the ¡°Notice¡±).

This Annex outlines additional rights, obligations, and practices under applicable local law beyond those described in the Notice. If there is any conflict between this Annex and the Notice, the provisions of this Annex shall take precedence for Candidates in the covered region.

European Economic Area

• Applicable Laws: EU General Data Protection Regulation (¡°GDPR¡±), Regulation (EU) 2016/679, and any applicable EEA member state¡¯s implementing legislation, as they may be amended or superseded from time to time.
• Candidate Data Subject Rights. EEA-based Candidates have the following rights:
  • Right to be informed about data collection and use.
  • Right to access your personal data.
  • Right to rectification of inaccurate or incomplete data.
  • Right to erasure (¡°right to be forgotten¡±) under certain conditions.
  • Right to restrict processing of your data.
  • Right to data portability.
  • Right to object to certain types of processing.
  • Rights related to automated decision-making, including profiling.

United Kingdom

• Applicable Laws: UK General Data Protection Regulation (¡°UK GDPR¡±) and the Data Protection Act 2018, as they may be amended or superseded from time to time.
• Candidate Data Subject Rights. UK-based Candidates have the following rights:
  • Right to be informed about data collection and use.
  • Right to access your personal data.
  • Right to rectification of inaccurate or incomplete data.
  • Right to erasure of personal data, subject to limitations.
  • Right to restrict processing.
  • Right to data portability.
  • Right to object to processing.
  • Rights related to automated decision-making and profiling.

Contact Information

If you have questions about your privacy rights, this Annex, or the Applicant and Candidate Privacy Notice, please contact the ÌìÃÀ´«Ã½ Privacy Team privacy@marvell.com.

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Annex C ¨C Israel

This Annex supplements the ÌìÃÀ´«Ã½ Global Applicant and Candidate Privacy Notice (the ¡°Notice¡±).

This Annex outlines additional rights, obligations, and practices under applicable local law beyond those described in the Notice. If there is any conflict between this Annex and the Notice, the provisions of this Annex shall take precedence for Candidates in the covered region.

Israel

• Applicable Laws. Israel¡¯s Protection of Privacy Law, 5741-1981 (¡°PPL¡±), as amended by Amendment No. 13, along with relevant labor court decisions and regulatory guidance issued by the Israeli Privacy Protection Authority (¡°PPA¡±), as they may be amended or superseded from time to time.
• Candidate Data Subject Rights. Israel-based Candidates have the following rights:
  • Right to access your personal data held in databases.
  • Right to rectification of inaccurate or incomplete data.
  • Right to deletion, unless retention is required by law.
  • Right to object to certain types of processing, including automated decision-making.
  • Right to be informed about cross-border data transfers.
  • Right to lodge a complaint with the Privacy Protection Authority (PPA).

Contact Information

If you have questions about your privacy rights, this Annex, or the Applicant and Candidate Privacy Notice, please contact the ÌìÃÀ´«Ã½ Privacy Team privacy@marvell.com.

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Annex D ¨C China?

This Annex supplements the ÌìÃÀ´«Ã½ Global Applicant and Candidate Privacy Notice (the ¡°Notice¡±).

This Annex outlines additional rights, obligations, and practices under applicable local law beyond those described in the Notice. If there is any conflict between this Annex and the Notice, the provisions of this Annex shall take precedence for Candidates in the covered region.

China

• Applicable Laws. China¡¯s Personal Information Protection Law (¡°PIPL¡±), along with the Cybersecurity Law and Data Security Law, and relevant labor regulations, as they may be amended or superseded from time to time.
• Candidate Data Subject Rights. China-based Candidates have the following rights:
  • Right to be informed about the purpose, method, and scope of data collection.
  • Right to access your personal data.
  • Right to correct inaccurate or incomplete data.
  • Right to delete personal data under certain conditions.
  • Right to restrict or object to specific processing activities.
  • Right to data portability, where technically feasible.
  • Right to withdraw consent, where consent is the legal basis for processing.
  • Right to lodge a complaint with the relevant supervisory authority.

Contact Information

If you have questions about your privacy rights, this Annex, or the Applicant and Candidate Privacy Notice, please contact the ÌìÃÀ´«Ã½ Privacy Team privacy@marvell.com.

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Annex E ¨C Singapore

This Annex supplements the ÌìÃÀ´«Ã½ Global Applicant and Candidate Privacy Notice (the ¡°Notice¡±).

This Annex outlines additional rights, obligations, and practices under applicable local law beyond those described in the Notice. If there is any conflict between this Annex and the Notice, the provisions of this Annex shall take precedence for Candidates in the covered region.

