PRIVACY

DISCLAIMER

Disclaimer — English

Pro Mach, Inc. Disclaimer

This page may contain other proprietary notices and copyright information, the terms of which must be observed and followed. INFORMATION ON THIS WEB SITE IS PROVIDED "AS IS" WITHOUT WARRANTY OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON-INFRINGEMENT. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF IMPLIED WARRANTIES, SO THE ABOVE EXCLUSION MAY NOT APPLY TO YOU.

Information on this web site may contain technical inaccuracies or typographical errors. Information may be changed or updated without notice. Pro Mach, Inc. may also make improvements and/or changes in the products and/or the programs described in this information at any time without notice.

Pro Mach, Inc. does not want to receive confidential or proprietary information from you through our web site. Please note that any information or material sent to Pro Mach, Inc. will be deemed NOT to be confidential. By sending Pro Mach, Inc. any information or material, you grant Pro Mach, Inc. an unrestricted, irrevocable license to use, reproduce, display, perform, modify, transmit and distribute those materials or information, and you also agree that Pro Mach, Inc. is free to use any ideas, concepts, know-how or techniques that you send us for any purpose.

Information Pro Mach, Inc. publishes on the World Wide Web may contain references or cross references to other products, programs and services that are not announced or available in your country. Such references do not imply that Pro Mach, Inc. intends to announce such products, programs or services in your country. Consult a Pro Mach, Inc. representative for information regarding the products, programs and services which may be available to you.

Pro Mach, Inc. makes no representations whatsoever about any other web site which you may access through this one. When you access a non-Pro Mach, Inc. web site, please understand that it is independent from Pro Mach, Inc. and that Pro Mach, Inc. has no control over the content on that web site. In addition, a link to a non-Pro Mach, Inc. web site does not mean that Pro Mach, Inc. endorses or accepts any responsibility for the content, or the use, of such web site. It is up to you to take precautions to ensure that whatever you select for your use is free of such items as viruses, worms, trojan horses and other items of a destructive nature.

IN NO EVENT WILL PRO MACH, INC. BE LIABLE TO ANY PARTY FOR ANY DIRECT, INDIRECT, SPECIAL OR OTHER CONSEQUENTIAL DAMAGES FOR ANY USE OF THIS WEBSITE, OR ON ANY OTHER HYPERLINKED WEBSITE, INCLUDING, WITHOUT LIMITATION, ANY LOST PROFITS, BUSINESS INTERRUPTION, LOSS OF PROGRAMS OR OTHER DATA ON YOUR INFORMATION HANDLING SYSTEM OR OTHERWISE, EVEN IF WE ARE EXPRESSLY ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

Furthermore, all information contained within this website is the property of Pro Mach, Inc. Copyright 2019.

PRIVACY POLICY

Pro Mach, Inc. Privacy Notice

Last Updated: September 21, 2026

Pro Mach, Inc., and its affiliates and subsidiaries (collectively, “ProMach,” “us,” or “we”) recognize the importance of data privacy and information security. This Privacy Notice explains how we may collect, use, and disclose (“process”) your personal information when you access and use our services that link to this Privacy Notice (including, our website as www.ProMachBuilt.com (the “website”), any sales, consulting services, marketing activities, events, social media platforms and other activities described in this Privacy Notice) (collectively, our “Services”). This Privacy Notice does not apply to your use of any third-party sites linked to this website.

We reserve the right to update this Privacy Notice periodically. Any changes will be posted on our website and will take effect immediately. Your continued access to the Services constitutes your acceptance of the changes. We encourage you to review this Notice periodically to stay informed about how we are protecting your data.

You can jump to particular topics by going to the headings below:

Defining Personal Data
Personal Data We Collect and How We Use It
Legal Basis for Processing Your Information
Sources Who Provide Us Personal Data
The Purposes for Personal Data Processing
Special Categories of Personal Data or Information on Children
Sharing Your Personal Data
ProMach Does Not Sell Personal Data
Cookies, Automated Tracking, and Data Analytics
Information Security
Third Party Websites
Data Retention
Transferring and Storing Personal Data
Use of Subprocessors
Your General Privacy Rights and Choices
Request Verification
Data Privacy Framework Compliance and International Data Transfers
Privacy Notice Updates
Questions / How to Contact Us
Supplemental Canada Privacy Rights Statement
Supplemental U.S. State Privacy Rights Statement
Supplemental European Privacy Rights Statement

Defining Personal Data
For purposes of this Privacy Notice, the term “Personal Data” means any information that relates to a natural person who can be identified, directly or indirectly, in particular by reference to an identifier and that is subject to, or afforded protection under, a data protection law, statute, or regulation. For example, Personal Data may include a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

An identifiable natural person, or "Data Subject," is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location information, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

Personal Data We Collect and How We Use It
ProMach collects and uses the following, or similar, types of Personal Data in the course of our routine business operations:

We have a legitimate interest in collecting user-generated content to enhance our services and improve user experience.

