Privacy Policy

Last update: May 2018

At Herholdt Controls, we respect your privacy and we want to be transparent about the types of personal information we collect about you and how we use it. In this Website Privacy Notice (hereafter the "Notice"), we explain who we are, how we collect, share and use personal information we obtain from you when you visit a web platform (hereafter the "Website"), and how you can exercise your privacy rights.

Please note that this Notice describes the collection of personal information that takes place generally on all Herholdt Controls websites and the specific processing activities that take place on each Herholdt Controls websites may be different. Therefore, some of the processing activities described in this Notice might not apply to the particular Herholdt Controls website that you are visiting.

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Notice.

The Website that you are visiting is managed by the local Herholdt Controls affiliate (hereafter "Herholdt Controls"), who is the data controller for all personal information that is collected via a Website.

1. What personal information we collect and why

We collect various types of personal information on our Website. The personal information that we may collect about you broadly falls into the following categories:

Information that you provide voluntarily

Certain parts of our Website may ask you to provide personal information voluntarily, including:

• your contact details: such as first and last name, date of birth, address, phone number, e-mail address, gender;
• details about the products/services you are using or interested in;
• credit card details;
• business contact details, including your business affiliation;
• CVs and job applications for online recruitment purposes.

The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

Information that we collect automatically

When you visit our Website, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.

Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, preferences, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.

Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.

We use cookies and similar tracking technology (collectively, "Cookies") to collect and use personal information about you. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice.

Information that we obtain indirectly from third parties

From time to time, we may receive personal information about you that we obtain from other sources (for example: installers when they create an account on your behalf on one of our Websites).

The types of information we collect from third parties may include: email address, details about your existing installation, etc. We use this information to maintain and improve the accuracy of the records we hold about you, to provide technical assistance for the setting-up or maintenance of our solutions and to manage our customer account relationship with you.

2. For what purposes we use your personal information

We use the personal information we collect from you for the following purposes:

• to create your account on our Website;
• to communicate efficiently with you and to answer any questions or queries you may have;
• to manage your online purchases on our Website;
• to administer and monitor the stability and performance of our Website in order to improve it;
• to ensure the content on our Website is relevant to you and is presented in the most effective manner for you;
• to notify you when updates of our Website are available and of changes to any products or services we offer or provide through it;
• to send you information or promotions on our products and proposed services;
• to subscribe you to our newsletter;
• to send you personalized advertisements that we think may interest you based on your preferences and your use of our Website;
• to understand your preferences and improve your experience and customer satisfaction when you visit our Website and our services;
• to carry out statistical analyses on the use of this Website and visit frequency; and
• for online recruitment purposes (please read the Jobs Application Privacy Notice that is available on our Website).

We will use the personal information we collect from you only for the purposes described in this Notice or for purposes that we explain to you at the time we collect your personal information.

3. Who we share your personal information with

We may disclose your personal information to the following categories of recipients:

• to Herholdt Controls affiliates, third party service providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website), or who otherwise process personal information for purposes that are described in this Notice or notified to you when we collect your personal information;
• to any competent law enforcement body, regulatory, government agency, court or other third party where we believe such disclosure is necessary (i) as a matter of complying with applicable laws or regulations, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
• to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Notice;
• to any other person with your consent to the disclosure.

4. On what legal basis we process your personal information

We will process the personal information collected on our Website based on the necessity to manage our relationship with you, based on our legitimate interests which will depend on the personal information concerned and the specific context in which we collect it, or based on your consent.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

5. Transfers of personal information outside the EU/EEA

We operate at a global level and, as a result, your personal information may be transferred to, and processed in, countries other than the country in which you are resident. In some cases, these countries may be located outside the European Union / European Economic Area (EU/EEA) and therefore may have data protection laws that are different to the laws of your country of residence.

Specifically, our Website servers are located in the EU/EEA, but we may share or give access to your personal information to Herholdt Controls affiliates, third party service providers and partners who may be operating outside the EU/EEA (for example, we may use web hosting providers or cloud computing service providers who store or access your personal information outside the EU/EEA).

Where that is the case, we make sure that your personal information is transferred to third countries outside the EU/EEA that are deemed "adequate" by the European Commission (a list of adequate countries is available here [link]), or alternatively, where your personal information is not sent to a country that provides adequate protection, we will put in place appropriate safeguards to guarantee that your personal information remains protected while it is being processed outside the EU/EEA in accordance with applicable privacy laws. These appropriate safeguards may include signing the European Commission's Standard Contractual Clauses with the Herholdt Controls affiliate, third party service provider or partner outside the EU/EEA with whom we share your personal information. For further information about transfers of personal information outside the EU/EEA, please refer to the "How to contact us" section below.

6. How long we store your personal information

We will retain your personal information for as long as necessary to enable us to fulfil the purposes described in this Notice and where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested).

