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I. PRIVACY SHIELD
The United States Department of Commerce and the European Commissionhave agreed on a set of data protection principles to enable U.S.companies to satisfy the requirement under EU law that adequateprotection be given to Personal information transferred from the EU tothe United States (EU-U.S. Privacy Shield Framework). To learn moreabout the Privacy Shield program, and to view ZEKS Compressed AirSolutions, LLC’s certification, please visit http://www.privacyshield.gov/list.
ZEKS Compressed Air Solutions, LLC has a Global Data ProtectionOfficer who assists in ensuring compliance with this Policy and datasecurity issues. ZEKS Compressed Air Solutions, LLC educates itsemployees concerning compliance with this Policy and hasself-assessment procedures in place to assure compliance. ZEKSCompressed Air Solutions, LLC's Global Data Protection OfficerMichelle Trumpower and its Corporate Legal Team are available to anyof its valued employees, customers, vendors, business partners orothers who may have questions concerning this Policy or data securitypractices. Relevant contact information is provided herein. ZEKSCompressed Air Solutions, LLC is subject to the investigatory andenforcement powers of the U.S. Federal Trade Commission with respectto the Privacy Shield Framework.
This Policy applies to all Personal information received by ZEKSCompressed Air Solutions, LLC in any format including electronic,paper or verbal. ZEKS Compressed Air Solutions, LLC collects, storesand processes Personal information concerning current and formeremployees, as well as applicants for employment through its Internetwebsites, its intranet site, electronic mail and manually. ZEKSCompressed Air Solutions, LLC will not sell or share this informationwith third parties in ways different than what is disclosed in thisPolicy. On a global basis, ZEKS Compressed Air Solutions, LLC willestablish and maintain business procedures that are consistent withthis Policy. Notwithstanding the foregoing, ZEKS Compressed AirSolutions, LLC has separate policies governing the processing ofapplicants and employee personal data and external personal data inthose countries that are members of the EU. These policies areconsistent with EU data protection law.
ZEKS Compressed Air Solutions, LLC collects, stores, and processesPersonal information from current and past employees and applicantsfor employment, such as name, contact information, governmentidentifier, financial account information, and family information.This information is maintained at the Corporate and Regional HQ levelby ZEKS Compressed Air Solutions, LLC and its authorized agents,depending on the level of the position as well as the local office ofthe employee or applicant. ZEKS Compressed Air Solutions, LLC collectsPersonal information for employment related purposes and legitimatehuman resource business reasons such as personnel and job candidateadministration and assessment, recruitment and staffing; payrolladministration; absence monitoring; training and development;management planning; appraisal and promotion; union negotiation;production and publication of company address books and telephone ande-mail directories; managing email and other communication systems;production of employee Identity cards; monitoring the use of companyresources; information to contact close relatives in case ofemergency; filling employment positions; administration and operationsof its benefit and compensation programs; meeting governmentalreporting requirements; security, health and safety management;performance management; company network access; managing andadministering the Ethics HelpLine; facilitating workplacecommunications; workforce analytics, and authentication. ZEKSCompressed Air Solutions, LLC does not request or gather informationregarding political opinions, religion, philosophy or sexualpreference. To the extent ZEKS Compressed Air Solutions, LLC maintainsinformation on trade union membership, medical health, race orethnicity, ZEKS Compressed Air Solutions, LLC will protect, secure andprocess that information in a manner consistent with this Policy andapplicable law.
ZEKS Compressed Air Solutions, LLC also collects, stores, andprocesses Personal information from prospective customers, consumers,vendors, professional advisers and consultants, distributors, dealers,suppliers business partners and others, such as name, contactinformation, assist in the administration of employee benefit andcompensation programs, and financial or other payment information.This information may be maintained at its corporate offices in Swords,Ireland, Davidson, North Carolina, Piscataway, New Jersey or at otherZEKS Compressed Air Solutions, LLC facilities, and its authorizedagents, consistent with local legislation. ZEKS Compressed AirSolutions, LLC collects this Personal information for, among otherthings, legitimate business reasons such as processing and fulfillingorders; customer service; the provision of services or products toZEKS, product, warranty and claims administration; meetinggovernmental reporting and records requirements; maintenance ofaccurate accounts payable and receivable records; marketing; internalmarketing research; safety and performance management; financial andsales data; and contact information. All Personal informationcollected by ZEKS Compressed Air Solutions, LLC will be used forlegitimate business purposes consistent with this Policy.
