Small Parts, Inc. (“Small Parts”, “we”, “us”, or “our”), respects your privacy and are committed to protecting it through our compliance with this Privacy Policy (this “Policy”). We are a 100% employee-owned (ESOP) precision manufacturer and member of the MPI Companies family of businesses, with operations in Logansport, Indiana; Beaumont, California; Ciudad Juárez, Mexico; and Reynosa, Mexico. This Policy describes how we collect, use, disclose, and otherwise process Personal Information when you visit www.smallpartsinc.com and any associated subdomains, portals, mobile-optimized pages, request-for-quote tools, careers interfaces, and other online services that link to this Policy (collectively, the “Site”), and our practices for using, maintaining, protecting, and disclosing that information. This Policy also explains the rights and choices you may have with respect to your Personal Information.

This Policy applies only to information we collect:

through the Site.
when you communicate with us by email, text, chat, and other electronic messages, between you and the Site.
when you interact with our advertising and applications (including mobile apps) on third-party websites and services, if those applications or advertising include links to this policy.]

This Policy does not apply to information collected by:

us offline or through any other means, including on any other website operating by the Company or any third party (including our affiliates and subsidiaries) that does not link to this Policy; or
any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or through the Site.

Additional information about the collection and use of the Personal Information of Small Parts employee-owners or contractors is addressed under our internal human resources policies and applicable law.

We may provide additional or different privacy policies that are specific to certain features, services or activities.

Please read this Policy carefully. By accessing or using the Site or otherwise providing Personal Information to us, you acknowledge that you have read and understood this Policy. If you do not agree, please do not use the Site or provide Personal Information to us. This policy may change from time to time (see Changes to This Policy). Your continued use of the Services after we make changes as to the Policy is deemed to be acceptance of those changes, so you should review the Policy periodically for updates.

At a Glance

Below is a brief summary of this Policy. The summary is provided for convenience only and is qualified in its entirety by the remainder of the Policy.

What we collect: Personal Information, business information, content of communications, employment application information, technical drawings and files you upload for quoting, device and usage information, and limited cookie data.
Why we collect it: to respond to your inquiries and RFQs, manage customer and supplier relationships, evaluate job applications, operate and improve the Site, communicate with you, support our security and compliance programs, and comply with law.
Who we share it with: our affiliated MPI Companies businesses, service providers (such as hosting, analytics, applicant tracking, and email vendors), professional advisors, and government and other authorities when legally required.
Your choices: you can update your information, unsubscribe from marketing email, adjust browser cookie controls, and exercise the rights described below, including rights available to California residents.
How to reach us: you can write to us at our office address (see Contact Us) or write to [email protected].

1. Information We Collect

We collect Personal Information from three principal sources: (i) information you provide to us directly; (ii) information collected automatically when you interact with the Site; and (iii) information we receive from third parties and other sources.

“Personal Information” is information that identified, relates to, or describes, directly or indirectly, you as an individual. The types and categories of personal data we collect or process include:

identifiers and contact information, including first and last name, job title, employer or business name, business address, business email address, telephone number, and country of residence;
commercial and transactional information, including the products, services, capabilities, or industries about which you are inquiring; project descriptions; volume and timing expectations; preferred facility location (Logansport, IN; Beaumont, CA; Juárez, MX; Reynosa, MX); and the content of any RFQ, drawing, or specification;
technical files and documents that you choose to upload, including engineering drawings, models, and specifications in formats such as PDF, DXF, and STEP (up to 25 MB), together with any Personal Information those files may contain;
employment application information, including resume, work history, education, skills and qualifications, references, professional licenses and certifications, work authorization status (to the extent permitted by applicable law), voluntary demographic information you choose to provide for equal employment opportunity reporting, and any other information you submit through our applicant tracking system or other careers tools;
communications content, including the contents of any email, telephone call, voicemail, video conference, chat, message submitted through a form, or other correspondence you direct to us; and
any other information you choose to provide.

2. HOW WE COLLECT YOUR PERSONAL INFORMATION

2.1 Information You Provide Directly

You may provide Personal Information when you interact with the Site, such as when you submit a request for quote (“RFQ”), use the contact form, request engineering consultation, request a facility visit, apply for a job, join our talent network, subscribe to communications, request marketing materials or product information, attend a trade show or other event at which we collect information, or otherwise communicate with us.

