Effective July 24, 2020.
If you are an employee of OPW or an OPW affiliate, you should refer to the Employee Privacy Notice provided by your employer. If you are intending to apply for a job with us or join our talent network, you should refer to the Privacy Notice on our Careers Portal.
- Who we are and contact details
- What personal data we collect
- What we do with the personal data we gather
- Data sharing
- Lawful bases
- Security and confidentiality
- How long we will hold your personal data
- Transfers of personal data
- Third-party sites and services
- Rights to your personal data
- Persons under 16
- Cookies and other tracking technologies
- How to contact us
1. WHO WE ARE AND CONTACT DETAILS
9393 Princeton-Glendale Road
Hamilton, Ohio 45011, USA
You can contact us via e-mail at email@example.com or you can call us at +1-523-870-3301.
2. WHAT PERSONAL DATA WE COLLECT
We may collect the following personal data directly through you, including through your activity on our site and by your use of any of our connected devices or smart technology, from our service providers, from publicly available information, and through third parties, including but not limited to repair shops or dealerships and other businesses that we may partner with to provide you enhanced or joint products and services.
(i) Contact information and other Personal identifiers – includes information such as your full name, email address, mailing address, phone number that you may provide on the website when signing up for our subscription services, when signing up for our training programs or that we may otherwise collect to market or do business with you;
(ii) Information about the device you use to access our sites and services (e.g. IP address and other Internet or other electronic network activity information including, but not limited to, browsing history, search history and information regarding your interaction with our sites, applications or other connected devices);
(iii) Commercial information related to your relationship with OPW, for example, if you are a distributor, the number of products sold;
(iv) Transaction information that includes details of products you have purchased from us in any manner, or financial or payment-card information related to a transaction where applicable;
(v) Any other information you may provide (for example, when you request more information about a product at a trade fair.
3. WHAT WE DO WITH THE PERSONAL DATA WE GATHER
We use the personal data we gather about you for the following purposes:
(i) to understand your needs, provide you with products and services, and respond to your inquiries;
(ii) for internal analysis, i.e. to see how many unique visitors access the OPW website(s) or otherwise use our services;
(iii) to administer promotions, services (e.g., registration for webcasts, etc.) and offers which you register for;
(iv) Subject to the provisions below, we will also use your personal data for other marketing-related purposes;
(v) To improve the products and services offered through the OPW website;
(vi) To measure the number of visitors to the OPW website and the areas of the website that are of most interest to visitors and to customize the OPW website;
(vii) For internal record keeping
a. To facilitate sale of products
b. To keep record of repairs performed on any products/systems
(viii) To provide training information to any relevant parties
(ix) To facilitate subscription services; and
(x) To audit interactions with you or concurrent transactions, detect security incidents, protection against fraudulent activity, and otherwise debug or repair errors that impair the functionality of our systems and services.
We do not use the personal data that you provide through the OPW website to make automated decisions about you.
To the extent permitted by applicable law, OPW may also use your personal data as we believe to be necessary or appropriate:
(i) under applicable law, including laws outside your country of residence;
(ii) to comply with legal process;
(iii) to respond to requests from public and government authorities, including public and government authorities outside your country of residence;
(iv) to enforce our terms and conditions;
(v) to protect our operations or those of any of our affiliates;
(vi) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and
(vii) to allow us to pursue available remedies or limit the damages that we may sustain.
Where required by local law, we will obtain your prior consent:
(i) in order to send you marketing communications about OPW and its brands;
(ii) in order to provide your personal data to Dover Affiliates for their marketing purposes, and
(iii) in order to provide your personal data to third parties and other partners for joint marketing efforts or their own marketing efforts.
Please note that you always have the right to withdraw your consent.
Otherwise we may contact you by email, phone, fax, mail, or other means unless you direct us not to do so.
We may use your personal data for our own marketing purposes, including, but not limited to notifying you of new services, offers or other information via mail, email, telephone, text message, and other means.
If you do not want us to use your personal data for marketing purposes or to provide your personal data to Dover Affiliates or to third parties for their marketing purposes, you may opt-out of such uses by notifying us in accordance with the procedure set forth below under the heading, “Rights to your Personal Data.”
5. DATA SHARING
We may share your personal data with our affiliates (i.e., affiliated businesses and operating companies) (collectively, "Dover Affiliates") in pursuance of the purposes set out in section 3 above.
We may share your personal data with third-party service providers (including contractors who provide services to us) to assist with any of the uses of personal data described above. We may also share your personal data with distributors that use contact information for distribution outreach, including marketing of VSG products and services.
We may share or transfer your personal data to a third party if OPW or Dover enters into, or is involved in, a business transaction such as a merger, acquisition, reorganization, or sale of some or all of its assets.
6. LAWFUL BASES
Under the laws in the European Union (EU), we are required to identify the lawful bases for which we use your personal data. These are:
(i) Legitimate Interest – we have a legitimate interest in contacting you where you provide us with your details, to manage our relationship with you and to monitor and improve the use of the OPW website and to send you marketing communications.
(ii) Consent – where we are required by local law to collect consent in order to send you marketing communications
(iii) Compliance with a legal obligation – where we are required to collect and disclose your personal data because we are subject to a legal or regulatory obligation
We do not intend to collect any sensitive personal data (which is defined under EU law to include, for example, personal data on ethnicity, racial origin and health) through any OPW-branded websites.
