KOLLMORGEN PRIVACY NOTICE
1. Who are we?
Kollmorgen Corporation (“Kollmorgen”)
203A West Rock Road
Radford, VA 24141
We are a manufacturer of mechanical motion control solutions and provide these products and components to customers.
2. What does this Privacy Notice cover?
We at Kollmorgen 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 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 the effect of refusing to provide the personal data requested;
- explains where we store your personal data and whether we transfer your data outside of the European Economic Area;
- explains your rights, if applicable, under the California Consumer Privacy Act (“CCPA”);
- explains the different rights and choices you have when it comes to your personal data; and
- explains how you can contact us.
3. 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 centers or meetings with Kollmorgen representatives (in this context, please note that phone calls may be recorded, with your consent, for quality assurance purposes). We may also obtain such data from our authorized dealers and partners and other third parties.
The personal data we collect may include:
- 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, and information related to your account.
- Data pertaining to your purchase and use of our products and services (customer preferences and details, purchase history, order ID, etc.).
- If you visit our 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 our websites, the advertisements you’ve viewed or clicked through, the domain name of your Internet Service Provider and the like. Anonymous information of this kind is statistically evaluated by us, in order to optimize our Internet appearance and the technology behind it. If you opt not to provide us with personally identifiable information you may still access our website, however you will be unable to use certain functionalities on this site.
- If you are a job applicant, we may also collect personal data. We process the applicant information submitted by you, e.g. your name, contact details of your CV and your qualifications.
4. Where do we collect personal data about you from?
We may collect personal data about you from the following sources:
- Directly from you. This is information you provide to us through various sources including contacting us via contact form, email, phone, business card, business meeting, other landing pages on the internet, completion of documents in which you provide us with your details, or if engaging in business with us;
- If you contact us whether by email, telephone, or post;
- In person, for instance at an arranged meeting or event;
- Voluntary surveys conducted for research purposes;
- From an agent/third party acting on your behalf and/or via one of our distributors/representatives with whom you trade;
- Promotional marketing and events registration;
- Through publicly available sources, such as LinkedIn, Twitter, Facebook, Dun and Bradstreet;
- Through the acquisition of databases with your personal contact data, for which you have given consent to a third party;
- Cookies placed on your computer or mobile device when you visit our websites.
5. 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 to participate in consumer research;
- to respond to any questions or concerns you have raised;
- to otherwise carry out our obligations arising under any agreements we may have with you and to enforce the same;
- to verify your identity;
- to help us improve the user experience on our website, through website behavioral analytics tools.
- to process employment applications;
We will not use your information for any other purposes unless we are required to do so by law.
6. 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. This means that when you have consented to our Processing of your Personal Data, 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. If you have revoked your consent, we may nevertheless retain certain Personal Data for the period required in order for us to meet our legal obligations and defend ourselves in legal disputes. If we have not received your consent for Processing, the Personal Data will only be retained to the extent we are permitted to do so by law.
7. 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 coordinators, our distributors/representatives who are providing maintenance and/or support activities on our behalf. Such third-party providers have access to your data solely for the purposes specified in this Privacy Notice, and we require these providers to undertake security measures consistent with the protections specified in this Privacy Notice and required by applicable law.
- We share your personal information with our other Kollmorgen subsidiaries for internal reasons, primarily for business and operational purposes.
- 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 our website, our business or the public.
8. What legal basis do we have for using your personal data?
We process your information:
- To be able to provide you with products and/or services in line with our Terms & Conditions via the Kollmorgen website;
- As this is necessary for the performance of the inquiry responses, application engineering support, contract negotiation and contract fulfilment with you for or to take steps at your request;
- To comply with our legal obligations as required;
- As is necessary in pursuit of our legitimate interests in direct marketing, market research and web analytics, and this includes profiling related to audience segmentation and personalization. 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, personalize 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.
9. What happens if you do not provide us with the information we request or ask that we stop processing your information?
We may have contractual obligations under any agreements that we have signed with you that require us to process your information. If you don’t provide the information requested, we may not be able to carry out any of our obligations arising under such agreements. If you ask us to stop processing your information, and if we do not require this personal information to fulfil our contractual obligations, we will remove your data from our database, within 30 days of the date of the request.
10. Do we make automated decisions concerning you?
We do not carry out automated decision making or automated profiling.
