CALIFORNIA PRIVACY POLICY

This Section describes our online and offline practices with respect to collecting, processing, and disclosing personal information relating to California residents, as required by the CCPA.

A. Personal Information We Collect and Disclose

In the past 12 months, we have collected the following categories of personal information from consumers and disclosed such information to the following categories of third parties for the business or commercial purposes described below.

Categories of personal information:

1. Identifiers

Example: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, device ID, mobile ad ID, browser ID, email address, account username, or other similar identifiers

Categories of Third Parties to Whom Disclosed:

• IT and cloud/hosting service providers, such as our email providers, business application providers, managed services providers and IT consultants

• Analytics and marketing/advertising vendors and service providers

• Vendors for the purposes of providing goods and services ordered (e.g., for shipping and handling, supplier order, etc.)

• Financial institutions and payment processors

• Professional advisors (accountants, lawyers, and auditors)

2. Commercial Information

Example: Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

Categories of Third Parties to Whom Disclosed:

• IT and cloud/hosting service providers, such as our email providers, business application providers, managed services providers and IT consultants

• Analytics and marketing/advertising vendors and service providers

• Vendors for the purposes of providing goods and services ordered (e.g., for shipping and handling, supplier order, etc.)

• Financial institutions and payment processors

• Professional advisors (accountants, lawyers, and auditors)

3. Internet or other similar network activity

Examples: Browsing details, search details, information about your interaction with the website or advertisements, including page views, clicking tendencies, and time spent on a page, and other similar event or session data.

Categories of Third Parties to Whom Disclosed:

• IT and cloud/hosting service providers, such as our email providers, business application providers, managed services providers and IT consultants

• Online analytics and marketing/advertising service providers

4. Personal information types listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Example: A name, signature, physical characteristics or description, address, telephone number

*Some personal information included in this category may overlap with other categories.

Categories of Third Parties to Whom Disclosed:

• IT and cloud/hosting service providers, such as our email providers, business application providers, managed services providers and IT consultants

• Analytics and marketing/advertising vendors and service providers

• Vendors for the purposes of providing goods and services ordered (e.g., for shipping and handling, supplier order, etc.)

• Financial institutions and payment processors

• Professional advisors (accountants, lawyers, and auditors)

5. Professional or employment-related information

Example: Employer, position

Categories of Third Parties to Whom Disclosed:

• IT and cloud/hosting service providers, such as our email providers, business application providers, managed services providers and IT consultants

• Analytics and marketing/advertising vendors and service providers

• Vendors for the purposes of providing goods and services ordered (e.g., for shipping and handling, supplier order, etc.)

• Financial institutions and payment processors

• Professional advisors (accountants, lawyers, and auditors)

6. Sensory data

Example: Voicemail or similar audio recordings

Categories of Third Parties to Whom Disclosed:

• IT and cloud/hosting service providers, such as our email providers, business application providers, managed services providers and IT consultants

From time to time, we may be required to disclose your information to governmental authorities for the purpose of complying with applicable laws and regulations or in response to legal process. We may also disclose your personal information to third parties in connection with the sale of our business or assets, or any merger or similar corporate matter, when your personal information is part of the assets involved in such transaction.

Finally, we may “aggregate” or “deidentify” information from you pursuant to the CCPA, in which event the information is no longer considered “personal information.”

B. Applicable Retention Periods

For each category of personal information identified above, we will retain your personal information only for as long as necessary to fulfill your requests or the purposes for which it was obtained, as set forth in this section. The criteria used to determine our retention periods include (i) to fulfill the purpose for which the information was collected, (ii) for as long as we have an ongoing relationship with you, and (iii) as required by a legal obligation to which we are subject.

C. Categories of Sources of Personal Information

We collect these categories of personal information from the following categories of sources:

• Direct collection: We collect information directly from you when you choose to provide it to us by filling out forms on our website, creating an account with us, engaging in transactions with us, such as the purchase of a subscription or product, signing up to receive promotional or information communications from us, communicating with us about our goods and services, or otherwise directly providing the information to us.

• Technology-based collection: We also collect certain information from you automatically when you visit, use, or navigate our website. We collect certain identifiers (such as IP addresses, device IDs, mobile ad IDs) and internet and similar network activity (such as website usage data) from you indirectly using cookie, pixels, and passive tracking technologies, as described in the “Automatically Collected Information” section of our Policy above.

