Effective as of February 1, 2024
Hypertherm, Inc. (“Hypertherm,” “we”, “our”, or “us”) takes privacy seriously and wants to provide transparency regarding our privacy practices. This Privacy Notice is intended to describe how Hypertherm gathers information through our websites and our web-based and mobile applications (the “Apps/Sites”) and how Hypertherm may use, process, transfer, or share that information. If you are a current or former employee or job applicant who resides in California, please see the section “Additional Information for Employees and Job Applicants who are California Residents” for more information about how we may collect, use, or disclose your personal information for employment-related purposes.
Without prejudice to your rights under applicable laws, this Privacy Notice is not contractual and does not form part of your contract with us.
Information We Collect
As described in this Privacy Notice, we may collect certain Personal Information from or about you in connection with our provision of the Apps/Sites and services. “Personal Information” generally includes information about you that is linked to you as an identifiable individual. Subject to applicable law, Personal Information does not include de-identified data or publicly available information.
The sources and types of Personal Information we collect may vary depending upon our relationship with you and how you interact with us. For example, we may collect information from or about the following categories of Personal Information:
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Categories of Personal Information |
Examples of Personal Information |
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| Identifiers |
First and last name; business address; business email address; business name; business phone number; email address; telephone number; and/or other similar identifiers |
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Commercial and financial information |
Products or services purchased, obtained, or considered; product and service usage history; payment history or account activity; financial or bank account information and other information relating to your financial institution, including payment card information; and/or other purchasing or consumer histories or tendencies |
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Internet or other electronic network activity information |
Browsing and app history; clickstream data; browser and operating system type; navigation paths; date/time stamps; cookie identifiers; clear gifs; Internet service provider (ISP); referring/exit pages; device identifiers; and other information about device characteristics and how you interact with our Apps/Sites and services |
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Geolocation data |
Device location; geolocation; IP address; cell network data; and/or other similar locational data |
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Inference information |
Inferences we may infer from other Personal Information we have collected, which may include preferences and characteristics |
If you would like to update or correct your email address, street address or other personal information, contact us using the information in the Contact Us section.
Account Registration. You may register for an account to use certain services and functionality offered by our web-based or mobile applications, such as to measure or monitor the performance of our products and solutions or to manage the calibration or maintenance of our products and solutions. Personal information associated with your account is stored separately from other personal information we may collect about you through your use of the Apps/Sites.
Cookies and Similar Technologies. We may collect certain Personal Information using cookies and other technologies, such as web beacons, device IDs, geolocation, HTML5 local storage, Flash cookies, and IP addresses. We specifically use browser cookies for different purposes, including cookies that are strictly necessary for functionality and cookies that are used for personalization, performance/analytics, and advertising. When you use or visit the Apps/Sites we may also automatically collect certain data about your device, including information about your web browser, IP address, and time zone. Additionally, as you browse the Apps/Sites, we may collect information about the individual web pages or products that you view, what websites or search terms referred you to the Apps/Sites, and information about how you interact with the Apps/Sites. Our Use of Cookies and Similar Technologies section contains more information and options to control or opt-out of certain data collection or uses related to cookies and similar technologies.
Aggregated, De-identified, or Anonymous Data. We may create aggregated, de-identified, or anonymous information from Personal Information by removing data components (such as your name, email address, or linkable tracking ID) that makes the data identifiable, or through aggregation, obfuscation, or other means. For example, we may use aggregated, de-identified, or anonymized information to understand how to improve or enhance our services. Subject to applicable law, our use of such aggregated, de-identified, or anonymized information is not Personal Information or subject to this Privacy Notice.
