This Privacy Statement (“Statement”) sets forth the principles that govern our treatment of personal information across Brasseler USA. and its controlled subsidiaries and affiliates operating in the United States (“Brasseler USA”).

Brasseler USA is committed to protecting the personal information that our employees, customers, prospects, suppliers and vendors have entrusted to us. We collect and use personal information to perform our business functions and provide quality health care products and services to our customers. This Statement applies to personal information in any format or medium relating to employees, customers, vendors and others who do business with Brasseler USA.

Please be aware that this Statement does not pertain to our use, collection or disclosure of Protected Health Information (PHI) as governed by the Health Insurance Portability and Accountability Act (HIPAA). Certain affiliates and business operations have a HIPAA Notice of Privacy Practices, as required by HIPAA, and outlines how such affiliates and business operations manage use, collection and disclosure of PHI.

For more information about how we process your personal information in the recruitment context, please view our Global Recruitment Privacy Statement.

This Statement does not apply to those sites and services that do not display or link to this Statement or that have their own privacy statement. Some subsidiaries and affiliates may operate under their own privacy statement. Each time you use our sites and services, the current version of this Statement will apply. If you do not agree to this Statement, please do not use our sites or services.

We may collect categories of personal information listed above from the following categories of sources highlighted below:

• Personal information collected directly from you
• Third-party vendors
• Recruitment or talent agencies
• Our distributors
• When you browse or use our website, e-commerce services or social media pages
• Our business partners (non-vendors)
• Joint marketing partnerships
• Publicly available non-government and government data
• Contractors (e.g., consultants, agents and representatives)
• Consumer reporting agencies
• Covered individuals’ email accounts, chat logs, social media accounts
• Covered individuals’ devices
• Directly from covered individuals
• From other individuals, such as friends or family, with proper consent
• Third parties (e.g., data brokers)

Some of this data is collected in the following situations when:

• You apply for a position, or to do business, with our company
• We establish a contractual employment or commercial relationship
• We receive it from other companies within our corporate group
• You provide us with any type of service as a vendor
• When we provide you with any type of service, product or support
• When you browse or use our website, e-commerce services or social media pages

Generally, we collect, use and disclose your personal information to provide you with products and services and as otherwise related to the operation of our business. For more specific details on our disclosures of personal information, see the next section, “How We Share Your Personal Information.” Subject to restrictions and obligations of applicable laws, Brasseler USA and our vendors may use your personal information for some or all the following business purposes:

• Communicating with you
• Provide our products and services
• Marketing and advertising and promotional purposes
• Analytics, enhancement and personalization
• Security and fraud prevention
• Processing interactions and transactions
• Managing interactions and transactions
• Performing services
• Research and development
• Fulfilling regulatory requirements and quality assurance
• Internal business purposes
• Debugging and performance of systems
• Complying with law
• For any additional purposes to which you specifically consent

In addition, we may collect, use and disclose your personal information for the following additional operational business purposes:

