SMARTCONNECT PRIVACY POLICY - UNITED STATES AND CANADA

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The following applies to any individual residing within the United States of America and Canada.

Last Revised: December 1, 2020

ITW Food Equipment Group LLC and its affiliated entities (including Baxter, Bonnet, Centerline, Foster, Hobart, Traulsen, and Vulcan) (“FEG,” “we,” “us” or “our”) respects your personal privacy and is committed to adhering to applicable privacy and data protection laws and industry guidelines. This privacy policy (“Privacy Policy”) describes the information we collect, how we use and share it, and your rights with respect to the information we collect about you. This Privacy Policy applies to any information we collect or maintain about you, including (1) personal information that you provide to us on through your use of the mobile application that directed you here (the “Mobile Application”), the related services accessible through the Mobile Application, or on other sites of ours (the “Mobile Services”) (collectively with the Mobile Application, the “Mobile Application and Services”), and (2) information collected through your use of or interaction with the Mobile Application and Services. This Privacy Policy also explains the use of cookies and similar technologies on the Mobile Application and Services (see PASSIVE INFORMATION COLLECTION below).

This Privacy Policy applies only to the Mobile Application and Services that link to this Privacy Policy – not to any third-party sites that may be accessible from the Mobile Application and Services. In the event you are directed to FEG’s website, located at: https://www.itwfoodequipment.com/, or any other websites or resources, you understand and agree that your use of those websites will be governed by the privacy policy posted on each of those websites and/or resources and not this Privacy Policy. 

After reading this Privacy Policy, which is incorporated into and is a part of the Mobile Application End-User License Agreement, you will know:

1. What information FEG collects from or about you and how we use it
2. What choices you have about how FEG treats your information
3. How FEG protects your information
4. What FEG does about children visiting the Mobile Application and Services
5. Additional information applicable to California residents
6. How you can contact FEG
7. Changes in the Privacy Policy

CALIFORNIA RESIDENTS: Section 5 of this Privacy Policy, along with the Supplemental Notice for California Residents attached to this Privacy Policy below (which is a part of this Privacy Policy), provide additional information about how we collect and share your personal information and your rights under California law with respect to your personal information.

1. Information FEG Collects From You and How We Use It

YOUR CONSENT

By using, visiting or interacting with the Mobile Application and Services or providing personal information to us through your use of the Mobile Application and Services, you are consenting to the collection, use and disclosure of your personal information described in this Privacy Policy.

If you do not consent to the collection, use and disclosure of your personal information as described in this Privacy Policy, do not use the Mobile Application and Services or contact FEG pursuant to Section 6 below.

ACTIVE INFORMATION COLLECTION

Like many other applications, we actively collect information from our visitors both by asking specific questions through the Mobile Application and Services registration process and forms, or other methods made available to you on our Mobile Application and Services and when you correspond with us. Some of the information that you submit may be personal information (that is, information that can be uniquely identified with you, such as your name, address, e-mail address, phone number, etc.). FEG uses this information for the purposes for which you provide it and for any other purpose described at the time information is submitted by you, and as otherwise set forth in this Privacy Policy or as permitted or required by applicable law. For example, if you provide your name and contact information to register an account, such information will be used to identify your account and associate your Hobart branded device with your information.

We generally collect and use personal information provided to us on the Mobile Application and Services for the following purposes:

• to establish, develop and preserve our business relationship respectively with our customers and other individuals with whom we deal;
• to create, establish and administer your account and to respond to your inquiries;
• to provide the products and services that we offer and ensure that all related transactions are executed;
• for quality assurance purposes;
• as necessary, to establish or verify the credit of persons who use, or intend to use, one or more of the products offered by FEG;
• to manage our business and ensure the efficiency, reliability and security of our systems;
• to meet legal and regulatory requirements and to allow FEG to meet contractual requirements relating to the products and services we offer;
• to ensure our records are accurate and to protect customers and FEG from error and fraud;
• to understand and assess the interests, wants and changing needs of our customers and Mobile Application and Services visitors with a view to improving our products and services and developing new ones;
• in any other manner that you have consented to prior to such collection;
• to provide our customers and Mobile Application and Services users with personalized products and services as well as product recommendations; and
• to notify our customers and Mobile Application and Services users about changes to the Mobile Application and Services or upcoming products and services offered or provided by us, our affiliates or our business partners that may be of interest to our customers and Mobile Application and Services users.

