EU NOTICE

Effective Date: November 12, 2019

EU PRIVACY NOTICE FOR OUR WEBSITE VISITORS, CUSTOMERS AND OTHER BUSINESS CONTACTS

This Privacy Notice relates to EU personal data that is processed by the Burke Porter Group of brands (“BPG”, “we” or “us”), which includes Aspect Automation, Burke E. Porter Machinery Co., BEP Europe, CIMAT, Epic Equipment & Engineering, Inc., Galileo TP Process Equipment S.r.l., Kinematic Automation, Kleinknecht, Korvis, LISMAR, NACS Inc., Primatics, Titan Inc., Universal Balancing, Van Hoecke Automation, WinterPark Engineering, and XL Machine Co. Inc. BPG is a global leader in the design and manufacture of customized, intelligent machines serving a range of industries. As such, we engage in a limited number of personal data processing activities which are described in this Notice.

We take very seriously our obligations to protect the personal data that we process about our business contacts, including:

visitors to our websites;
individuals associated with our customers and prospective customers, marketing and other business contacts

in accordance with the data protection principles and requirements set out in the European Union General Data Protection Regulation (“GDPR”), Regulation (EU) 2016/679.

This Privacy Notice may change from time to time and all updates will be posted on this page. We will post these changes to this Notice and other accessible places in advance of their taking effect, in keeping with our continuing transparency obligation under the GDPR.

The terms used in this Privacy Notice shall be interpreted in accordance with the definitions provided in the GDPR.

1. WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA AND HOW TO CONTACT US

For purposes of the GDPR, the controller for the data processing activities covered by this Notice is:

For our website visitors: BPG International Finance Company LLC (Burke Porter Group), whose address is:

4760 Fulton St. East Suite 201, Ada, MI 49301

Burke Porter Group has appointed as its representative in the European Union:

GDPR Privacy

By post:
- BEP EUROPE nv
- Ten Briele 6
- 8200 BRUGGE
By phone:
- +32 50 /800 730
By email:
- Attn: GDPR Privacy, [email protected]

For individuals associated with our customers, prospective customers and vendors, the controller is the EU affiliate of the : BPG International Finance Company LLC (Burke Porter Group ) that you do business with. A list of our EU affiliates is provided in Annex 1 to this Privacy Notice.

EU AFFILIATES OF BURKE PORTER GROUP

BEP Europe: Bruges, Belgium
CIMAT: Bydoszcz, Poland
Galileo TP Process Equipment S.r.l.: Scandicci (FL), Italy; Sophia, Bulgaria
Kleinknecht: Siegen, Germany; Lohfelden, Germany; Wilnsdorf, Germany; Ilmenau, Germany
LISMAR: Ouderkerk aan de Amstel, The Netherlands
Universal Balancing: Bristol, United Kingdom
Van Hoecke Automation: Gavere, Belgium

CONTACT DETAILS

Questions regarding this Notice may be directed to us at: [email protected]
By phone:
- +32 50 /800 730
By post:
- At the address of our representative office (above) or the EU affiliate with which you do business (see Annex 1).

WHAT PERSONAL DATA WE COLLECT AND WHY?

We source, use and otherwise process personal data in different ways. In the sections listed below, we provide information about our personal data processing activities in relation to our:

Section 1.1 Website Visitors
Section 1.2 Representatives of our Existing or Prospective Customers, Vendors, Marketing and Other Business Contacts

1.1 WEBSITE VISITORS

A – SOURCES OF PERSONAL DATA

We may obtain personal data from the following sources:

a) from website visitors directly (for example, at the time of subscribing to any services offered on our website[s], including but not limited to email mailing lists, interactive services, posting material or requesting further goods or services);
b) from the website visitor’s device or browser; and/or
c) if a website visitor contacts us, we may keep a record of that correspondence.