2.2 Information Collected Automatically

When you access or use the Site, we and our service providers may automatically collect certain information about your device, browser, and usage of the Site. Categories of this information include:

device and connection information, such as internet protocol (IP) address, device type, operating system, browser type and version, language preferences, screen resolution, and mobile network information;
usage and analytics information, such as the pages and content you view, the search terms you use, the links you click, the date and time of your visits, the duration of your visits, the pages from which you arrive and to which you depart, scroll depth, and similar engagement signals; and
approximate geolocation, inferred from IP address.

See Section 6 (Cookies and Similar Technologies) for more detail.

2.3 Information From Third Parties and Other Sources

We may receive Personal Information about you from third parties and other sources, including:

our affiliates and the other operating companies of MPI Companies;
our service providers, such as our website host, analytics providers, email marketing platform, customer relationship management (CRM) tools, and applicant tracking system provider (Breezy HR or its successor);
publicly available sources, business directories, professional networking sites (such as LinkedIn), and industry association rosters (such as the Precision Metalforming Association, ASM International, the Metal Treating Institute, and INDEX);
referrals from your colleagues, employer, recruiters, or other persons;
business contacts you authorize as references in the employment application process; and
government, regulatory, and standards bodies in connection with our certifications and compliance activities.

3. How We Use Personal Information

We use Personal Information for the business and commercial purposes described below. Where required by applicable law, we will obtain your consent before processing Personal Information for any purpose that requires consent, and you may withdraw that consent at any time.

Operating the Site and Responding to You

to provide, maintain, secure, troubleshoot, and improve the Site and its features;
to receive, evaluate, and respond to your RFQs, engineering inquiries, contact form submissions, and other communications;
to provide you with information, capability literature, certifications, drawings, and quotations you request;
to schedule and coordinate facility visits, calls, and meetings.

Customer, Supplier, and Business Relationships

to onboard and manage current and prospective customer, supplier, and business partner relationships;
to enter into and perform agreements with the company or organization you represent;
to administer accounts, orders, deliveries, payments, returns, and warranty matters;
to perform due diligence, including screening against sanctions and denied party lists as required by U.S. export control and economic sanctions laws.

Careers and Recruiting

to review and process your employment application and assess your candidacy for current or future openings at Small Parts and the other MPI Companies businesses;
to communicate with you about your application, interview scheduling, and the status of openings;
to verify the information you provide, conduct interviews and reference checks, and — where permitted by law and with notice and consent as required — conduct background or other pre-employment checks before extending an offer;
to maintain our talent network and contact you about future opportunities;
to comply with equal employment opportunity, work authorization, and other employment-related laws and to support our diversity and inclusion reporting.

Marketing, Communications, and Events

to send you, in compliance with applicable law, communications about our capabilities, industries served, certifications, equipment, events, and other content we believe may be of interest;
to invite you to webinars, trade shows, plant tours, and other events; and
to measure the effectiveness of our marketing and communications.

You may opt out of marketing email at any time using the “unsubscribe” link in those messages or by contacting us as described in Section 15 (Contact Us). We may still send you transactional or relationship messages (for example, replies to your inquiries) after you opt out of marketing.

Analytics and Improvement

to understand how visitors find, use, and interact with the Site;
to test and develop new features, content, and capabilities; and
to measure the performance of campaigns and content.

Security, Compliance, and Legal

to protect the security and integrity of the Site, our systems, our personnel, our facilities, and our business;
to detect, investigate, and prevent fraud, abuse, security incidents, and other malicious, deceptive, or unlawful activity;
to comply with applicable law, regulation, court order, subpoena, government request, and our internal policies, including those relating to quality, anti-bribery, export controls (including the ITAR and the EAR), economic sanctions, and customs;
to establish, exercise, or defend legal claims; and
for general business administration, including audits, internal reporting, and corporate transactions such as mergers, acquisitions, financings, divestitures, restructurings, and asset sales.

Aggregate and De-Identified Data

We may aggregate or de-identify Personal Information so that it can no longer reasonably be associated with an identified or identifiable individual and use that information for any purpose. If we de-identify Personal Information, we will maintain and use it in de-identified form and will not attempt to re-identify it except as permitted or required by law.

4. How We Disclose Personal Information

We disclose Personal Information for the business and commercial purposes described above to the categories of recipients set out below. We do not sell Personal Information for monetary consideration.

