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PERSONAL DATA PROTECTION POLICY

NOTE: Klauke is a member of the Textron Inc. enterprise. Klauke adheres to the Textron Inc. Personal Data Protection Policy, which is set forth below.

Policy Statement
It is Textron policy that employees must process personal data fairly and lawfully. Textron operations are responsible for collecting personal data only for specific, lawful, explicit and legitimate purposes, and for further processing of personal data consistent with those purposes. It is Textron policy that personal data be adequate, relevant and not excessive to the purpose for which they are collected or further processed. Textron operations are responsible for making every reasonable effort to maintain such data accurately, provide reasonable means to correct, delete, or rectify any inaccurate data, and store such data for periods no longer than is necessary. If a Textron operation or facility falls within the jurisdiction of more than one governmental body, it is responsible for complying with the higher or highest data protection standard in effect should there be any variance in those standards.

Confidentiality & Security

Textron operations are responsible for taking prudent steps to safeguard the confidentiality and security of all personal data, including appropriate procedural, organizational and technical steps to protect personal data from accidental or unlawful destruction or accidental loss, alteration or disclosure. These steps include entering into written agreements with subcontractors who process personal data in accordance with Textron's instructions incorporating Textron's own data protection standards as a minimum.

Notification to Government Agencies

Textron operations will comply with required governmental agency notification requirements.

Data Subject Access, Corrections & Deletions

Textron recognizes the right of data subjects to obtain without constraint at reasonable intervals and without excessive delay or expense:

1. Confirmation concerning whether Textron, any representative or agent is holding or processing personal data relating to him or her;
2. Information on the purpose(s) of the processing, the categories of data concerned, and the recipients or categories of recipients;
3. Information in an intelligible form concerning the data relating to him or her being processed and the source of such data; and
4. Information, as appropriate, concerning the logic underlying the data processing.

Further, Textron recognizes the data subject's right to require, as appropriate, the rectification, erasure or blocking of data whenever the processing of such data does not comply with applicable laws and regulations. Textron operations will alert, to the extent practicable, third parties to whom the data have been disclosed of any such rectification, erasure or blocking.

Data Collection, Transfer & Processing
Textron operations are responsible for collecting, processing and transferring personal data in compliance with the law. Only in very limited and rare circumstances, will Textron operations pass on personal data to healthcare professionals, e.g. where the data subject's health and well-being would otherwise be adversely affected and the data subject is unable to give formal consent.

It is Textron policy that except as allowed or required by law, personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships, health or sex life or alleged commission of any offense not be processed and the collection and storage of such 'sensitive' personal data be particularly safeguarded.

For personal data obtained directly from the data subject, Textron operations are responsible for informing the data subject of the identity of those controlling the data, the purpose for which the data is being collected and processed and any further information the data subject may need for fair processing. This same standard applies to personal data not obtained directly from the data subject, except as allowed by law for statistical purposes.

Textron operations are responsible for informing the data subject prior to any initial transfer or processing of personal data for direct marketing purposes and, upon request, for blocking such action.

It is Textron policy not to transfer personal data to any entity, individual, or organization, particularly entities within third countries without adequate data protections, that does not meet the standards established by this policy without ensuring that:

1. The data subject has given his/her unambiguous consent;
2. The transfers are needed for the performance of a contract between the data subject and the controller or to implement a pre-contractual commitment made at the request of the data subject;
3. The transfers are needed for the conclusion or performance of a contract concluded in the interest of the data subject between the controller and a third party;
4. The transfers are needed to protect the vital interests of the data subject; or
5. The transfers are made from a register established pursuant to laws and regulations as being open for consultation by members of the general public or by any person who can demonstrate a legitimate interest.

Adherence to Safe Harbor Privacy Principles with Respect to Human Resource Data
Textron adheres to the Safe Harbor privacy principles developed by the U.S. Department of Commerce in coordination with the European Commission. Textron's Safe Harbor Policy applies to all human resource data transmissions from the European Union to the United States. The principles provide guidance for U.S. organizations on how to provide adequate protection for personal data from Europe as required by the European Union's Directive on Data Protection. Textron's Safe Harbor Policy is available for viewing at www.textron.com/legal/safe_harbor.html and can also be obtained from the Textron Director, Privacy or from each Segment Privacy Officer.

