REXNORD PMC DATA PRIVACY POLICY


Effective Date: October 4, 2021

LandNewco., Inc., 111 W Michigan Ave, Milwaukee, WI 53203, USA; email: [email protected] and each of its subsidiaries (collectively the "Group") take data privacy seriously. This Data Privacy Policy (“Privacy Policy”) informs our business partners (including customers, vendors and suppliers), job applicants and website users how we as controllers / responsible entities for data processing collect and process personal data and provides other information to our data subjects.

Definitions:
As this Privacy Policy shall cover the transparency and information obligations stemming from various national and state data protection laws as applicable to the Group, the terms and terminology used within this Privacy Policy shall be interpreted in light of the respective terminology used and defined by the applicable data protection law. For example:
personal data shall refer to (i) any information relating to a data subject to the extent the GDPR applies, and (ii) any personal information as defined in the CCPA to the extent the CCPA applies, and (iii) to any similarly defined data or information as specified in other applicable data protection laws to the extent other data protection laws apply.
data subject shall refer to (i) any identified or identifiable natural person to the extent the GDPR applies, and (ii) to any natural person who is a California resident, however identified, including by any unique identifier to the extent the CCPA applies (consumer), and (iii) to a similarly defined natural or legal person as specified in other applicable data protection laws to the extent other data protection laws apply.
controller shall refer to (i) any natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data to the extent the GDPR applies, and (ii) to any for-profit entity doing business in California and falling under the term ‘business’ as defined in the CCPA to the extent the CCPA applies, and (iii) to a similarly defined natural or legal person as specified in other applicable data protection laws to the extent other data protection laws apply. 
processor shall refer to (i) a natural or legal person, public authority, agency or other body which processes personal data on behalf of a controller to the extent the GDPR applies, and (ii) a service provider as defined in the CCPA to the extent the CCPA applies, and (iii) to a similarly defined natural or legal person as specified in other applicable data protection laws to the extent other data protection laws apply. 
GDPR shall refer to the EU General Data Protection Regulation as amended from time to time
CCPA shall refer to the California Consumer Privacy Act of 2018 as amended from time to time
 
  1. Controller: Who is the Controller for your Personal Data

    The responsible controller within the Group will depend on the processing activities that apply to you. The companies of the Group are identified in Annex 1. For example:

    • if you are a website user and visit a webpage of the Group, the Controller is the company of the Group identified on the webpage.

    • If you are a customer, vendor, supplier or business partner and you interact with a company of the Group for business reasons, the Controller is the subsidiary of the Group with whom you interact.

    • if you are a job applicant and you submitted your application, the subsidiary of the Group who offers the job to which you apply is the Controller.

    In the following, the term “Controller”, “we”, “us” or “our” refers to the company in Group that acts as the controller for the particular processing activities as explained above.
    If you have any questions as to who the Controller of your personal data is, please contact us via the contact details set out in section 9.

  2. Categories of Personal Data and Processing Purposes and Sources of Personal Data: What personal data do we process about you, why and from where?

    Depending on whether you are a customer, vendor, supplier, business partner, job applicant and/or website user the Controller may process the following categories of personal data for the identified processing purposes:

    2.1 Website Metadata

    As a website user, you may use our Websites without actively providing any personal data. In this case, we will collect only the following metadata resulting from your usage of our Websites: browser type and version, operating system and interface, website from which you are visiting (referrer URL), webpage(s) you visit on our Websites and activity on those Websites, date and time of Websites’ access, device identifier or MAC address and internet protocol (IP) address. This personal data includes Internet or other Electronic Network Activity Information under the CCPA.  Further personal data may be collected through cookies, see section 7 below.

    The metadata will be used to enable your access to our Websites. to improve our services as well as the quality of our Websites. We will analyze user behavior in anonymized form to prevent fraud and misuse of our IT systems, as well as to ensure physical, IT, and network security.

    Our website is not intended for use by those under the age of 16 and we do not knowingly collect, use, process or otherwise disclose information about children under the age of 16.

    2.2 Contact details

    If you contact us through a portal on any of our Websites, you will be asked to provide the following personal data: name, company, title, address, email address, telephone number, and fax number. We process such personal data to answer your queries or information requests. This personal data includes Identifiers under the CCPA.

    2.3 Newsletter and product catalogues

    If you request our newsletter or product catalogues, we collect and process the following personal data: name, title, company name, email address, postal address (if requesting postal mails), and your voluntary request to receive marketing emails or postal mails. This personal data includes Identifiers under the CCPA. We process such personal data to provide you with the requested emails or postal mails, as well as to analyze your interests for marketing purposes, to distribute additional marketing materials and to analyze the success of our marketing activities, customer segmentation and customer profiling, lead generation to the extent permitted by applicable law.

    2.4 Portal users

    If you request access to an online portal we operate, in addition to the information described in Section 2.1 of this policy, we collect and process the following personal data: name, title, company name, email address, portal access username, portal access password and your voluntary request to receive access to such portal. This personal data includes Identifiers under the CCPA. We process such personal data to facilitate your access to the portal, to protect the security of our systems and infrastructure, to meet regulatory and legal obligations, to establish or defend legal claims, and to meet contractual obligations.  We may also use such information to analyze your interests for marketing purposes, to distribute additional marketing materials and to analyze the success of our marketing activities, customer segmentation, customer profiling, lead generation, to the extent permitted by applicable law.

    2.5 Rexnord Connect ® and DiRXN ® users

    To the extent provided to us, we collect and process the following personal data of Rexnord Connect® and DiRXN® users: name, email address, company postal address. This personal data includes Identifiers under the CCPA. We process this information to facilitate the connected device operation and meet our contractual obligations.

    2.6 Business Partners

    To the extent provided to us, we collect and process the following personal data of current and potential business partner contacts: name, title, function, company name, company email address, company postal address, and any voluntary requests for communications from us. This personal data includes Identifiers under the CCPA. We process this information to facilitate business partner engagements, to protect the security of our systems and infrastructure, to meet regulatory and legal obligations, to establish and defend legal claims, and to meet contractual obligations.

    2.7 Visitors to Our Premises

    To the extent provided to us, we collect and process the following personal data of visitors to our premises: name, title, company name, function, company email address, company postal address, identity of visitor's contact, date and duration of visit, vehicle information, and information necessary to facilitate in-person visits in accordance with government and/or health regulator direction or advice, including, with visitor consent where necessary, temperature and only in accordance with applicable law.  This personal data includes Identifiers and Health Information under the CCPA. Our premises may also be subject to CCTV, biometric or other security solutions that may capture images and/or audio of visitors, in accordance with applicable law. We process this information to facilitate such in-person visits, to protect our company, employees and visitors, to meet regulatory and legal obligations, to establish and defend legal claims, and to meet contractual obligations.

    2.8 Job Applicants

    If you apply for a position with us, in addition to the information described in Section 2.1 above (to the extent applicable), we collect and process the following categories of personal data from or about job applicants:

    • Identifiers, including full name, contact information (e.g., personal and/or business address, personal and/or business phone/fax numbers, email addresses), user name and password (if using an applicant portal), citizenship / residency information, age (to the extent necessary); marital status, religious belief (if voluntarily provided by you)
    • Certain categories of sensitive information and data (to the extent permitted by applicable law), including facial photographs (if voluntarily provided by you), Characteristics of Protected Classifications (as defined under the CCPA), including gender, ethnicity, nationality, disability information, and military and veteran status (each only to the extent voluntarily provided by you with your express consent);
    • Professional or employment-related information, including languages spoken and skills, software experience, professional memberships, summaries of strengths and technical areas of expertise, pre-company work history information (e.g., previous employers and positions held, dates, locations, supervisors, responsibilities, salary), resume and cover letter information, references and information obtained from them, and related background check (to the extent permitted, and in accordance with applicable law);
    • Education information, including education, and certificates and degrees obtained; and
    • Other information, including any other information reasonably necessary for us to carry out our legal or regulatory obligations.


    We use such personal data to facilitate the collection, administration and processing of your application, to determine your suitability for the role for which you have applied or for similar roles within our Group, to conduct background checks (in accordance with applicable law) as part of your application, and to complying with applicable laws, company policies and employment-related requirements. Where required by law, we will provide an additional job applicant notice.

  3. Processing Basis and Consequences: What is the legal justification and business purpose for processing your personal data and what happens if you choose not to provide it?

    We rely on the following legal grounds for the collection, processing, and use of your personal data:

    • Processing is necessary to enable your use of the Website, Web Portal or App;

    • Processing is necessary for legitimate interests pursued by us or by a third party, except where such interests are overridden by your fundamental rights and freedoms to protect your personal data; such legitimate interests are the fulfilment of the processing purposes set out above in Section 2, in particular providing our services and information to you as requested by you, improvement of our services, improvement of the quality of our Website, related portals and apps, prevention of fraud, misuse of our IT systems, physical, IT and network security, as well as marketing relating to our products and services;

    • Processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract;

    • Processing is necessary for compliance with a legal obligation to which we are subject;

    • Processing is based on your consent where provided and necessary.

    Not providing your personal data may result in disadvantages for you. For example, you may not be able to register an account on the Website, purchase or use our products and services or receive marketing information. However, unless otherwise specified, not providing your personal data will not result in legal consequences for you.

  4. Categories of Recipients and International Transfers: Who do we transfer your personal data to and where are they located?

    In the preceding twelve (12) months, we have transferred and disclosed, and we further may transfer, your personal data to third parties for the processing purposes described above as follows. The personal data transferred may include Identifiers, Internet or other Electronic Network Activity Information, Health Information, Characteristics of Protected Classifications, Education Information and Professional and Employment-related Information and Sensitive Information:

    • Within the Group:

      Subsidiaries  within the Group may receive your personal data as necessary for the processing purposes described above. Depending on the categories of personal data and the purposes for which the personal data has been collected, different internal departments within the Group may receive your personal data. For example, our IT department may have access to your account data. Moreover, other departments within the Group have access to certain personal data about you on a need-to-know basis, such as the legal department, the finance department, or internal auditing. Depending on their processing activities, such subsidiaries may act as processors or as controllers.

      The relevant companies of the Group are identified in Annex 1.

    • To service providers / processors:

      Certain service providers(for a business purpose), whether affiliated or unaffiliated, may receive your personal data to process such data under appropriate instructions as necessary for the processing purposes described above as processors. Such service providers may include website service providers, marketing service providers, IT support service providers, cloud service providers, distributors, vendors and other service providers who support us in carrying out our business activities and maintaining our commercial relationship with you. Such service providers will act on our behalf and will be subject to contractual obligations to implement appropriate technical and organizational security measures to safeguard your personal data and to process your personal data only as instructed.

      You can ask for further details of currently engaged service providers by contacting us as set out in Section 8 below.

    • Other recipients:

      In compliance with applicable data protection law, we may transfer personal data to local or foreign law enforcement agencies, governmental authorities, judicial authorities, legal counsel, external consultants, or business partners. In case of a corporate merger or acquisition, personal data may be transferred to the third parties involved in the merger or acquisition.

      Any access to your personal data is restricted to individuals with a need-to-know and only if required to fulfill their job responsibilities.

    International transfers.You should expect that the recipients identified above which will receive or have access to your personal data are located inside or outside the European Economic Area ("EEA").
     
    • For recipients located outside of the EEA, some are located in countries which have been recognized by the European Commission to provide an adequate level of data protection from an EU data protection law perspective pursuant to Art. 45 GDPR (in particular, Canada, Israel, Switzerland, and UK).
     
    • Other recipients might be located in other non-EEA countries (such as Australia, China, India and the USA) which have not been recognized by the European Commission pursuant to Art. 45 GDPR. We will take all necessary measures to ensure that transfers out of the EEA are adequately protected as required by applicable data protection law.
      • In particular, where required by applicable data protection law, we have concluded standard data protection clauses as adopted by the European Commission or by a supervisory authority (Art. 46(2)(c) or (d) GDPR) with such recipients.
      • On request, we will make a copy of these standard data protection clauses, including the appendix as completed by us, available to you free of charge. To the extent necessary to protect business secrets or other confidential information, including personal data, we may redact part of the text of the appendix prior to sharing a copy, but shall provide a meaningful summary where you would otherwise not be able to understand its content or exercise your rights. On request, we shall provide you with the reasons for the redactions, to the extent possible without revealing the redacted information. Please submit your request via the contact details set out in Section 8.

    Sales. We do not share your personal data with the parties listed in this Privacy Policy in a manner that constitutes a "sale" under the CCPA or under Nevada Revised Statutes 603A.
  5. Retention Period: How long do we keep your personal data?

    Your personal data will be retained as long as necessary to provide you with the services and products requested. Your metadata will be deleted 26 months after your visit to the Website. Your newsletter registration data will be deleted after you inform us that you no longer want to receive marketing information from us. Your job applicant data will be deleted within the local statutory retention periods. If you are a customer or vendor contact, your data will be kept as long as we consider your company a customer of our products. In case of a deletion request, we may be required to delete all or certain of your personal data sooner.

    If we are required by applicable law to retain your personal data, we will not delete them. We may also retain your personal data if we need your personal data to establish, exercise, or defend a legal claim, only on a need-to-know basis. To the extent possible and commercially and technically practicable, we will restrict the processing of your personal data for such limited purposes after the termination of the contractual relationship.

  6. Your Rights: What rights do you have and how can you assert your rights?
    Right to withdraw your consent:If you have declared your consent regarding certain collecting, processing, and use of your personal data (in particular, regarding the receipt of direct marketing communication via email, SMS/WhatsApp, and telephone), you can withdraw this consent at any time. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal. You can withdraw your consent as follows: send an email request to [email protected] Further, you can object to the use of your personal data for the purposes of marketing without incurring any costs other than the transmission costs in accordance with basic tariffs.
    Additional data privacy rights:Pursuant to applicable data protection law, you may have the right to: (i) request access to your personal data; (ii) request rectification of your personal data; (iii) request erasure of your personal data; (iv) request restriction of processing of your personal data; (v) request data portability; and/or (vi) object to the processing of your personal data (including objection to direct marketing and profiling). Please note that these aforementioned rights might be limited under the applicable local data protection law.
    Detailed information on data privacy rights under GDPR: Below please find further information on your rights to the extent that the GDPR applies:
    • Right to request access to your personal data: As provided by applicable data protection law, you have the right to obtain from us confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, to request access to your personal data. This access information includes, inter alia, the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipient to whom your personal data has been or will be disclosed. However, this is not an absolute right and the interests of other individuals may restrict your right of access. You may have the right to obtain a copy of the personal data undergoing processing free of charge. For further copies requested by you, we may charge a reasonable fee based on administrative costs.
    • Right to request rectification: As provided by applicable data protection law, you have in certain circumstances the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you may have the right to complete incomplete personal data, including by means of providing a supplementary statement.
    • Right to request erasure (right to be forgotten): As provided by applicable data protection law, you have the right to request from us the erasure of personal data concerning you in certain circumstances and we may be obliged to erase such personal data.
    • Right to request restriction of processing: As provided by applicable data protection law, you have the right in certain circumstances to request from us restriction of processing your personal data. In such case, the respective data will be marked and may only be processed by us for certain purposes.
    • Right to request data portability: As provided by applicable data protection law, you have the right in certain circumstances to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit the data to another entity without hindrance from us.
    • Right to object: Under certain circumstances, you may have the right to object to the processing of your personal data at any time by us on grounds relating to your particular situation where the processing is based on Art. 6 (1) lit e) or f) GDPR, including profiling and direct marketing. In such cases, we are required to no longer process your personal data, unless – in certain circumstances – we can demonstrate compelling legitimate grounds for the processing which overrides your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
    • Right to lodge a claim: You also have the right to lodge a complaint with the competent data protection supervisory authority in the relevant EU Member State (e.g., the place where you reside or work) of an alleged infringement of the GDPR.
    Further information on data privacy rights under California "Shine the Light" law and CCPA
    • California "Shine the Light" law: California Civil Code Section 1798.83, also known as California's "Shine the Light" law, permits residents of California to request certain details about information we may disclose to third parties for direct marketing purposes.
    • CCPA: Subject to certain exceptions and qualifications, as a California resident, you have the right to: (i) request access to your personal information; and (ii) request deletion of your personal information. Should you wish to request the exercise of your rights as detailed above with regard to your personal information, we will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon this request. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf may submit these requests.
     
    Contact details to exercise your data privacy rights:To exercise your rights, please contact us as stated under Section 8 below.
     
  7. Cookies and other tracking technologies

    When you visit our Website, we will use cookies to ensure you get the best website experience. These cookies might process and store information about you, your preferences, or your device. Because we respect your right to privacy, you can choose not to allow some types of cookies. Full information on the various cookies, including the party responsible for the cookie, the type of information processed by the cookies, the purposes of the cookies and the classification of the cookie as “necessary cookie”, “performance cookie”, “functional cookie” or “targeting cookies” can be found in the cookie management tool accessible here.