1. SOURCES OF INFORMATION AND PURPOSES OF COLLECTION AND PROCESSING
The following is intended to describe the various sources through which we may collect Personal Information and the purposes for which we collect and process it. As noted above, the sources and types of Personal Information and our purposes may vary depending upon our relationship with you:
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Sources of Personal Information |
Categories of Personal Information from Source |
Purposes of Collection and Use |
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Communications and Interactions with Us or on Our Behalf We may collect Personal Information from you when you interact with the Apps/Sites or services, register for the services, sign up for or participate in our events or programs, submit inquiries or request information from us, complete surveys, or otherwise contact or communicate with us directly by email, telephone, or a messaging service (including web-based chat services). We may also collect Personal Information from you when we process your requests to us, including sales and service requests (such as by field service personnel), and requests for information. |
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Communications and Interactions with Us via Social Media We may collect Personal Information from you through Social Media when we send you targeted marketing communications, or when you contact or communicate with us directly via Social Media. |
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By Participating In Sweepstakes, Other Promotions, and Customer Research We may collect Personal Information from you or your authorized representatives when you participate in a sweepstakes or other promotion that we sponsor, or when you engage in customer research or surveys that we have sponsored. |
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Account Administration and Transactions We may collect Personal Information from you and from records we create in connection with administering your account, when you complete transactions, or when we send you surveys pertaining to your transactions or customer satisfaction. We may also collect Personal Information from you when you register for an account to use our mobile apps or when you use our mobile apps while logged into your account. |
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Marketing, Direct Sales, and Conversion Tracking Interactions with Us We may collect Personal Information from you when we send you marketing information about our products, services, sales, events, and/or promotions via phone, email, or other means. We may also share information across our business units or brands to identify or facilitate potential sales opportunities. We may use Personal Information to improve how we reach you, the content we share with you, to conduct market research, and to improve business operations, our platform, and overall customer engagement. |
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From Business Partners and Service Providers We may collect Personal Information from our business partners, service providers, third-party training and e-commerce platforms, data providers, and from publications. We may also collect Personal Information from third parties who are authorized to act on our behalf, or to facilitate sales or service interactions. |
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Please note, when you purchase from us online or through our catalogs, or when you choose to enter a sweepstakes or other promotion, we may need to contact you via phone, email or mail to address questions or issues specific to your order, entry, etc., even if you have opted to not receive communications.
2. HOW WE MAY SHARE INFORMATION
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Categories of Third Parties with Whom We May Share Personal Information |
Categories of Personal Information We May Share |
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Channel Partners Hypertherm sells its products through channel partners. When you contact us regarding purchasing a Hypertherm product or service, we may share your personal data with a channel partner in order to fulfill your request. |
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Affiliates Hypertherm may share Personal Information with our business units, subsidiaries, joint ventures, brands, or other companies under our common control (collectively, “Affiliates”) for the purposes described in this Privacy Notice. We will require our Affiliates to honor this Privacy Notice. |
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Technical and Operational Service Providers and Business Partners We may engage third parties to perform certain functions on our behalf. To do so, we may disclose Personal Information to our third-party business partners and service providers in order to maintain and operate the Apps/Sites and to provide, improve, and personalize the services, including to fulfill orders or requests for the services, process credit card transactions, to administer your account, and for other technical and processing functions, such as sending e-mails on our behalf, administering transactions, and technical support. We may also share Personal Information with service providers or other third parties to detect, protect against, and respond to security incidents or other malicious, deceptive, illegal, or fraudulent activity or other threats and for legal compliance purposes or pursuant to legal process. |
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Marketing, Advertising, and Analytics Providers for Our Marketing and Brand Purposes We may share Personal Information with third-party providers for marketing, advertising, and analytics purposes. For additional information regarding our advertising practices, please see the Advertising section. We may also share Personal Information with third-party providers for commercial prospecting, product development, and to conduct product and branch perception and awareness surveys. |
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Government Entities and Legal Compliance We may share Personal Information with government entities and agencies, regulators, law enforcement, and other third parties, including to comply with laws or regulations or the legal process of a court of law, government authority, or an industry self-regulatory organization having appropriate jurisdiction; to respond to a subpoena, search warrant, or pursuant to legal process, and for fraud- or crime-prevention purposes; or to establish, exercise, protect, and/or defend the rights of Hypertherm, or the rights or safety of third parties. |
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Professional Service Firms We may share Personal Information with professional service firms in connection with our legal and regulatory obligations and to establish or exercise our rights and defend against claims, including, for example, auditors, law firms, and consultants. |
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Corporate Transactions Subject to applicable law, we reserve the right to transfer some or all Personal Information in our possession to a successor organization in the event of a merger, acquisition, bankruptcy, re-organization, or other sale or transfer of all or a portion of our assets, or in contemplation of any such proposed transaction, including for the purpose of permitting the due diligence required to decide whether to proceed with such a transaction. If any such transaction occurs, the purchaser will be entitled to use and disclose the Personal Information collected by us in the same manner that we are able to, and the purchaser will assume the rights and obligations regarding Personal Information as described in this Privacy Notice. |
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3. USE OF COOKIES AND SIMILAR TECHNOLOGIES
The Apps/Sites may use cookies and similar technologies to improve user experience, for performance and analytics, and to improve our content, products, and services. We may also use cookies and similar technologies for purposes of marketing and advertising, including interest-based advertising. For more information on interest-based advertising, see the Advertising section.