Where we rely on the legitimate interest lawful basis to use your personal data, you always have the right to object to such use by contacting us using the details above.
Where we rely on your consent to use your personal data, you always have the right to withdraw your consent at any time by contacting us using the details above.
7. SECURITY AND CONFIDENTIALITY
We are committed to ensuring that your personal data is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the personal data we collect online. However, we are not able to guarantee the confidentiality of non-confidential data such as feedback, questions, comments or ideas that you voluntarily provide to us (e.g., via the “Contact” tab or similar features on any OPW-branded website). We reserve the right to use and disclose such non-confidential information as we deem appropriate in compliance with applicable law.
There is no perfect security, and reasonable security is a process that involves risk management rather than risk elimination. While we are committed to developing, implementing, maintaining, monitoring and updating a reasonable information-security program, no such program can be perfect; in other words, all risk cannot reasonably be eliminated. Data-security incidents and breaches can occur due to vulnerabilities, criminal exploits or other factors that cannot reasonably be prevented. Accordingly, while our reasonable security program is designed to manage data-security risks and thus help prevent data-security incidents and breaches, it cannot be assumed that the occurrence of any given incident or breach results from our failure to implement and maintain reasonable security measures.
8. HOW LONG WILL WE HOLD YOUR PERSONAL DATA
We will retain your personal data for as long as:
(i) we have a relationship with you;
(ii) we are required by law, or
(iii) we need to in order to protect ourselves as a business or protect any other third party.
If you have any questions about our retention policy, please contact us using the details set out above.
9. TRANSFERS OF PERSONAL DATA
As a global organization, we will transfer your personal data across borders. OPW is based in the U.S., although we have locations in countries worldwide. Where a transfer of personal data across borders is required to comply with applicable laws, we will implement appropriate or suitable safeguards (such as EU Commission approved Standard Contractual Clauses) to protect that personal data. Please contact us using our details above should you require further information.
10. THIRD-PARTY SITES AND SERVICES
11. RIGHTS TO YOUR PERSONAL DATA
Under certain laws, you have the right to seek access to your personal data, seek rectification or erasure of your personal data, restrict our use of your personal data, object to our use or request data portability. Please contact us if you wish to exercise any of these rights.
In any event, you can always ask us for more information about the people who will be able to see and access your personal data.
In accordance with applicable laws, you may choose to restrict the collection or use of your personal data by us by emailing us at firstname.lastname@example.org. This includes where you:
(i) have previously not objected to us using your personal data for our direct marketing purposes, but now wish to opt-out of receiving future marketing emails from us;
(iii) do not want us to share your personal data with Dover Affiliates and/or our business (and other) partners for marketing purposes;
(iv) believe that personal data we are holding on you is incorrect or incomplete so that we can consider your concern(s) and, where appropriate, correct any personal data found to be incorrect. Or, you may contact us if you wish to review or change your personal data by using the “Contact” tab on our home page; or
(v) do not want to be contacted by us in the future (unless you initiate the contact).
Individuals who are residents of California have certain consumer rights under applicable California privacy laws, which are subject to certain limitations and/or restrictions. Specifically, under California law you may have the right to:
- Request that we disclose information about the personal information collected, used, disclosed or sold;
Request that we delete personal information collected or maintained by us;
Opt-out of the sale of your personal information, if there are any sales of personal information; and
Not receive discriminatory treatment for exercising your privacy rights.
Note that if you make such a request, we must verify your request before we can respond. Whenever feasible, we will match at least two data points in the identifying information provided by the consumer to the Personal Information already maintained by us, but it may require more data points depending on the information requested. We will avoid collecting highly sensitive pieces of personal information, unless necessary. If we cannot verify your identity, we may need to deny your request. We will generally respond within 45 days. A consumer may use an authorized agent to submit a request on the consumer’s behalf. When using an authorized agent, we require that you provide the authorized agent with written permission to do so, and have them verify their own identity and agent status with us. If you are placing a request on behalf of a household, we will need a verified request on behalf of each member of the household.
Note that where we act as a service provider to another business, we will direct your request to that business.
12. PERSONS UNDER 16
We do not knowingly collect or allow the collection of personal data from persons under the age of 16. If you are the parent or guardian of a person under the age of 16 and believe that the person has provided personal data to us, please contact us at email@example.com.
13. COOKIES AND OTHER TRACKING TECHNOLOGIES
When you visit the OPW website, we may use “cookies” and similar technologies to help us recognize and serve you better. Cookies are small files that contain information sent by a website that is saved on your computer’s hard drive. You may delete cookies from your computer or set your browser to reject cookies. However, doing so may limit some functionalities of our site. Please see our Cookies Policy for more information about our use of these technologies on the OPW website. Some websites have “do not track” features that allow you to tell a website not to track you. These features are not all uniform, and OPW does not currently respond to those signals.
14. HOW TO CONTACT US
If you have any questions, comments or concerns, or wish to exercise any of your privacy rights, you may contact us by:
9393 Princeton-Glendale Road
Hamilton, OH 45011, USA
If for any reason you are dissatisfied with our handling of your requests or have other concerns about our data-processing practices, depending on where you are located, you may also have a right to raise your concerns or complain to your local data-protection regulator.