Privacy Policy

Last Updated: January 21, 2019

1. About us

IEP Technologies, LLC (“IEP Technologies”, “we”, “us,” “our”) is responsible for the collection, processing and storage of your data. For more information about us, please visit About Us at any time.

The careful handling of your personal data is our highest priority. We process your personal data in compliance with applicable law, including in the EU, the General Data Protection Regulation (“GDPR”) and the respective national provisions.

This Privacy Policy applies IEP Technologies’ website, which is accessible at www.ieptechnologies.com, and to all other websites of our company that can be accessed under our domain (www.ieptechnologies.com), or that link to this Privacy Policy (collectively, the “Website”). If you switch to websites of other operators located on our Website, their own privacy policies apply, the content of which the respective operators of these websites are responsible. This Privacy Policy is incorporated into our Terms of Use, which also applies when you access or use the Website.

This Privacy Policy provides an overview of the personal data processing practices of our group companies. You will find below an overview of all our services in the context of which we collect and process personal data on our Website.

If separate or additional conditions apply to individual services or we ask you for your consent, we will point this out to you separately before using the respective service (e.g., for newsletter subscription).

Notwithstanding the steps we take to protect your personal data, no method of transmission over the Internet or method of electronic storage is 100% secure. IEP Technologies cannot guarantee the security or integrity of your data and shall not be liable for breaches of security or integrity, third-party interception in transit, or any damage caused to your computer or other property by visiting our Website. If you have any questions regarding the security of our Website, contact us at info.iep.us@hoerbiger.com.

We may change this Privacy Policy from time to time. Please check the “Last Updated” legend at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on this Website.

2. Why we process your data

When you visit and interact with our Website, we may collect information about you, including “personal data” as defined in Section 3 below.

We use the personal data we collect from you in a variety of ways. For example, if you wish to contact us, we will ask you for your name, email address, phone number, professional title, and address, and other similar personal information you voluntarily provide to us so that we can communicate with you. It is your decision whether you would like to provide this data. Data that we require from you to provide our services are indicated as such.

Your personal data is collected and processed for the following purposes on the basis of the following legal bases:

• Contract initiation pursuant to Art. 6 (1) lit. a), b) GDPR)
• Processing of contracts pursuant to Art. 6 (1) lit. b) GDPR
• Customer management pursuant to Art. 6 (1) lit. b), c), f) GDPR
• Communication and data exchange pursuant to Art. 6 (1) lit. a), b), c), f) GDPR
• Direct Marketing and advertising pursuant to Art. 6 (1) lit. a), f) GDPR
• Implementation of declarations of consent pursuant to Art. 6 (1). 1 lit. a) GDPR
• Ensuring the proper operation of data processing systems in accordance with Art. (1) lit. c) and f) GDPR
• Applicant selection, hire and onboarding procedures and resource management on the basis of Art. 6 (1) lit. a), b) GDPR

3. Which data we collect and process from you

We collect different categories of personal data from you. Personal data is all information relating to an identified or identifiable natural person or as defined under applicable law; an identifiable natural person is one who can be identified directly or indirectly, in particular by assignment to an identifier such as a name. Personal data includes, for example, information such as your name, your address, your telephone number and your date of birth (if stated).

Statistical information that cannot be directly or indirectly associated with you – such as the popularity of individual websites of our offer or the number of users of a page – does not qualify as personal data. IEP Technologies collects personal data is collected directly and indirectly, as explained below. In both cases, personal data will only be collected to the extent necessary; the data will only be processed for the purposes stated under Section 2 above. It is your decision whether you want to transmit data to us which is not technically necessary yet optimizes the use of our services for you. Corresponding data fields are marked as 'voluntary'.

If you give us personal data of a third party, you represent that you have provided notice to, and received authorization to provide such information from, that third party.

The personal data we collect directly from you includes:

• Your salutation and name, e.g. for personalizing your user account (closed login area),
• E-mail address and, if applicable, a password chosen by you, e.g. in the context of using your customer account or contacting us via our contact form,
• Candidate data submitted in connection with our online application procedure,
• Data that you voluntarily transmit to us when using our services, such as your email address, phone number, professional title, and address when you use of our contact form,
• Data that you voluntarily transmit to us as part of the use of our services, other data that you voluntarily choose to provide.