A “cookie” is a small text file that a web server stores in browser software. A browser sends cookies to a server when the browser makes a connection to the server (for example, when requesting a web page from the same domain that created the cookie). The purpose of cookies is to remember the browser over time and distinguish one browser instance (or user) from all others. Some cookies and other technologies may serve to track Personal Information previously entered by a web user on the Apps/Sites. Cookies can remember login information, preferences, and similar information.
Hypertherm’s policy is that Cookies do not carry identification or password data that allows access to your Personal Information stored on Hypertherm servers. Generally, we use cookies to remind us of who you are, tailor our products and services to suit your personal interests. Cookies help us to process your order; track your status in our promotions, contests, and sweepstakes; and/or analyze your visiting patterns. Cookies, as well as other tracking technologies, such as HTML5 local storage, and Local Shared Objects (such as “Flash” cookies), and similar mechanisms, may record information such as a unique identifier, information you enter in a form, IP address, and other categories of data. We may use cookies to collect certain information about you and your use of our services and offerings, such as IP addresses, domain names, and the type of device and operating system being used. We may also use cookies to identify your device when you revisit the Apps/Sites to, for example, track statistical information related to navigation throughout the Apps/Sites. We may also use web beacons or “pixels,” and in certain circumstances may collect IP address, screen resolution and browser software and operating system types, clickstream patterns, dates, and times that our Apps/Sites are accessed, and other categories of data.
The Apps/Sites currently use Google Analytics. Please read “How Google uses data when you use our partners’ sites or apps,” which you can find at https://www.google.com/policies/privacy/partners/, for information about how Google Analytics collects and processes data. If you wish to opt out of Google Analytics, please visit https://tools.google.com/dlpage/gaoptout.
Most browsers allow you to control cookies, including whether or not to accept them and to remove them. If you want to block the use and saving of cookies from the Apps/Sites on to the computer’s hard drive, you should take the necessary steps within your web browser’s settings to block all cookies from the Apps/Sites and external serving vendors. You can generally set your browser to not accept cookies or to notify you when you are sent a cookie, giving you the chance to decide whether or not to accept it. Please note that if you choose to erase or block your cookies, or otherwise delete certain information, certain parts of our Apps/Sites or services may not function correctly and you may not be able to continue to purchase products. For information on how to disable cookies, refer to your browser’s documentation. For more information, go to manage my cookie preferences.
We or third parties may conduct certain advertising practices on our Apps/Sites as described below.
Interest-Based Advertising and Ad Choices
Interest-based advertising is advertising that is targeted to you based on your web browsing and app usage over time and across websites or apps. You have the option to restrict the use of information for interest-based advertising and to opt-out of receiving interest-based ads.
The opt-outs for interest-based advertising require that strictly necessary cookies are not blocked by the settings in your web browser. To learn more about this type of advertising and how to opt-out of this form of advertising, you may either visit optout.aboutads.info to opt-out of sites and services participating in the Digital Advertising Alliance (“DAA”) self-regulatory program, or visit optout.networkadvertising.org to opt-out of this form of advertising by members of the Network Advertising Initiative (“NAI”). If you live in the United States, you can visit Ad Choices to opt-out of interest-based advertising with participating entities for each region. These websites also provide detailed information about how interest-based advertising works.
Opting out does not mean that you will no longer receive advertising from us, or when you use the Internet. It just means that the data collected from our Apps/Sites will not be used for interest-based advertising. Note that electing to opt-out will not stop advertising from appearing in your browser or applications, although it may make the ads you see less relevant to your interests.