    Necessary Cookies

    These cookies are necessary for the Website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you in a request for services, such as setting your privacy preferences, logging in, or filling in forms.

    You can set your browser to block or alert you about these cookies, but if you do, some parts of the Website will not work.

    Performance Cookies

    These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Website. They help us to know which pages are the most and least popular and see how visitors move around the site.

    In order to place those cookies, we require your consent. If you do not allow these cookies, we will not know when you have visited our site, and will not be able to monitor its performance.

    Functional Cookies

    These cookies enable our Website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our Websites.

    In order to place those cookies, we require your consent. If you do not allow these cookies, then some or all of these services may not function properly.

    Targeting Cookies

    These cookies may be set through our Websites by our advertising partners. They may be used by those advertising partners to build a profile of your interests and show you relevant advertisements on other sites.

    They can uniquely identify your browser and internet device. In order to place those cookies, we require your consent. If you do not allow these cookies, you will experience less targeted advertising.

  8. Questions and Contact Information

    If you have any questions about this Privacy Policy, please contact us at 111 W Michigan Ave, Milwaukee, WI 53203, USA; email: [email protected]

    If you want to exercise your rights as stated above in Section 6, please contact us at the above postal address or email [email protected]

    If you want to exercise your rights under CCPA or the California Shine the Light Law you may also contact us at the toll-free number 833-397-1086.

  9. Changes to this Privacy Policy

    We may update this Privacy Policy from time to time in response to changing legal, regulatory, or operational requirements. We will notify you of any such changes, including when they will take effect, by updating the Effective Date at the top of this page or as otherwise required by applicable law.


Annex 1
Group Companies
Legal Entity  Address
British Autogard Limited  2 Wilkinson Road, Love Lane Industrial Estate, Cirencester, GL7 1YT, UK
Cambridge International, Inc.  105 Goodwill Road, Cambridge, MD 21613, USA
Centa Antriebe Kirschey GmbH  Bergische Strasse 7, 42781 Haan, Germany
Centa Corp  2400 Curtiss Street, Downers Grove, IL 60515, USA
Centa Nordic AB  Metallgatan 4 C, 262 72 Ängelholm
Centa Transmissions Ltd.  2 Wilkinson Road, Love Lane Industrial Estate, Cirencester, GL7 1YT, UK
Cline Acquisition Corp  5210 Edwards Road, Taylors, SC 29687-2814, USA
LandNewco, Inc.   111 W Michigan St, Milwaukee, WI 53203, USA
Micro Precision Gear Technology Limited  Duxons Turn , Hemel Hempstead , Hertfordshire , HP2 4SB , UK
Precision Gear LLC  1900 Midway Drive, Twinsburg,OH 44087, USA
Regal Beloit America, Inc.  200 STATE ST BELOIT WI 53511, USA
Regal Rexnord Corporation  200 STATE ST BELOIT WI 53511, USA
Rexnord Flattop Europe BV  Einsteinstraat 1, 2691GV's-Gravenzande, Netherlands
Rexnord Flattop Europe Srl  Via dell'Industria 4, 42015 Correggio, Italy
Rexnord Flattop Holdings BV  Einsteinstraat 1, 2691GV's-Gravenzande, Netherlands
Rexnord France Holdings SAS  3087 rue de la Gare, 59299 Boeschepe, France
Rexnord Germany PT GmbH  Industriestrasse 1, 57501 Betzdorf, Germany
Rexnord GmbH  Industriestrasse 1, 57501 Betzdorf, Germany
Rexnord Industries, LLC   111 W Michigan St, Milwaukee, WI 53203, USA
Rexnord International, Inc.   111 W Michigan St, Milwaukee, WI 53203, USA
Rexnord Kette GmbH  Industriestrasse 1, 57501 Betzdorf, Germany
Rexnord MCC Deutschland Kette GmbH  Industriestrasse 1, 57501 Betzdorf, Germany
Rexnord Tollok S.r.L.  Viale Adriatico 9, 44020 Masi Torello, Italy
 The Falk Service Corporation   111 W Michigan St, Milwaukee, WI 53203, USA