PASSIVE INFORMATION COLLECTION

Some of the information we collect depends on the settings on your mobile device. Please check your mobile device if you want to learn what information your mobile device sends or how to change your settings. In addition to the information sent by your mobile device, as you navigate through the Mobile Application, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies and means, such as navigational data collection.

Like most application developers, we and our approved partners use cookies and similar technologies, local shared objects (or any other successor tracker technology), Software Development Kits, and pixel tags that automatically receive and track certain data about how you and other users interact with our Mobile Application and Services, preferences expressed and settings chosen. For example, we may collect information about the technology you use (such as type of mobile device, operating systems, network used, and Internet and telecommunications service providers) and server log data (such as access dates and times, online features or pages viewed, system activity, and the third-party site or service you were using before interacting with our Mobile Application and Services).  These technologies are described in more detail below.

“Cookies” are small text files that are stored on your browser or device by websites, mobile apps, online media and advertisements. There are different types of cookies. Cookies served by the entity that operates the website or app you are visiting or using are called “first party cookies” (so cookies served by FEG while you are using our Mobile Application and Services are first party cookies). Cookies served by companies that are not operating the website or app you are visiting or using are called “third party cookies” (so, we may a website analytics provider to set a cookie on your computer via our Mobile Application and Services while you visit our Mobile Application and Services, and that would be a third party cookie). Cookies may also endure for different periods of time. “Session Cookies” last only as long as your browser or app is open. These are deleted automatically once you close your browser or app. Other cookies are “persistent cookies” meaning that they survive after your browser or app is closed (for example, they may recognize your computer when you re-open our online services).

“Local shared objects” (also called Flash cookies or HTML5 cookies) and any other successor technology refers generally to the collection of cookie-like data stored on a browser or computer by web sites, ads, or third parties.

“Pixel tags” (also called beacons or pixels) are small blocks of code installed on (or called by) a web page, app or advertisement which can retrieve certain information about your device and browser, including device type, operating system, browser type and version, web site visited, time of visit, referring web site, IP address, and other similar information (including the small text file (the cookie) that uniquely identifies the device). Pixels provide the means by which third parties can set and read browser cookies from a domain that they do not themselves operate and collect information about visitors to that domain, typically with the permission of the domain owner. “Software Development Kits” (also called SDKs) function like pixels and cookies, but operate in the mobile app context where pixels and cookies cannot always function. The primary app developer can install pieces of code (the SDK) from partners in the app, thereby allowing such partners to collect certain information about user interaction with the app, information about the user device and network information.

In this Privacy Policy, these and similar technologies are collectively referred to as “cookies and technologies.” The following table sets out the different categories of cookies and technologies that our Mobile Application and Services may use and why we use them:

Cookie Types:

Authentication

• Purpose: These cookies and technologies tell us when you're using our Mobile Application and Services so we can show you the appropriate features and content such as your account information, purchase history and to edit your account settings.

Security and Mobile Application and Services Integrity

• Purpose: These cookies and technologies support or enable security features to help keep our Mobile Application and Services safe and secure. For example, they enable us to remember when you are logged into a secure area of our Mobile Application and Services and help protect your account from being accessed by anyone other than you.

Online Service Features

• Purpose: These cookies and technologies provide functionality that help us deliver products and services. For example, cookies help you log in by pre-filling fields. We may also use these cookies and similar technologies to help us provide you and others with social plugins (for example, Facebook, YouTube, LinkedIn) and other customized content and experiences.

Analytics and Research

• Purpose: These cookies and technologies are used to understand, improve and research our Mobile Application and Services, and better understand the interests of people who interact with our Mobile Application and Services. For example, we and our approved partners may use these cookies and technologies to understand how you are using Mobile Application and Services features, and segmenting audiences for feature testing. We and our partners may use these technologies and the information we receive to improve and understand how you use and interact with our Mobile Application and Services.
  • For example, our Mobile Application and Services uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to analyze use patterns and may collect information about your use of our Mobile Application and Services. More information on Google Analytics can be found here: www.google.com/policies/privacy/partners/. If you would like to opt-out of having your data used by these cookies, please use the Google Analytics opt-out available here:

    https://tools.google.com/dlpage/gaoptout/.

RETENTION OF PERSONAL INFORMATION

FEG retains the personal information collected from the Mobile Application and Services as long as necessary to provide the services, products and information you request or as permitted by applicable law.

Disclosure of Personal Information

FEG will not sell or otherwise disclose personal information collected from the Mobile Application and Services to any third person, except as permitted by this Privacy Policy, as permitted or provided by applicable law or with your consent.

We may disclose personal information you provide to us via this Mobile Application and Services or that we collect through your use of the Mobile Application and Services as follows:

• to affiliates, business partners, service providers and contractors who support our business, in which case we will limit the amount of information disclosed to that which is necessary in order for them to provide the services or products we have engaged them to provide. We will strive to protect personal information rendered accessible to affiliates, business partners, service providers and contractors by contractual agreements requiring them to adhere to confidentiality and security practices that provide for maintaining such information confidential and inaccessible to others;
• to respond to law enforcement requests, where required by applicable laws, court order or governmental regulations;
• in the event of a sale, merger, liquidation, dissolution, reorganization, assignment or other transfer of our business to which the information relates, in which case we will enter an agreement with the buyer that requires it to treat personal information in accordance with this Privacy Policy and use it for the same purposes as we are entitled to so under this Privacy Policy and includes other protective terms required by applicable law; and
• to report unlawful acts to law enforcement agencies and to seek law enforcement assistance in accordance with applicable laws.

We will have no liability for disclosure of information obtained due to errors in transmission or the unauthorized intervention of third parties.

We may provide aggregate statistics about our customers, sales, online traffic patterns, and related information to reputable third parties, but these statistics will not include any personally identifying information.

We may allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf on our Mobile Application and Services and across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, pixel tags, and other technologies to identify your mobile device or computer when you use or interact with our Mobile Application and Services, as well as when you visit other web sites and services. When third-party ad providers collect data on our Mobile Application and Services for their own purposes (not solely on behalf of FEG), any such data collected and maintained by such third-party ad providers will be subject to the terms of use and privacy policies of those providers.

The Mobile Application and Services may use social media plugins (for example, the Facebook “Share” button, “Share to Twitter”' button) to enable you to easily share information with others. When you visit our Mobile Application and Services, the operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our Mobile Application and Services. If you are logged into the social media website (for example, Facebook, Twitter, Google+) while browsing on our Mobile Application and Services, the social plugins allow that social media website to receive information that you have visited our Mobile Application and Services. The social plugins also allow the social media website to share information about your activities on our Mobile Application and Services with other users of their social media website. For example, Facebook social plugin allows Facebook to show your comments on our pages to your Facebook friends. FEG does not control any of the content from the social media plugins. For more information about social plugins from other social media websites you should refer to those sites' privacy and data sharing statements.

We may transfer the information described in this Privacy Policy to, and process and store it in, the United States and other countries, some of which may have less protective data protection laws than the region in which you reside. Where this is the case, we will take appropriate measures to protect your information in accordance with this Privacy Policy. Nonetheless, your personal information may be subject to foreign laws and may be accessible by foreign government authorities, courts, law enforcement and regulatory agencies.

2. Choices You Have About How FEG Uses Your Information

We strive to provide you with as many choices and as much control as possible regarding the personal information we collect about you. We will only send you commercial electronic messages by email, text or similar means if we have your consent. You have the right to withdraw that consent at any time by sending us an e-mail message at websupport@itwfeg.com.