In addition, data about you is collected indirectly when using our services:

• Technical connection data, e.g. the page called up on our website, your IP address, shortened by the last three digits, date and time of the call,
• Data collected in the context of website tracking.

Minors:

Our Website is not intended for minors under the age of 16 and we do not knowingly collect personal data from minors.

No one under the age of 16 may provide any information to or on the Website. If we determine that a minor under the age of 16 has sent us personal data without the parental consent or consent of the minor, we will delete the data immediately. If you believe we might have any information from or about a child under the age of 16, please contact us at info.iep.us@hoerbiger.com

4. Who has access to your data and to whom we transmit your data

1. Access by third party providers

   Access to your personal data stored by us is limited to our employees and the service providers commissioned by us, who require use or access to your personal data in order to support our business or in connection with the administration and support of the activities noted above.

   If third parties gain access to your data, we have obtained your permission or there is a legal basis for this.

   We also use service providers to provide services and process your data (including hosting, sending letters or e-mails, maintaining and analyzing databases, securing our web servers or website tracking). Insofar as special provisions apply for these services, we have carried them out for you in the following way for the respective service. The service providers are bound by contractual obligations to keep personal data confidential, process the data exclusively on our instructions and are obliged to comply with the applicable data protection regulations. All contractors have been carefully selected and will only have access to your data to the extent and for the time required to provide the services or to the extent to which you have consented to the processing and use of your data.

2. Data exchange within the group of companies

   IEP Technologies is a global company. As such, we may disclose or share personal data we collect or you provide within the IEP Technologies group of companies to which we belong for internal administrative purposes worldwide. The servers of some of the service providers we use are located in the US and other countries outside the European Economic Area (“EEA”). Companies in these countries may be subject to data protection laws that do not protect personal data to the same extent as is the case in the EEA. If your data is processed in a country that does not have a recognized high level of data protection such as the EEA, we use contractual regulations or other recognized instruments to adequately protect your personal data. We expressly point this out to you again within the scope of the individual services.

   Insofar as personal data is transferred to third countries, this is done on the basis of the EU Commission's decision on appropriateness to the EU-U.S. Privacy Shield pursuant to Art. 45 GDPR or the EU Standard Contractual Clauses 2010 pursuant to Art. 46 (2) lit. c GDPR in conjunction with the decision of the EU Commission of 05.02.2010 (2010/87/EU) or your consent pursuant to Art. 49 (1) lit. a) GDPR.

3. Transmission to law enforcement and criminal investigation authorities

   In exceptional cases we transmit personal data to law enforcement and criminal investigation authorities. This is done on the basis of corresponding legal obligations, e.g. from the EU Code of Criminal Procedure, the Fiscal Code, the Money Laundering Act or state police laws or international laws as they may apply.

5. Storage periods

We store personal data within the framework of legal regulations or your consent. We use the following criteria to determine the concrete storage period:

We store the personal data until the purposes for which they were collected cease to apply (e.g. at the end of a contractual relationship or through the last activity, if no continuing obligation exists, or in the case of a revocation of your consent for the specific data processing).

Further data will only be stored if

• legal storage obligations (e.g. according to tax law and national trade laws) exist;
• the data is still needed to assert and exercise legal claims or to defend against legal claims, e.g. due to technological and forensic requirements to defend against attacks on our web servers and their prosecution;
• the deletion would be contrary to the legitimate interest of the data subjects;
• or another exception pursuant to Art. 17 (3) GDPR applies.

6. Your rights regarding your personal data

In the EEA and depending on the country where you reside, you may have legal rights to which we would like to draw your attention below. Of course, our data protection officer is also available to answer any questions you may have about your personal data that we have collected and processed using the contact details given below.

1. Right to information and data transferability

   You have a right of information about the personal data we process concerning you at any time.

   If the data processing is based on your consent or according to Art. 6 (1) lit. b) GDPR on a contract, you can also request in accordance with Art. 20 (1) GDPR to receive the personal data stored about you in a structured, current and machine-readable format. At your request, we will also forward the data directly to another controller.

2. Right to rectification, restriction and deletion

   Furthermore, in accordance with Articles 16 to 18 GDPR, you can request us to correct, restrict (block) or delete your personal data if we have processed the data incorrectly, if there is a reason to restrict further data processing, or if data processing has become illegal for various reasons, or if its storage is inadmissible for other legal reasons. We would like to point out that your right to deletion may be restricted by legal retention periods.

