ACUANT
EUROPEAN PRIVACY NOTICE

Effective Date: June 13, 2022

This European Privacy Notice contains information on how we collect, store, process, transfer, share use data that identifies or is associated with residents of the European Economic Area ("EEA"), Switzerland, and the United Kingdom ("UK") ("personal data") and information regarding our use of cookies and similar technologies. This European Privacy Notice applies solely to residents of the EEA, Switzerland, and the UK ("you"). Unless otherwise expressly stated, all terms in this section have the same meaning as defined in our Privacy Notice or as otherwise defined in the General Data Protection Regulation 2016 ("GDPR").

Acuant, Inc. is the controller of the personal data we hold about you in connection with your use of our website, forms, or any information that you submit to Acuant. This means that we determine and are responsible for how your personal data is used.

Personal Data We Collect From You When You Use our Sites and How We Use It

We collect personal data as set out in the "Our Collection of Personal Information" and "Our Use of Personal Information" sections of our Privacy Notice. We will indicate where the provision of certain personal data is mandatory. If you choose not to provide such personal data, we may not be able to provide those parts of the Sites to you or respond to your other requests.

This privacy notice does not provide detail on how our products or services process your personal information. For information on how our products or services process your personal information, please see our Product Privacy Notice.

Information We Collect About You Automatically

We also automatically collect personal data indirectly about how you access and use our Site, and information about the device you use to access the Site, or otherwise engage with us. Please see the "Personal Information Automatically Collected" section of our general Privacy Notice for more information about what data we collect and how we use it.

• For more information on cookies and other tracking technologies we use, please see our Cookie Notice.
• We may link or combine the personal data you provide and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.
• We may anonymise and aggregate any of the personal data we collect (so that it does not directly identify you) and may use the anonymised and aggregated information or disclose it as set out in our general Privacy Notice.

How Long Will We Store Your Personal Data

We will usually store the personal data we collect about you for no longer than necessary, including for the purposes of our legitimate business interests and satisfying any legal or reporting requirements, and in accordance with our legal obligations and legitimate business interests.

Where we have collected your personal data for marketing purposes, we will retain your personal data for as long as you remain subscribed to our mailing lists or until you inform us that you no longer wish to receive marketing from us by unsubscribing or using our webform.

For account management purposes, we will retain the personal data for as long as we have the relationship with your organization. If Acuant no longer has a relationship with your organization, then we will only keep the relevant information, such as invoices, for audit purposes in accordance with applicable law requirements. If Acuant is informed you are no longer the contact we need to liaise with or you leave your organisation, we may remove your details from our system.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and the applicable legal requirements.

Recipients of Personal Data

We may share your personal data with the recipients as set out in the "Our Disclosure of Personal Information" section of our general Privacy Notice.

Marketing and Advertising

From time to time we may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services.

• For some marketing messages, we may use personal data we collect about you to help us determine the most relevant marketing information to share with you.
• We will only send you marketing messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the unsubscribe link at the bottom of our marketing emails or by contacting us.

Storing and Transferring Your Personal Data

• Security. We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, change or damage. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.
• International Transfers of Your Personal Data. The personal data we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations, including in the United States. For example, if you are accessing our website from the EEA, your personal data will be processed outside of the EEA to the US.
• As a global organization, we have sales teams located all over the world. It will be necessary for your personal data to be transferred to them for account management activities or, where you have requested it, for marketing purposes.
  
  In the event of such a transfer, we ensure that: (i) the personal data is transferred to countries recognised as offering an equivalent level of protection; or (ii) the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission.
  
  If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of this European Privacy Notice.

Your Rights in Respect of Your Personal Data

As an individual, you have rights under the GDPR regarding the use of your personal data, these are:

• The right to withdraw consent – you can withdraw consent at any time.
• The right to erasure – you can request that GBG remove your personal data from our systems.
• The right to restrict processing – you can request that GBG only process your personal data for the purposes you specify.
• The right to data portability – you can request that the personal data you have provided to GBG be ported to another organisation.
• The right to access your personal data – You have a right to know what personal data GBG hold on you and for what purpose we are processing your personal data. This is known as a Subject Access Request (SAR).
• The right to rectification – you have the right to ask us to rectify any information you believe is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• The right to object to processing – you have the right to object to processing if we are able to process your information because the processing is in our legitimate interests.
• The right to obtain information upon request on the balancing test we have carried out when determining we are able to rely on legitimate interest as our lawful basis for processing your personal data.

Please keep in mind that some of these rights are subject to an internal assessment that one of the grounds under the GDPR is satisfied.

You can send these requests using this form, or by post to:

UK Representative:
Privacy & Data Compliance Team
GBG
The Foundation
Herons Way
Chester Business Park
Chester
CH4 9GB
United Kingdom

Or you can make a request in person or call +44 (0) 1244 657277.

Our EEA representative is located in Spain at the following address

GBG
Edifici El Triangle 4a planta
Placa de Catalunya
1 08002 Barcelona
Spain
T: +34 (0) 935 451 156
Via email to DPO@gbgplc.com

You are not required to pay any charge for exercising your rights. We have one calendar month to respond to you. If GBG are unable to comply with your request, we will provide you with an explanation.

If you wish to exercise one of these rights, please contact us using the contact details at the end of this European Privacy Notice.

Due to the confidential nature of data processing we may ask you to provide proof of identity when exercising the above rights. This can be done by providing a scanned copy of a valid identity document or a signed photocopy of a valid identity document.

Where you believe Acuant have not taken our responsibilities with your personal data seriously, you have the right to complain to your local data protection authority. Information about how to contact your local data protection authority is available here.

Cookies and Similar Technologies Used on Our Site

Our Site use cookies and similar technologies such as pixels and Local Storage Objects (LSOs) like HTML5 (together "cookies") to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to monitor and analyse how you use and interact with our Site so that we can continue to improve our Site. It also helps us and our advertising partners to determine products and services that may be of interest to you, in order to serve you targeted advertisements. Please see our Cookie Notice for more information about these practices and your choices regarding cookies.

Our Policy Towards Children

Our Sites are not directed at persons under 16. We do not knowingly collect or solicit personal data from any persons under the age of 16. If you believe that we might have any information from a child under 16 please contact us using the details at the end of this European Privacy Notice.

Changes to This European Privacy Notice

We may update this European Privacy Notice from time to time and so you should review this page periodically. When we change this European Privacy Notice in a material way, we will update the "Effective Date" above. Changes to this European Privacy Notice are effective when they are posted on this page.

Contact Us

Please contact DPO@gbgplc.com if you have any questions, comments and requests regarding this European Privacy Notice.