PRIVACY POLICY

Torrington Forming Machinery Inc. (“Torrington”, “we”, or “us”) provides engineering designs services for metal forming application and manufacturing of metal forming machines such as swagers, vaills and push-pull (the “Service”). Torrington is committed to protect the personal information of its clients and users.

Purpose and Scope of the Policy

This Privacy Policy describes how we collect, use and disclose your personal information and how your personal information can be accessed, rectified, and deleted when necessary.

This policy does not extend to websites operated by third parties. Our Website and Service may contain content from third parties or links to other websites that are not controlled by us, including links to websites of Torrington’s Partners (as such term is defined in our General Terms and Conditions of Use and Sale). Furthermore, we do not control privacy policies of such websites or third parties. Torrington is therefore not liable for their privacy policies, procedures and practices. If you request a quote or purchase a product from a Partner, you are deemed to have given your consent to the terms and conditions of the Partner, as well as to the privacy policy of the Partner, and such terms and conditions and privacy policies shall be applicable for your information that is collected and used by the Partner. You acknowledge that Torrington cannot be held liable for any issues related to obligations of privacy of our Partners.

1. Personal Information Collected

1.1 Information that you provide to us

We ask for and collect your personal information in several ways, including, but not limited to when you obtain information on our products and services, contact us, purchase a Product, request design support, or post on our social media accounts. Our systems automatically process content and information you and others provide in order for us to optimize your customer experience.

You have the right to refuse to provide any personal data. You can also choose to withdraw any consent you may have given in relation to the processing of your personal data at any time, by contacting Torrington at the address indicated hereunder. Your rights are outlined at Section 8 of the present Privacy Policy. However, we may not be able to operate adequately the Website and Service if you do not provide certain data.

Depending on the circumstances, personal information may include the following:

• Account Information.

When you purchase equipment from Torrington, we require certain information such as your first name, last name, phone number and email address.

• Contact Form and Other Contact Information.

When you communicate with us for general inquiries through our contact form, via the live chat embedded in the Website, or by any other means of communication, we will collect and store records of these interactions, when appropriate, as well as the information that is contained in such communications, in order for us to respond appropriately.

• Payment and Shipping Information.

When you make a financial transaction with Torrington (i.e. make a purchase), we may require, in addition to your name and email, your billing and shipping address and telephone number in order to confirm and ship your order and comply with applicable law. As we do not accept credit cards and accept payments only via cheques or wire transfer, we do not store your (or your company’s) banking information.

1.2 Information provided on our Website

We do not collect information from users that visit our website, such as the information that can be collected with cookies or other analytics services. However, we may in the future. If we do, this Privacy Policy will be updated and will be made available on our website.

2. The Use and Sharing of Your Personal Information

We collect, store, and process information, including personal and non-personal information, in a variety of ways in operating our business, mainly:

• to allow us to provide our products and services.
• to analyze your usage trends and preferences.
• to improve our Website and Service.
• to detect, prevent and address security issues.
• to answer questions and information requests.
• to improve our inventory management.
• for the purposes of marketing, advertising or contests.
• for any other purposes authorized or required by law.

It is often necessary to use the services of third parties for the purposes of providing our own services to you. For example, third parties (including Partners) to whom we may share your personal information may assist us with the delivery of Products and customer service. We may need to share your information with them for these purposes. When we disclose your personal information to third parties, we take reasonable measures to ensure that the rules set forth in this Privacy Policy are complied with. These third parties will obtain only the personal information that is necessary for the purpose for which Torrington has employed them.

3. Storage and Processing

The information we collect is stored on our servers or the servers of our service providers, if applicable. Your information may be stored and processed in any location where Torrington or its subsidiaries, affiliates or service providers have facilities.

For users located in the European Economic Area (“EEA”), we may transfer personal data we have collected from you to servers, to Torrington’s authorized personnel or to other third parties located outside of the EEA. However, when transferring your information, Torrington will ensure that the country where they are transferred offers an adequate level of data protection. Such can either be achieved if an adequacy decision of the EU Commission according to Art. 45 of the General Data Protection Regulation (GDPR) exists or by providing appropriate safeguards according to Art. 46 GDPR. In the absence of an adequacy decision of the EU Commission or of appropriate safeguards we will inform you about the risk of such transfer and will transfer the data only with your consent. We may share information collected with other affiliates companies of Torrington in Canada. The European Commission has decided that Canada ensures an adequate level of protection regarding personal data.