Your choice to opt out on a particular browser or mobile device will apply only to the collection and use of information from that particular browser or mobile device. Opting out on a particular device will not opt you out of information collection on other devices (including mobile devices), nor will it limit cross-device sharing on those other devices. Similarly, opting out on a particular browser will not opt you out of information collection on other browsers. (This opt-out works through cookies set on a particular browser, so if you delete cookies from a web browser, or use a different browser, you will need to opt out again.) If you use different browsers on a device or multiple mobile devices, for each browser and device you wish to opt out, please opt out each device and browser separately at optout.aboutad.info and at optout.networkadvertising.org.
Do-Not-Track
Do-Not-Track is a public-private initiative that has developed a “flag” or signal that an Internet user may activate in the user’s browser software to notify websites that the user does not wish to be “tracked” by third parties as defined by the initiative. Please note that the Apps/Sites do not alter their behavior or use practices when we receive a “Do Not Track” signal from browser software.
5. INFORMATION FROM CHILDREN UNDER 18
On our Apps/Sites, we do not intentionally gather Personal Information from individuals under the age of 18. If you become aware that an individual under 18 years of age has provided us with Personal Information without parental consent, please contact us at the information in the How You Can Contact Us section. If we become aware that an individual under 18 years has provided us with Personal Information without parental consent, we will take steps to remove the data as permitted by law.
6. SECURITY
Hypertherm takes the privacy and security of individuals and their personal information very seriously. We have implemented technical, administrative, and organizational measures to safeguard the security and integrity of Personal Information. Although Hypertherm takes these measures to safeguard against unauthorized access and disclosure of Personal Information, Hypertherm cannot fully eliminate security risks associated with the storage and transmission of Personal Information. Once we receive your transmission, we will use all commercially reasonable efforts to protect its security on our systems.
7. LINKS TO OTHER WEBSITES
Our Apps/Sites and services may contain links or otherwise provide access to another website, mobile application, or Internet location (collectively “Third-Party Sites”). Please note that we have no control over and are not responsible for Third-Party Sites, their content, or any goods or services available through the Third-Party Sites. Our Privacy Notice does not apply to Third-Party Sites. We encourage you to read the privacy policies of any Third-Party Site with which you choose to interact.
Hypertherm posts information about programs and events that are sponsored by or co-sponsored by other organizations. Should you choose to register electronically for any of these events, Hypertherm will have no control over the third-party sponsors' use of this information.
8. YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
This section describes the rights you may have with respect to your Personal Information as well as how to exercise those rights. Subject to applicable law, you may have the right to request confirmation from us as to whether or not we are processing your Personal Information. Where we are processing your Personal Information, subject to applicable law, you may also have the following rights regarding your Personal Information:
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Request access to, modification of, or correction of your Personal Information. You may have the right to request access to, modification of, or correction of your Personal Information. If you have registered for an account, you can also make changes to your Personal Information within your account settings.
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Request deletion of your Personal Information. You may have the right to request that we delete the Personal Information that we have collected about you.
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Data portability. In certain circumstances, you may have the right to receive the Personal Information concerning you that you provided to us or to request that we transmit your Personal Information to another data controller.
Depending on where you live, you may be entitled by law to exercise some or all of the rights described above. If you are not entitled to these rights under applicable law, we may offer such rights to you voluntarily and at our discretion, and we reserve the right to limit or revoke any such rights at any time, as may be permitted by applicable law.
To exercise your rights, please contact us at the email or telephone number in the How You Can Contact Us section of this Privacy Notice. If you have registered for an account, you can also access and update certain Personal Information within your account. You may also authorize someone to exercise the above rights on your behalf.
As permitted by law, certain data elements may not be subject to access, modification, portability, and/or deletion. We will respond to authorized and verified requests as soon as practicable and as required by law. To protect your privacy and security, we may take steps to verify your identity in order to respond to your request. The above rights are subject to our being able to reasonably verify your identity and authority to make these requests. These rights are also subject to various exclusions and exceptions under the law. Under certain circumstances, we may be unable to implement your request, pursuant to applicable law. We will advise you of any reason for denying or restricting a request to the extent permitted by law.
European Data Subject Rights
Residents of the European Union have the right to access any personal information that Hypertherm processes about them, and to request information about:
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What personal data we hold about the individual
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The purposes of the processing
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The categories of personal data concerned
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How long we intend to store the personal data
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If we did not collect the data directly from the individual, information about the source
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The right to have incomplete or inaccurate data about the individual corrected or completed and the process for the request
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The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
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The right to lodge a complaint and whom to contact in such instances; if you are located in the United Kingdom, you may lodge a complaint with the UK ICO; if you are located in the European Economic Area, you may lodge a complaint with your local supervisory authority
California “Shine the Light” Rights
Under Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of Personal Information the business shares with third parties for those third parties' direct marketing purposes, and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To exercise your rights, you may make one request each year by contacting us at the information in the How You Can Contact Us section. Be sure to provide in the request sufficient information to properly identify you and/or the members of your family.
9. UPDATING COMMUNICATIONS PREFERENCES AND WITHDRAWING CONSENT
Withdrawing Consent
If applicable, you may at any time withdraw the consent you provided for the processing of your Personal Information for the purposes set forth in this Privacy Notice by contacting us at the information in the How You Can Contact Us section. Please be advised that, subject to applicable law, if you withdraw your consent, such withdrawal will not apply to or affect the processing of your Personal Information that occurred prior to your withdrawal of consent.
We want to communicate with you only if you want to hear from us. If you prefer not to receive information from us, you can unsubscribe anytime using the unsubscribe link that is included in any email you may receive from us. Please be sure to include your email address, full name, and specifically what information you do not want to receive.
How to Opt-Out of Marketing Communications
If you would like to stop receiving newsletters or other marketing or promotional messages, notifications, or updates, you may opt-out of receiving future communications for marketing purposes, both from Hypertherm or sent by Hypertherm on behalf of third parties. You may opt-out of receiving communications based on topic/purpose or may opt out of all such promotional emails:
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by following the instructions at the bottom of the email received; or
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by contacting us directly (See the How You Can Contact Us section of this Privacy Notice).
Once you have submitted your email address to opt-out of all promotional mailings, please note that you may continue to receive emails for a time while our system updates your request. Regardless of recorded opt-out preferences, please be advised that you may not be able to opt-out of receiving certain service or transactional messages from us, including legal notices, and other communications for administrative or transactional purposes.
Additional Information for App Users: Deleting Your App Account
Our mobile apps may permit you to create an in-app account that will associate your use of Hypertherm’s cutting solutions with you. We store the in-app account information separately from other personal information we may collect about you. If you wish to delete your in-app account, which will not impact personal information we may collect about you that is not associated with your use of the Hypertherm mobile app with account features, please contact us using the How You Can Contact Us section of this Privacy Notice.
10. TRANSFER OF DATA TO THE U.S.
Please note that if you are visiting or using the Apps/Sites or services from outside of the United States, your information may be transferred to, stored, and/or processed in the United States. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. If you are located outside of the United States, the transfer of Personal Information may be necessary to provide you with the requested information, products, and services and/or to perform any requested transaction. By using any portion of the Apps/Sites or services, you acknowledge and consent to the transfer of your information to our facilities in the United States.
11. IF YOU ARE LOCATED IN THE UNITED KINGDOM OR THE EUROPEAN ECONOMIC AREA
If you are located in the United Kingdom or the European Economic Area (Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, or Sweden), the controller of your data is Hypertherm, Inc., and we may be contacted using the “How You Can Contact Us” section below.
Basis for processing your Personal Information. We will process your personal information based upon your consent, as necessary to perform a contract with you or that we are entering into with you, or based on legitimate interests. If you would like more information about the legitimate interests and bases for processing in particular processing operations, we invite you to contact us using the “How You Can Contact Us” section below.
Examples of personal information processed based upon your consent. If we are directing marketing communications to you, in your individual capacity, we do so with your consent unless an exception applies (such as to send you direct marketing about similar products or services to ones you have already purchased from us). If you wish to withdraw your consent, please contact us using the information in the “How You Can Contact Us” section below. Withdrawing your consent will not affect processing operations we have already completed based upon your consent.
Examples of personal information processed based upon a contract with you. If we have entered into a contract with you, in your individual capacity, we will process your personal information as necessary to enter into and perform our obligations under the contract. These can include, for example, processing your payment information to collect payment and your contact information for shipping or update information.