ZEKS Compressed Air Solutions, LLC may process and disclose Personalinformation to service providers, advisors, potential transactionalpartners, or other third parties in connection with the consideration,negotiation, or completion of a corporate transaction in which an ZEKSCompressed Air Solutions, LLC business is acquired by or merged withanother business, or sells, liquidates, or transfers all or a portionof its assets.
ZEKS Compressed Air Solutions, LLC also may process or disclosePersonal information as is reasonably necessary or legally required onimportant public interest grounds, to respond to lawful requests bypublic authorities (including to meet national security or lawenforcement requests), to meet governmental reporting or recordsrequirements, or for the establishment, exercise or defense of legalclaims by ZEKS Compressed Air Solutions, LLC or other companies withinits corporate group.
For purposes of this Policy, the following definitions shall apply:
"Agent" means any third party that processes Personalinformation provided by ZEKS Compressed Air Solutions, LLC to performtasks on behalf of or at the instruction of ZEKS Compressed AirSolutions, LLC.
"ZEKS" means ZEKS, it’s parent company ZEKS Compressed AirSolutions, LLC plc, and its subsidiaries, divisions and groups, withbrands such as ZEKS Compressed Air Solutions, LLC.
"Personal information" means any information or set ofinformation that identifies or could be used by or on behalf of ZEKSCompressed Air Solutions, LLC to identify an individual. Personalinformation does not include information that is anonymized, orpublicly available information that has not been combined withnon-public Personal information.
"Sensitive Personal information" means Personalinformation that reveals race, ethnic origin, trade union membership,political opinions, or religious or philosophical beliefs, thatconcerns health or sex life, or that contains criminal records. Inaddition, ZEKS Compressed Air Solutions, LLC will treat as SensitivePersonal information any Personal information received from a thirdparty where that third party treats and identifies the Personalinformation as sensitive.
IV. PRIVACY PRINCIPLES
ZEKS Compressed Air Solutions, LLC commits to subject the Personalinformation covered by this policy to the following principles:
(1) NOTICE: Where ZEKS Compressed Air Solutions, LLC collectsPersonal information directly from individuals, it will inform themabout the purposes for which it collects, stores and processesPersonal information about them, the types of non-Agent third partiesto which ZEKS Compressed Air Solutions, LLC discloses thatinformation, and the choices and means, if any, ZEKS Compressed AirSolutions, LLC offers individuals for limiting the use and disclosureof their Personal information. Notice will be provided in clear andconspicuous language when individuals are first asked to providePersonal information to ZEKS Compressed Air Solutions, LLC, or as soonas practicable thereafter, and in any event before ZEKS Compressed AirSolutions, LLC uses the information for a purpose other than that forwhich it was originally collected.
(2) CHOICE: ZEKS Compressed Air Solutions, LLC will offerindividuals the opportunity to choose (opt-out) whether their Personalinformation 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 wasoriginally collected or subsequently authorized by the individual.
For Sensitive Personal information, ZEKS Compressed Air Solutions,LLC will give individuals the opportunity to affirmatively andexplicitly consent (opt-in) to the disclosure of the information to anon-Agent third party or the use of the information for a purposeother than the purpose for which it was originally collected orsubsequently authorized by the individual.
ZEKS Compressed Air Solutions, LLC will provide individuals withreasonable mechanisms to exercise their choices should requisitecircumstances arise.
(3) DATA INTEGRITY AND PURPOSE LIMITATION: ZEKS Compressed AirSolutions, LLC will use Personal information only in ways that arecompatible with the purposes for which it was collected orsubsequently authorized by the individual. ZEKS Compressed AirSolutions, LLC will take reasonable steps to ensure that Personalinformation is relevant to its intended use, accurate, complete and current.