Context	Types of Information	Primary Purpose for Collection and Use of Information
Customer, Vendor, Suppliers, and Similar Business Contacts	ProMach may collect and process the following categories of Personal Data concerning our customers, vendors, suppliers, and similar business contacts: name and surname, contact details, job title, bank account details and financial information (including credit/income history), transaction history, business correspondence and communications, and background records.	We are executing on a contractual obligation in contacting our clients and communicating with them concerning normal business administration such as those related to sales orders and management, promotion and quotation submitting, warranty management, credit collection, compliance with legal requirements, tax and accounting purposes, and defense or promotion of our interests and claims.
Social Media Platforms	ProMach is engaged on social media platforms, and you may voluntarily choose to access these platforms, or otherwise follow our activities online. We will only collect the information that you voluntarily provide to us on these platforms, and such information is generally limited to names, online identifiers, email addresses, and other contact information. Please do not post any sensitive Personal Data, or other information that is considered private or confidential, on our publicly available social media platforms.	We use this information to update and maintain the page to provide you with content and features of our Services, as well as to improve our product outreach. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We have a legitimate interest and/or may obtain your consent to collect this information.
Consumer Inquiries and Communications	There may be other times that you provide ProMach information about yourself or others. For example, if you communicate with ProMach’s helpline or a sales representative, you may provide your Personal Data, such as contact data (e.g., name, address, telephone, email) and other Personal Data related to your communication (e.g., employer, consumer preferences, and interests).	We have a legitimate interest in collecting Personal Data that we think is reasonably necessary to your inquiry or that is otherwise related to your communication. We will collect and retain such information in accordance with the purposes you provided it, and with our legitimate business interests.
Cookies and First-Party Tracking	ProMach uses cookies and small data files. “Cookies” are small pieces of data that a website sends to a computer’s hard drive while a website is viewed.	We have a legitimate interest in making our website operate efficiently and in improving our marketing efforts and Services. See our Cookie Policy below.
Cookies and Third-Party Tracking	We participate in behavior-based advertising and the gathering of analytics. This means that a third-party uses technology (e.g., a cookie) to collect data about your use of our websites so that they can provide us with website and user analytics, as well as for the purposes of advertising products and services tailored to your interests on our website, or on other websites.	We have a legitimate interest in engaging in behavior-based advertising and capturing website analytics in improving our marketing efforts. For additional information on our use of cookies, please see our Cookie Policy. Additionally, you can manage your cookie consent preferences in the cookie consent manager via our website’s cookie banner.
Email Interconnectivity	If you receive an email from us, we may use certain tools to capture data related to when you open our message or click on any links or banners contained within.	We have a legitimate interest in understanding how you interact with our communications to improve relevance and engagement.
Employment-related information	If you apply for a job posting or become an employee of ProMach, we collect the information necessary to process your application or to retain you as an employee. This may include, among other things, your name, address, email address, I-9 information, Social Security Number or Personal Public Service Number, work history, resume, EEO information, veteran status, disability status, healthcare information, and bank account information. Providing this information is required for employment.	We use information about current employees to fulfil our contract of employment or the anticipation of a contract of employment with you. In some contexts, we are also required by law to collect information about our employees. We are executing on a contractual obligation in using your information to have efficient staffing and workforce operations.
Feedback and Support	We collect personal information from you contained in any inquiry you submit to us regarding our Services, such as completing our online forms, calling, or emailing for the purposes of general inquiries, support, and chat requests, or to report an issue. When you communicate with us through our live support chat or over the phone, your messages and calls may be recorded and analyzed for training, quality control, and for sales and marketing purposes. During such interactions, we will notify you of the recording via either voice prompt or script.	We have a legitimate interest in receiving and acting upon, your feedback, issues, or inquiries to improve support and service offerings.
Mailing List	When you sign up for one of our blogs, newsletter, or mailing lists, we collect contact information such as your name, email address and company affiliation.	We collect this information based on your consent, which you provide when you sign up for our blog, newsletter, mailing list, or webinar. You may withdraw your consent at any time by using the unsubscribe link in our communications or by contacting us directly.
Payment Information	We collect payment and billing information when you receive certain Services. For example, we ask you to designate a billing representative, including name and contact information, upon registration. You might also provide payment information, such as payment card details, which we collect via secure payment processing services.	We are executing on a contractual obligation in obtaining payments for certain Services.
Website Users	We use technology to monitor how you interact with our Services. ProMach collects Personal Data for the purpose of providing information or updates about ProMach or its products to individuals who visit the Website.	We have a legitimate interest in using Personal Data you submit (e.g., name, address, employer) for internal purposes including the administration of the Website and data analytics (as described in more detail below), for compliance with law or legal processes, to satisfy any of our contractual obligations, and to promote ProMach's legitimate interests, such as marketing and promotions.
Web Logs and Usage Data	Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings.	We have a legitimate interest in monitoring our networks and visitors to our Services. Among other things, it helps us to monitor performance and to understand which of our Services and features are the most popular.
Device Data	We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.	We have a legitimate interest in collecting device data to ensure the security, stability, and performance of our Services. This information helps us detect and prevent fraudulent activity, monitor system usage, optimize compatibility across different devices, and understand how users interact with our Services to improve functionality.
Location Data	We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.	We collect geolocation information based on our legitimate interest in enhancing service relevance, optimizing user experience, and ensuring compliance with applicable location-based legal requirements.
User-generated Content (UGC)	Reviews, comments, or questions you submit, including feedback provided through surveys, contact forms, social media channels, or direct communications with our team.	We have a legitimate interest in collecting user-generated content to enhance our services and improve user experience.

