Who are we?

We are American Precision Industries, Inc. (“Portescap”).

110 Westtown Road

West Chester, PA 19382 U.S.A.

Telephone: +1-610-235-5499

Email: [email protected]

and an Altra Industrial Motion Corp. operating company.

We are a manufacturer of mechanical motion control solutions and provide these products and components to customers.

We have created this privacy policy to demonstrate our commitment to you and to ensure you are aware of our latest position regarding privacy globally. The following information discloses our current information gathering and dissemination practices for our websites. We’ll be the “controller” of the information you provide to us. This policy is updated continuously to reflect the measures taken by Portescap in relation to your personal data.

Our global affiliates are:

Data Privacy Contact: [email protected]

Our website links to other websites, which will have their own privacy notices and terms.

What does this Privacy Notice cover?

We at Portescap take your personal data seriously. This policy:

• sets out the types of personal data that we collect about you;

• explains how and why we collect and use your personal data;

• explains for how long we keep your personal data ;

• explains when, why and with whom we will share your personal data;

• sets out the legal basis we have for using your personal data;

• explains where we store your personal data and whether we transfer your data outside of the European Economic Area;

• explains the different rights and choices you have when it comes to your personal data; and

• explains how you can contact us.

What personal data do we collect about you?

We will collect certain personal information about you in the course of your relationship with us and according to the specific processing activities listed below. This may include interactions through our website, customer centres or meetings with Portescap representatives. We may also obtain such data from our authorised dealers and partners and other third parties.

The personal data we collect may include:

If you are a client/customer/prospective customer:

-Your contact information (name, email address, postal address, phone number, company name and contact details, job function, job title, industry sector), names and contact information of individuals you work with, work related records and reports, device and tool information related to your account, diagrams, notes, information collected using CCTV cameras in our facilities, and any other information you choose to provide.

-Data pertaining to your purchase and use of our products and services (customer preferences and details, purchase history, order ID, etc.).

If you visit your website, we may also collect personal data via cookies or similar techniques, including, but not limited to:

-Your IP address, your cookie ID, your web browser, your operating system, your location, the web pages you visit on your websites, the advertisements you’ve viewed or clicked through, the domain name of your Internet Service Provider and the like. Information of this kind is statistically evaluated by us, in order to optimize our Internet appearance and the technology behind it. For complete details of our cookies, please visit our Cookie Policy at https://www.portescap.com/en/cookie-policy.

-Personal data such as your contact information (name, email address, work address, etc.) upon use of the various forms on our website, such as contact forms, webinar subscriptions, newsletter subscriptions, etc.

If you are a job applicant:

-Personal data
-We process the applicant information submitted by you, e.g. your name, contact details of your CV and your qualifications.

If you are a Portescap employee:

-Your personal data including your name, email address, postal address, phone number, former work details including educational qualifications and professional experience, birth date, gender, nationality and work data.

-Your financial data as provided by you such as bank account data, salary data, etc. for payroll and compensation purposes.

-Your health data and data on your family, for insurance purposes, if required to be stored by the Company, in accordance with the local laws.

Where do we collect personal data about you from?

We may collect personal data about you from the following sources:

Directly from you:

• Information you provide to us through various source including contacting us via contact forms, phone, business cards, business meetings, other landing pages on the internet, completion of documents in which you provide us with your details, or if you engage in business with us;

• If you contact us whether by email, telephone, facsimile, or post;

• In person, for instance at an arranged meeting or event, including when you provide us with a business card or fill out our registration form when you meet us at an event;

• Voluntary surveys via SurveyMonkey conducted for research purposes;

• Newsletter, webinar and events registration;

• MotionCompass™ registration;

• When visiting one of our facilities in the world when we ask you to provide your name and other data;

• Cookies placed on your computer or mobile device when you visit our websites; and

• Using CCTV cameras. We have cameras on our premises and your image and movements may be recorded while you are on our sites or premises.

• If you are an employee, temporary or job applicant, then from your application letter, resume, references, and other information directly provided by you, including employee contracts signed by you;

From Third Parties

• From third party websites , when you click on Portescap ads or information on these websites, or otherwise specifically express an interest in learning more about us;
• Through acquisition of databases with your personal contact data, for which you have given consent to a third party;
• From an agent/third party acting on your behalf and/or via one of our distributors/representatives with whom you trade;
• If you are an employee, temporary employee or job applicant, from any recruitment consultant in use by you;
• Through organizers of an event that you have registered for and we have attended, provided we have a legitimate interest in contact you;
• Through publicly available sources, such as LinkedIn, Twitter, Facebook and D&B "Hoovers;
• Recruitment agencies;
• From an agent/third party acting on your behalf. [e.g. from one of our recruitment agencies];

How and why do we use your personal data?