Once the purpose for processing your personal information no longer exists, or the period of retention has expired, or if you ask us to delete your personal information, we may continue to store your personal information for a limited period of time if necessary to comply with applicable legal, tax or accounting requirements.

When we no longer have a purpose to process your personal information, we will make sure your personal information is either deleted or anonymised.

7. How we protect your personal information

We are committed to ensuring the security of your personal information. We utilize robust precautions to protect the confidentiality and security of the personal information within our Website, by employing technological, physical and administrative security safeguards, such as firewalls and carefully developed security procedures, for example, when you enter confidential information (such as login credentials or information submitted from within the Website). We encrypt the transmission of that information using secure socket layer technology (SSL). These technologies, procedures and other measures are used in an effort to ensure that your personal information remains safe, secure, and only available to you and to those you authorized to access your personal information. However, no internet, e-mail or other electronic transmission is ever fully secure or error free, so you should take care in deciding what information you send to us in this way.

8. Minors

The services we provide on this Website are not intended for individuals below the age of 18. If you are under 18, please do not provide your personal information on this Website.

9. What data protection rights you have and how you can exercise them

You have the following data protection rights:

• You may request access to and obtain a copy of your personal information.
• You may also request that any personal information that is inaccurate or incomplete be rectified or completed.
• You may request that your personal information be erased under certain legal conditions (for example, where the personal information is no longer needed to achieve the purposes for which the information was initially collected).
• In addition, you may object to the processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information under certain legal conditions.
• You have the right to opt-out of electronic marketing communications we send you at any time and free of charge. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the "How to contact us" heading below.
• Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available here.

You may exercise any of the rights above at any time by contacting us as described under the "How to contact us" section below. We will respond to your request in accordance with applicable data protection laws.

10. External links

If any part of our Website provides links to third party websites, those websites do not operate under this Notice. We are not responsible for the online collection on third parties' websites and we recommend you examine the privacy notices posted on those websites to understand their procedures for collecting, using and disclosing personal information.

11. Updates to this Notice

We may update this Privacy Notice in response to changing legal, technical or business developments and where that is the case, we will provide an updated version of this Privacy Notice on our Website.

You can see when this Privacy Notice was last updated by checking the "last update" date displayed at the top of this Privacy Notice.

12. How to contact us

If you have any questions, concerns or complaints about this Notice, or the way we process your personal information, or if you want to exercise your rights as described above, please use this request form.

Cookie Policy

Last updated: May 2018

At Herholdt Controls, we respect your privacy and we want to be transparent about the types of personal information we collect about you and how we use it. In this Cookies Notice (the "Notice") we explain how Herholdt Controls use cookies and other similar technology ("Cookies") to recognise you when you visit our website at www.hhcontrols.com and our other websites (the "Website"). We also explain what these technologies are and why we use them, as well as your rights to control our use of them.

Please note that this Notice describes what types of Cookies we use generally on all our Websites and the specific Cookies that are used on each Website may be different. Therefore, some of the Cookies described in this Notice might not apply to the particular Website you are visiting.

What are cookies?

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.

Cookies set by the website owner (in this case, Herholdt Controls) are called "first party cookies". Cookies set by parties other than the website owner are called "third party cookies". Third party Cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third party Cookies can recognise your computer both when it visits the website in question and also when it visits certain other websites.

Why do we use Cookies?

We use first party and third party Cookies for several reasons. Some cookies are required for technical reasons in order for our Website to operate, and we refer to these as "essential" or "strictly necessary" Cookies. Other Cookies also enable us to track and target the interests of our users and to enhance the experience on our Website. Third parties serve Cookies through our Website for advertising, analytics and other purposes. This is described in more detail below.

The specific types of first and third party Cookies served through our Website and the purposes they perform are described in the table below.

What about other tracking technologies?

Cookies are not the only way to recognise or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called "tracking pixels" or "clear gifs"). These are tiny graphics files that contain a unique identifier that enable us to recognise when someone has visited our Website (or opened an e-mail that we have sent them). This allows us, for example, to monitor the traffic patterns of users from one page within our Website to another, to deliver or communicate with Cookies, to understand whether you have come to our Website from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of e-mail marketing campaigns. In many instances, these technologies are reliant on Cookies to function properly, and so declining Cookies will impair their functioning.

Flash Cookies or Local Shared Objects

Our Website may also use so-called "Flash Cookies" (also known as Local Shared Objects or "LSOs") to, among other things, collect and store information about your use of our services, fraud prevention and for other site operations.

If you do not want Flash Cookies stored on your computer, you can adjust the settings of your Flash player to block Flash Cookies storage using the tools contained in the Website Storage Settings Panel. You can also control Flash Cookies by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash Cookies (referred to "information" on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash Cookies that are not being delivered by the operator of the page you are on at the time).

Please note that setting the Flash Player to restrict or limit acceptance of Flash Cookies may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our services or online content.