Definitions
Consent - the freely given and informed agreement by a person (i.e., the "data subject") to the processing of his/her personal data. The data subject may withdraw his/her consent at any time and may attach any condition or limitation he/she believes to be appropriate.
Personal Data - any information relating to an identified or identifiable natural person (i.e., a private individual as opposed to a corporation or other comparable entity). An identifiable person is someone who can be identified, directly or indirectly, in particular by reference to an identification number or the person's physical, physiological, mental, economic, cultural or social characteristics. Personal data may relate to employees or other natural persons, including customers, clients, investors, suppliers, contractors or other individuals.
Data Subject -a natural person, a private individual about whom information is collected, stored or processed.

Scope

This policy applies to all Textron operations and business units. To the extent any Textron operation or business unit already has a data protection policy in place, this policy shall supersede any inconsistencies and/or supplement any such policies. Textron's financial services businesses, Textron Financial and Cessna Finance, are subject to privacy regulations with respect to their customers. These operations will continue to follow their own privacy policies regarding their customers and will follow this Textron policy in all other respects, including the personal data of their employees.

Responsibility
The Textron Director, Privacy is responsible for the administration of this policy and monitoring enterprise wide compliance. Each segment is responsible for appointing a Segment Privacy Officer responsible for segment compliance. A Reference Guide containing more detailed guidance is available from the Textron Director, Privacy.

Use of cookies
What are cookies? Cookies are small text files that are saved on your hard drive or on a mobile device. Only the website that created a cookie and saved it on your equipment can retrieve and read it. Cookies are used for, for instance, to bookmark your products, record the page of the website you visited and the duration of your visit. Cookies that indicate the page you visited are so-called "Session Cookies", while "Permanent Cookies" provide information about earlier visits. Websites you visit directly are "First-party Cookies". "Third party Cookies" distribute your content onto our website, from YouTube for example.

Which type of cookies do we use?

  • Essential cookies: Certain cookies are absolutely essential to the functioning of our website. They identify you as a registered user and ensure that you can use the websites in line with your registration.
  • Performance Cookies: We also use cookies to understand how you use our website and to improve the website's performance. We do this using Google Analytics, a web analysis service of Google Inc. ("Google"). Google Analytics uses cookies to analyse how you have used the website. The information created by the cookie about how you have used this website is usually transmitted to and stored on a Google server in the USA. The transmitted IP address is shortened to protect your privacy. Only in exceptional cases is the full IP address transmitted to and shortened on a Google server in the USA. On behalf of this website's operator, Google will use this information to evaluate how you have used the website. It is then able to compile reports about the website activities and offer other services associated with website and Internet usage to the website operator. The IP address transmitted from your browser by Google Analytics is not amalgamated with any other Google data. You can stop cookies being stored by making an appropriate setting in your browser software (see Use of cookies). However, please be aware that you may then be unable to use all the functions of this website. You can also prevent the data created by the cookie and relating to your use of the website (incl. your IP address) being captured at Google and this data being processed by Google by downloading and installing the browser Plugin available at the following link (https://tools.google.com/dlpage/gaoptout?hl=en).
  • Functionality cookies These cookies are used to store your user preferences. You will then, for example, not have to keep entering your full username in the login window and your regional and language preferences will be stored. Your product selection for product comparisons and bookmarks will also be recorded for the session in this way. We also make YouTube videos available on our website, which means YouTube can store cookies on your equipment.

How do I change the cookie settings in my browser? Most web browsers offer the option to allow or deactivate certain cookies. Some browsers also indicate what information the cookie stores. We advise you to allow cookies from our website, as some functions may not work properly otherwise. To change the cookie settings in your browser, proceed as follows:

  • Internet Explorer: Go to Tools, Internet options, General, Browser history and click on Delete or Settings to make any changes. Additional settings can be found at Tools, Internet options and Privacy. For further information, Opens external link in new windowvisit the Internet Explorer website.
  • Firefox: Go to Tools, Options, Privacy and the options for setting cookies are displayed. For further information, Opens external link in new windowvisit the Firefox website.
  • Chrome: Click on the Tool symbol, Settings, Display advanced settings, Privacy, Content setting; you can make your settings under Cookies. For further information, Opens external link in new windowvisit the Chrome website.
  • Safari: Click on Settings, Privacy. You can make your settings under Cookies. For further information, Opens external link in new windowvisit the Safari website.


Effective Date

This policy is effective July 2012.