Where permitted by applicable law, we may use information, including personal information and data, for various purposes, including to:

• to contact you to discuss the services or products you receive from us (and any changes to them);

• to contact you to offer additional services or products we have in our portfolio;

• to contact you to invite you to events we are hosting or attending;

• to respond to any questions or concerns you have raised;

• to deal with administrative matters such as invoicing and renewal;

• to otherwise carry out our obligations arising under our contract with you and to enforce the same;

• to carry out anti-money laundering checks;

• to verify your identity;

• to contact you to ask you to participate in consumer research via an online or telephone survey;

• to help us target our marketing communications and adverts so that they’re more relevant to you;

• to use your pseudonymised details to show you advertising on such Social Media platforms such as LinkedIn or Twitter, or via other third party advertising that may appear on other websites you use.

• to help us improve the user experience on our website, through website behavioural analytics tools.

•  to carry out any other purpose that is compatible with the purpose for which the information was collected;

• to ensure safety and government compliance in our manufacturing and office facilities;

• to ensure the security of the information you provide to us;

• to comply with our obligations under the law, including record-keeping, reporting, accounting, tax and other obligations;

• if you are an employee, temporary employee or job application, to process employment applications; to process your data for payroll, payments and reimbursements; to review your work, for compensation planning and to create development plans for you; to provide you with insurance; and to maintain records;

• to process employment applications

We will not use your information for any other purposes unless we are required to do so by law.

How long do we keep your personal data?

How long we keep your information will depend on the purpose for which we use it.

We will only retain your Personal Data for as long as it is necessary to fulfil the purposes outlined in this policy or the purposes of which you have otherwise been informed. Where our processing of your data is based only on your consent, then, we will retain the data for as long as the customer relationship lasts (and, where applicable, until the expiry of the warranty period) or until you withdraw your consent. Where we continue to have a legal basis for using your data apart from consent, then we may continue to hold your data for the period required in order for us to meet our legal obligations; defend ourselves in legal disputes or if we determine that we have a legitimate interest to do so.

We determine standard retention periods for different categories of data in our possession.

Where it isn't possible to determine standard retention periods, we do so on the basis of the following criteria:

• our relationship with you;
• the purposes and uses of your data (this includes present and future uses);
• the legal obligations we are subject to;
• the legal basis we have for processing your data (consent, performance of contract, etc.);
• the level of risk with retaining or using your data;
• your rights under the GDPR and other relevant laws; and
• any other relevant circumstances.

Who do we share your personal data with?

We share your personal information with third parties who perform functions on our behalf and who also provide services to us, such as professional advisors, IT consultants carrying out testing and development work on our business technology systems, research and mailing houses and function co-ordinators, our distributors/representatives who are providing maintenance and/or support activities on our behalf and third party service providers and applications in use for our business functions, such as hosting service providers.
 

We share your personal information with our other Altra Group companies for internal reasons, primarily for business and operational purposes.
 

As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or merges with us your personal information will be disclosed to such entity.
 

If any bankruptcy or reorganization proceeding is brought by or against us, all such information will be considered an asset of ours and as such it is possible they will be sold or transferred to third parties.
 

Where required we share your personal information with third parties to comply with a legal obligation; when we believe in good faith that an applicable law requires it; at the request of governmental authorities conducting an investigation; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to the our website, our business or the public.
 

These third parties comply with similar and equally stringent undertakings of privacy and confidentiality.
 

No other third parties have access to your information unless we specifically say so in this Privacy Notice, or the law requires this.
 

Portescap services may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our services with other media, and vice versa. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features. We accept no responsibility for the privacy practices of these entities.

What legal basis do we have for using your personal data?

We process your information on the following legal bases:

• Performance of Contract: We process various types of data such as your contact data, financial data, work related information, etc., once you enter into a contract with us, in order to perform the contract between us. This enables us to provide you with products AND/OR services in line with our Terms & Conditions via the Portescap websites; as is necessary for the various purposes like performance of inquiry responses, application engineering support, contract negotiation and contract fulfilment with you ; to take steps at your request; to comply with our legal obligations as may be applicable;
   

• Legitimate Interests: We use your personal data for our legitimate interests which include communication, management in relation to your contract with us, record-keeping, review, research and analysis, to fulfil our legal obligations under non-European laws, security, storage, etc. This includes in pursuit of our legitimate interests in direct marketing, market research and web analytics and includes profiling related to audience segmentation and personalisation. While there are some risks with this type of activity, on balance, we consider the risk to your rights of data protection is outweighed by the significant benefits in providing information which we think will be of interest to you, and enabling us to enhance, modify, personalise or otherwise improve our services/communications for the benefit of our customers. We’ve also implemented protections for your rights, by balancing our legitimate interests with any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You’ve the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on legitimate interests. More information on this right and on how to exercise it is set out below.
   