4.1 Affiliates

We share Personal Information with our parent, subsidiaries, and other affiliated operating companies of MPI Companies for the purposes described in this Policy, including providing coordinated customer service, evaluating candidates across our companies, internal reporting, and back office support.

4.2 Service Providers and Processors

We share Personal Information with third-party vendors and service providers that perform services on our behalf, under contract, only for purposes consistent with this Policy. Categories include:

website hosting, content delivery, security, and IT infrastructure providers;
analytics providers (for example, providers of web analytics tools);
email marketing, CRM, and communications platforms;
applicant tracking system providers, including Breezy HR, and background check, reference check, and assessment vendors used in recruiting;
payment processing and accounting providers (for customer and supplier billing);
logistics, customs, and shipping providers;
professional advisors such as attorneys, accountants, auditors, insurers, and consultants;
vendors that help us host plant tours, trade shows, and events.

4.3 Business Partners

We may share Personal Information with business partners with whom we jointly offer products, services, capabilities, or events, but only as needed for those joint activities. These partners include MPI Companies sister operating companies, customers, distributors, and select third parties whose offerings complement ours.

4.4 Government Authorities and Legal Process

We may disclose Personal Information to government authorities, law enforcement agencies, regulators, courts, and other third parties when we believe in good faith that doing so is necessary or appropriate to: (a) comply with applicable law, regulation, legal process, or governmental request, including in connection with U.S. export control, sanctions, customs, and tax laws; (b) respond to subpoenas, warrants, and court orders; (c) protect our rights, property, safety, employee-owners, customers, or others; (d) investigate or prevent fraud, security, or other illegal activity; or (e) enforce our agreements and policies, including these Terms and any terms and conditions of sale.

4.5 Corporate Transactions

If Small Parts or any of its affiliates is involved in a merger, acquisition, financing, reorganization, restructuring, sale of assets, or similar transaction, or in the event of insolvency, bankruptcy, or receivership, Personal Information may be transferred or disclosed to the counterparties and their advisors as part of due diligence and as part of the transferred assets, subject to appropriate confidentiality protections.

4.6 With Your Consent or At Your Direction

We may disclose Personal Information for any other purpose with your consent or at your direction.

5. Legal Bases for Processing (EEA, UK, and Similar Jurisdictions)

To the extent the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”), the UK GDPR, or a similar law applies to our processing of your Personal Information, we rely on the following legal bases:

Performance of a contract: to take steps at your request prior to entering into a contract, and to perform a contract to which you or your employer or principal is a party (for example, processing your RFQ or job application, or fulfilling an order).
Legitimate interests: our or a third party’s legitimate interests, where those interests are not overridden by your rights and interests — for example, operating and securing our Site, marketing to business contacts, managing our business and personnel, and pursuing or defending legal claims.
Legal obligation: to comply with our legal and regulatory obligations, including export control, tax, customs, employment, and corporate records obligations.
Consent: where you have given consent (for example, for certain marketing activities, where required).
Vital interests: in rare cases, to protect your or another person’s vital interests.

Where we rely on legitimate interests, you may have the right to object to that processing, as described in Section 9 (Your Rights and Choices).

6. Cookies and Similar Technologies

We and our service providers use cookies, web beacons, pixels, tags, scripts, and similar tracking technologies (collectively, “cookies”) to recognize you and your device, remember your preferences, understand how the Site is used, and measure the effectiveness of our content.

We use the following categories of cookies:

Strictly necessary cookies, which are required for the Site to function. These cannot be disabled in our systems.
Performance and analytics cookies, which help us understand how visitors interact with the Site by collecting information such as the pages visited, time on page, navigation paths, and errors encountered.
Functional cookies, which remember choices you make (for example, language) to provide a more personalized experience.
Targeting and advertising cookies, which may be set by us or our partners to build a profile of your interests and show you content more relevant to you on our Site or others. To the extent we use these on the Site, we will do so in a manner consistent with applicable law and any consent banner displayed on the Site.

Most browsers let you refuse or accept cookies and clear them at any time. You can also typically set your browser to alert you when cookies are being placed. If you reject cookies, certain parts of the Site may not function properly. Some web browsers (including Safari, Edge, and Firefox) may transmit “Do Not Track” signals; because there is no industry consensus on how to respond to these signals, we currently do not respond to them, except that we will honor opt-out preference signals such as the Global Privacy Control (“GPC”) where required by law.

