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Privacy notice

Last updated: May 24, 2018

ITW Air Management (Vortec and Paxton Products) respects your right to privacy. This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights.
This Privacy Notice only applies to personal information that we collect through our websites at www.vortec.com, www.paxtonproducts.com & www.itw-air.com (“Website”).
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 Privacy Notice.

1. The personal information we collect and why
2. The legal basis for processing personal information
3. Who do we share your personal information with and how
4. Data retention
5. Your data protection rights for personal information held by ITW Air Management
6. Will my personal information be transferred abroad?
7. Security measures for your personal information
8. Cookies and Similar Technologies
9. Links to third party websites
10. Changes to our Privacy Notice
11. How to contact us

1. The personal information we collect and why
The personal information that we may collect about you through the Website broadly falls into the following categories:

Information that you provide voluntarily
Certain parts of our Website may ask you to provide personal information voluntarily, such as through completing a Web form:
• name, title and address;
• personal contact information (phone, email, fax, etc.);
• name, address, department, contact information and other information in relation to a company that you represent (if any) and your function within this company;
• VAT number;
• user preferences (e.g., preferred language settings);
• your marketing preferences;
• Service requests and orders placed;
• shopping cart and payment information; and
• Newsletter subscriptions, enrolment for promotions, use of special offers, etc.
• Survey answers, reviews, ratings and other types of feedback provided;
• Content of any communication sent through the website, including any information posted in social communities on the website or otherwise shared with ITW Air Management and/or other users;
• any other information that you enter on, or upload to, the website (e.g., content that you fill into an online form, a photo that you upload).

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:
• IP address, operating system, browser type, browser version, browser configuration, name of internet service provider, and other types of computer and connection related information relevant to identifying your type of device, connecting to the website, enabling data exchange with you and your device, and ensuring a convenient use of the website;
• URL and IP address of the website from which you accessed, or were directed to, our website, including date and time;
• subpages visited while on our website, links followed on the website, including date and time;
• the full Uniform Resource Locator (URL) click stream to, through and from the website, including date and time;
• shopping history, including open and completed transactions;
• search terms entered; and
• services/products viewed or searched for on the website.
Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content or products on our Website are 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.
Some of this information may be collected using cookies and similar tracking technologies, as explained further under the heading “Cookies and similar tracking technology” below.

2. The legal basis for processing personal information
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only (i) where the processing is in our legitimate interests and not overridden by your rights, (ii) where we need the personal information to perform a contract with you, or (iii) where we have your consent to do so.
We will process your personal information for any of the purposes below:
• administering, operating, maintaining and improving the website;
• contacting you to inform your organisation of new products and services we will be providing;
• evaluating your organisation's eligibility for certain types of offers, products or services;
• helping us to improve and personalise the website, our marketing, products and services;
• performing analytics and conducting customer research, including general market re-search or surveying our customers' needs and opinions on specific issues, generating sales and traffic patterns, and to analyse advertising effectiveness, both on an anonymous basis (e.g., by aggregating data) or on an individual basis (if legally permissible);
• answering your questions and responding to your requests;
• providing your organisation with information about our other products and services and regular updates on issues that may be of interest to your organisation performed through marketing channels such as (but not limited to): traditional mail, email, telephone, fax, newsletter, text / SMS / MMS messaging, social media posts, online advertising and search engine advertising, including periodic sending of promotional materials on products, services and promotions of ITW Air Management specifically dedicated to your organisation (direct marketing);
• creating statistical data about use of our Website and Social Media Pages, products and services;
• confirming that your organisations' orders have been received and to process them, to validate your organisation as a registered customer when using our services and calling our customer services;
• providing the relevant products and services to your organisation, for administration of your organisation's account with us and customer services, and for billing purposes;
• our internal purposes such as management, research, analytics, corporate reporting and to improve business efficiencies;
• ensuring security for your organisation and our staff, and help maintain service quality (calls to our customer services may be monitored and/or recorded for authentication, security, quality and training purposes);
• tracing nuisance or malicious calls;
• complying with applicable laws, regulations, court orders, government and law enforcement agencies’ requests, to operate our systems properly and to protect ourselves, our users and customers and to solve any customer disputes;
• segmenting our customer base and help us develop offers, products and services to provide your organisation with the best customer experience;
• communicating with you on other matters (e.g., to send you service reminders, technical notices, updates, security alerts, support and administrative messages or service bulletins);
• administering rewards, surveys, sweepstakes, contests, or other promotional activities or events;
• complying with legal obligations, prevent unlawful uses of the website, resolve disputes, and enforce our agreements; and
• other purposes that you have specifically agreed to; and otherwise as permitted by applicable law.
We will seek your consent before collecting, processing and using your personal information for the above-mentioned purposes, if and to the extent legally required. Likewise, if we wish to use your personal information for a new or different purpose that is not compatible with the purpose for which we collected or received it, we will notify you and will only make such other use if it is required or permitted by applicable law or if you have consented to it.
For the purposes mentioned above, only a limited number of individuals within ITW Air Management (e.g. individuals in sales, marketing, support, legal, finance, IT and accounting departments, as well as certain managers with assigned responsibility) will receive access to your personal information.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.