B – PERSONAL DATA THAT WE COLLECT AND PROCESS

a) name
b) email address
c) phone number
d) location
e) operating system
f) browser type
g) cookie data (for more information please see our Cookie Notice)
h) preferences regarding online marketing
i) IP address

When you contact BPG, we may keep a record of your communication to help solve any issues you might be facing. We may use your email address to inform you about our services, such as letting you know about upcoming changes or improvements.

As is true of most web sites, we gather certain information automatically and store it in log files. This information may include IP addresses, browser type, referring/exit pages, operating system, date/time stamp, and clickstream data. We may collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). BPG may associate your device identifiers or phone number with your BPG Account. We use this information to analyze trends, to administer the site, and to track how visitors interact with the site.

Where we use cookies or similar technologies to fulfil this purpose we will seek your prior consent. For further information on how we use cookies and similar technologies, or to manage your cookie preferences, please see our Cookie Notice.

C – WHY DO WE COLLECT YOUR PERSONAL DATA AND WHAT ARE OUR LAWFUL BASES FOR IT?

Website Visitors
We may use your personal data to/for	Our lawful basis for doing so is:	Our legitimate interests in doing so are:
Provide our website services to you	Legitimate Interest	Website Management Promote our goods and services Account Management
Establish and manage our relationship		Understand the market in which we operate Management Reporting (including at an intra-group level) Account Management
Learn about our websites(s) users’ browsing patterns and the performance of our website(s)		Website Management
Security		Managing security, risk and crime prevention Management Reporting (including at an intra-group level)
Let you know about our products, services and events that may be of interest to you by letter, telephone, email or other forms of electronic communication		Promote our goods and services Management Reporting (including at an intra-group level)
Learn about how our products or services may be used		Understand the market in which we operate Management Reporting (including at an intra-group level)

Where we use your email to communicate marketing information to you we will seek your prior consent where we are required to do so by law.

If you wish to withdraw your consent to receiving emails from us, or if you object to our using your contact details for these purposes, including direct marketing, please notify us using the contact details provided in Section 1. If you wish to withdraw your consent to the application of cookies, please see our Cookie Notice.

Our website may contain links to other sites that are not owned or controlled by BPG. Please be aware that BPG is not responsible for the privacy or security practices of such other sites. We encourage you to be aware when you leave our site and to read the privacy statements of each and every website that collects personal data In addition, the BPG website located at https://www.burkeportergroup.com/ contains links to sites of BPG based outside the EU.

1.2 REPRESENTATIVES OF OUR EXISTING OR PROSPECTIVE CUSTOMERS AND VENDORS

A – SOURCES OF PERSONAL DATA

We may obtain your personal data from the following sources:

a) Directly from an individual associated with a customer, prospective customer or vendor,
b) from our customer, prospective customer or vendor,
c) from other entities within the Company Group of Brands;
d) during networking events that we have either hosted, or sponsored, or attended; and/or
e) from publicly available sources (for example, your company website or social media sites)

B – PERSONAL DATA THAT WE COLLECT AND PROCESS

We may collect the following categories of personal data relating to our corporate customers’ employees, officers, authorized signatories, and other associated individuals. This may include:

a) name;
b) business name;
c) business address;
d) business email address;
e) business telephone number; and/or
f) job title.

C – WHY DO WE COLLECT YOUR PERSONAL DATA AND WHAT ARE OUR LAWFUL BASES FOR IT?

Representatives of our Existing or Prospective Customers and Vendors
We may use your personal data to/for	Our lawful basis for doing so is:	Our legitimate interests in doing so are:
Provide you with our products or services or receive products or services from you	Legitimate Interest	Efficiently fulfil our contractual and legal obligations Management Reporting (including at an intra-group level)
Establish and manage our relationship		Efficiently fulfil our contractual and legal obligations Account Management Understand the market in which we operate Management Reporting (including at an intra-group level)
Learn about how our products and services are or may be used		Understand the market in which we operate Management Reporting (including at an intra-group level)
Security		Managing security, risk and crime prevention Management Reporting (including at an intra-group level)
Let you know about our products, services and events that may be of interest to you by letter, telephone, email or other forms of electronic communication		Promote our products and services Management Reporting (including at an intra-group level)

Where we use your email to communicate marketing information to you we will seek your prior consent where required to do so by law.

