Effective Date: January 1, 2020

Please take a few minutes to familiarize yourself with our Privacy Notice. This Privacy Notice applies to this and all other websites (collectively referred to as the "Site") offered or operated by Elettra Tech Inc. or its subsidiaries or affiliated companies (collectively referred to as "Elettra Tech"), except for any Elettra Tech Sites that have their own posted Privacy Notice. Please note that the Site is hosted by Elettra Tech in the United States and any information you provide may be transferred to the U.S. or other countries.

Information we collect

We may collect the following types of information:

• Information you provide - When you sign up for access to Elettra Tech' online resources (including any customer applications), download documents or complete online forms, we may ask you for certain personal information. You may be asked to provide personal information such as: name, title, function, e-mail address, address and certain demographic information. When placing an order or carrying out a transaction on the Site, you may be asked for financial information such as credit card details. You may also voluntarily share other information such as feedback, opinions, or information shared via the Contact Us feature.
• Cookies - A cookie is a piece of data stored on a user's computer that is tied to information about the user. When you visit the Site, we send one or more cookies to your computer or other browsing device. We use cookies to improve the quality of our service, including for storing user preferences, improving search results and ad selection, and tracking user trends. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some Elettra Tech features and services may not function properly if your cookies are disabled.
• Web beacons - Web pages may contain electronic images (called a "single-pixel GIF" or "web beacon") that allow a web site to count users who have visited that page or to access certain cookies. We use web beacons to track the effectiveness of an email campaign and to transfer an individual's unique user identification (often in the form of a cookie) and associate your updated information into our database. Our practice is to include web beacons in HTML-formatted email messages (messages that include graphics) that we send directly or through third parties in order to determine, among many other items, which email messages were opened and to note whether a message was acted upon. In general, any electronic image viewed as part of a web page, including an ad banner, can act as a web beacon.
• Web beacons - Web pages may contain electronic images (called a "single-pixel GIF" or "web beacon") that allow a web site to count users who have visited that page or to access certain cookies. We use web beacons to track the effectiveness of an email campaign and to transfer an individual's unique user identification (often in the form of a cookie) and associate your updated information into our database. Our practice is to include web beacons in HTML-formatted email messages (messages that include graphics) that we send directly or through third parties in order to determine, among many other items, which email messages were opened and to note whether a message was acted upon. In general, any electronic image viewed as part of a web page, including an ad banner, can act as a web beacon.
• Log information - When you access the Site via a browser, application or other client, our servers automatically record certain information. This may include information such as your web request, your interaction with a service, Internet Protocol (IP) address, browser type, browser language, the date and time of your request, and one or more cookies that may uniquely identify your browser or your account.
• Please see our Cookie Policy for more detailed information regarding cookies and web beacons.

No sensitive personal information or personal information of minors

Elettra Tech does not need or want to collect any sensitive personal information (called special category data in the EU) through the Site. Similarly, minors under the age of 18 should not provide any personal information to Elettra Tech through the Site. The Site does not knowingly accept sensitive personal information or personal information of minors from users of the Site and/or any third party sites.

How we use this information

• We use information we collect to help us improve the Site and deliver content and functionality that is best suited for you and your device.
• To analyze your use of the Site for trend monitoring and promotional purposes
• The information we collect allows us to keep you posted on Elettra Tech' latest announcements, events, and services that we believe may be of interest to you if this is in accordance with your marketing preferences.
• We may use your information to send important notices or communications regarding services you have ordered from Elettra Tech, even if you have opted out from our marketing communications.
• To respond to inquiries and comments and provide you with support via your preferred communication channels
• To keep the Site safe and secure and comply with our legal requirements and obligations
• To set up and manage your user account
• For any other new purpose for which we notify you before collecting any personal data

How we share your information

You can choose which, if any, of our online resources you wish to participate in. Elettra Tech only shares personal information in the following limited circumstances:

• We provide such information to our subsidiaries and affiliated companies where it is necessary to meet the purpose for which you have submitted your personal data and in particular if necessary for the provision of services, account administration, sales, marketing and support. We take steps to ensure that Elettra Tech companies follow our data protection policy, this privacy notice and applicable local law when handling personal data. This includes having in place proper data transfer mechanisms such as EU standard contractual clauses.
• To third party contractors and providers that perform certain functions on behalf of Elettra Tech, such as sending email, removing repetitive information from customer lists, analyzing data and processing credit card payments, direct marketing services, and cloud hosting services. These parties only have access to such information as necessary to perform their functions and may not use it for any purpose other than to provide services to us.
• Elettra Tech, like all companies, is required to respond to lawful requests from law enforcement bodies to access Elettra Tech premises and systems for purposes relating to national security. This will be strictly limited to the data relevant to the scope of a request and to data subjects covered by the legal jurisdiction of requests.
• We may also process personal data directly relevant to investigating and handling a criminal or civil lawsuit or to take action to prevent fraud, abuse or other violations of our Site Terms of Use.
• For other lawful purposes that may arise such as due to any merger, acquisition, financing, sale of company assets or interests in the company, or transition of service to another provider, or in the event of an insolvency, bankruptcy, or receivership.

Safeguarding your information

Elettra Tech uses commercially reasonable efforts to employ security measures designed to protect your personal information from loss, destruction, or access by unauthorized persons. These include, but are not limited to:

• Physical safeguards such as locked doors and file cabinets, controlled access to our facilities and secure destruction of media containing your personal information.
• Technology safeguards, like the use of anti-virus and endpoint protection software, and monitoring of our systems and data centers to ensure that they comply with our security policies.
• Organizational safeguards, like training and awareness programs on security and privacy, to make sure employees understand the importance and means by which they must protect your personal information.

Data Retention

We will retain your information for as long as is necessary for the purposes for which it was collected. The criteria used to determine our retention periods include:

• How long is the data needed to provide you with our products or services or to operate our business?
• Do you have an account with us? In this case, we will keep your data while your account is active or for as long as needed to provide the services to you.
• Are we subject to a legal, contractual, or similar obligation to retain your data? Examples can include mandatory data retention laws in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of contract or litigation.

Accessing and controlling your information

You have the following rights in most circumstances:

• The right of access-The right to know whether data concerning you is being processed and if so, the right to gain access to it with a few exceptions.
• The right to rectification-The right to ensure data held about you is accurate, and if it is not, have it corrected.
• The right to erasure or right to be forgotten-Where Elettra Tech does not have an overriding legal basis to retain your personal information.
• The right to restrict processing-In some circumstances, you have the right to limit how Elettra Tech processes your personal information if Elettra Tech does not have an overriding legal basis to continue processing.
• The right to be informed-Elettra Tech has a responsibility to provide you with the information contained in this privacy notice and to answer questions if you ask for more detail about anything contained here.
• The right to data portability-The right to obtain a copy of the personal data you provided to Elettra Tech, in a format you can easily take away and load onto another device.
• The right to object-You have the right to withdraw consent or object to processing when processing is based upon consent or legitimate interest as the lawful basis, with some exceptions.

For many of our services, we provide mechanisms for you to electronically access and update your personal information by logging into your online accounts. You may opt out of promotional email communications from us by clicking on a link provided in our promotional email messages or sending us an email at [email protected]. After opting out, you will no longer receive marketing or promotional communications but will continue to receive other messages, such as important notices or communications regarding services you have ordered from Elettra Tech. For cookies/trackers, you can click the 'More Information' link on any Elettra Tech cookie banner to check that preferences are correct. You can selectively provide consent and withdraw consent via that link.

California residents: Your California privacy rights

California law permits residents to receive: (1) a listing of categories of personal information Elettra Tech has collected about them, (2) the identity of any third parties to whom Elettra Tech has disclosed personal information for a business purpose or sold personal information within the previous calendar year and (3) the categories of personal information disclosed or sold to those third parties. California law requires us to request certain personal information to verify your identity prior to these disclosures and prohibits discrimination based on your exercise of these rights. You can submit a request for disclosure by contacting us at [email protected], calling +1.877.854.3577 or completing our online personal data access request form. Please note that Elettra Tech does not sell personal information to third parties or disclose personal information to third parties for the third parties' direct marketing purposes.