3. Who do we share your personal information with and how
For the purposes mentioned above, we may share your personal information with third parties. In order to make improvements to our website we may gather information that helps us understand how customers use it. For example, we may research the collected information to determine which areas of the site our customers most frequently access. ITW Air Management may provide aggregate statistics about our customers, sales, traffic patterns, and related site information to reputable third-party vendors, but these statistics will not include individual identifying information. Personal information such as your name and email address will not be used in our research.
We do not sell, trade, rent, disclose, transfer or otherwise share your personal information, except as follows:
Our group companies, third party service providers and partners: We may employ third party service providers (i.e., companies or individuals engaged by us) to perform certain functions on our behalf and under our instructions. Examples include database management, maintenance services, web analytics, handling in-bound inquiries, delivering packages, sending postal mail and email, removing repetitive information from customer lists, analysing data, providing sales and marketing assistance, processing credit card payments, and providing customer service. Third party service providers may for instance include IT companies, credit card processors, credit rating agencies or legal, financial and other advisors. Any third-party provider who provides data processing services to us, or who otherwise processes personal information for purposes that are described in this Privacy Notice will have access only to such personal information as it needs to perform its specific functions, and only for the purpose of performing these functions. We will ensure that any third-party service provider is aware of and abides by these obligations. We will also ensure that any third-party service provider processes your personal information as required by applicable data protection laws and that they adopt adequate technical and organizational security measures.

Courts, competent law enforcement authorities and regulatory, government agency: We may share personal information when we believe it necessary to comply with applicable law or regulation, to exercise, establish or protect our legal rights, or to protect your vital interests, the rights or safety of our website, other users, or third parties (e.g., for fraud protection purposes). Without limitation, this may include cases in which we are required to share personal information by the law or binding order of courts, law enforcement authorities or regulators.

• Potential or actual buyers (and its or their agents and advisers): As we continue to develop our business, we might sell all or parts of our website or business. We may disclose your personal information to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business or website, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice.

Any other person: if agreed by you (e.g., where you consent to other types of data transfers in connection with enrolling for a specific service).

4. Data retention
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible in accordance with our standard backup deletion/destruction policies.

5. Your data protection rights for personal information held by ITW Air Management
You have the following data protection rights:
• If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below. Upon receipt of your written request and enough information to permit us to identify your personal information, we will disclose to you the personal information we hold about you and to which you are entitled, for which we may make a charge up to the maximum as allowed by applicable law. You may request that we rectify any personal information that is inaccurate or delete any personal information that you think we no longer have a legitimate purpose for processing, as may be required by law. Requests to delete personal information are subject to any applicable legal and ethical reporting or document retention obligations imposed on us.
• In addition, you can object to the processing of your personal information in certain situations, including where your personal information is processed on the basis of legitimate interests.
• You can also ask us, in certain situations, to restrict processing of your personal information (i.e. stop processing but retain the information), or to provide portability of your personal information (i.e. transfer your personal information to you or another party as you request). Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
• You have the right to opt-out of marketing communications we send you at any time. 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, which in the UK is the Information Commissioners' Office https://ico.org.uk/.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

6. Will my personal information be transferred abroad?
Our group companies and third-party service providers and partners operate [around the world / in [countries]]. Accordingly your personal information may be transferred to, or processed in, in any country other than the country in which you are resident. This may include countries where applicable data protection laws provide a lesser degree of protection than your home country. Specifically, our Website servers are located in the United States. This means that when we collect your personal information we may process it in any of these countries.
For instance, if you are located within the EU/EEA or Switzerland, the country where the recipient is located may not qualify as a safe country within the European Data Protection Directive (95/46/EC), the EU General Data Protection Regulation (679/2016) or the Federal Data Protection Act of Switzerland. In such cases, ITW Air Management will nevertheless ensure an adequate level of protection for your personal information in compliance with applicable data protection laws. This includes ensuring that the recipient abides by the principles of the Privacy Shield (for recipients in the US). It also includes implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies; these require all group companies to protect personal information they process from the EEA in accordance with European Union data protection law.
Our Standard Contractual Clauses can be provided on request. [We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.]

7. Security measures for your personal information
We are committed to protecting the confidentiality and security of the information that you provide to us and we put in place appropriate technical, physical and organisational security measures to protect against any unauthorised access or damage to, or disclosure or loss of, the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.
You should also be aware that communications over the internet, such as e-mails, are not secure unless they have been encrypted.

8. Cookies and Similar Technologies
We use cookies, web beacons, unique identifiers and similar technologies to collect and store information (which may include your personal information) about how you interact with our websites, communications and services and selected third party websites which belong to our partner advertising networks. We may use these technologies to show you relevant adverts based upon this information, this is called interest-based advertising.
Cookies are small text files placed on your device which uniquely identify your device. Cookies cannot be used to run programs or deliver viruses to your device.
Web beacons (also known as “Pixel tags“) are small blocks of code on webpages or in our emails that allow us to read and set cookies. Web beacons are often used in connection with cookies to help operate our websites, emails and collect information about online activity.
For more information about our use of these technologies, interest-based advertising and your choices, please refer to our Cookies Notice.

9. Links to third party websites
This privacy notice does not apply to third party websites which our websites link to or which advertise on our websites. These third-party websites operate their own privacy notice or policy which we encourage you to read.

10. Changes to our Privacy Notice
We may amend this Privacy Policy from time to time for example, to keep it up to date or to comply with changing legal, technical or business requirements. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.
You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.

11. How to contact us
If you have any questions or concerns about our use of your personal information, please contact us using the following details:


ITW Air Management
10125 Carver Road
Cincinnati, Ohio 45242

Contact Number: 1-513-891-7474

E-mail: privacy@itw-air.com

The data controller of your personal information is ITW Air Management.