2. WHO DO WE SHARE YOUR PERSONAL DATA WITH?

BPG shares personal data within the corporate group, and with authorized contractors and third-party agents, as described below. Unless we have a lawful basis for doing so, we do not share your personal data with anyone else. We do not sell your personal data to third parties.

BPG AFFILIATES

BPG is a global manufacturer whose operations are supported by centralized IT systems that are hosted in the United States. We share your personal data with other entities in the Burke Porter Group where necessary for us to conduct our business. The following table shows how we share different types of personal data within BPG.

OUR SERVICE PROVIDERS

We may disclose personal data to organizations that provide a service to us, subject to contractual safeguards obligating them comply with contractual requirements imposed by the GDPR

For example, we share personal data with the following types of service providers:

a) technical support providers who assist with our website and IT infrastructure;
b) third party software providers, including ‘software as a service’ solution providers, where the provider hosts the relevant personal data on our behalf;
c) our advertising and promotional agencies and consultants and those organizations selected by us to carry out marketing campaigns on our behalf; and/or
d) providers that help us store, collate and organize information effectively and securely, both electronically and in hard copy format, and for marketing purposes.

COMPANY MERGERS AND TAKEOVERS

We may transfer your personal data to potential purchasers and their advisors, subject to appropriate confidentiality obligations, in the event we decide to dispose of all or parts of our business.

BPG’S LEGAL OBLIGATIONS AND LEGITIMATE INTERESTS

We may share personal information with brands, organizations or individuals outside of BPG if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

meet any applicable law, regulation, legal process, subpoena or enforceable governmental request.
enforce applicable Terms of Service, Terms of Use, or other potential violation of BPG contracts or rules, including investigation of potential violations.
detect, prevent, investigate or otherwise address fraud, security or technical issues.
protect against harm to the rights, property or safety of BPG, our users or the public as required or permitted by law.

3. TRANSFERS OF PERSONAL DATA OUTSIDE THE EU/EUROPEAN ECONOMIC AREA

International transfers within BPG are governed by the EU Commission-approved Standard Contractual Clauses for Controllers [and for Processors].

We may also transfer your data to third-party vendors and business partners outside the EU, such as our customer relationship management systems providers HubSpot and Zoho. Where we do so, the data is used to maintain sales contact databases, inform marketing decisions and actions, report on marketing results, and improve user experience of the websites.

The BPG website located at https://www.burkeportergroup.com/ and the websites of EU and U.S.-based BPG brands (including Burke E. Porter Machinery Co., BEP Europe, CIMAT, Epic Equipment & Engineering, Inc., Galileo TP Process Equipment S.r.l., Kleinknecht, Korvis, LISMAR, NACS Inc., Primatics, Titan Inc., Universal Balancing, Van Hoecke Automation, WinterPark Engineering, and XL Machine Co. Inc.) are hosted and administered in the United States.

We may transfer your data from the United States to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Site.

When transferring your personal data to service providers and business partners outside the EEA, we will do so if a data processing agreement is in place where required and:

a) the transfer is to a non-EEA country which has an adequacy decision by the EU Commission or to an organization in the US that is EU-US Privacy Shield certified;
b) the transfer is covered by the Standard Contractual Clauses or other safeguards approved by the European Commission to safeguard personal data transfers; or
c) the transfer is to an organization which has Binding Corporate Rules approved by an EU data protection authority or an approved Code of Conduct.

You may request a copy of the above-referenced documentation by notifying us using the contact details provided in Section 1.

4. RETENTION PERIOD

We will keep and process your personal data only for as long as is necessary for the purposes for which it was collected in connection with your relationship with us, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defense of legal claims.

5. YOUR RIGHTS TO YOUR PERSONAL INFORMATION

BPG shall allow an individual access to their Personal Information and allow the individual to correct, amend, or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated. Please email [email protected] to review and update your personal contact information.