Singapore

• Applicable Laws. Singapore¡¯s Personal Data Protection Act 2012 (¡°PDPA¡±), including amendments introduced under the Personal Data Protection (Amendment) Act 2020, and relevant guidance issued by the Personal Data Protection Commission (¡°PDPC¡±), as they may be amended or superseded from time to time.
• Candidate Data Subject Rights. Singapore-based Candidates have the following rights:
  • Right to be informed: Receive notice of the purposes for which your personal data is collected, used, or disclosed.
  • Right to access: Request access to your personal data and information about how it has been used or disclosed in the past year.
  • Right to correction: Request correction of inaccurate or incomplete personal data.
  • Right to withdraw consent: Withdraw consent for the collection, use, or disclosure of your personal data, subject to legal and operational limitations.
  • Right to data portability: (Pending implementation) Request transfer of your personal data in a commonly used format to another organization.

Contact Information

If you have questions about your privacy rights, this Annex, or the Applicant and Candidate Privacy Notice, please contact the ÌìÃÀ´«Ã½ Privacy Team privacy@marvell.com.

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Annex F ¨C APAC

This Annex supplements the ÌìÃÀ´«Ã½ Global Applicant and Candidate Privacy Notice (the ¡°Notice¡±).

This Annex outlines additional rights, obligations, and practices under applicable local law beyond those described in the Notice. If there is any conflict between this Annex and the Notice, the provisions of this Annex shall take precedence for Candidates in the covered region.

India

• Applicable Laws. India¡¯s Digital Personal Data Protection Act, 2023 (¡°DPDPA¡±), along with relevant provisions of the Information Technology Act, 2000 (as amended), as they may be amended or superseded from time to time.
• Candidate Data Subject Rights. India-based Candidates have the following rights:
  • Right to be informed: Receive notice of the purposes and scope of personal data collection and use.
  • Right to access: Request access to your personal data and information about its processing.
  • Right to correction: Request correction of inaccurate or incomplete personal data.
  • Right to erasure: Request deletion of personal data, subject to legal and operational requirements.
  • Right to grievance redressal: Submit complaints regarding data handling to ÌìÃÀ´«Ã½ or the Data Protection Board.
  • Right to nominate: Designate another individual to exercise your rights in the event of incapacity or death.

Japan

• Applicable Laws. Japan¡¯s Act on the Protection of Personal Information (¡°APPI¡±), and relevant labor regulations, as they may be amended or superseded from time to time.
• Candidate Data Subject Rights. Japan-based Candidates have the following rights:
  • Right to be informed: Receive notice of the purposes and scope of personal data collection and use.
  • Right to access: Request disclosure of your personal data held by ÌìÃÀ´«Ã½.
  • Right to correction: Request correction of inaccurate or incomplete personal data.
  • Right to deletion: Request deletion of personal data, subject to legal and operational requirements.
  • Right to object: Object to certain uses of your personal data, particularly if used beyond the original purpose.
  • Right to data security: Expect appropriate safeguards to prevent unauthorized access, loss, or leakage.
  • Right to lodge a complaint: Submit concerns to the Personal Information Protection Commission (PPC).

South Korea

• Applicable Laws. South Korea¡¯s Personal Information Protection Act (¡°PIPA¡±), including its most recent amendments, and relevant guidance issued by the Personal Information Protection Commission (¡°PIPC¡±), as they may be amended or superseded from time to time.
• Candidate Data Subject Rights. South Korea-based Candidates have the following rights:
  • Right to access your personal data.
  • Right to rectification of inaccurate or incomplete data.
  • Right to deletion, subject to legal and operational requirements.
  • Right to suspend processing of personal data under certain conditions.
  • Right to be informed about third-party disclosures and cross-border transfers.
  • Right to lodge a complaint with the Personal Information Protection Commission (PIPC).

Vietnam

• Applicable Laws. Vietnam¡¯s Decree No. 13/2023/ND-CP on Personal Data Protection (¡°Decree 13¡±), effective July 1, 2023, along with relevant provisions of the Law on Cybersecurity and Civil Code, and relevant labor regulations, as they may be amended or superseded from time to time.
• Candidate Data Subject Rights. Vietnam-based Candidates have the following rights:
  • Right to be informed about the processing of your personal data.
  • Right to consent to specific processing purposes (consent must be explicit and documented).
  • Right to access your personal data.
  • Right to correct inaccurate or incomplete data.
  • Right to delete personal data under certain conditions.
  • Right to restrict or object to processing activities.
  • Right to withdraw consent, subject to legal and operational limitations.
  • Right to data provision (portability).
  • Right to lodge a complaint and seek compensation for violation.

Contact Information

If you have questions about your privacy rights, this Annex, or the Applicant and Candidate Privacy Notice, please contact the ÌìÃÀ´«Ã½ Privacy Team privacy@marvell.com.