• Affiliates: We may share information with our corporate affiliates and subsidiaries for purposes consistent with this Statement.
• Service providers: We may provide personal information to vendors, contractors, business and service partners or other third parties who provide services to us.
• Vendors and suppliers: If you have a business or professional relationship with us, we will use your information to develop and conduct our business relationship with you and to comply with tax and other regulations.
• Employees and candidates: If you apply for a job via our career center, we use your personal information to consider you for employment, for diversity & inclusion programs and statistics, other governmental reporting requirements or programs (such as immigration and EEO), and to administer your account.
• Customers: We use our customers’ information to maintain our commercial relationship, to ensure the proper operation of the day-to-day business, to comply with tax and other regulations and to administer sales and marketing activities.
• Patients of our customers: We provide support services to patients of our customers who use our healthcare products and services, when required.
• Prospective customers: We use information from prospective customers to respond to their requests for information, products or services and for marketing activities.
• Visitors of company facilities: Some of our buildings have physical access controls and video surveillance systems for security purposes.
• Website and social media users: We collect personal information from visitors and users of our website and social media pages and use the information to manage your account registration, to store your preferences and settings, to provide interest-based advertising, to conduct statistics and to analyze how you use our website and online services.
• Payment processors: If you pay for use of our services, you may use a third-party payment processor to take payment from you. These third parties are properly regulated and authorized to handle your payment information.
• In connection with a merger, acquisition or business transfer: If Brasseler USA sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a reorganization, merger or transfer of all or a material part of its business, Brasseler USA may use, transfer or disclose your information to the party or parties involved in the transaction as part of that transaction.
• Service improvement and analytics: We may use your personal information to analyze your usage of the service, improve the service, improve the rest of our company and help us understand user activity on the service.
• Comply with Law: In certain circumstances, we may be required to disclose personal information when required by law, when required to protect our legal rights or in an emergency where the health or security of an individual is endangered.
• Use for new purposes: We may use your personal information for reasons not described in this Statement where permitted by law and when the reason is compatible with the purpose for which we collected it.
• At your direction: We may disclose your personal information at your direction or with your consent.

De-Identified/ Anonymized Information. We may de-identify or anonymize the information we collect so the information cannot reasonably identify you or your device, and disclosure of de-identified and anonymized information is not subject to any restrictions under this Statement.

We may disclose your personal information to the following categories of third parties:

• Third-party service providers, which can include providers of services such as data analysis, fraud prevention, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.
• Our subsidiaries and affiliates, including Brasseler USA offices and business entities, subsidiaries, affiliates or their successors or assigns, for any of the purposes described in this Statement.
• Payment service providers to perform payment processing functions on our behalf.
• Security, IT service providers and web hosting providers to help host, function and maintain our website and to ensure the safety and security of our website.
• Customer relationship management, advertising/marketing agencies, to host and assist with our customer relationship management solutions, to send out communications on our behalf, to help us provide a personalized service on our website and provide recommendations as to goods or services you may be interested in.
• Advertising and analytics service providers to carry out analytics and compile statistics to help us improve and tailor our products and services and offer more personalized experiences to our customers.
• Loyalty scheme management, helps us manage our loyalty scheme, including tracking the number of points you have earned and assisting in the fulfillment of rewards.
• Online signing, where legal documents need to be signed to enable us to provide a service, we employ other companies to provide an online e-document signing service.
• Credit reference agencies, law enforcement and fraud prevention agencies to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime in accordance with applicable law.
• Professional advisors, including legal advisors, tax and accounting advisors and business consultants, enable our advisors to provide their business services to us.
• Social media providers and advertisers, for marketing and analytics purposes, and to provide social media features on our website.
• Suppliers of our products, in limited circumstances, to administer the supply and sale of our products – for example, to claim rebates and for warranty purposes.
• Prospective buyer/seller, in the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.
• External parties, including external auditors, external agencies and public authorities or government bodies, as required by law.
• Internal personnel and departments, including executives, board of directors, finance and accounting teams, operation and maintenance teams, legal, compliance, regulatory-quality teams and other internal employees on a need-to-know basis.
• Authorized business contacts, such as B2B customers, business partners, customer service representatives and sales/marketing teams, representatives or agents.
• Other authorized third parties, including trade unions or work councils or those to whom you authorize us to disclose your personal information in connection with products or services we provide to you.

Depending on where you are located, you may have certain rights under applicable privacy laws over the personal information we hold about you. These may include:

• Right of access. To access your personal information that is being processed by us and what is the purpose of processing your personal information.
• Right to rectification (correction). To request rectification of the personal information concerning you if the data is inaccurate or incomplete.
• Right to deletion. To delete the personal information concerning you.
• Right to the restriction of processing. You have the right to restrict the processing of your personal information.
• Right to object. The right in certain circumstances to request that we stop processing your Personal Information.
• Right to information. To be informed whether we process your data.
• Request portability of your personal information. To request your personal information in a structured, commonly used and machine-readable format.
• Right to withdraw your consent. If your personal information is processed on basis of your consent, you have the right to withdraw your consent at any time.
• File a complaint with a data protection supervisory authority. You have a right to complain to a data protection authority about our collection and use of your personal information.
• Rights in relation to automated decision making and profiling. No automated decision-making, including profiling, is used when processing your personal information.
• Right to opt-out of targeted advertising (or “sharing”). To opt out of targeted advertising, including the “sharing” of your personal information for cross-context behavioral advertising.
• Right Not to Receive Discriminatory Treatment. You have the right to not be discriminated against for exercising your privacy rights.