The GDPR provides you with certain rights in relation to the processing of your personal data, including to:

Request access to personal data about you (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you, and to check that we are lawfully processing it.
Request rectification, correction, or updating to any of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request personal data provided by you to be transferred in machine-readable format (“data portability”).
Request erasure of personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove personal data where you have exercised your right to object to processing (see below).
Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you (e.g. if you want us to establish its accuracy or the reason for processing it).
Object to the processing of your personal data in certain circumstances. This right may apply where the processing of your personal data is based on the legitimate interests of Company, as explained above, or where decisions about you are based solely on automated processing, including profiling.
Withdraw your consent. If we are processing you persona data on the basis of your consent, you have the right to withdraw your consent at any time.

These rights are not absolute and are subject to various conditions under:

applicable data protection and privacy legislation; and
the laws and regulations to which we are subject.

If at any time you decide that you do not want to be contacted by us for direct marketing purposes or if you would like to exercise any of your rights as set out above, please notify us of your wishes using the contact details provided in Section 1.

We will do our best to respond to any requests or concerns that you may have in regard to our processing of your personal data. If you are not satisfied with our response, you may submit a complaint to [email protected].

You also have the right to submit a complaint to the relevant data protection supervisory authority in the European Union.

ANNEX 1.

Burke Porter Group has appointed as its representative in the European Union:

GDPR Privacy

By post:
- BEP EUROPE nv
- Ten Briele 6
- 8200 BRUGGE
By phone:
- +32 50 /800 730
By email:
- Attn: GDPR Privacy, [email protected]

EU AFFILIATES OF BURKE PORTER GROUP:

BEP Europe: Bruges, Belgium

BEP EUROPE nv
Ten Briele 6
8200 BRUGGE

CIMAT: Bydoszcz, Poland

4 Bogdan Raczkowski St.
City of Bydgoszcz, 85-862
Poland

Galileo TP Process Equipment

Via del Pantano, 73A
50018 Scandicci (Florence) – Italy
Elin Pelin, 45
Sophia – Bulgaria

Kleinknecht: Siegen, Germany; Lohfelden, Germany; Wilnsdorf, Germany; Ilmenau, Germany

Eiserntalstraße 358
D-57080 Siegen
Lange Straße 14
D-34253 Lohfelden
Auf der Landeskrone 2
D-57234 Wilnsdorf
Weimarer Straße 1b
D-98693 Ilmenau

LISMAR: Ouderkerk aan de Amstel, The Netherlands

Lismar Engineering B.V.
Ambachtenstraat 55
1191 JM OUDERKERK AAN DE AMSTEL
The Netherlands