• Collection via social media: We may collect personal information about social media users, including basic user profile information (such as username), user-generated content (such as posts, comments, pages, profiles, or feeds) and associated metadata (such as time and location of a post or comment); contact details (such as name, email address, telephone number, if made public by the user); and additional individual information published by the user (such as employer, profession, age, location, education information, habits, etc.). The type and scope of personal data obtained from social media platforms depends on the type of APIs and permissions set out by the respective platforms and the administrative permissions granted by customers, where applicable.

• Third-party collection: On occasion, we may obtain consumer data from brokers or marketing vendors. We use this personal information to supplement the personal information we collect from you directly for our marketing and advertising purposes.

D. Business or Commercial Purposes for Collecting and Disclosing Personal Information

We collect and disclose the personal information described above for the following business or commercial purposes:

• Making our products and services, including our website, and their features and tools, available to you.

• Authenticating your credentials or facilitating any login to our systems or services, including through the use of single-sign-on options provided by third parties.

• Registering you for an account with us.

• Negotiating, entering into, and managing our relationship and agreements with you, including fulfilling any purchases or transactions with us.

• Allowing our affiliates and related brands to communicate with you and deliver relevant information to you, including information about our products or services.

• Operating our business, including engaging in accounting, auditing, invoicing, or reconciliation and collection activities, determining the effectiveness of our marketing or sales strategies or processes, managing our communications.

• Analyzing market and consumer trends and developing financial, product, or profile insights.

• Providing and optimizing your experience on our website, including ensuring that our content is presented to you in the most effective manner.

• Communicating with you and responding to your inquiries and communications regarding our products, services, the functionality of our website, and other issues.

• Sending you informational communications and promotional solicitations, tracking your marketing preferences, and for our internal marketing purposes.

• Managing customer service issues, including issues relating to the performance of our goods, services, and customer feedback.

• Developing, updating, and improving our products and services (including our website), our administrative processes that support our business, and customer experience, and otherwise improving our knowledge and insights regarding users.

• Preventing and detecting fraud, financial crime, hacking activities, security breaches, and other unlawful activities in connection with the use of our website or use of our products or services.

• Enforcing our agreements with you or our organizational partners and customers, complying with our legal or regulatory obligations, and defending or advancing legal claims.

• Notifying you about changes to our services or material changes to this Policy.

• Providing you with surveys or otherwise soliciting feedback from you.

• Performing other functions as otherwise described to you at the time of collection or to which you otherwise consent.

E. Sensitive Personal Information

We do not use or disclose “sensitive personal information” (as defined by the CCPA) for the purposes of inferring any characteristics about California consumers. As a result, we treat all such information as “personal information,” for the purposes of our obligations under the CCPA.

F. Sale or Sharing of Personal Information

In the past 12 months, we have not “sold” or “shared” (as those terms are defined by the CCPA) any personal information of any California resident. We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age.

G. Your Rights Under the CCPA

Subject to exceptions, the CCPA provides California residents with the rights discussed below. For convenience, and as required by the CCPA, we explain how you can exercise those rights, to the extent they are applicable.

1. Right to Know. You have the right to request that we provide you certain information about our collection and use of your personal information during the past twelve (12) months (or longer, as permitted by the CCPA). Specifically, you may request that we disclose (in whole or part):

• The categories of personal information we collected about you;

• The categories of sources for the personal information we collected about you;

• The business and commercial purposes for collecting (or selling or sharing, if applicable) your personal information;

• The categories of third parties to whom we disclose (or sell or share, if applicable) your personal information;

• The specific pieces of personal information we collected about you;

• If we disclosed your personal information for a business purpose, the categories of personal information received by each category of third party; and

• If applicable, the categories of personal information that we sold, and for each category, the categories of third parties whom such information was sold.

As noted above, you have the right to request that we provide copies of the specific pieces of personal information we collected about you. If a verifiable consumer request is made, and subject to any exceptions or limitations under the CCPA, we will take steps to deliver the personal information to you either by mail or electronically. If we provide the information to you electronically, it will be in a portable and readily useable format, to the extent technically feasible. Consistent with the CCPA and our interest in the security of your personal information, we will describe but may not provide copies of certain personal information we may receive from you (e.g., driver’s license number, other government-issued identification number, financial account number, health or medical identification number, account password, or security questions or answers) in response to a CCPA request, to the extent any of those items are in our possession.

2. Right to Request Deletion. You have the right to request that we delete personal information we collected from you, subject to any exceptions or limitations under the CCPA.

3. Right to Correct Inaccurate Information. If we maintain inaccurate personal information about you, you have the right to request that we correct that inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.

