Privacy Policy for espec.com

PRIVACY NOTICE

Last Updated: 2-25-2021

ESPEC North America, Inc. and our subsidiary Hobbs Engineering, Inc. ( collectively “ESPEC”) value the trust you place in us when you provide us with your personal information. We take your privacy seriously and are committed to protecting it.

This Privacy Notice applies to any information, including personal information, ESPEC collects online.

This Privacy Notice explains:

• What information may be collected and the means of collection: Your information may be collected in several ways. For example, when you provide information to us (such as name, mailing address, email address or other personal information); when you use or interact with our website or services (general non-personal information about your use of our website or services may be collected, such as IP addresses, through the use of automated technology like cookies and beacons); and when information is collected from publicly available sources or shared with us by a third party.
• How we use information: We may use information for various purposes, including providing you with information about our company, products, promotions and other special offers, and conducting research and analysis on our website, products, marketing efforts and sales.
• When we share personal information: We do not sell or rent your personal information to third parties. We may share your personal information with (1) third parties with your consent; (2) our subsidiaries and affiliates; (3) our partners, advertisers or other third parties (primarily for business and operational purposes); (4) third parties providing services on our behalf; and (5) other third parties to comply with legal obligations.
• How we safeguard information: We use industry-accepted security measures to help protect your personal information from unauthorized access, alteration, loss, or misuse.
• Cookies, beacons, and how to stop automated collection of information: Automated technology (e.g., cookies and beacons) is used to collect general non-personal information and, in some cases, IP addresses. Cookies and beacons can be deleted to stop information collection.
• What laws govern the operation of ESPEC’s websites and international transfers of personal information: Our websites are governed and operated in accordance with the laws of the United States, while designed to be compatible with the laws of the countries in which we operate.
• How we will inform you of changes to this Privacy Notice: We may change this Privacy Notice at any time. If we make material changes, we will seek to provide you with reasonable notice of the changes. Changes will be effective immediately upon the posting of the revised Privacy Notice on our corresponding website.
• How you can communicate with us about this Privacy Notice or your personal information: This Privacy Notice contains contact information that you may use if you have any questions or concerns about this Privacy Notice or your personal information.
• Country Specific Information: Note that the laws of certain countries may require that we set out specific information in this Privacy Notice as it relates to such countries. Such country-specific information applies to this Privacy Notice and information collected online by ESPEC only if and to the extent the laws of the applicable jurisdiction require such application.

ESPEC websites may contain links to the websites of other companies. These websites may collect data independently of ESPEC. Please be aware that we do not control and are not responsible for the content, privacy policies, or practices of the websites of other companies. You should review the privacy notices of these websites before deciding whether to submit information to them.

PLEASE NOTE THAT OUR WEBSITES ARE NOT INTENDED FOR CHILDREN UNDER THE AGE OF 18 OR AN EU MEMBER NATION’S MINIMUM DIGITAL AGE OF CONSENT. IF YOU ARE UNDER THE AGE OF 18 OR THE DIGITAL AGE OF CONSENT IN YOUR COUNTRY, PLEASE DO NOT PROVIDE INFORMATION OF ANY KIND. WE DO NOT COLLECT PERSONAL INFORMATION FROM ANY PERSON WE ACTUALLY KNOW IS AN INDIVIDUAL UNDER THE APPLICABLE AGE OF CONSENT FOR DATA COLLECTION AND PROCESSING ACTIVITIES.

PLEASE READ THIS PRIVACY NOTICE CAREFULLY, BECAUSE BY USING OUR WEBSITES YOU ARE ACKNOWLEDGING YOU UNDERSTAND AND AGREE TO THE TERMS OF THIS PRIVACY NOTICE.

WHAT INFORMATION MAY BE COLLECTED AND THE MEANS OF COLLECTION

Your information may be collected in several ways, including: when you provide information to us; when information is collected automatically; or when information is shared with us by a third party.

• Information you provide to us through one of our websites

We collect information, including personal information such as name, mailing address, email address or other personal information, when you provide it through: registration to receive emails; a request for information; submission of comments; or by participating in a survey.

Providing personal information to us is purely optional. However, if you refuse to provide details that are essential (e.g. in a registration form), it will be impossible to use some of the features and functions of the website and/or to benefit from our services.

• Information collected automatically when you visit one of our websites

We, may place cookies, beacons or other tracking technologies in your browser to automatically collect general non-personal information when you visit one of our websites. Your IP address, which in some jurisdictions may be considered personal information, may also be collected through the use of automated technology. When you are on our website, our cookies or beacons are placed on your computer via ESPEC content that you may be viewing.

The type of information that may be collected automatically includes:

• internet browser type
• computer type
• IP address**
  • **NOTE: An IP address is a number that is assigned to your computer by your Internet Service Provider (ISP) so you can access the internet. Some ISPs assign a new IP address every time you access the internet while other ISPs assign you the same number every time you access the internet. In instances when you are assigned the same IP address, it is possible for information about your browsing habits to be associated with your individual personal computer.
• operating system
• webpages visited
• links clicked
• date and time of visits

This information helps us provide a better website experience by diagnosing problems with our servers, evaluating site navigation and better understanding the demographics of our site visitors so we can provide more relevant content, functionality and offers.

• Information shared with us by a third party

We may receive information about you from other sources such as public databases, data aggregators or companies/websites where you have consented to have your information shared with other companies.

We may also receive information about you from social networking sites if you or other users (e.g., your “friends”) give us access to your profiles, comments, or “connections”, if you “like” us, or if you choose to participate in a ESPEC sponsored page or program residing in a social networking site (e.g., ESPEC Facebook page). The type of information that we may receive includes lists of your friends, comments you have shared, groups and location.

Our websites may also have “plugins” and other website features from third parties, such as the Facebook “Like” button and Facebook Conversations and other features which allow for login or other website functionality or interactions with social networking sites. These “plugins” and features, including their operation and use, and the information you provide to those third parties as part of their use, are governed by the privacy policy and practices of the third party providing them. Please be aware that we do not control and are not responsible for the privacy policies or practices of such parties. You should review the privacy notices and applicable terms before deciding whether to use the third party “plugins” or features.

HOW WE USE INFORMATION

We may use information to:

• respond to your questions and requests,
• provide you with information about our company, products, services, promotions and other special offers,
• communicate with you about your account and other matters, and at our discretion, changes to any ESPEC policy that may affect you,
• manage, improve and conduct research and analysis related to our websites, products, services, advertising, promotions and sales, including, for example, to make our websites easier to use with better content by understanding how people use our websites, products and services,
• process transactions,
• implement other activities disclosed at the time you provide your information,
• implement social networking features you have activated, and/or
• combine all the information we collect or receive about you for any of the foregoing purposes.

To the extent that you provide us with financial information in connection with shopping or commercial services, we will use the financial information to bill you for products and/or services. By submitting your credit card and related personal information, you are authorizing ESPEC to give that information to the merchant and credit card company for order confirmation and fulfillment.

WHEN WE SHARE PERSONAL INFORMATION

We will not sell or rent your personal information to third parties. Periodically, we may share your personal information with our subsidiaries, affiliates, business partners and service providers, such as in the circumstances below. We may also share aggregated and/or anonymous information with our business partners for their own business purposes.

• Your agreement to have your personal information shared with third parties

While on our websites, you may have the opportunity to opt-in to receive information and/or marketing offers from another company or consent to the sharing of your information with a third party. If you opt-in or agree to have your personal information shared, your personal information will be disclosed to the third party, and the personal information you disclose will be subject to the privacy policy and business practices of that third party.

• ESPEC subsidiaries, affiliates and business partners

We may share your personal information with subsidiaries and affiliates in the family of companies controlled by ESPEC Corporation, or with our partners, advertisers or other third parties primarily for business and operational purposes.