You, or an authorized individual, who we can verify is acting on your behalf, can exercise the applicable rights by contacting us using the “How to Contact Us” contact details at the bottom of this Statement or by submitting your request to our Individual Rights form.

Nothing in this Statement should be interpreted to establish data protection and privacy rights that go beyond the rights provided under applicable laws. In the event we are unable to fulfill your request, we will explain the reason for our decision, including, where applicable:

• If the right differs in your state of residence.
• If there are relevant exceptions under applicable privacy law.
• How the rights of other individuals or parties interact with your specific request.

We do not charge a fee to process or respond to your requests unless permitted under applicable law. If we determine that a request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

If you wish to exercise your rights or have other questions or concerns related to your rights under relevant law, contact us using the “How to Contact Us” contact details at the bottom of this Statement or by submitting your request to our Individual Rights form.

Your Marketing Preferences: We may periodically send promotional materials or notifications related to our services. If you no longer wish to receive promotional marketing materials from us, you may opt out of receiving such materials. You may unsubscribe from receiving marketing or other commercial emails from us by following the instructions included in the email.

Consent to Telephone Communications: We use our customers’ telephone numbers to maintain our commercial relationship, to ensure proper operation of the day-to-day business, to comply with tax and other regulations and to administer sales and marketing activities. By providing your telephone number to us, you are providing prior express written consent to receive marketing and informational calls, faxes and text messages from Brasseler USA and our affiliates using an automatic dialer and prerecorded voice messages. Your consent is not a condition of purchasing any products or services and can be revoked at any time.

1. What are cookies?

A cookie is a small removable data file that is stored by your web browser on your computer. Cookies are used to provide website users with tighter security, customized content, tailored advertising, tracking of orders and to make shopping carts work. We also use other forms of tracking technologies, such as web beacons, pixels and tags, which serve a similar purpose to cookies, and which allow us, for example, to monitor and improve our website and email communications, track the actions of our users (including website users and email recipients), measure the success of our marketing campaigns and compile statistics about usage of our website. When we refer to cookies in this Statement, we also mean these tracking technologies.

1. How do we use cookies?

Like most other websites, we use cookies on our website, through which we collect device information and certain marketing information. Below, we explain below the types of cookies we use on our website and their purpose. We may allow certain approved third parties to place their cookies on our websites. You can find more detailed information on those third parties and their privacy notices here, through our cookie banner or through the “Manage cookie settings” link, which is available at the bottom of all webpages on our website.

Essential cookies: These cookies are required to enable core functionality, and for this reason users cannot disable these. Without these cookies, that core functionality, like adding items to your shopping basket, cannot be provided.

Analytics cookies: These cookies help us improve or optimize the experience we provide. They allow us to measure how visitors interact with our website, and we use this information to improve the user experience and performance of the website. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about the use of the Services and report on activities and trends. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Functional cookies: We may use cookies that are not essential but enable various helpful features on our websites. For example, these cookies collect information about users’ interaction with the website and may be used to remember users’ preferences (such as language preference) and the presentation of the website (such as the font size).

Advertising cookies: We use these cookies to collect information about your browsing habits in order to make advertising more relevant to you and your interests. These cookies are also used to limit the number of times you see an advert as well as help measure the effectiveness of an advertising campaign. We may share this information with other parties who help manage online advertising.

Social media cookies: These cookies are used when you share information using a social media sharing button on our website or when you engage with our content on or through a social site such as Facebook. These cookies collect information about your social media interaction with our website. This information may be linked to targeting/advertising activities.