(4) ACCOUNTABILITY FOR ONWARD TRANSFER: ZEKS Compressed AirSolutions, LLC uses third-party Agents to assist us in accomplishingthe purposes described in this Policy, for example to support ourcustomers, perform technical operations, and store and transmit data.ZEKS Compressed Air Solutions, LLC will confirm that any third partyto which it discloses Personal information will appropriatelysafeguard the privacy of that Personal information. Examples ofappropriate privacy safeguards include: a contract obligating thethird party to provide at least the same level of protection as isrequired by the relevant privacy principles, the third party beingsubject to EU data protection law, Privacy Shield certification by thethird party, or the third party being subject to another EuropeanCommission adequacy finding (e.g., companies located in Switzerland).Where ZEKS Compressed Air Solutions, LLC has knowledge that a thirdparty is using or disclosing Personal information in a manner contraryto this Policy, ZEKS Compressed Air Solutions, LLC will takereasonable steps to prevent or stop the use or disclosure. ZEKSCompressed Air Solutions, LLC holds third parties to which itdiscloses Personal information accountable for maintaining the trustour employees and customers place in the company. ZEKS Compressed AirSolutions, LLC may remain liable under the Privacy Shield Principlesif any Agent processes Personal information in a manner inconsistentwith the Privacy Shield Principles, unless ZEKS Compressed AirSolutions, LLC first demonstrates that it is not responsible for theevent giving rise to the damage.
(5) ACCESS AND CORRECTION: Upon request, ZEKS Compressed AirSolutions, LLC will grant individuals reasonable access to Personalinformation that it holds about them. In addition, ZEKS Compressed AirSolutions, LLC will take reasonable steps to permit individuals tocorrect, amend or delete information that is demonstrated to beinaccurate or incomplete. Any employees that desire to review orupdate their Personal information can do so by contacting their localHuman Resources Representative.
(6) SECURITY: ZEKS Compressed Air Solutions, LLC will takereasonable precautions to protect Personal information in itspossession from loss, misuse and unauthorized access, disclosure,alteration and destruction. ZEKS Compressed Air Solutions, LLCprotects data in many ways. Physical security is designed to preventunauthorized access to database equipment and hard copies of sensitivePersonal information. Electronic security measures continuouslymonitor access to our servers and provide protection from hacking orother unauthorized access from remote locations. This protectionincludes the use of firewalls, restricted access and encryptiontechnology. ZEKS Compressed Air Solutions, LLC limits access toPersonal information and data to those persons in ZEKS Compressed AirSolutions, LLC's organization, or as Agents of ZEKS Compressed AirSolutions, LLC, that have a specific business purpose for maintainingand processing such Personal information and data. Individuals whohave been granted access to Personal information are aware of theirresponsibilities to protect the security, confidentiality andintegrity of that information and have been provided training andinstruction on how to do so.
(7) RECOURSE, ENFORCEMENT AND LIABILITY: ZEKS Compressed AirSolutions, LLC will conduct compliance audits of its relevant privacypractices to verify compliance with this Policy and the relevantprivacy principles. Any employee that ZEKS Compressed Air Solutions,LLC determines is in violation of this Policy will be subject todisciplinary action up to and including termination of employment.
V. DISPUTE RESOLUTION
Any questions or concerns regarding the use or disclosure ofPersonal information should be directed to the ZEKS Compressed AirSolutions, LLC Data Protection and Privacy Office at the address givenbelow. ZEKS Compressed Air Solutions, LLC will investigate and attemptto resolve complaints and disputes regarding use and disclosure ofPersonal information in accordance with the principles contained inthis Policy. For complaints that cannot be resolved between ZEKSCompressed Air Solutions, LLC and the complainant, ZEKS Compressed AirSolutions, LLC has agreed to participate in the dispute resolutionprocedures of the panel established by the EU data protectionauthorities and to cooperate and comply with the Swiss Federal DataProtection and Information Commissioner to resolve disputes pursuantto the relevant privacy principles. In some circumstances,complainants may be able to appeal these decisions by invoking bindingarbitration. All of these dispute resolution mechanisms are free ofcharge to you.