• Third parties providing services on our behalf

We may share your personal information with unrelated companies that help us carry out your requests, make various features, services and materials available through our websites, respond to your inquiries and for the other purposes described in the section above on “How we use information”. The unrelated companies to which we may provide this information may include potential or actual advertisers, providers of advertising services (including website tracking services), commercial partners, sponsors, licensees, researchers and other similar parties.

• To comply with Legal proceedings and other special circumstances

We may share your personal information with third parties to comply with a legal obligation such as at the request of governmental authorities conducting an investigation; to verify or enforce our websites’ terms of use or other applicable policies; or to protect the rights, property, safety or security of visitors to our websites, the public or third parties. We may also disclose your personal information as part of the sale of one of our business divisions or brands to another company.

HOW WE SAFEGUARD INFORMATION

We take information security seriously and use industry-accepted security measures to help protect your personal information from unauthorized access, alteration, loss, or misuse. For example, we store personal information on computer systems with limited access and these systems are located in controlled facilities. When we transmit very confidential information (e.g., a credit card number) over the internet, we protect it through the use of data encryption methods.

Please remember not to ever send your credit card numbers, social security, or any personal passwords through unsecured email. Also remember not to ever share your passwords, never leave your computer unattended, and always log-out when you are done using it.

COOKIES, BEACONS, AND HOW TO STOP AUTOMATED COLLECTION OF INFORMATION

ESPEC uses automated technology to collect general non-personal information. Automated collection of information occurs mainly through the use of two technologies: cookies and web beacons.

• “Cookies”

What is a cookie —A cookie is a small file that a website you are visiting places in your computer through your internet browser. Cookies have the ability to identify your computer and store information like web pages visited, advertisements viewed, frequency, and type of browser used.

Cookies are usually managed through your internet browser.

If the website you are visiting provides free content (e.g., yahoo.com) then it is likely that you will also see advertisements of other websites/companies. If so, the website you are visiting and the companies that sponsor the advertisements may place their own cookies in your computer. Displaying on-line advertisements in unrelated websites is primarily accomplished through a practice called third party ad serving or targeted advertising.

How are cookies used —Cookies are normally used to help with security (e.g., time you out of a secured browsing session after a certain period of inactivity), site navigation (e.g., remember your preferences so that you don’t need to reenter information like language preference), and improve your browsing experience (e.g., deliver content, advertisements, or offers that are consistent with your browsing habits).

Cookies can remain in your computer for the duration of a browsing session or for a predetermined period of time. Cookies that remain in your computer for the duration of a browsing session are called “session” cookies (e.g., the contents of an online “shopping basket” will disappear at the end of your browsing session). Cookies that remain in your computer for a predetermined period of time are called “persistent” cookies (e.g., selecting English in a website that offers content in multiple languages so that the content is displayed in English when you return to the website even weeks or months later).

Accepting, disabling or deleting cookies – You may be able to set your browser to notify you before you receive a cookie, giving you the chance to decide whether to accept it, or to block cookies altogether. To do so, please refer to your browser’s help menu.

Most browsers also allow you to erase cookies already stored. Please be aware that deleting cookies will likely have a negative effect on the performance of the websites you visit and, consequently, you may not be able to see content or use applications offered through the websites.

To delete cookies that have been installed in your computer, please refer to your browser’s help menu. Below are links to some of the most popular internet browsers where you can find additional information on managing cookies:

• Internet Explorer
• Firefox
• Chrome
• Safari
• Opera

You can also learn more about cookies at:

https://allaboutcookies.org/

https://www.onguardonline.gov/

• Web “beacons”

What is a web beacon —Web beacons are small pieces of computer code placed in transparent graphic images displayed in websites you may be viewing or emails you may receive. Web beacons are not noticeable since they are usually placed within a very small portion of an image being observed. Web beacons are also known as pixel tags, clear GIFs, and web bugs.

How web beacons are used —Web beacons are normally used to monitor website traffic. Web beacons can also be used with cookies to gain an understanding of how website users navigate and process the content contained in websites. For example, a company owning a network of websites may use web beacons to count and recognize users traveling through its multiple websites. Being able to recognize users allows the website owner to personalize users’ visits and make them more user-friendly.