7. Third-Party Services and Plug-Ins

The Site may include embedded content, maps, videos, plug-ins, or links to third-party websites or services, including those of MPI Companies and other operating companies, customers, certifying bodies, social media platforms (such as LinkedIn), video platforms, mapping providers, and our applicant tracking system provider (Breezy HR). These third parties may collect information about you when you interact with their features. Their processing of your Personal Information is governed by their own privacy policies. We are not responsible for the privacy practices of these third parties, and we encourage you to read their policies.

8. Data Security and Retention

We maintain administrative, technical, and physical safeguards designed to protect Personal Information against unauthorized access, use, alteration, destruction, and disclosure. These safeguards include access controls, encryption in transit for web traffic to and from the Site, vendor due diligence, training, and incident response procedures aligned with the quality and information security expectations of the certified standards under which we operate, including IATF 16949:2016, AS9100D, ISO 9001:2015, and ISO 14001:2015. No method of transmission over the internet or method of electronic storage, however, is 100% secure. We cannot guarantee absolute security, and you are responsible for keeping any credentials and devices you use to access the Site secure.

We retain Personal Information for as long as necessary to fulfill the purposes for which it was collected, to provide our services, to maintain our business records, and to comply with our legal, regulatory, tax, accounting, and reporting obligations, after which it will be deleted, destroyed, or de-identified. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the information; the potential risk of harm from unauthorized use or disclosure; the purposes for which we process the information; whether we can achieve those purposes through other means; and applicable legal requirements.

9. Your Rights and Choices

Depending on where you live and subject to applicable law, you may have certain rights with respect to your Personal Information. These may include:

Right to know / access: to confirm whether we process Personal Information about you and to obtain a copy or description of that information and of how we process it.
Right to correct: to request correction of inaccurate or incomplete Personal Information about you.
Right to delete: to request deletion of Personal Information we hold about you, subject to certain exceptions.
Right to data portability: to receive a copy of certain Personal Information in a portable, readily usable format, or to have it transmitted to another controller, where technically feasible.
Right to opt out of sale or sharing: to opt out of the “sale” or “sharing” of Personal Information as those terms are defined under applicable law. As stated above, we do not sell Personal Information for monetary consideration; see Section 10 (Notice to California Residents) for California-specific policies.
Right to limit use of sensitive Personal Information: to direct us to limit our use of sensitive Personal Information to permitted purposes, where this right is provided by law.
Right to object or restrict processing: to object to or restrict certain processing, including direct marketing and processing based on legitimate interests, where this right is provided by law.
Right to withdraw consent: to withdraw any consent you have given, without affecting the lawfulness of processing based on consent before its withdrawal.
Right against automated decision-making: not to be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects, where this right is provided by law. We do not currently use solely automated decision-making in connection with the Site.
Right to lodge a complaint: to lodge a complaint with a supervisory authority where you live, work, or believe an alleged infringement occurred.
Right of non-retaliation: we will not discriminate or retaliate against you for exercising any of these rights.

To exercise these rights, please contact us using the information in Section 15. We will respond to verifiable requests within the time periods required by applicable law. To protect your privacy and security, we will take reasonable steps to verify your identity before fulfilling your request, and we may need to ask you for additional information. You may use an authorized agent to make a request on your behalf, subject to verification.

10. Notice to California Residents (CCPA/CPRA)

This Section 10 supplements the rest of the Policy and applies only to natural persons who reside in California (“consumers” or “you”) and whose Personal Information we process. We provide this notice under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively, the “CCPA”). Capitalized terms used in this Section 10 and not otherwise defined have the meanings given to them in the CCPA. We employ team members in California and operate a manufacturing facility in Beaumont, California.