VI. INTERNET PRIVACY AND COOKIES
ZEKS Compressed Air Solutions, LLC sees the Internet, intranets andthe use of other technologies as valuable tools for communicating andinteracting with consumers, employees, vendors, business partners andothers. ZEKS Compressed Air Solutions, LLC recognizes the importanceof maintaining the privacy of Personal information collected throughwebsites that it operates. ZEKS Compressed Air Solutions, LLC's solepurpose for operating its websites is to provide informationconcerning products and services to the public. In general, visitorscan reach ZEKS Compressed Air Solutions, LLC on the Web withoutrevealing any Personal information. Visitors on the Web may elect tovoluntarily provide Personal information via ZEKS Compressed AirSolutions, LLC websites but are not required to do so. ZEKS CompressedAir Solutions, LLC collects information from visitors to the websiteswho voluntarily provide Personal information by filling out andsubmitting online questionnaires concerning feedback on the website,requesting information on products or services, or seeking employment.The Personal information voluntarily provided by website users iscontact information limited to the user's name, home and/or businessaddress, phone numbers and email address. ZEKS Compressed AirSolutions, LLC collects this information so it may answer questionsand forward requested information. ZEKS Compressed Air Solutions, LLCdoes not sell this information.
ZEKS Compressed Air Solutions, LLC may also collect anonymousinformation concerning website users through the use of"cookies" in order to provide better customer service."Cookies" are small files that websites place on users'computers to identify the user and enhance the website experience.Company personnel periodically audit ZEKS Compressed Air Solutions,LLC’s commercial websites to determine what cookies are used on each.The cookies used are typically not intrusive and are not typicallyconnected to visitors’ contact or other identifiable information.Visitors may set their browsers to provide notice before they receivea cookie, giving the opportunity to decide whether to accept thecookie. Visitors can also set their browsers to turn off cookies.Visitors can learn how to control or delete cookies used on ZEKSCompressed Air Solutions, LLC’s websites by visiting http://www.aboutcookies.org fordetailed guidance. If visitors do suppress the website cookies,however, some areas of ZEKS Compressed Air Solutions, LLC websites maynot function properly.
The table below describes the cookies used on www.zeks.com.
We use a session cookie that lasts for the duration of your visit toour site and is used for load balancing.
User data is not linked to any of your contact information.
Persistent Cookies for Site Analytics
Google Analytics– we use this to understand how the site isbeing used in order to improve the user experience. User data is notlinked to any of your contact information.
You can find out more about Google’s position on privacy as regardsits analytics service at https://support.google.com/analytics/answer/6004245?hl=en
Adobe Site Catalyst- we use this to understand how the siteis being used in order to improve the user experience. User data isnot linked to any of your contact information.
You can find out more about Adobe’s position on privacy as regardsits analytics service at http://www.omniture.com/en/privacy/product
Few, if any, of ZEKS Compressed Air Solutions, LLC's websites aredirected toward children. Nevertheless, ZEKS Compressed Air Solutions,LLC is committed to complying with applicable laws and requirements,such as the United States' Children's Online Privacy Protection Act ("COPPA")
ZEKS Compressed Air Solutions, LLC websites may contain links toother "non-ZEKS Compressed Air Solutions, LLC" websites.ZEKS Compressed Air Solutions, LLC assumes no responsibility for thecontent or the privacy policies and practices on those websites. ZEKSCompressed Air Solutions, LLC encourages all users to read the privacystatements of those sites; their privacy practices may differ fromthose of ZEKS Compressed Air Solutions, LLC.
VII. EUROPEAN UNION - GDPR
7.1. As mentioned, this Policy sets forth the privacyprinciples that ZEKS Compressed Air Solutions, LLC follows withrespect to Personal information transferred to ZEKS Compressed AirSolutions, LLC from anywhere in the world, including transfers fromthe European Economic Area (EEA) (which includes the twenty-eightmember states of the European Union (EU) plus Iceland, Liechtensteinand Norway).