How to delete web beacons —To delete web beacons, you will need to delete cookies from your browser (see the section above on “Accepting, disabling or deleting cookies”).

You can learn more about web beacons at:

https://www.allaboutcookies.org/faqs/beacons.html

WHAT LAWS GOVERN THE OPERATION OF ESPEC’s WEBSITES AND INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

Our websites are governed and operated in accordance with the laws of the United States, while designed to be compatible with the laws of the countries in which we operate.

Because we are an international business, your personal information may be processed and maintained in the United States and/or transferred from the United States to another country that does not have the same privacy laws as the United States or your country of residence. We will always handle your personal information in accordance with this Privacy Notice.

Be aware that by using our websites or providing us with information, you are: (a) agreeing that our websites are subject to the laws of the United States, and (b) consenting to the collection, processing and maintenance of such information in the United States and/or the transfer of such information from the United States to other countries.

Note that the laws of certain countries may require that we set out specific information in this Privacy Notice as it relates to such countries. Click below to read the information related to those countries. Such country-specific information applies to this Privacy Notice and information collected online by ESPEC only if and to the extent the laws of the applicable jurisdiction require such application.

European Union, European Economic Area, Switzerland

GDPR (General Data Protection Regulation)

California, USA

CCPA (California Consumer Privacy Act)

Japan

JAPPI (Japanese Act on the Protection of Personal Information)

HOW WE WILL INFORM YOU OF CHANGES TO THIS PRIVACY NOTICE

Please note that we reserve the right to change this Privacy Notice, at any time. To the extent that we make material changes, we will seek to provide you with reasonable notice of the changes. Changes will be effective immediately upon the posting of the revised Privacy Notice on our corresponding website. Please check back from time to time.

HOW YOU CAN COMMUNICATE WITH US ABOUT THIS PRIVACY NOTICE OR YOUR PERSONAL INFORMATION

If you have any questions or concerns about this Privacy Notice or your personal information, please let us know by contacting us at the below email and mail addresses:

By email: PrivacyInquiries@espec.com

By webform: Contact us now (select ‘right to be forgotten’)

By mail:

ESPEC North America, Inc.
Privacy Inquiries
4141 Central Parkway
Hudsonville, MI 49426
USA

Note that the applicable laws of certain countries may grant you rights, including, if applicable in your jurisdiction, the right to request us:

• to provide you with information about our processing, including information on the source from which we obtained your personal information, how we process your personal information and to obtain a copy of the personal information we have about you
• to correct or update your personal information
• not to contact you in the future
• to delete your personal information
• to stop the processing of your personal information
• to notify any change or requirement of deletion to a third party to which your personal information has been passed

Not all such rights may be applicable in your jurisdiction; ESPEC will comply with applicable laws.

Please be aware that in accordance with our routine record keeping, at our discretion and from time-to-time, we may delete records that contain personal information.

PLEASE NOTE THAT OUR WEBSITES ARE NOT INTENDED FOR CHILDREN UNDER THE AGE OF 18 OR AN EU MEMBER NATION’S MINIMUM DIGITAL AGE OF CONSENT. IF YOU ARE UNDER THE AGE OF 18 OR THE DIGITAL AGE OF CONSENT IN YOUR COUNTRY, PLEASE DO NOT PROVIDE INFORMATION OF ANY KIND. WE DO NOT COLLECT PERSONAL INFORMATION FROM ANY PERSON WE ACTUALLY KNOW IS AN INDIVIDUAL UNDER THE APPLICABLE AGE OF CONSENT FOR DATA COLLECTION AND PROCESSING ACTIVITIES.