3. Rights of objection

   If our data processing is based exclusively on our legitimate interest pursuant to Art. 6 (1) lit. f) GDPR, you may object to this processing pursuant to Art. 21 (1) GDPR. Then we will stop processing your data unless we can prove grounds for processing which outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend a legal claim. Furthermore, you always have the right to object to the use of your data for the purpose of direct advertising with effect for the future pursuant to Art. 21 (2) GDPR.

4. Right of revocation

   If you have allowed us to process your personal data by giving your consent, you have a right of revocation with effect for the future pursuant to Art. 7 (3) GDPR.

5. Right of appeal to the Supervisory Authority

   You are free to complain to a supervisory authority if you believe that our processing of your personal data violates the GDPR or other national and international data protection laws.

6. California Privacy Rights

   Under California Civil Code section 1798.83, California residents who have an established business relationship with us are entitled to ask us for a notice describing the types of personal customer information we have shared with third parties for those parties’ direct marketing purposes during the preceding calendar year. That notice will identify the categories of information shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you are a California resident and would like to request a copy of this notice, please submit a written request to info.iep.us@hoerbiger.com

7. Choices about how we use and disclose your information

We strive to provide you with choices regarding the personal data you provide to us.

Cookie settings

You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly. For more information, please visit Section 9 below.

Do Not Track

We do not currently respond to “do not track” signals.

Communications from IEP Technologies

If you do not wish to have your contact information used by IEP Technologies, you can indicate your preferences on the forms we use to collect your data or ask us not to process your personal data for these purposes by contacting us at info.iep.us@hoerbiger.com. You may also stop receiving email correspondence from us by selecting “unsubscribe” located on emails you receive from IEP Technologies. Please note that this does not apply to information IEP Technologies provides in order to establishment an account with you, address your purchase order, warranty registration, product service experience, or other transactions.

8. Contact information

Should you have any questions or concerns about this Privacy Policy and our privacy practices, to exercise your data protection rights, you may contact us / our Data Protection Officer at the contact information provided below.

Please also address the revocation of your consent to the following contact details, indicating which declaration of consent you would like to revoke:

Responsible	Data Protection Officer (for IEP Germany & IEP Switzerland)
IEP Technologies, LLC 417-1 South Street Marlborough, MA 01752 United States of America Tel: +1-855-793-8407 Fax: +1-508-485-3115 Info.iep.us@hoerberger.com Representative within the EU pursuant to Art. 27 GDPR: IEP Technologies GmbH Kaiserswerther Straße 85C 40878 Ratingen, Germany datenschutz.iep.de@hoerbiger.com	SITS Deutschland GmbH Einsteinstraße 2a 63868 Großwallstadt Germany dataprivacy@sits.com

9. Supplementary notes and provisions on individual services

1. Contact form

   Data that you submit to us via our contact form will be processed for the purposes of communication and data exchange, so as to respond to your specific request. These data are stored as long as their processing is required for these purposes or until expiration of any subsequent retention periods.

2. Online application procedure

   We offer you the opportunity to apply to us online by e-mail. The transmission of the e-mail as well as the sent file attachments takes place via the Internet and is therefore unencrypted without the use of additional tools. Your electronic application data will be received by the relevant personnel department and only forwarded to the department responsible for the respective position or to the persons in charge of processing. All parties involved treat your application documents with the necessary care and with absolute confidentiality.

   After completion of the applicant selection process, we will store your application documents up to 3 months and then delete or destroy any copies unless we have concluded an employment contract with you. Should we wish to include your application documents in our applicant pool, we will contact you. In the notification you can actively consent to the further storage of your documents.

   Please note that applications that you send us by e-mail will be sent to us unencrypted. We therefore recommend the use of encryption software.

3. Customer account

   We offer our US distributors/representatives the opportunity to create a personal customer account on our website. Account allows you to personalize, link, and save your favorite settings to the services you choose on our Website.

4. Data processing for direct marketing purposes

   Postal advertising

   To the extent permitted by law, we may also use your name and the postal address known to us to send you advertising for our own offers. The legal basis is Art. 6 (1) lit. f) in conjunction with Recital 47 GDPR. Our legitimate interest is to promote sales or demand from our existing customers. Of course, you can object to the processing of your data for advertising purposes at any time in the future. A message in e-mail form to the above mentioned contact data is sufficient. We will then delete your data from our mailing list. The data proving your objection will be kept for another 6 years in accordance with Art. 17 (3) lit. e) GDPR, unless other applicable retention periods apply. During this period, however, your personal data will not be used for further processing.