If you are working with our affiliates in the EU or are a datasubject in the EU protected by GDPR, you can invoke your rightsunder GDPR towards the relevant EU ZEKS Compressed Air Solutions,LLC affiliate that controls your personal data at local, nationallevel for the performance of the day to day operations of therelevant affiliate, each acting as a separate controller. Forall cross-border processing of personal data in the EEA at grouplevel, the controller is ZEKS Compressed Air Solutions, LLC Company, aNew Jersey Corporation, established at 800-E Beaty Street, Davidson,NC 28036-1840 USA (“ZEKS Company”). With respect to such cross-borderprocessing of individuals in the EEA, ZEKS Company has as mainestablishment in the EEA: ZEKS Compressed Air Solutions, LLCInternational Ltd., Belgian Branch, Alma Court Building, LennekeMarelaan 6, 1932 St-Stevens-Woluwe, Belgium, with Belgian companynumber 0826.378.038 (“ZEKS Ltd. Belgian Branch”).
7.2. For job applicants, employees and former employees of ourEU ZEKS Compressed Air Solutions, LLC affiliates, separate notices andpolicies exist in line with EU law, which inform them about our dataprocessing and their rights.
When you are not a job applicant, employee or former employee, wehereunder inform you about your rights under GDPR and how to performthem. In such case, the processing of personal data by the relevantZEKS Compressed Air Solutions, LLC entities may be based on thenecessity to perform a contract with you or in order to take steps atyour request prior to entering into a contract, because we have alegal obligation to do so, or because it is in our legitimate interestto do so (for instance if you are working for one of our suppliers orcustomers who have to receive your data for normal businessoperations, or because you want to browse through our website), or,alternatively, may be based on your consent (for instance when youhave consented to the use of your personal data for direct marketing purposes).
7.3. Under the GPDR individuals have:
The performance of these rights may be subject to certain conditionsand exceptions as provided by the GDPR. Individuals who want toperform these rights can do so by contacting:
For current ZEKS Employees: Current EU employees cansubmit data inquiry requests from the intranet under the menuoptions MyResources / Policies and Procedures / GDPR Data Subject Requests
ZEKS Compressed Air Solutions, LLC Privacy Inquiries (ZEKS)
ZEKS Compressed Air Solutions, LLC Company
800 Beaty Street,Building E
Davidson, North Carolina
Attention: Michelle Trumpower, Global Data Protection and Privacy Officer
ZEKS Compressed Air Solutions, LLC Privacy Inquiries(ZEKS)
ZEKS Compressed Air Solutions, LLC International Ltd.
Lenneke Marelaan 6
Attention: Data Privacy Inquiries (Legal / HR)
The inquiries should include the individual's name, address, andother relevant contact information (phone number, email address). ZEKSCompressed Air Solutions, LLC may require that you provide additionalinformation in order to verify your identity and will use allreasonable efforts to honor such requests as quickly as possible andwithin the time limits set forth by applicable law.
7.4. Except as otherwise permitted or required by applicablelaw or regulatory requirements, the relevant ZEKS Compressed AirSolutions, LLC entity that controls your personal data retainspersonal data only for as long as necessary to fulfill the legitimatebusiness purposes for which the personal data was collected(including, for the purpose of meeting any legal, tax, accounting orother reporting requirements or obligations). If destroying or erasingpersonal data is not mandatory by law, we may make it anonymous suchthat it cannot be associated with or tracked back to the individual. Local ZEKS Compressed Air Solutions, LLC entities may have policiesthat deviate from the above.
With respect to other transfers outside the EEA to third partysuppliers, ZEKS Compressed Air Solutions, LLC ensures adequatepersonal data protection through the implementation of standardcontractual clauses - as recognized by the European Commission- withthese third party suppliers, or it will work with suppliers who arealso certified under the EU – U.S. Privacy Shield and the U.S. – SwissPrivacy Shield Framework.
VIII. CHANGES TO THIS POLICY
The practices described in this Policy are current Personal dataprotection policies as of May 25, 2018. ZEKS Compressed AirSolutions, LLC reserves the right to modify or amend this Policy atany time consistent with the requirements of the relevant principlesand applicable law. Appropriate notice will be given concerning such amendments.