DATA PRIVACY

Data Privacy Policy for ROSS OPERATING VALVE, ROSS CONTROLS®, ROSS DECCO®, Automatic Valve Industrial, and Pneumatrol Limited collectively the “ROSS Global Family”.

At the ROSS Global Family we are committed to processing personal information about our customers in ways that comply with our legal obligations under GDPR (General Data Protection Regulations), LGPD (Lei Geral de Proteção de Dados), and other regulations as well as being clear with our customers about what we do with their personal information.

Some of the key points of ROSS privacy statement are:

• We do not sell your personal data to third parties
• We do make it easy for you to manage your information
• You can unsubscribe using the link at the bottom of any email we send you
• We do use data to give you the best experience with the ROSS Global Family, for example to provide the best customer service and ensure information we share is relevant, useful, and timely

This document covers information we collect about you, whether via our websites, through our customer service or sales facilities, our distributors or otherwise. Please read it carefully to understand how your personal information will be treated.

INFORMATION WE MAY GATHER FROM YOU

• To maintain our relationship with you while you are a customer or potential customer
• To process orders and provide agreed goods and services to you
• For invoicing, processing payments, account set up and maintenance
• To communicate with you, including to respond to information requests /inquiries submitted and/or to obtain your feedback on our products and services
• For record keeping, statistical analysis and internal reporting
• To notify you about changes to our products and services
• To send you promotional emails about products, services, offers and other things we think may be relevant to you
• To notify you about price changes
• To notify you of any important announcements
• To monitor the quality of our products and services
• To investigate any complaint you make
• To provide evidence in any dispute or anticipated dispute between you and us
• As we may otherwise consider necessary to support the operation of our Website

LEGAL BASIS FOR PROCESSING

In terms of the legal basis we rely on to process your personal information, these are as follows:

• Where you have provided your consent for direct marketing communications of our own products and services, including marketing communications sent by electronic means (e.g. email)
• For the performance of a contract with you (such as a contract for the provision of goods and services) or to take steps at your request prior to entering into this contract
• To comply with legal obligations, including health and safety and environmental legislation, performing anti- money laundering, terrorism prevention and sanctions screening checks, complaints and investigations or litigation
• To protect your vital interests or the vital interests of another person, e.g. where you or they are seriously injured or ill
• For our legitimate interests in:
  • Management of your account (including processing payments) and our relationship with you, and communicating with you
  • Operating our Websites
  • Sending direct marketing on our own products and services where you have not provided your consent and the marketing communication is sent by non-electronic means (e.g. post or telephone); processing orders and supplying our products and services; and
  • Our internal business purposes which may include processing for the purposes of record keeping, research, reporting and statistics, data security, to ensure the quality of our products and services, investigating and responding to queries and complaints, obtaining credit references and credit checks, providing payment performance data to credit reference agencies, changing our pricing, debt collection, fraud detection and prevention, risk management, recruitment and training of our personnel, and protecting our rights, property and safety (and that of others). You can object to processing carried out based on our legitimate interests at any time by emailing sales@rosscontrols.com.

HOW WE SHARE YOUR PERSONAL INFORMATION

When we use your personal information for the purposes specified above, we may share your personal information with:

• Third party provider(s) who provide the following types of services to us: marketing, logistics, software and customer relationship management
• Third party providers, distributors, or agents we appoint as our sales agents or to perform services on our behalf, who are provided with access to certain ROSS Group customer account details in order to process sales or provide services on our behalf.
• Licensed credit reference agencies, debt collection agencies and lawyers when we carry out credit checks, to report on your payment performance and/or or seek to recover debts due to us
• Our accountants, auditors, lawyers, or similar advisers when we ask them to provide us with professional advice
• Investors and other relevant third parties in the event of an actual or potential sale or other corporate transaction related to the ROSS Global Family
• Any other third parties, if authorized by you to do so
• We do not sell your personal data to third parties

How Long We Keep Your Personal Information

We retain your personal information for no longer than is necessary for the purposes for which the personal information is collected. When determining the relevant retention periods, we will consider factors including:

• Legal obligation(s) under applicable law to retain data for a certain period of time
• Statute of limitations under applicable law(s)
• Potential disputes
• Guidelines issued by relevant data protection authorities

Otherwise, we securely erase your information once this is no longer needed.

USE OF COOKIES ON OUR WEBSITE

Our website uses cookies to improve the user’s experience while visiting the website.

Where applicable, our website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer / device. This complies with recent legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer / device.

Cookies are small files saved to the user’s computer’s hard drive that track, save and store information about the user’s interactions and usage of the website. This allows our website, through its server to provide the users with a tailored experience within this website.