10.1 Categories of Personal Information Collected and Disclosed

In the preceding twelve (12) months, we have collected the following categories of Personal Information about California consumers, as those categories are described in the CCPA:

CCPA Category	Examples	Collected
A. Identifiers	Name, business address, business email, telephone number, account name, IP address.	Yes
B. Customer records (Cal. Civ. Code § 1798.80(e))	Name, signature, employer, contact information.	Yes
C. Protected classifications	Age, citizenship/work authorization (in recruiting); voluntary EEO demographics.	Yes (recruiting only)
D. Commercial information	Records of products or services purchased, obtained, or considered.	Yes
E. Biometric information	Not collected through the Site.	No
F. Internet or other network activity	Browsing history, search history, information on interaction with the Site.	Yes
G. Geolocation data	Approximate location inferred from IP address.	Yes (approximate)
H. Sensory information	Recordings of calls and security/video footage at our facilities (with notice).	Sometimes
I. Professional or employment-related information	Job history, qualifications, references, role with a customer or supplier.	Yes
J. Non-public education information	Education history submitted in job applications.	Yes (recruiting only)
K. Inferences	Inferences drawn from the above to create a profile reflecting preferences, predispositions, behavior, or aptitudes.	Limited
L. Sensitive Personal Information	Government identifiers (e.g., for work authorization in recruiting); account log-in credentials. We do not use sensitive Personal Information for purposes that would require an opt-out under the CCPA.	Limited

Sources of collection, business and commercial purposes, and categories of recipients to whom we disclose each category are described above in Sections 1 through 4.

10.2 No Sale or Sharing for Cross-Context Behavioral Advertising

We do not sell Personal Information for monetary consideration, and we do not knowingly sell or share the Personal Information of California consumers within the meaning of the CCPA. We do not knowingly engage in “sharing” Personal Information for cross-context behavioral advertising. We do not have actual knowledge that we sell or share the Personal Information of consumers under eighteen (18) years of age.

10.3 Retention

We retain each category of Personal Information for the period described in Section 8.

10.4 California Rights

California consumers have the rights described in Section 9, including the rights to know, access, correct, delete, and (where applicable) limit the use and disclosure of sensitive Personal Information. To make a verifiable consumer request, please use the contact information in Section 15 or, if available, the “Do Not Sell or Share My Personal Information” or “Your Privacy Choices” link displayed on the Site. We will not discriminate against you for exercising these rights.

10.5 Shine the Light

California Civil Code Section 1798.83 permits California residents who have an established business relationship with us to request information once per year about our disclosures of certain categories of Personal Information to third parties for those third parties’ direct marketing purposes. To make such a request, please contact us as described in Section 15.

11. International Data Transfers

Small Parts is headquartered in the United States and has affiliated operating companies and facilities in the United States and Mexico. We use service providers located in various countries. Personal information that we collect may be transferred to, stored in, or processed in countries other than the country in which you reside, including the United States. Data protection laws in those countries may differ from, and in some cases offer less protection than, the laws of your country.

Where required by law, we implement appropriate safeguards for international transfers, which may include standard contractual clauses approved by the European Commission, the UK International Data Transfer Addendum, or other lawful transfer mechanisms. By using the Site or providing Personal Information to us, you understand that your information may be transferred internationally for the purposes described in this Policy, subject to those safeguards.

12. Children’s Privacy

The Site is intended for a business audience and is not directed to, or intended for, children under the age of eighteen (18). We do not knowingly collect Personal Information from children under the age of eighteen (18). If we learn we have collected or received Personal Information from a child under eighteen (18) years old without verification of parental consent, we will delete that information. If you are a parent or guardian and believe that your child has provided Personal Information to us, please contact us as described in Section 15 so that we can delete the information.

13. Changes to This Policy

We may update this Policy from time to time , and we will provide notice of any such changes to this Policy as required by law. The date the Policy was last updated is identified at the top of the page. We will notify you of changes to this Policy by updating the “Last Updated” date at the top of this Policy and post the updated Policy on the Site. We may email or otherwise communicate reminders about this Policy, but you should check the Site periodically to see the current Policy and any changes we have made to it.

14. Accessibility and Language

We are committed to making our Site, including this Policy, accessible to people with disabilities. If you need this Policy in an alternative format or language, please contact us using the information in Section 15, and we will make reasonable efforts to accommodate you.

15. Contact Us

If you have questions, comments, or requests regarding this Policy or our privacy practices, please contact us using one of the methods below. We will respond as promptly as we can and within the time periods required by applicable law.

Small Parts, Inc.

Attn: Privacy Officer / Legal Department

600 Humphrey Street

Logansport, IN 46947, USA

Telephone: 574-753-6323

Email: [email protected]

For inquiries related to MPI Companies operating companies other than Small Parts, please consult the privacy notice of the applicable operating company.