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 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 (tools.google.com/dlpage/gaoptout). Alternatively, you can disable the future analysis of your website visit by Google Analytics, by "clicking" on the link below. By clicking on the link, a so-called "opt-out cookie" is configured, which means that the analysis of your visit to our site will be prevented in the future: Google Analytics deactivation. Please note that if you delete the cookies in your browser settings, this may also delete the opt-out cookie and its re-activation may become necessary.
  • 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, visit the Internet Explorer website.
  • Firefox: Go to Tools, Options, Privacy and the options for setting cookies are displayed. For further information, visit 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, visit the Chrome website.
  • Safari: Click on Settings, Privacy. You can make your settings under Cookies. For further information, visit the Safari website.

Social Media Plugins
Our website uses the following social media plugins:

  • Facebook "Share" buttons
    The Facebook "Share" button (Facebook Inc.) is identified by the Facebook logo and is data protection compliant. A direct connection between your browser and the Facebook server is not established until you click on the Facebook "Share" button (and only then). As a result, Facebook receives the information that you have visited this website with your IP address. If you click on the Facebook "Share" button while you are logged into your Facebook Account, you may link the content of our web pages to your Facebook profile. This means that Facebook can assign your visit to these web pages to your user account. We have no knowledge of the content of the data transmitted to Facebook or the way such data may be used by Facebook. You will find further information on this in Facebook's data protection declaration at: de-de.facebook.com/policy.php.
  • “google+1″ buttons
    The “google+1″ button (Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) is identified by the “g+1″ symbol. A direct connection between your browser and the google+1 server is not established until you click on the “google+1″ button (and only then). We have no knowledge of the content of the data transmitted to Google or the way such data may be used by Google. According to Google, no personal data is retrieved if the user does not click on the "g+1" button. If you click on the "g+1" button while you are logged into your Google+ account, your personal data and IP address are retrieved and processed by Google. For further information on the purpose and extent of data capture and the options for protecting your privacy please consult Google Inc.'s data protection statements at: www.google.com/intl/en/policies/privacy/
  • “Twitter″ button
    The Twitter button (Twitter Inc., 795 Folsom Street, Suite 600, San Francisco, CA 94107, USA) is identified by the Twitter symbol. By using the "Re-Tweet" function, i.e. by activating the "Tweet" button, a link is made between the website you are visiting and your user account at Twitter. This information is displayed to other Twitter users accordingly. We have no knowledge of the content of the data transferred or the way in which it may be used by Twitter. For more detailed information please visit the website of Twitter Inc.: twitter.com/privacy.

Information via Newsletter

  • Insofar as as we send e-mail messages with advertising information on Textron, the brands/companies of Klauke, Greenlee and HDE, as well as the services and promotions they offer, this is done only with the express consent of the recipient. The contents of the e-mail messages result from the respective descriptions. In the absence of descriptions, the aforementioned contents shall apply.
  • The notifications as part of ongoing business relationships, which include in particular organisational and technical information for customers and business partners, do not constitute advertising information and may also be sent without prior consent.
  • If you want to receive the Newsletter, we require from you a valid e-mail address as well as information that enable us to verify whether you are the owner of the e-mail address or that the owner consents to receipt of the newsletter.
  • Alongside the e-mail address, we also ask for the following information: title, forename, surname, company, sector, address, post code and country. We use the personal data to address you personally for the purposes of the Newsletter. We therefore require the title and your name. The other information is used for statistical purposes, on the basis of which we can adapt the content of our Newsletter to the recipients thereof.
  • As part of the subscription process, we store the times of subscription and confirmation and the IP address. We are legally bound to log the applications in order to demonstrate a proper subscription.
  • A statistical evaluation of reading behaviour is conducted only to allow us to establish whether the recipients have opened the Newsletter. For this purpose, the Newsletter contains a so-called "web beacon", a pixel-size file, which is retrieved by our server when the Newsletter is opened. No other personal evaluations (e.g. checking which recipient has clicked which links) take place.
  • Before the Newsletter is sent, the owner of the e-mail address is sent a confirmation e-mail in which they have to confirm the Newsletter subscription. Unconfirmed subscriptions are automatically deleted within two weeks at the latest. We are entitled to refrain from sending a confirmation e-mail if the e-mail address has already been confirmed.
  • Your can revoke your consent to the storage of data, the e-mail address and the use thereof to send the Newsletter at any time by sending us a message or using the Unsubscribe link which is contained in every Newsletter e-mail. After unsubscribing, we will delete your data stored for the purpose of sending the Newsletter.

Effective Date
These principles apply as of March 2015.