Examples of personal information processed based upon legitimate interests. We may process your personal information for our legitimate interests or the legitimate interests of third parties, which include advertising or market and opinion research, as far as you have not objected to the use of your data; entering into a contract with a third party (which could include your employer) and performing our obligations under that contact; obtaining information and exchanging data with credit agencies where this goes beyond our economic risk; the examination and optimization of processes for needs analysis; the further development of services and products as well as existing systems and processes; the disclosure of personal data within the framework of due diligence in the course of company sale negotiations; for comparison with European and international anti-terrorist lists, insofar as this goes beyond the legal obligations; the enrichment of our data, e. g. by using or researching publicly accessible data; statistical evaluations or market analysis; benchmarking; the assertion of legal claims and defense in legal disputes which are not directly attributable to the contractual relationship; the restricted processing of data, if a deletion is not possible or only possible with disproportionately high effort due to the special type of storage; the development of scoring systems or automated decision-making processes; the prevention and investigation of criminal offences, if not exclusively for the fulfilment of legal requirements; and complying with our legal obligations as a U.S. company with offices in Mexico and supporting customers around the world. These are further detailed in the “Sources of Information and Purposes of Collection and Processing” and “How We May Share Information” sections above. If you would like more information, or to object to a particular processing operation based upon legitimate interests, please contact us using the information in the “How You Can Contact Us” section below.
Our use of automated decision-making. We may engage in decision-making or profiling in the course of our processing operations. We do not, however, engage in solely automated decision-making, including profiling, that in our view would produce legal effects or similarly significantly affect you.
Retention of Personal Information. We retain personal information in accordance with our internal policies, which establishes general standards and procedures regarding the retention, handling, and disposition of our records, including personal information. Personal information is retained as long as necessary to meet legal and regulatory requirements. Retention may be extended if we are required to preserve personal information in connection with litigation, investigations, and proceedings.
12. ADDITIONAL INFORMATION FOR EMPLOYEES AND JOB APPLICANTS WHO ARE CALIFORNIA RESIDENTS
This subsection contains information about how we may collect, use, and disclose personal information about California residents we have collected for employment-related purposes. This subsection does not contain information about how we may collect, use, and disclose personal information about California residents not related to any employment-related purpose, which is described in the remainder of this Privacy Notice. This subsection does not apply to non-California residents.
In the preceding 12 months, we may have collected the following categories of information about employees, contractors, and job applicants who are California residents:
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Categories of Personal Information |
Examples |
Purpose of Collection and Use |
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Identifiers |
First and last name; home address; personal email address; telephone number; employee or personnel number; other account or user identification information; Social Security number; driver’s license information; and emergency contact details. |
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California Consumer Records Law information |
First and last name; Social Security number; home address; personal email address; telephone number; driver’s license number; education and employment history; bank account numbers, credit or debit card numbers, and other financial information; insurance policy numbers; medical conditions and other health information; workplace accommodations and related documentation; FMLA calculations and related leave records; worker’s compensation claim information; and other medical and health insurance information; signature. |
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Characteristics of protected classifications under California or federal law |
Date of birth, age, or age range; criminal history; criminal records; disability status; drug test results; gender or gender identity; income level; marital status; military or veteran status; nationality; pregnancy status; racial or ethnic origin; sexual orientation; trade union membership; as well as similar information about your household members and dependents. |
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Financial information |
Bank account numbers, credit or debit card numbers, and other financial information. |
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Internet or electronic network activity |
IP address and device platform. |
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Geolocation data |
Locational information based upon IP address. |
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Audio, electronic, visual, or similar information |
Photographic images; company meetings; and video surveillance data. |
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Professional or employment-related information |
Job application details; current employment; employment history; salary, wages, and other compensation data; benefits and entitlement data; bonus payments and amounts; company or entity; business unit or division; employment contract information; employment start date; employment end date; hours of work; job title or role; manager/supervisor; office location; employee key card or access card use data; travel booking details; travel history; performance ratings; professional memberships; background check references and related information; military service records and related documentation; employment visa and sponsorship status; past work samples; fillable responses to job application content; and any disciplinary action and/or reason for termination. |
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Education information |
Academic transcripts; awards or honors; degrees earned; education and training history; grades; languages spoken; and other qualifications and certifications. |