You may also send us an e-mail message at websupport@itwfeg.com to request access to, correct, or delete any personal information that you have provided to us. To protect your privacy, we will only respond to e-mail messages sent from the e-mail account you used to set up your account. Should you elect to have your information deleted, we will also delete your user account.

If you do not wish for us to collect cookies, you may set your settings to refuse cookies, or to alert you when cookies are being sent. If you do so, please note that some parts of this Mobile Application and Services may then be inaccessible or not function properly. Removing or rejecting cookies does not necessarily affect third-party Flash cookies (see “Local shared objects” above) which may be used by us or our partners in connection with our Mobile Application and Services. To delete or disable Flash cookies, please visit here for more information.

3. How FEG Protects Your Information

We work hard to protect your personal information. All information collected through the Mobile Application and Services is stored within a secured database that is not accessible to the outside world. All FEG servers are protected behind both hardware and software firewalls. Low-level access to all information is restricted to authorized support personnel only.

The safety and security of your information also depend on you. Never share your password with anyone else, notify us promptly if you believe your password security has been breached, and remember to log off of your Mobile Application and Services when the Mobile Application and Services are not in use.

Our Mobile Application may contain links to other websites operated by third parties that may be of interest to you. We cannot control these third-party sites, which may collect personal information from you. When you follow a link and leave this Mobile Application and Services or Online Service, you do so at your own risk. We encourage you to read that third party's privacy policy or contact them directly regarding their privacy practices.

4. What FEG Does About Children Visiting This Mobile Application and Services

This Mobile Application and Services are not intended for children under the age of 18. We will not knowingly collect information from Mobile Application and Services visitors in this age group. We encourage parents to talk to their children about their use of the Internet and the information they disclose online. If your child has submitted personal information and you would like to request that such information be deleted from our records, you may do so by using the feedback mechanisms provided at the FEG or by writing us at the address set forth in Section 6 below.

5. CALIFORNIA RESIDENTS

The California Consumer Privacy Act of 2018 (CCPA) gives California residents the right to know what personal information FEG collects about them, including whether it is being sold or disclosed to third parties. The CCPA also grants certain rights to California residents, including the right to delete their personal information (subject to certain exceptions) and the right to prevent FEG from selling their personal information. Companies are also prohibited from retaliating or discriminating against consumers for exercising their rights under the CCPA.

The Supplemental Notice for California Residents attached to this Privacy Policy below provides California residents with additional information about how FEG collects and shares personal information, including the categories of personal information FEG has collected from or about California consumers in the preceding 12 months, the categories of sources from which the information was collected, the purposes for which the information is used, the categories of third parties to whom we have disclosed the information, and if we sell the personal information, the categories of third parties to whom we sell it.

California residents also have certain rights with respect to FEG’s use and disclosure of personal information:

• Right to Notice.  Before or at the time we collect personal information from you, you have the right to receive notice of the personal information to be collected and the purposes for which we use it. The Supplemental Notice for California Residents attached to this Privacy Policy below is intended to satisfy this requirement.

You also have the right to request that we disclose to you the categories of personal information we have collected about you in the preceding 12 months, along with the categories of sources from which the personal information was collected, the purpose for collecting or selling the personal information, the categories of third parties with whom we shared the personal information, and the categories of third parties with whom we sold the personal information.

• Right of Access.  You have the right to request that we disclose or provide you with access to the specific pieces of personal information we have collected about you in the preceding 12 months.
• Right to Deletion.  You have the right to request that we delete the personal information we collect from you.  However, in certain situations we are not required to delete your personal information, such as when the information is necessary in order to complete the transaction for which the personal information was collected, to provide a good or service requested by you, to comply with a legal obligation, to engage in research, to secure the Mobile Application and Services, or to otherwise use your personal information internally in a lawful manner that is compatible with the context in which you provided the information.
• Right to Opt-Out of the Sale of Personal Information.  If FEG sells your personal information to third parties, you have the right, at any time, to direct us not to sell your personal information.  FEG does not sell your personal information.

• Right Not to Be Subject to Discrimination.  You have the right to be free from discrimination or retaliation for exercising any of your rights under the CCPA as described above.

To exercise any of the rights described above, you can call us at 800-777-2828 or use the online submission form available at https://www.hobartcorp.com/contact-us.  California residents who are unable to review or access this Privacy Policy, including the Supplemental Notice for California Residents below, due to a disability may call us at 800-777-2828 or email us at websupport@itwfeg.com to access this Privacy Policy in an alternative format.

We value the security and confidentiality of your personal information. Therefore, if you exercise your right to notice, right of access, or right to deletion, we must first verify your identify to make sure that you are the person about whom we have collected personal information. We verify every request carefully and ask that you respond promptly to any request for evidence needed to verify your identity.

6. How You Can Contact FEG

If you have any questions, comments or concerns about this Privacy Policy or the information practices of FEG, our Mobile Application and Services, or of our service providers, contractors and business partners, please contact us at the information below and address your request to:

ITW FEG

Attn: Innovation Director, ITW Food Equipment Group

155 Harlem Ave

Glenview, IL 60025

Toll-Free (USA): 800-777-2828

7. Changes In The Privacy Policy

FEG reserves the right to update or modify this Privacy Policy, at any time and without prior notice, by posting the revised version of this Privacy Policy in Mobile Application. If we modify this Privacy Policy, the modifications will only apply to personal information we collect after we have posted the revised Privacy Policy in the Mobile Application.

FEG Privacy Policy - Supplemental Notice for California Residents

Last Updated 12/01/2020

Why? 

This Supplemental Notice for California Residents provides certain information required under the California Consumer Privacy Act of 2018 (CCPA) and applies to both FEG’s online and offline activities involving personal information about California residents. This Supplemental Notice for California Residents is incorporated into and a part of the FEG Privacy Policy. For more information about FEG’s collection, use, and disclosure of information, as well as your rights under the CCPA, please review the FEG Privacy Policy.

What? 

The personal information that we collect, disclose, and sell depends on your relationship and interaction with FEG. Please review the Consumer Type below that applies to your relationship or interaction with FEG to learn about the categories of personal information we have collected about you in the preceding 12 months, along with the categories of sources from which the personal information was collected, the purpose for collecting or selling the personal information, the categories of third parties with whom we share the personal information, and if we sell the information, the categories of third parties to whom we sell it. If you interact with FEG in more than one way, please review each Consumer Type below that applies to you in order to learn about the personal information we collect and how we use and share it in connection with each particular relationship.

In addition to the purposes for collecting and sharing personal information described under each Consumer Type below, FEG collects and discloses any and all personal information (regardless of your relationship or interaction with us) as necessary or appropriate to: comply with laws and regulations; monitor, investigate, and enforce compliance with and potential breaches of FEG policies and procedures and legal and regulatory requirements; comply with civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or summons; and exercise or defend the legal rights of FEG and its employees, affiliates, customers, contractors, and agents.

Personal Information

In this Supplemental Notice, “personal information” (or “PI”) means any information that identifies, relates to, describes, or is capable of being associated with you or your household, whether directly or indirectly. In the charts below, we use the following categories of personal information to describe the personal information we collect, use, and share about California consumers:

• Commercial Information: Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Financial Information: Financial information, including bank account number, credit or debit card number, or other financial information.
• Identifiers: Identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol (IP) address, email address, account name, or other similar identifiers.
• Inferences: Inferences drawn from any of the information listed above to create a profile about an individual reflecting the individual’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. (e.g., predications about an individual’s preferences or tendencies).
• Geolocation Data: An individual’s precise geolocation data.
• Network Activity Data: Internet or other electronic network activity information, such as browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.
• Professional Information: An individual’s professional or employment-related information.