12. How do we keep your personal data secure?
- Data transmission
A transmission of your data to third parties generally does not take place, unless we are legally obliged to do so, or the data transfer is necessary for the implementation of the contractual relationship or you have given your express prior consent to the transfer of your data.
External service providers and partner companies will only receive your data if this is necessary to process your order.
We attach great importance to processing your data within the EU / EEA. However, it may happen that we use service providers who process data outside the EU / EEA. In these cases, we ensure that an appropriate level of data protection is established at the recipient before the transmission of your personal data. This means that a level of data protection is achieved through EU standard contractual clauses.
- Data security
We have taken extensive technical and operational precautions to protect your data from accidental or intentional manipulation, loss, destruction or access by unauthorized persons. Our security procedures are regularly checked and adapted to technological progress. We ensure the security of your personal data by adhering to our Privacy Notice and all GDPR requirements. We also take steps to ensure all our subsidiaries, agents, affiliates and suppliers employ adequate levels of security.
13. What about marketing?
Kollmorgen would like to contact you from time to time about our product solutions, available support resources, 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.
14. 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 within the European Economic Area (EEA). If we or our service providers transfer personal data outside of the EEA, we always require that appropriate safeguards are in place to protect the information when it is processed. Some portions of our sales, marketing, customer service, operations and engineering functions are based in non-EEA countries. We have put in place safeguards to protect personal data processed in or accessed from non-EEA countries. 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.
For California Residents Only: Under the CCPA all information collected from residents of California is stored on our servers located at our headquarters in Radford, VA which is based in the United States of America.
15. 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 including:
What does this mean?
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.
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.
The right to rectification
You are entitled to have your information corrected if it’s inaccurate or incomplete.
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.
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.
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.
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).
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.
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.
16. 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.
17. 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 we 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.
18. For California Residents Only: Your Rights Under the CCPA
The CCPA applies to California residents only, and supplements this Privacy Notice with additional disclosures, rights, and obligations. Any terms defined in the CCPA, unless otherwise defined, have the same meaning when used in this Section 18.
(a) Disclosures about the information we collect
To learn more about the types of Personal Information we collect from you, see Sections 3, 4, & 5 of this Privacy Notice. To learn about the business or commercial purposes for collecting this Personal Information, see Sections 7 & 8 of this Privacy Notice. To learn about the sources of Personal Information, see Section 4 of this Privacy Notice. To learn about who we share this Personal Information with, see Section 7 of this Privacy Notice.
(b) Rights under the CCPA
As of January 1, 2020, California law permits residents of California to request certain details about how their Personal Information is shared with third-parties or affiliated companies. California residents may exercise the following rights with respect to their Personal Information:
i. Right to Knowledge and Access
Up to two times each year, California residents may request that Kollmorgen disclose what Personal Information we collect, use, disclose, and sell. In addition to the rights set forth in Section 15 of this Privacy Notice we will disclose to you:
If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
Sales, identifying the Personal Information categories that each category of recipient purchased; and
Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
ii. Right to Deletion
In addition to the rights set forth in Section 15 of this Privacy Notice, California residents may request the deletion of their Personal Information collected or maintained by us. Once we confirm your verifiable request, we will delete (and direct our service providers to delete) your Personal Information from our records. We may deny your deletion request if retaining the information is necessary to:
Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
iii. Right to Opt-Out
California residents have the right to opt-out of the sale of Personal Information to third-parties. However, as disclosed in this Privacy Notice, Kollmorgen does not sell your information to third parties (see Section 7).
(c) Exercising your rights and verifying your request
If you wish to exercise any of these rights, or if you otherwise have any questions, comments or concerns about this CCPA Statement, please contact us using the details at the end of this Privacy Notice:
If you are exercising any of these rights, Kollmorgen will confirm receipt of your request within 10 days and provide you with information about how we will verify your request and when you should expect a response. Within 45 days Kollmorgen will respond to your request, unless we require an additional 45 days, in which case we will give you notice and an explanation of the reason for the extension.
Kollmorgen will not discriminate against any California resident for exercising their rights under the CCPA (e.g. denying access to goods, charging different prices, etc.), unless permitted by applicable law, including differences reasonably related to the value provided by the California consumer’s Personal Information.
19. 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:
203A West Rock Road
Radford, VA 24141
CCPA Toll Free Number: 1-866-394-3223
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.