Universal Balancing: Bristol, United Kingdom

Douglas Road Industrial Park
Bristol, BS15 8PD
United Kingdom

Van Hoecke Automation: Gavere, Belgium

Industriepark Asper
Legen Heirweg 29
B-9890 Gavere

	Website Visitors, Marketing and Other Business Contacts		Existing or Prospective Customers and Vendors
Entity’s Website	How User Data is Collected	How User Data is Used	How User Data is Collected	How User Data is Used
Aspect Automation	User submission through contact page; contact information is sent to a distribution email and user’s information stored on the back-end of WordPress.	Added to sales database to establish and maintain relationship.	User submission through contact page; contact information is sent to a distribution email and user’s information stored on the back-end of WordPress.	Added to sales database to establish and maintain relationship.
Burke Porter Group	Users can complete contact submission through contact page; contact information is sent to a distribution email ([email protected]) and user’s information stored on the back-end of WordPress indefinitely.	Added to sales database, email marketing to inform about how our products and services are or may be used.	Users can complete contact submission through contact page; contact information is sent to a distribution email ([email protected]) and user’s information stored on the back-end of WordPress indefinitely.	Added to sales database, email marketing to inform about how our products and services are or may be used.
Burke E. Porter Machinery Co	User submission through contact page; contact information is sent to a distribution email and user’s information stored on the back-end of WordPress.	Added to sales database, email marketing to inform about how our products and services are or may be used.	User submission through contact page; contact information is sent to a distribution email and user’s information stored on the back-end of WordPress.	Added to sales database, email marketing purposes.
CIMAT	User submission through contact page; contact submission is sent to a distribution email and user’s information stored on the back-end of WordPress.	Added to sales database, email marketing to inform about how our products and services are or may be used, reporting on marketing results, improve user experience of website.	User submission through contact page; contact submission is sent to a distribution email and user’s information stored on the back-end of WordPress.	Added to sales database to establish and maintain relationship.
Epic Equipment	User submission through contact page; contact information is sent to a distribution email and user’s information stored on the back-end of WordPress.	Added to sales database to establish and maintain relationship.	User submission through contact page; contact information is sent to a distribution email and user’s information stored on the back-end of WordPress.	Added to sales database to establish and maintain relationship.
Galileo TP Process Equipment	User submission directly to [email protected] email.	Galileo directly maintains communication and relationship with new customers.	User submission directly to [email protected] email or contact Gaileo employees directly.	Galileo directly maintains communication and relationship with existing customers.
Kinematic Automation	User submission through contact page; contact information is sent to a distribution email and user’s information stored on the back-end of WordPress.	Added to sales database to establish and maintain relationship.	User submission through contact page; contact information is sent to a distribution email and user’s information stored on the back-end of WordPress.	Added to sales database to establish and maintain relationship.
Kleinknecht	User submission through contact page; contact submission is sent to a distribution email and user’s information stored on the back-end of WordPress.	Added to sales database to establish and maintain relationship.	User submission through contact page; contact submission is sent to a distribution email and user’s information stored on the back-end of WordPress.	Added to sales database to establish and maintain relationship.
Korvis	User submission through contact page; contact submission is sent to a distribution email and user’s information stored on the back-end of WordPress.	Added to sales database to establish and maintain relationship	User submission through contact page; contact submission is sent to a distribution email and user’s information stored on the back-end of WordPress.	Added to sales database to establish and maintain relationship.
NACS, Inc.	User sends email to a sales distribution email.	Added to sales database.	User sends email to a sales distribution email.	Added to sales database.
Primatics	User submission through contact page; contact submission is sent to a distribution email and user’s information stored on the back-end of WordPress.	Added to sales database to establish and maintain relationship.	User submission through contact page; contact submission is sent to a distribution email and user’s information stored on the back-end of WordPress.	Added to sales database to establish and maintain relationship.
Titan	User submission through contact page; contact submission is sent to a distribution email and user’s information stored on the back-end of WordPress.	Added to sales database to establish and maintain relationship.	User submission through contact page; contact submission is sent to a distribution email and user’s information stored on the back-end of WordPress.	Added to sales database to establish and maintain relationship.
Universal Balancing	User submission through contact page; contact submission is sent to a distribution email and user’s information stored on the back-end of WordPress and within HubSpot.	Added to sales database, email marketing to inform about how our products and services are or may be used, reporting on marketing results, improve user experience of website.	User submission through contact page and/or service page; contact submission is sent to a distribution email and user’s information stored on the back-end of WordPress and within HubSpot.	Added to sales database to establish and maintain relationship.
Van Hoecke Automation	User sends email to a sales distribution email.	Added to sales database.	User sends email to a sales distribution email.	Added to sales database.
WinterPark Engineering	User submission directly to [email protected] email.	WinterPark directly maintains communication and relationship with new customers.	User submission directly to [email protected] email or contact WinterPark employees directly.	WinterPark directly maintains communication and relationship with existing customers.
XL Machine Company	User submission through contact page and RFQ form; contact submission is sent to a distribution email and user’s information stored on the back-end of WordPress.	Added to sales database, email marketing purposes.	User submission through RFQ form; contact submission is sent to a distribution email and user’s information stored on the back-end of WordPress.	Added to sales database, email marketing purposes.