Types of Tracking Technologies We Use. Brasseler USA may collect personal information using a variety of tracking technologies, such as cookies, web beacons, embedded scripts, browser fingerprinting, GPS, iBeacons, ETags, recognition technologies and location-identifying technologies (collectively “Tracking Technologies”).

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. Currently, we do not monitor or take any action with respect to Do Not Track technology. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Disabling Tracking Features. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers and, in some but not all instances, can be blocked by selecting certain settings. Please be aware that if you disable or remove these technologies, some parts of our website may not work.

How can you manage cookies?

When you first visit our website, you will be asked to set your cookie preferences. You can also update your cookie selection at any time, by clicking on the “Manage cookie settings” link, which is available at the bottom of our website. To find out more about Cookies please visit: www.allaboutcookies.org which contain further information about these technologies and online privacy.

Categories of Personal information Collected, Disclosed and “Shared”

The following chart details which categories of personal information about California residents we collect, as well as which categories of personal information we have collected and disclosed for our operational business purposes in the preceding 12 months. The chart also details the categories of personal information that we “share” or may have shared for purposes of cross-context behavioral advertising, including in the preceding 12 months.

Sale and Share of Personal Information

We do not “sell” your personal information, including your Sensitive Personal Information, as defined under the CCPA. We have not engaged in such sales in the 12 months preceding the date this Statement was last updated. Without limiting the foregoing, we do not “sell” or knowingly “share” the personal information, including the Sensitive Personal Information, of minors under 16 years of age.

In the past 12 months we may share personal information when we participate in online advertisements using third party cookies on our websites. You can opt out of the use of sharing of your personal information for cross-context behavioral advertising by clicking the “Do Not Share My Personal Information” link that is specified in the relevant Brasseler USA footer or by submitting your request to our Individual Rights form.

Purposes for the Collection, Use and Disclosure of Sensitive Personal Information

We may collect, use and disclose sensitive personal information for purposes of: performing services on behalf of our business; providing goods or performing services as requested by you; ensuring security and integrity; short term transient use such as displaying first party, non-personalized advertising; order processing and fulfillment; servicing accounts and providing customer service; verifying customer information; processing payments; activities relating to quality and safety control or product improvement; securing the access to and use of, our facilities, equipment, systems, networks, applications and infrastructure; preventing, detecting and investigating security incidents; resisting and responding to fraud or illegal activities; and other collection and processing that is not for the purpose of inferring characteristics about an individual. We do not use or disclose Sensitive Personal Information for additional purposes.

Rights and Requests

If you are a California resident, you may request:

• Right to Deletion of Personal Information. California residents have the right to request the deletion of their personal information. We may not delete some or all requested personal information if we are required to retain it by applicable law or are permitted to retain it by applicable law.
• Right of Access: This is the right to request disclosure of personal information collection and sharing practices.
• Right to Know. You may request to receive details about how we collect, use and share your Personal Information. You may request to receive the specific pieces of personal information that we have collected about you.
• Right to Correct Inaccurate Personal Information: The right to correct inaccurate personal information that we maintain about you.
• Right to Opt-Out of Sharing: The right to opt out of the “sharing” of your personal information for cross-context behavioral advertising.
• Right to Not Receive Discriminatory Treatment: We do not discriminate against you for exercising any CCPA rights, such as the access and deletion rights described above.

We will verify and respond to your request in a manner consistent with applicable law, taking into account the type and sensitivity of the personal information subject to the request. We may need to request additional personal information from you, such as mailing address, telephone number and/or email address, in order to verify your identity and protect against fraudulent requests.

To make a request, please contact us using the “How to Contact Us” contact details at the bottom of this Statement, including by calling us at 1-800-472-4346, or by submitting your request to our Individual Rights form.

Authorized Agents. If an agent would like to make a request on your behalf as permitted by applicable law, the agent may use the submission methods noted in the section entitled “Rights and Requests.” As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent.