Thomson Industries, Inc. Privacy Notice

Who are we?

Responsible according to Art. 4 para. 7 GDPR is

We are Thomson Industries, Inc. ("Thomson")

and a Regal Rexnord operating company.

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

We use your information as further explained in this Privacy Notice. We’ll be the “controller” of the information you provide to us.

Our representative subsidiaries in Europe are

Further subsidiaries and representatives of other regions.

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

How can you contact our data protection officer?

Our data protection officer can be contacted at: For Thomson Neff Industries GmbH: thomson.datenschutz.deutschland(at)regalrexnord.com or under the postal address with the addition "Attn: Data protection officer”.

For Tollo Linear AB there is a coordinator at Thomson Industries, Inc. for all GDPR relevant topics. E-Mail: thomson.privacy.scandinavia(at)regalrexnord.com.

Who do we share your personal data with?

We may share your personal information with third parties who perform functions on our behalf and who also provide services to us, such as authorized Thomson distributors, professional advisors, IT consultants carrying out testing and development work on our business technology systems, researchers, and collateral fulfilment service providers.

We may share your personal information with our other Regal Rexnord 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 legal obligations; 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.

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.

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 [thomsonlinear.com 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.
• To protect your vital interests AND/OR the vital interests of your employer

As this is necessary in pursuit of our legitimate interests in discussing, quoting and supplying Thomson products and services and this may include profiling related to your job title, employer’s industry, geography, application types and previously documented product interests. 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 service your potential and actual needs for Thomson goods and services. We’ve also implemented protections for your rights by the creation and sustained review of Record of Processing Activity documents related to all personal data processes and related implementation in related data systems. 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.

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 or our data processing service providers’ 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 agree on an appropriate level of data protection to protect the data during processing. Some portions of our sales, marketing, customer service, operations and engineering functions are based in non-EEA countries. We have taken measures to protect personal data processed in or accessible from countries outside the EEA. You can obtain a copy of the security guarantees for such transfers by contacting us using the information at the top of this Privacy Policy.

How long do we keep your personal data?

How long we keep your information will depend on the purpose for which we use it. The criterion for the duration of the storage of personal data is the respective statutory national retention period. After the deadline, the corresponding data will be routinely deleted if they are no longer required to fulfil the contract or to initiate a contract.

Example for Germany retention periods:

• Information relevant to financial statements (e.g. invoices) = 10 years
• Commercial correspondence = 6 years
• Applications = 6 months after letter of refusal
• Employees documents = 10 years after leaving the company

We only keep your information for as long as is reasonably necessary for the purposes set out in this Privacy Notice and to fulfil our legal obligations. We have internal rules that set out how long we retain information.

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.

How can you make a request to exercise your rights?

To exercise any of the above rights or to ask a question, please contact us at the contact information provided at the top 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 I complain to a supervisory authority?

You can always contact the supervisory authority with a complaint. Your supervisory authority depends on your state of residence, your work or the alleged infringement. A list of supervisory authorities (for the non-public sector) and their addresses can be found at:

https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html

Legal or contractual provisions for providing personal data; necessity for the contractual conclusions; obligation of the data subject to provide the personal data; possible consequences of failure

We inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual regulations (e.g. information on the contractual partner). In some cases, it may be necessary for a contract to be concluded if a data subject provides us with personal data which must subsequently be processed by us. For example, the person concerned is obliged to provide us with personal data if our company enters into a contract with him/her. Failure to provide personal data would mean that the contract with the data subject could not be concluded. Prior to the provision of personal data by the data subject, the data subject must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of personal data is required by law or contract or required for the conclusion of the contract, whether there is an obligation to provide the personal data and what consequences the failure to provide the personal data would have.

Do we make automated decisions concerning you?

No, we do not carry out automated decision making or automated profiling.

Website visitors

When you access our website, information of a general nature is automatically recorded. This information (server log files) includes, for example, the type of web browser, the operating system used, the domain name of your Internet service provider and alike. This is only information that does not allow conclusions about your person. This information is technically necessary to correctly deliver the contents of web pages requested by you and is mandatory when using the internet. Anonymous information of this kind is statistically evaluated by us, in order to optimize our Internet appearance and the technology behind it.

Website registration with your name, email address and basic contact details is required in order to save configurations made with Thomson online sizing and selection tools, to save preferences for unit of measure and currency, to request quotations, and to download 3D/2D CAD drawings. Basic contact information is also required for standard contact forms used to request customer service, to conduct e-commerce (North American only) or to otherwise engage with Thomson associates online.

The Thomson software error logging system collects data from the system when an error occurs. Most of the information is not personal and is related to system state or type of error that occurs. If/when an error occurs while a customer or employee is filling out a form, the data the individual enters will be stored. The data is required in order to understand if any of the values created the error. The log data is stored for a maximum of six months for error analysis.

As a legal basis we refer to the balancing of interests according to Art. 6 para. 1 lit. f of the GDPR.

Our legitimate interest is to offer you a high-quality internet presence to be successful on the market.

Various service providers, such as web hosters, are involved in the provision of the web service. An inspection of the data cannot be excluded. In order to safeguard your interests, appropriate contracts have been concluded for order processing.

Use of cookies:

When you use our website, cookies are stored on your computer. Cookies are small text files that are stored on your hard drive, assigned to the browser you are using, and that provide certain information to the body that sets the cookie. Cookies cannot run programs or transmit viruses to your computer. They serve to help the Internet offer more user-friendly and effective experiences overall. We also use cookies to identify you for follow-up visits if you have an account with us. Otherwise you would have to log in again for each visit. This website uses the following types of cookies, the scope and operation of which are explained below:

Transient cookies

These cookies are automatically deleted when you close the browser. These include, in particular, the session cookies. These store a so-called session ID, with which various requests from your browser can be assigned to the common session. This will allow your computer to be recognized when you return to our website. The session cookies are deleted when you log out or close the browser.

Persistent cookies

These cookies are automatically deleted after a specified period, which may differ depending on the cookie. You can delete the cookies in the security settings of your browser at any time.

Flash Cookies

The Flash cookies used are not detected by your browser but by your Flash plug-in. Furthermore, we use HTML5 storage objects, which are stored on your device. These objects store the required data regardless of your browser and do not have an automatic expiration date. If you do not want to process the Flash cookies, you must install a corresponding add-on, eg. Eg "Better Privacy" for Mozilla Firefox ( https://addons.mozilla.org/en/firefox/addon/betterprivacy/) or the Adobe Flash killer cookie for Google Chrome. You can prevent the use of HTML5 storage objects by using private mode in your browser. In addition, we recommend that you regularly delete your cookies and the browser history manually.

Prevention of cookies

You can configure your browser setting according to your wishes. You may decline the acceptance of third-party cookies or all cookies. Please be aware that you may not be able to use all functions of this website.

Legal basis and duration of storage

The legal bases for possible processing of personal data and their duration of storage vary and are presented in the following sections.

Website Analysis

For purposes of analyzing and optimizing our websites, we use various services, which are presented below. This analysis allows us to understand, for example, how many people visit our site, what information is most in demand, and how people find it. Among other things, we collect data on which website an affected person came to a website (so-called referrer), which subpages of the website were accessed or how often and for which length of stay a subpage was viewed. This helps us to design and improve our offers in a user-friendly way. The data collected is not intended to personally identify individual users. Anonymous or at most pseudonymous data are collected. The legal basis for this is Art. 6 para. 1 f of the GDPR.

Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Inc, (1600 Amphitheatre Parkway Mountain View, CA 94043, USA). Usage includes the Universal Analytics operating mode. This makes it possible to assign data, sessions and interactions across multiple devices to a pseudonymous user ID, thus analyzing the activities of a user across devices.

Google Analytics uses cookies that allow you to analyze the use of the website. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. However, in the event of activation of IP anonymization on this website, your IP address will be shortened beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there. The IP address provided by Google Analytics as part of Google Analytics will not be merged with other Google data. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website activity and internet usage to the website operator. In these purposes, our legitimate interest lies in the data processing. The legal basis for the use of Google Analytics is § 15 Abs. 3 TMG or Art. 6 Abs. 1 f DSGVO. The data sent by us and linked to cookies, user IDs (e.g. user ID) or advertising IDs will be automatically deleted after 50 months. The deletion of data whose retention period has been reached is done automatically once a month. For more information about Terms of Use and Privacy, please visit

https://marketingplatform.google.com/about/analytics/terms/us/

or

https://policies.google.com/?hl=en

You can prevent the storage of cookies by a corresponding setting of your browser software; however, please note that if you do this, you may not be able to use all the features of this website to the fullest extent possible. In addition, you may prevent the collection by Google of the data generated by the cookie and related to your use of the website (including your IP address) as well as the processing of this data by Google by using https://tools.google.com/dlpage/gaoptout?hl=EN download and install. Opt-out cookies prevent future collection of your data when you visit this website. To prevent Universal Analytics tracking across devices, you must opt-out on all systems you use. If you click here, the opt-out cookie will be set: Disable Google Analytics.

Newsletter recipients

With your consent according to art. 6 para. 1 a GDPR you can subscribe to our newsletter, with which we inform you about our current offers.