4. Conservation Period

Torrington undertakes to retain your personal data only for the period required to accomplish the purposes for which they are processed, unless further recording is permitted or requested by applicable law e.g., in case of retention periods imposed by the applicable laws in force. We will delete data provided based on a consent according to Art. 6 para. 1 lit a) GDPR if the user withdraws the consent unless further recording is permitted or requested by applicable law.

5. Marketing

As part of our Services, Torrington may send you information about products and services of ours that we think you might like, as well as those of our Partners’.

If you have agreed to receive marketing, you may always opt out at a later date by contacting us at the email hereafter. You have the right at any times to stop Torrington from contacting you for marketing purposes.

6. Children and Our Services

Torrington services are not directed to children, and you may not use our services if you are under the age of 21. You must also be old enough to consent to the processing of your personal data in your country (in some countries we may allow your parent or guardian to do so on your behalf by contacting sales@torrington-machinery.com). We do not knowingly collect personal information from children under 21 or under the applicable age limit in your jurisdiction for giving consent to the processing of personal data (the “Age Limit”). If you are a parent of a child under the Age Limit and become aware that your child has provided personal information to Torrington, please contact us at sales@torrington-machinery.com and you may request exercise of your applicable access, rectification, cancellation, and/or objection rights.

7. Cookie Policy

We do not use cookies.

8. Your Rights

You may exercise any of the rights described in this section by sending an email to sales@torrington-machinery.com. Please note that we may ask you to verify your identity before taking further action on your request. Other rights may be granted to the user according to the applicable regulations on the protection of personal data.

If the request is related to data that is stored by any Partners, you may request the information from the Partner directly. In the case where your data is transferred to the Partner based on your demand in order to obtain a quote or Products, the relationship is between yourself and the Partner. Torrington does not have any control over the Partners and how they store data and cannot be held liable for those requests and the failure to meet them.

• Right to access –You have the right to request copies of your personal information held by us.
• Right to rectification –You have the right to request that Torrington correct any information you believe is inaccurate, you also have the right to request Torrington to complete information you believe is incomplete. To make sure that the personal information we maintain about you is accurate and up to date, please inform us immediately of any change in your personal information at sales@torrington-machinery.com.
• Right to erasure –You have the right to request that Torrington erase your personal data, under certain conditions. The right is not absolute and only applies in certain circumstances. For example, individuals have the right to have their information erased if:
  • The personal data is no longer necessary for the purpose which Torrington originally collected or processed it for;
  • The data has to be erased to comply with a legal obligation;
  • The data was collected from a child.
• Right to restrict processing –You have the right to request that Torrington restrict the processing of your personal data, under certain conditions.
• Right to object processing –You have the right to object to Torrington processing of your personal data, under certain conditions.
• Right to data portability –You have the right to request that Torrington transfer the data that we have collected to another organization, or directly to you, under certain conditions.

9. Security

We take reasonable precautions to protect the privacy, accuracy, and reliability of any information you provide to us and we use adequate technical and organizational safety measures in order to protect your information from loss, misuse, destruction, unauthorized access, copy or alteration. We have also implemented physical and organizational safeguards in accordance with which only employees who need the information to perform a specific job are granted access to personally identifiable information. However, while we endeavor to use security measures consistent with industry standards and reasonable efforts to safeguard the confidentiality of your information, we cannot guarantee that information provided to us will not be intercepted and remain secure. Therefore, you transmit any information to or from the Website and Service at your own risk.

10. Update

This Privacy Policy may be amended from time to time, due to the development of our Service, our Website or for legal matters. When modifying our Privacy Policy, we will make commercially reasonable efforts to advertise such modifications on our Website. Your continued use of the Website and the Service after any such change constitutes your acceptance of this Privacy Policy, as revised.

This Privacy Policy was last updated on October 12^th, 2023.

11. Contact Person

Any request to access, rectify, and delete your personal information and any question or comment you may have with respect to our Privacy Policy must be sent to the Privacy Officer by mail or email using the following contact information and we will respond within 30 days at the latest. In certain circumstances, Torrington may extend the delay for a maximum of 60 days if the requests are complex and numerous.

Torrington USA

102, Wolcott Road Wolcott

CT 06716

UNITED STATES

Torrington Canada

3705 Place Java,

Unit 160 Brossard, Qc

J4Y 0E4

CANADA

sales@torrington-machinery.com