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Sensitive personal information |
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We may have collected personal information about employees, contractors, and job applicants who are California residents from the following sources:
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Categories of Sources |
Categories of Personal Information |
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Through job applications and the application and hiring process We may collect personal information about job applicants and employees through job applications and related application materials that they submit to us. |
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From employees We may collect personal information from employees as part of the onboarding process and continued employment process. We may also collect additional personal information automatically from employees as they use our information and communication systems. |
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Third party suppliers We may collect personal information about job applicants or employees through third-party suppliers, which may be Service Providers under the CCPA or not. We use these third-party suppliers to conduct background checks, source application information (such as when an individual applies for a position through Workday), or to identify potential candidates who may be a good fit to work with us (such as outside recruitment agencies). |
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Other third parties We may collect personal information about job applicants or employees through other third parties, such as through reference calls during the hiring process or communicating with other entities to track and maintain appropriate records of education, training, and development activities, or from healthcare providers, as necessary to make hiring, employment, and promotion decisions. |
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We disclose personal information of job applicants, contractors, and employees who are California residents as follows, and we may have done so in the past 12 months:
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Category of Third-Party Recipient and Purpose of Disclosure |
Categories of Personal Information |
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Service providers We engage third-party service providers to perform a variety of services on our behalf, which may mean that we have to disclose personal information about job applicants and employees to these third parties. For example, we may disclose personal information to a payroll provider in order to process payroll, or to a SaaS provider to provide software used by employees to fulfill their job duties. We put in place appropriate measures to make sure that our service providers keep the personal information confidential and secure. |
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Financial institutions We may disclose personal information about employees to financial institutions in order to pay employee compensation. |
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Benefit plans We may disclose personal information about employees or their dependents to our benefits providers in order to provide benefits to our employees and their dependents, such as health, dental, and disability insurance. |
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Professional Services Firms We may disclose personal information about job applicants or employees to professional services firms that help us comply with our legal and regulatory obligations and establish, enforce, and otherwise exercise our rights and defend against claims, including, for example, auditors, law firms, and consultants. |
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Parents, Affiliates, and Subsidiaries We may disclose personal information about job applicants or employees to our parents, affiliates, subsidiaries, or other related companies, in order to make employment or hiring decisions, to provide employ benefits and compensation, or to otherwise manage and operate the business. |
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Government Entities We may disclose personal information about job applicants and employees to Government Entities and law enforcement officials, for various reasons, including as required by law or regulation or to confirm or verify a California resident’s right to work in the United States. |
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Merger and Acquisition Activity We may disclose personal information about job applicants or employees to third parties in connection with the proposed or actual financing, insuring, sale, securitization, assignment, or other disposal of all or part of our business or assets (including accounts) for the purposes of evaluating and performing the proposed transaction. We also reserve the right to transfer some or all personal information in our possession to a successor organization in the event of a merger, acquisition, bankruptcy, or other sale or transfer of all or a portion of our assets. If any such transaction occurs, the purchaser will be entitled to use and disclose the personal information collected by us in the same manner that we are able to, and the purchaser will assume the rights and obligations regarding personal information as described in this Privacy Notice. |
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The CCPA requires us to state that we do not use or disclose sensitive personal information about job applicants, prospective employees, current or former employees, or contractors for purposes other than to perform the services reasonably expected by an average job applicant or employee who applies for a job or is employed by us; to prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information; or to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those reasonable for those actions.
Should you have additional questions, comments, or concerns regarding this Privacy Notice, or to opt-out of certain information dissemination as permitted under this Privacy Notice, please contact us by regular mail, email, fax, or phone:
21 Great Hollow Road
PO Box 5010
Hanover, NH 03755
United States
Web form: https://secure.ethicspoint.com/domain/media/en/gui/74304/index.html
14. UPDATES TO OUR PRIVACY NOTICE
This Privacy Notice is subject to revision and changes. The most recent version of the Privacy Notice is reflected by the version date located at the top of this page. We encourage you to visit this page often to review our current Privacy Notice and stay informed of how we may process your information.