• Consent: We use consent to process your data for certain purposes such as when you consent to receive marketing communication such as newsletters, when you express interest in associating with us or to know more about us, etc. You can withdraw your consent at any time by writing to us at the e-mail addresses provided below, or by clicking on the opt-out link on any of the communications sent to you. For more on your rights, please see below.
   

• Legal Obligation: We are required to process, retain, use and share some of your personal data under European laws.
   

• Employees: For our current, past, and future employees we use a combination of performance of contract, legitimate interests, legal obligations and consent where applicable to process your data. For instance, when you apply to us for a job, we use consent to process your data. Similarly, when you are employed with us, we use performance of contract and legitimate interests to process your data.

Do we make automated decisions concerning you?

We do not make automated decisions concerning you.

We do a minor amount of profiling, including analysis of website behavior via cookies, and lead scoring in our marketing automation tool.  Our marketing automation platform to which we subscribe to, has a built-in predictive lead scoring functionality which may be used for automated decisions.

Do we use Cookies to collect personal data on you?

To provide better service to you on our websites, we and our service providers use cookies to collect your personal data when you browse. These are installed only with your consent. For information about our use of cookies, how to change your preferences, or how to decline them or turn them off, please read our Cookie Policy.

What about marketing?

Portescap would like to contact you from time to time about our new similar products and promotional offers by email, telephone and/or post.
 

You can unsubscribe / opt out at any time by clicking the “Unsubscribe” link in any of our communications or by contacting us using the details at the end of this Privacy Notice.
 

Our group companies in the Altra Group would also like to contact you from time to time about their products and promotional offers by email, telephone, post. The Group has a wide range of products and services that we do not offer but that may be of interest to you, or they may be able to service your requirements where we are unable to do so.
 

Each organisation will have its own privacy terms about how it will handle your information. These will tell you how you can opt-out of receiving marketing from them if you change your mind at any time (in addition to using the “Unsubscribe” option in any of their communications).
 

For advertising by post we refer to Art. 6 para. 1 lit f of the GPDR.

It is our legitimate interest to maintain and strengthen our market position.

Where do we store your personal data? Do we transfer your personal data outside the EEA?

All information you provide to us is stored on our data processing service provider’s secure servers.

Where possible, we try to only process your information in the country of its origin. If we or our service providers transfer personal data outside of the country of origin, we always require that appropriate safeguards are in place to protect the information when it is processed. The broad locations where our data in our possession could be transferred include:

• Our group entities are located in Switzerland, India, Brazil, China, Korea and Japan, and our parent, Altra's group entities are additional in the United States, Germany and France. Transfers of data within Portescap and Altra group entities are safeguarded via Standard Contractual Clauses entered into between the entities.
• We use hosting service providers. These transfers to the U.S. are safeguarded via EU-US and EU-Swiss Privacy Shield certifications.
• Some portions of our sales, marketing, customer service, operations, security and engineering functions are based in countries other than the country of origin of the data. We have put in place safeguards to protect personal data processed in or accessed from countries other than the country of the origin of the data. Many of these involve transfers of data to the United States, and are safeguarded via EU-US and EU-Swiss Privacy Shield certifications.

You can obtain a copy of the safeguards in place for such transfers by contacting us using the details at the end of this Privacy Notice.

What rights do you have in relation to the personal data we hold on you?

By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country.

1. The right to be informed

You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Privacy Notice.

2. The right of access

You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Notice).

This is so you’re aware and can check that we’re using your information in accordance with data protection law.

3. The right to rectification

You are entitled to have your information corrected if it’s inaccurate or incomplete.

4. The right to erasure

This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.

5. The right to restrict processing

You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.

6. The right to data portability

You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.

7. The right to object to processing

You have the right to object to certain types of processing, including processing based on our legitimate interests and processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).

8. The right to lodge a complaint

You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.

9. The right to withdraw consent

If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.

How can you make a request to exercise your rights?

To exercise any of the rights above, or to ask a question, contact us using the details set out at the end of this Privacy Notice.

How will we handle a request to exercise your rights?

We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.

We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:

• baseless or excessive/repeated requests, or

• further copies of the same information.

Alternatively, the law may allow us to refuse to act on the request.

How can you contact us?

If you have questions on the processing of your personal data, would like to exercise any of your rights, or are unhappy with how we’ve handled your information, please contact us here:

PORTESCAP

110 Westtown Road

West Chester, PA 19382 U.S.A.

Telephone: +1-610-235-5499

E-mail: [email protected]

Or our global affiliates at:

Data Privacy Contact: [email protected]

If you’re not satisfied with our response to any complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the data protection regulator in your country.

Last update September 12, 2019. V3