Legal Basis for Processing Your Information
If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
– Send users information about special offers and discounts on our products and services.
– Develop and display personalized and relevant advertising content for our users.
– Analyze how our Services are used so we can improve them to engage and retain users.
– Support our marketing activities.
– Diagnose problems and/or prevent fraudulent activities.
– Understand how our users use our products and services so we can improve user experience.
Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time by sending an email to [email protected].

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way.
For investigations and fraud detection and prevention.
For business transactions provided certain conditions are met.
If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim.
For identifying injured, ill, or deceased persons and communicating with next of kin.
If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse.
If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.
If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records.
If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced.
If the collection is solely for journalistic, artistic, or literary purposes.
If the information is publicly available and is specified by the regulations.

Sources Who Provide Us Personal Data
The Personal Data that we collect and process on our customers, vendors, suppliers, and similar business contacts is primarily derived directly from the individual or from his/her business employer. For website users, we collect Personal Data that you choose to enter into, or provide simply by accessing, our Website. ProMach may also receive Personal Data from third-parties who provide services to us, such as trade shows, or mailing or other distribution list services.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

The Purposes for Personal Data Processing
The categories of Personal Data we collect and purposes for which they are processed are as follows:

Complete a Transaction: You provide Personal Data to ProMach so we can provide you services and products or information pertaining to our services and products. Often, this transaction is governed by a binding contract and in order for ProMach to satisfy the terms and conditions of that contract, we need to collect, use, and retain, your Personal Data.
Contact Us: You may submit an inquiry or comment to ProMach along with your name and contact information (e.g., address, phone number, email address). ProMach uses this information for the purpose of replying to your inquiry.
Questionnaires and Surveys: ProMach may ask you to complete optional surveys and opinion polls for the purpose of obtaining your input relating to our present or planned products and their use. These surveys help ProMach to better meet your needs. In conducting these surveys, we may ask you to provide your name and contact information (e.g., address, phone number, email address).
Product Purchasing and Extended Warranty: If you purchase products from ProMach, we ask for your name and contact information (e.g., address, phone number, email address), shipping and billing information, and similar information to facilitate the order. You will also be asked to provide your credit card number and security code solely to our credit card processing vendor for purposes of payment. ProMach will not have access to, or store, your credit card information. You may also register certain ProMach products on our Website so we can provide information updates, accommodate your warranty, and for similar business purposes. Here, we will ask you for your name, contact details and product serial and code number of the products.
Locating a Distributor: If you use the Website to locate a nearby ProMach distributor, we will ask you for a location. Information about your location will be retained and analyzed for our own internal statistical business purposes.
Customer Updates: ProMach asks you to provide name and contact information (e.g., address, phone number, email address) so that updates to our products, safety data sheets, safety and other corporate information may be sent to you.
ProMach Account: If you create an account on a ProMach Website, we collect the account information that you submit, such as your name, email address, and log-in information. We also collect information regarding your orders through the account, such as your history of purchases.
Emails for Marketing Information: If you provide us with your email address and consent to receive marketing information, ProMach may send useful information about ProMach products, such as advertisements, videos, contests, rebates, and e-newsletters to your email address. You may unsubscribe from our marketing practices at any time.
Any Other Form of Contact Where You Submit Your Personal Data: You may provide us with your Personal Data in other ways, and we will handle any such Personal Data in accordance with this Privacy Notice.