4. Right to Opt-Out of Sales or Sharing. You have the right to request that we opt you out of the “selling” or “sharing” of your personal information for the purposes of cross-context behavioral advertising. We do not “sell” or “share” any personal information.

5. Right to Limit Use or Disclosure of Sensitive Personal Information. You have the right to direct us to limit our use and disclosure of your sensitive personal information for certain purposes, where the law allows and subject to applicable exceptions or limitations. We do not process “sensitive personal information” for a purpose that would entitle you to exercise this right.

H. Exercising Your Right to Know, Request Deletion, or Correct Inaccurate Information

To exercise the rights described above, you—or someone authorized to act on your behalf—must submit a verifiable consumer request to us by sending an e-mail to this address, with the subject line: “CCPA Request,” or calling us at 800-763-4434. Your request must include your name, email address, mailing address, phone number, the nature of your inquiry and the context in which we may have received your information. If you are an agent submitting a request on behalf of a consumer, we may request that you submit a signed permission from the consumer authorizing you to make the request. In order to protect the privacy and data security of consumers, the verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of such consumer; and

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

As indicated above, please be aware that the CCPA provides certain limitations and exceptions to the foregoing rights, which may result in us denying or limiting our response to your request.

You may only make a verifiable consumer request to know twice within a 12-month period. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We may also request that you provide additional information if needed to verify your identity or authority to make the request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you or the consumer on whose behalf you are making the request.

The CCPA requires us to respond to a verifiable consumer request within forty-five (45) days of its receipt; however, we may extend that period by an additional 45 days. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response via e-mail. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request, provided that you may request disclosure beyond the 12-month period as permitted by the CCPA. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For requests to know specific pieces of information collected about you, we will select the format of our response; the format will be readily useable and should allow you to transmit the information from one entity to another. We will not charge a fee to process or respond to a 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 the request.

J. Our Commitment Not to Discriminate

Consistent with the CCPA, we will not discriminate against you for exercising any of your CCPA rights by:

• Denying you goods or services.

• Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

• Providing you a different level or quality of goods or services.

• Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

K. Data Disclosures for Direct Marketing Purposes

California Civil Code § 1798.83 (California’s Shine the Light Act) further permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from providing your personal information to certain of our affiliates and other third parties for their marketing purposes. Please note that while we do not currently disclose your personal information to third parties for direct marketing purposes, you may still tell us your preference for disclosing your personal information to our affiliates by contacting us at the contact information below.

Additional Information for Nevada Residents

Under Nevada law, Nevada “consumers” may request that certain “operators” of internet sites and online services refrain from the “sale” of their “covered information” to third parties (as such terms are defined under Nevada law). We do not engage in “sales” of personal information as defined under Nevada law.

Data Retention

We retain personal information for as long as necessary to fulfil the purposes we collected it, including for the purposes of satisfying any legal, accounting, or other mandatory reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, whether we can achieve those purposes through other means, and the applicable legal requirements. We also consider any specific limitation periods under applicable law.

Information Security

We use appropriate administrative, technical, and physical measures to protect your personal information from loss, theft, and unauthorized use, disclosure, or modification. Please be aware that no data transmission over the Internet is 100% secure. While we strive to protect your personal information, we cannot ensure or warranty the security of any information you transmit to us and you do so at your own risk.

Data Location

You understand and agree that information about you may be stored or processed by information technology systems located in the United States of America or jurisdictions that may have laws that differ from the laws of your country of residence or the jurisdiction in which you reside.

Links to Third-Party Websites

Our website may contain links to third-party digital properties (e.g., social media sites). Such third-party digital properties have separate privacy policies that you should review. We cannot and do not take responsibility for the content of linked websites or those companies’ data-handling practices.

Privacy of Children Online

Our website is intended for use by a general audience. We do not knowingly collect the personal information of any individual under the age of 16. If you believe we have collected the personal information of a child under 16, please contact us at the information below.

Changes to the Privacy Policy

While we always aim to provide complete and transparent information about how we process your personal information, we reserve the right to amend or update this Policy from time to time or to create additional policies in order to accurately reflect changed circumstances or new legal requirements.

Please note that we may change this Policy from time to time. If there are changes to our Policy, we will post them here and update the “Last Updated” date at the top of this document. Continued use of our website after any changes is deemed to be acceptance of those changes. Accordingly, we encourage you to check the Policy periodically for updates.

Contact Us

If you have any questions regarding our information handling practices, please contact us by e-mail at this address or by using the contact information provided below:

Solve Industrial Motion Group
154 Commerce Dr.
Loveland, OH 45140