Customers

Categories of PI Collected - Identifiers

• Sources of PI: Directly from Consumer
• Purposes of Collecting or Sharing PI
  • to install the Mobile Application and register you as a user
  • for our everyday business purposes such as to process your requests, inquiries, or other communications with us
  • to process and manage your purchases, transactions, and payments with us
  • to detect security incidents and other fraudulent activity
  • to monitor and improve the functionality  of our Mobile Application and Services
  • to help maintain the safety, security, and integrity of our Mobile Application and Services
  • to deliver content and advertisements to you
  • to make recommendations to you about goods or services which may interest you
  • to measure and analyse the effectiveness of the advertising we serve you
  • to monitor trends so we can improve the Mobile Application
  • to manage our relationship with you including notifying you of changes to the Mobile App or any Mobile Services and responding to inquiries
  • to enable you to participate in a prize draw, competition or complete a survey
• Third Parties to Whom we Disclose PI
  • internet service providers
  • data analytics providers
  • government entities
  • operating systems and platforms
  • social networks
  • consumer data resellers
  • research partners
• Third Parties to Whom we Sell PI
  • We Do Not Sell This Information

Categories of PI Collected - Commercial Information

• Sources of PI: Directly from Consumer
• Purposes of Collecting or Sharing PI
  • to install the Mobile Application and register you as a user
  • to process and manage your purchases, transactions, and payments with us
• Third Parties to Whom we Disclose PI
  • internet service providers
  • data analytics providers
  • government entities
  • operating systems and platforms
  • social networks
  • consumer data resellers
  • research partners
• Third Parties to Whom we Sell PI
  • We Do Not Sell This Information

Categories of PI Collected - Network Activity Data​

• Sources of PI: Directly from Consumer
• Purposes of Collecting or Sharing PI
  • to monitor and improve the functionality  of our Mobile Application and Services
  • to help maintain the safety, security, and integrity of our Mobile Application and Services
  • to administer and protect our business and this Mobile Application including troubleshooting, data analysis and system testing
• Third Parties to Whom we Disclose PI
  • internet service providers
  • data analytics providers
  • government entities
  • operating systems and platforms
  • social networks
  • consumer data resellers
  • research partners
• Third Parties to Whom we Sell PI
  • We Do Not Sell This Information

Categories of PI Collected - Financial Data​ 

• Sources of PI: Directly from Consumer
• Purposes of Collecting or Sharing PI
  • to process payments for purchases made through the Mobile Application
• Third Parties to Whom we Disclose PI
  • internet service providers
  • data analytics providers
  • government entities
  • operating systems and platforms
  • social networks
  • consumer data resellers
  • research partners
• Third Parties to Whom we Sell PI
  • We Do Not Sell This Information

Categories of PI Collected - Geolocation Data​

• Sources of PI: Directly from Consumer
• Purposes of Collecting or Sharing PI
  • to install the Mobile Application and register you as a user
  • to process purchases and deliver Mobile Services including managing payments
  • to deliver content and advertisements to you
  • to make recommendations to you about goods or services which may interest you
  • to measure and analyze the effectiveness of the advertising we serve you
  • to monitor trends so we can improve the App
• Third Parties to Whom we Disclose PI
  • internet service providers
  • data analytics providers
  • government entities
  • operating systems and platforms
  • social networks
  • consumer data resellers
  • research partners
• Third Parties to Whom we Sell PI
  • We Do Not Sell This Information

Categories of PI Collected - Inferences

• Sources of PI: Directly from Consumer
• Purposes of Collecting or Sharing PI
  • to deliver content and advertisements to you
  • to make recommendations to you about goods or services which may interest you
  • to measure and analyze the effectiveness of the advertising we serve you
  • to monitor trends so we can improve the App
• Third Parties to Whom we Disclose PI
  • internet service providers
  • data analytics providers
  • government entities
  • operating systems and platforms
  • social networks
  • consumer data resellers
  • research partners
• Third Parties to Whom we Sell PI
  • We Do Not Sell This Information