For the registration to our newsletter we use the so-called double opt-in procedure. This means that after your registration we will send you an e-mail to the specified e-mail address in which we ask you to confirm that you would like the newsletter to be sent. If you do not confirm your registration within 24 hours, then you will not be eligible to receive promotional emails from Thomson and specific requests to be added to our email list will be deleted automatically after one month. Excluded from this automatic deletion process is any information related to a request from you for Thomson information or assistance. In addition, we store your IP addresses and the time of registration and confirmation. The purpose of the procedure is to be able to prove your registration and, if necessary, to clarify a possible misuse of your personal data.

After your confirmation we will save your e-mail address for the purpose of sending you the newsletter. The legal basis is Art. 6 para. 1 a GDPR.

You can revoke your consent to receive the newsletter at any time and unsubscribe from the newsletter. You can declare your revocation by clicking on the link provided in every newsletter e-mail or by sending a contact request to the data protection officer specified above.

Newsletter tracking:

We would like to point out that we evaluate your user behaviour when sending the newsletter. For this analysis, the e-mails sent contain so-called web beacons or tracking pixels, which are stored on our website. For evaluation purposes, we link the above data and web beacons to your e-mail address and an individual ID. Links received in the newsletter also contain this ID.

With the data obtained in this way, we create a user profile to tailor the newsletter to your individual interests. We record when you read our newsletters, which links you click on in them and deduce your personal interests. We link this data to actions taken by you on our website. You can object to this tracking at any time by clicking on the “Unsubscribe from all Thomson e-mails” link provided in each e-mail. The information is collected for as long as you have subscribed to the newsletter. After a cancellation we store the data purely statistically.

Such tracking is also not possible if you have images turned off or if your email client is set for plain text only. In this case the newsletter will not be displayed completly and you may not be able to use all functions. If you display the images manually, the above tracking takes place.

Privacy for applicants

You can apply to our company electronically, especially by e-mail. We will of course use your details exclusively for processing your application and will not pass them on to third parties. Please note that unencrypted e-mails are not transmitted with access protection.

If you have applied for a specific position and it has already been filled or if we consider you suitable for another position, we would be happy to forward your application within Regal Rexnord. Please let us know if you do not agree to a forwarding.

Your personal data will be deleted immediately after completion of the application process or after a maximum of 6 months, unless you have expressly given us your consent for a longer storage of your data or a contract has been concluded. The legal basis is Art. 6 Para. 1 a, b and f GDPR and § 26 BDSG. After completion of the application, our legitimate interest in the further storage of your data lies in the defence against unjustified claims.

Privacy for customers

For the purposes of the pre-contractual offer phase or for order fulfilment or service provision, we process personal data such as address and contact data, information on discussions held, your requirements, offers and other information that we receive from you. In the case of corporate customers, we also process information, in particular contact data, about our contact persons. For the purpose of payment processing, we may store and process data relating to your bank account and/or credit card information. If external partners are involved in the provision of services or the fulfilment of orders, the necessary information for the provision of their services may be passed on to them. During the processing of information, auxiliary systems (IT environment, CRM/ERP systems, financial accounting) can be used to which service providers have access within the framework of maintenance. In these cases we agree the necessary contracts for order processing. The legal basis is Art. 6 para. 1 lit b of the GDPR.

What about marketing?

Thomson would like to contact you from time to time about similar products, services and promotional offers by email, telephone and post.

You can expect to receive no more than 6 marketing emails per month from us.

You can unsubscribe / opt out at any time by clicking the “Unsubscribe” link in any of our communication or by sending us an e-mail to thomson.privacy.europe(at)regalrexnord.com and mentioning “Unsubscribe” in the subject line.

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

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

Privacy for suppliers

When selecting suppliers or service providers, we will store and process information about you. Within the scope of supplier verification/assessment, we can obtain and store further information, e.g. from credit agencies. For order processing purposes, we will also process order-specific information in addition to your master data. In the case of company contacts, we also process information, in particular contact data, about our contact persons. During the processing of information, auxiliary systems (IT environment, CRM/ERP systems, financial accounting) can be used to access the service providers within the framework of maintenance. In these cases we agree the necessary contracts for order processing. The legal basis is Art. 6 para. 1 lit b of the GDPR.

Changes to the Privacy Policy

We reserve the right to change our privacy practices when necessary due to changes in relevant and applicable legal or regulatory requirements, our business practices, or in our attempts to better serve your needs. Notice of such changes to our privacy practices will be given in the manner described in the revised Privacy Policy that will be posted at this location.

Updated 10. January 2024