ESPEC is subject to the European Union General Data Protection Regulation (GDPR), a data protection law applicable to the European Union (EU), European Economic Area (EEA), and Switzerland, effective May 25, 2018. ESPEC is also subject to the California Consumer Privacy Act (CCPA) applicable to California, USA and the Japanese Act on the Protection of Personal Information (JAPPI) applicable to Japan. Your rights under the GDPR, the CCPA or the JAPPI include those mentioned previously in this Privacy Notice, as well as the right, under certain conditions as described in the GDPR, the CCPA or the JAPPI:

• to have personal data transmitted to you or another controller in a commonly used machine readable format (right to data portability);
• to require that ESPEC erase personal data in certain circumstances, and, where the data has been made public, to take reasonable steps to inform controllers that are processing the data that you have requested its erasure, including any links to, copies or replication of it (right to erasure);
• to more information about ESPEC’s processing through an access request and to provide the information in a commonly used electronic form (right of access);
• to obtain restriction of processing of personal data (right to restrict processing);
• where processing is based upon consent, the right to withdraw such consent;
• to object, on the grounds relating to your particular situation, to processing of your personal data (right to object);
• to obtain the rectification of inaccurate personal data (right to rectification); and
• to lodge a complaint with the relevant Data Protection Authority. Contact details for the EU data protection authorities can be found at https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. Contact details for the California data protection authorities can be found at [url=https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201720180AB375]https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201720180AB375[/url].

If you have any requests for ESPEC under GDPR, CCPA or JAPPI, you should contact us at:

By email: PrivacyInquiries@espec.com

By webform: Contact us now (select ‘right to be forgotten’)

By mail:

ESPEC North America, Inc.
Privacy Inquiries
4141 Central Parkway
Hudsonville, MI 49426
USA

ESPEC processes personal information primarily based upon consent, but may also process personal information where legally obligated to do so, or on the basis of legitimate interests. For example, ESPEC may process personal information you provide to us on the basis of a legitimate interest as necessary for the purposes of (1) responding to your questions and requests, such as when we provide customer service or address and resolve claims or disputes that may arise, or (2) managing and improving our websites, such as when we identify your location and language preferences for content delivery, when we monitor comments and reviews on our websites to prevent terms of use violations, or when we enable the operation of privacy compliance notices and consent and opt-out functions for cookies. Other legitimate interests may be applicable to our processing of your data as described in this Privacy Notice.

ESPEC processes personal information only for the legitimate purposes described in this Privacy Notice and, if applicable, only such other purposes as are compatible with such purposes, and not for additional incompatible purposes. In addition, ESPEC will not maintain your personal information longer than is necessary, and will only do so in accordance with GDPR, CCPA or JAPPI requirements. ESPEC considers relevant criteria for determining the period during which ESPEC will maintain your personal information, for example, the nature and categories of the personal information, the purpose for which the personal information is stored (including the need for further processing in accordance with the legitimate purpose for which it was collected), the security measures that can be applied to protect such personal information and safeguards that can be implemented to reduce any risks, and the balance of any potential impact on the data subject (both positive and negative).

As we described previously in this Privacy Notice, because we are an international business, your personal information may be transferred for processing, including outside the United States. You can read below for more information on how ESPEC complies with the GDPR requirements relating to such transfers to the United States.

Access - EU individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to that information. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks to correct, amend, or delete inaccurate data transferred to the United States should submit a written request to PrivacyInquiries@espec.com. If requested to remove data, we will respond within a reasonable timeframe.

Choice - We will provide an individual an opt-out or opt-in choice before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to PrivacyInquiries@espec.com.

Onward Transfers - ESPEC is responsible for the processing of personal data it receives, and subsequently transfers to a third party acting as an agent on its behalf.

In certain situations, ESPEC may be required to disclose personal data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.

Enforcement - Please note that ESPEC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission regarding personal data.

Dispute Resolution - ESPEC commits to resolve complaints about your privacy and our collection or use of your personal information. Inquiries or complaints should first contact ESPEC at:

By email: PrivacyInquiries@espec.com

By webform: Contact us now (select ‘right to be forgotten’)

By mail:

ESPEC North America, Inc.
Privacy Inquiries
4141 Central Parkway
Hudsonville, MI 49426
USA