   Telephone advertising

   To the extent permitted by law, we may also use your name, company affiliation and telephone number provided to inform business customers about our own offers, assuming your presumed interest. The legal basis is Art. 6 (1) lit. f) in conjunction with Recital 47 GDPR, § 7 (2) No. 2 UWG (Germany), or the respective applicable regulations. Our legitimate interest is to promote sales or demand from our existing business customers. Of course, you can object to the processing of your data for advertising purposes at any time in the future. A message in e-mail form to the above mentioned contact data is sufficient. We will then delete your data from our mailing list. The data proving your objection will be kept for another 6 years in accordance with art. 17 (3) lit. e) GDPR. During this period, however, your personal data will be blocked for further processing.

10. Use of our website – Profiling, cookies and web tracking

1. Google Analytics

   This Website uses Google Analytics, a web analysis service of Google LLC "("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the Website analyze how users use the Website. The information generated by the cookie about your use of this Website is usually transferred to a Google server in the USA and stored there. However, if IP anonymization is activated on this Website, Google will reduce your IP address within Member States of the European Union or in other countries party to the Agreement on the EEA beforehand. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On our behalf, Google will use this information to evaluate your use of the Website, to compile reports on website activity and to provide the website operator with other services relating to website usage and Internet usage. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data. One way to object to web analysis by Google Analytics is to set an opt-out cookie that instructs Google not to store or use your data for web analysis purposes. Please note that with this solution the web analysis will only not take place as long as the opt-out cookie is stored by the browser. If you would like to set the opt-out cookie now, please click https://developers.google.com/analytics/devguides/collection/gajs/?hl=de#disable.

   You may also refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available under the following link. The current link is: http://tools.google.com/dlpage/gaoptout?hl=de.

   Recipient of the data: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA

   Privacy-Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

2. Google Analytics Audience

   Google Analytics Audience is a feature within Google Analytics that allows us to analyze the success of our marketing activities across different users.

3. Social Media Buttons

   Our Website uses the Social Media Buttons for LinkedIn and YouTube. These social media buttons are not integrated as plugins via a so-called iFrame, but deposited as links. By pressing the Social Media Buttons you will be forwarded directly to the page of the respective provider. The social media buttons may allow these companies to receive personal data about you and your visit to our Website.

4. DoubleClick by Google

   DoubleClick by Google uses cookies to show you advertisements that are relevant to you. Your browser will be assigned a pseudonymous identification number to check which ads have appeared in your browser and which ads have been viewed. The cookies do not contain any personal information. Using the DoubleClick cookie allows Google and its affiliate Websites to serve ads based on previous visits to our or other Websites on the Internet. The information generated by the cookies is transmitted and stored by Google for evaluation. Google transmits the data to third parties only because of legal regulations or as part of order processing. Google will not merge your data with other data collected by Google.

   If you do not agree with this form of processing, you can prevent the storage of cookies by setting your browser accordingly. You may also prevent the collection of the data generated by the cookies and related to your use of the Websites by Google, as well as the processing of such data by Google, by clicking on the following link installing the downloadable browser plug-in <https://support.google.com/ads/answer/7395996?hl=de>. Alternatively, you can also disable the DoubleClick cookies on this page <http://www.google.com/ads/preferences/html/opt-out.html>.

   Recipient of the data: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA

   Privacy-Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

5. YouTube video, embedded via iFrame in the extended privacy mode

   We use Youtube, a service provided by Google, to show you video content. To protect your privacy, we have activated the extended privacy mode.

   YouTube also uses cookies to collect information about visitors to its website. YouTube uses these to capture video statistics, prevent fraud, and improve usability. Opening a video usually also leads to a connection to the Google DoubleClick network. If you start the video, this could trigger further data processing, especially if you are already logged in to Youtube. We have no influence on that.

   By pressing the Start button on the video you consent to the transmission of data to Youtube LLC.

   For more information about privacy on YouTube, please see their privacy policy.

   For more information about privacy on YouTube, please see their privacy policy <http://www.youtube.com/t/privacy_at_youtube>.

   Recipient of the data: YouTube LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA

   Privacy-Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active