Advertising cookies

Third parties may serve Cookies on your computer or mobile device to serve advertising through our Website. These companies may use information about your visits to this and other Websites in order to provide relevant advertisements about goods and services that you may be interested in. They may also employ technology that is used to measure the effectiveness of advertisements. This can be accomplished by them using Cookies or web beacons to collect information about your visits to this and other sites in order to provide relevant advertisements about goods and services of potential interest to you. The information collected through this process does not enable us or them to identify your name, contact details or other personally identifying details unless you choose to provide these.

Google Analytics

This Website uses Google Analytics, a web analysis service from Google Inc. ("Google"). Google Analytics uses Cookies, or text files. These are saved on your computer and allow your usage of the website to be analysed. The information generated by the Cookie about your usage of this Website is generally sent to a Google server in the USA and saved there. However, if IP anonymisation is activated on this Website, your IP address is shortened by Google within the member states of the EU or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address sent to a Google server in the USA and shortened there. Google will use this information on behalf of the operator of this Website to evaluate your usage of the Website, to compile reports about the Website activities and to perform further services connected to Website usage and Internet usage in its dealings with the Website operator. The IP address sent by your browser as part of Google Analytics is not combined together with other data by Google.

You can prevent these Cookies from being saved by making an appropriate setting in your browser software. However, you may then not be able to use all the Website's functions to their full extent.

You can also prevent the data (incl. your IP address) generated by the Cookie and related to your usage of the Website from being sent to Google and processed by Google by using the above-mentioned opt-out links. More information is available at https://analytics.google.com.

How can I control Cookies?

You have the right to decide whether to accept or reject Cookies. You can exercise your Cookie preferences by clicking on the appropriate opt-out links provided in the Cookie table above.

You can set or amend your web browser controls to accept or refuse Cookies. If you choose to reject Cookies, you may still use our Website though your access to some functionality and areas of our Website may be restricted. As the means by which you can refuse Cookies through your web browser controls vary from browser-to-browser, you should visit your browser's help menu for more information.

You can generally accept or decline the use of cookies through a functionality built into your web browser.

Click here to learn more about the "Private Browsing" setting and managing cookie settings in Firefox; Click here to learn more about "Incognito" and managing cookie settings in Chrome; Click here to learn more about "InPrivate" and managing cookie settings in Internet Explorer; or Click here to learn more about "Private Browsing" and managing cookie settings in Safari.

In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com.

Updates to this Notice

We may update this Notice in order to reflect, for example, changes to the Cookies we use or for other operational, legal or regulatory reasons. Please therefore re-visit this Notice regularly to stay informed about our use of cookies and related technologies.

The date at the top of this Notice indicates when it was last updated.

Privacy

For more information about how Herholdt Controls is using your personal information, please read our Web Privacy Notice here.

Where can I get further information?

If you have any questions about our use of Cookies, or the way we process your personal information, please use the following form.

Conflict Minerals Policy Statement

Herholdt Controls is deeply concerned by reports that profits from the sale of certain metals mined in the Democratic Republic of the Congo (DRC) or adjoining countries has helped fuel war and human rights violations in the eastern Congo.

In fact in August 2012, the United States Securities and Exchange Commission ("SEC") issued its final rules regarding "Conflict Minerals" (known as '3TG' - Tantalum, Tin, Tungsten and Gold) as defined in and required by section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Act"). As a result, many companies are now focusing on whether and to what extent their products contain Conflict Minerals and whether such Conflict Minerals come from the Democratic Republic of Congo and the adjoining countries named in the Act.

As directed by the Act, the U.S. Securities and Exchange Commission (SEC) has adopted rules requiring companies to disclose whether they use tantalum, tin, gold and tungsten that originated in the DRC and if so, to issue a report identifying their products that are not conflict free and their due diligence efforts to determine the source and chain of custody of the metals. Conflict free means the product does not contain tantalum, tin, gold and tungsten that directly or indirectly finances or benefits armed groups in the DRC or an adjoining country. In addition, governments around the world are developing policies related to supply chain due diligence of these metals.

Herholdt Controls, like many companies in electronic industry, uses tin and gold to manufacture their products, therefore we are aware which products are impacted and targeting our efforts accordingly, not buying products and materials containing Conflict Minerals directly from Conflict Mines, and finally asking our suppliers to work towards ensuring that any materials containing 3TG elements, supplied to Herholdt Controls, are not originated from Conflict Mines.

Herholdt Controls requires that suppliers whose products contain tungsten, tantalum, tin, gold, submit these informations to Herholdt Controls using the standardized EICC/GeSI Conflict Minerals Reporting Template that traces the metals back through the supply chain.

If Herholdt Controls becomes aware of a supplier whose supply chain includes tin from a conflict source, Herholdt Controls will take the appropriate actions to remedy the situation in a timely manner, including reassessment of supplier relationships, to achieve that objective.

Herholdt Controls expects our suppliers to take similar measures with their suppliers to ensure alignment throughout the supply chain.