Users are advised that if they wish to deny the use and saving of cookies from our website onto their computers hard drive, they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors.

Our website uses tracking software to monitor its visitors to better understand how they use it. This software is provided by Google Analytics, which uses cookies to track visitor usage. The software will save a cookie to your computer’s hard drive in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information. You can read Google’s privacy policy here for further information http://www.google.com/privacy.html.

Click on the link below to access your Cookies Settings Selection Options:

Cookie Settings Selection

CONTACT & COMMUNICATION

Users contacting this website, and/or its owners do so at their own discretion and provide any such personal details requested at their own risk. Your personal information is kept private and stored securely until a time when it is no longer required or has no use, as detailed in the Data Protection Act 1998. Every effort has been made to ensure a safe and secure form to email submission process, but we advise users using such form to email processes that they do so at their own risk. This website and its owners use any information submitted to provide you with further information about the products / services they offer or to assist you in answering any questions or queries you may have submitted. This includes using your details to subscribe you to any email newsletter program the website operates but only if this was made clear to you and your express permission was granted when submitting any form to email process. Or whereby you the consumer have previously purchased from or enquired about purchasing from the company a product or service that the email newsletter relates to. This is by no means an entire list of your user rights regarding receiving email marketing material.

MARKETING

We may send you direct marketing on our own products and services by e-mail if this is in line with any marketing preferences that you have provided to us.

We will only send you direct marketing in relation to our own products and services by email:

• Where you have consented to this
• Where you have not objected to this

Your agreement to the use of your personal information for direct marketing purposes is optional and if you choose not to consent, your visit to and use of our Website will not be affected.

You can choose to opt out of receiving direct marketing information from us at any time, through the ‘Unsubscribe’ link at the bottom of any ROSS Global Family email you receive, or by contacting us directly by filling in the contact us form on our website.

When you inform the ROSS Global Family that you no longer prefer information related to you or your company shared in the manner described herein, the ROSS Group will take reasonable and affirmative steps to delete such information from its data bases.

SOCIAL MEDIA PLATFORMS

Communication, engagement, and actions taken through external social media platforms that this website and its owners participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.

Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution regarding their own privacy and personal details. Neither this website nor its owners will ever ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.

This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.

SHORTENED LINKS IN SOCIAL MEDIA

This website and its owners through their social media platform accounts may share web links to relevant web pages. By default, some social media platforms shorten lengthy URLs [web addresses].

Users are advised to take caution and good judgement before clicking any shortened URLs published on social media platforms by this website and its owners. Despite the best efforts to ensure only genuine URLs are published, many social media platforms are prone to spam and hacking and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.

CONTACT US

For further information regarding this Privacy Policy or to make a complaint please contact us by filling in the contact us form on our website.

FOR CALIFORNIA RESIDENTS

California Civil Code Section 1798.83 permits Sites’ users who are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make a request, please contact us: dataprivacy@rosscontrols.com or fill out the online Contact Us Form.

Furthermore, California residents have the following rights with respect to personal data we may have collected about them:

REQUESTS TO KNOW

You have the right to request that we disclose:

• The categories of personal data we have collected about you;
• The categories of personal data about you we have sold or disclosed for a business purpose;
• The categories of sources from which we have collected personal data about you;
• The business or commercial purposes for selling or collecting personal data about you;
• The categories of personal data sold or shared about you, as well as the categories of third parties to whom the personal data was sold, by category of personal data for each party to whom personal data was sold; and
• The specific pieces of personal data collected.

You may submit a request to know via dataprivacy@rosscontrols.com. The delivery of our response may take place electronically or by mail. We are not required to respond to requests to know more than twice in a 12-month period.

REQUESTS TO DELETE

You have the right to request that we delete any personal data about you that we have collected. Upon receiving a verified request to delete personal data, we will do so unless otherwise authorized by law. You may submit a request to delete personal data via dataprivacy@rosscontrols.com.

AUTHORIZED AGENTS

You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney pursuant to Probate Code sections 4000-4465 may submit a request on your behalf.

METHODS FOR SUBMITTING CONSUMER REQUESTS AND OUR RESPONSE TO REQUESTS

You may submit a request for access and requests to delete personal data about you via: via email at dataprivacy@rosscontrols.com

Upon receipt of a request, we may ask you for additional information to verify your identity. Any additional information you provide will be used only to verify your identity and not for any other purpose.

We will acknowledge the receipt of your request within ten (10) days of receipt. Subject to our ability to verify your identity, we will respond to your request within 45 days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. In order to protect your privacy and the security of personal data about you, we verify your request by sending an email to the known address and asking for verification. We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

THE RIGHT TO NON-DESCRIMINATION

You have the right not to be discriminated against for the exercise of your California privacy rights described above.