CROWN EQUIPMENT CORPORATION

 

SAFE HARBOR PRIVACY POLICY

 

 

 

Crown Equipment Corporation ("Crown") respects individual privacy and values the confidence of its customers, employees, business partners and others. Not only does Crown strive to collect, use and disclose Personal Information in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices. This Safe Harbor Privacy Policy (the "Policy") sets forth the privacy principles that Crown follows with respect to transfers of Personal Information from the European Union (EU) to the United States.

 

SAFE HARBOR

 

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (the "Safe Harbor Principles") to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to Personal Information transferred from the EU to the United States. Consistent with its commitment to protect personal privacy, Crown adheres to the Safe Harbor Principles.

 

SCOPE

 

This Policy applies to all Personal Information received by Crown in the United States from the EU, in any format including electronic, paper or verbal.

 

DEFINITIONS

 

For purposes of this Policy, the following definitions shall apply:

 

"Agent" means any third party that uses personal information provided to Crown to perform tasks on behalf of and under the instructions of Crown.

 

"Crown" means Crown Equipment Corporation, its successors, subsidiaries, divisions and groups in the United States.

 

"Personal Information" means any information or set of information that identifies or could be used by or on behalf of Crown to identify an individual. Personal Information does not include information that is encoded or anonymous or publicly available information that has not been combined with non-public personal information.

 

"Sensitive Personal Information" means Personal Information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. In addition, Crown will treat as Sensitive Personal Information any information received from a third party where that third party treats and identifies the information as sensitive.

 

 


PRIVACY PRINCIPLES

 

The privacy principles in this Policy are based on the Safe Harbor Principles.

 

NOTICE: Where Crown collects Personal Information directly from individuals in the EU, it will inform them about the purposes for which it collects and uses Personal Information about them, the types of non-agent third parties to which Crown discloses that information, and the choices and means, if any, Crown offers individuals for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to Crown, or as soon as practicable thereafter, and in any event before Crown uses the information for a purpose other than that for which it was originally collected.

 

Where Crown receives Personal Information from its subsidiaries, affiliates or other entities in the EU, it will use such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such Personal Information relates.

 

CHOICE: Crown will offer individuals the opportunity to choose (opt-out) whether their Personal Information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

 

For Sensitive Personal Information, Crown will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

 

Crown will provide individuals with reasonable mechanisms to exercise their choices.

 

DATA INTEGRITY: Crown will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Crown will take reasonable steps to ensure that Personal Information is relevant to its intended use, accurate, complete, and current.

 

TRANSFERS TO AGENTS: Crown will obtain assurances from its agents that they will safeguard Personal Information consistently with this Policy. Where Crown has knowledge that an agent is using or disclosing Personal Information in a manner contrary to this Policy, Crown will take reasonable steps to prevent or stop the use or disclosure.

 

ACCESS AND CORRECTION: Upon request, Crown will grant individuals reasonable access to Personal Information that it holds about them. In addition, Crown will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

 

SECURITY: Crown will take reasonable precautions to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

 

ENFORCEMENT: Crown will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Crown determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

 

DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of Personal Information should be directed to the Crown Privacy Office at the address given below. Crown will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between Crown and the complainant, Crown has agreed to participate in the dispute resolution procedures of the panel established by the European data protection authorities to resolve disputes pursuant to the Safe Harbor Principles.

 

CONTACT INFORMATION

 

Questions or comments regarding this Policy should be submitted to the Crown Privacy Office by mail or email as follows:

 

Crown Privacy Office

40 S. Washington Street

New Bremen, Ohio 45869

 

Email: privacyoffice@crown.com

 

CHANGES TO THIS SAFE HARBOR PRIVACY POLICY

 

This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. Appropriate public notice will be given concerning such amendments.

 

EFFECTIVE DATE: October 29th, 2012