Special Categories of Personal Data or Information on Children
ProMach does not ask for, and does not collect, special categories of Personal Data related to our customers, vendors, suppliers, or similar business contacts, or our Website users. Our website is not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Data from such individuals. We may ask you to confirm that you have not and will not provide such information to us or in postings on the Website when you register with, or otherwise access, it. If we become aware that such information has been provided or posted on the Website, we will delete it from our records.

If you become aware of any data we may have collected from children under the age of 16, please contact us at [email protected].

Sharing Your Personal Data
ProMach primarily uses Personal Data for our business and commercial purposes, and we do not sell or lease any Personal Data to any third-party for any purpose. ProMach may share or disclose your Personal Data within ProMach or to a third-party in the following circumstances:

Intra-Group: ProMach may share Personal Data about you within ProMach’s different offices and locations in order to provide you with services or to facilitate our own legitimate business interests.

Third-Party Service Providers: We will share your Personal Data with third-party service providers to help us provide services to you and process Personal Data on our behalf. For example, ProMach may retain a third-party to help us determine what marketing information you might find useful or provide cloud storage services. We may disclose your Personal Data to consultants, advisors, and attorneys in the process of obtaining tax, legal advice, or other professional services. We may use a third-party service provider to process credit card information you submit.

Required Disclosures: We may be required to share Personal Data with courts, tribunals, opposing or other related parties to the proceedings and their professional advisors, in response to a court order, subpoena, civil discovery request, other legal process, or as otherwise required by law.

Legal Compliance and Protections: We may disclose Personal Data to courts, tribunals, opposing or other related parties to the proceedings and their professional advisors, when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of ProMach, our users, or others. This may include exchanging Personal Data with other companies and organizations for fraud prevention and credit risk reduction.

Corporate Restructuring: We may share Personal Data in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of ProMach’s business or assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by ProMach or our Website users is among the assets transferred.

ProMach Does Not Sell Personal Data
We do not sell or rent Personal Data that we have collected or retain about you to any other third-party for any purpose. Accordingly, we do not offer individuals the ability to “opt-out” of the selling or renting of Personal Data because we do not engage in those practices.

Cookies, Automated Tracking, and Data Analytics
Please visit our Cookie Policy to learn how we use cookies, automated tracking tools, and data analytics, and your choices related to the programs.

Information Security
ProMach will take reasonable steps to protect the Personal Data it collects from loss, misuse, unauthorized access, disclosure, alteration, and destruction. ProMach has put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the Personal Data it collects from loss and misuse and unauthorized access, disclosure, alteration, or destruction. Access to your personal information is limited to authorized personnel who require the data to perform their duties and who are trained on the importance of maintaining its confidentiality. Our service providers and business partners are contractually obligated to protect personal information and are prohibited from using it for unauthorized purposes.

Please note that despite our reasonable efforts, no security measure is ever perfect or impenetrable, so we cannot guarantee the security of your Personal Data, and you provide it to us at your own risk.

Transmission of personal information to and from our Services is at your own risk. You should only access our Services through secure networks and environments. If we are legally required to inform you of a data breach, we may notify you electronically, in writing, or by telephone, in accordance with applicable laws.

Third Party Websites
This Website contains links to other third-party websites. ProMach does not control and is not responsible for the operation of such sites. This Privacy Notice does not apply to your use of any third-party sites linked to this website. Please refer to the privacy notices of those other sites if you have questions about their privacy practices.

Data Retention
ProMach retains your Personal Data collected as reasonably necessary to fulfill the purposes for which the Personal Data was collected and to comply with legal obligations or for the establishment, exercise, or defense of a legal claim.

The specific retention period depends on the nature of the personal information and the reasons for which it was collected For our customers, vendors, suppliers, and other business contacts, we retain your Personal Data for the duration needed to complete or facilitate our contract, agreement or engagement, and for a reasonable amount of time thereafter in accordance with our legitimate business needs and functions.

Transferring and Storing Personal Data
ProMach is a global company and primarily stores data within the United States of America. In addition, due to the global nature of our operations, some of the recipients of your Personal Data, including different ProMach offices and our service providers, may be located outside the country of your residence, including in countries outside the European Economic Area (EEA), and these countries may not provide the same level of data protection as in your jurisdiction.

Where required, we implement appropriate safeguards for international data transfers, such as industry best practices and compliance with applicable regulations. These measures ensure that personal data remains protected even when transferred outside these jurisdictions.

Use of Subprocessors
ProMach engages certain third-party service providers (“subprocessors”) to support the delivery of our Services. We maintain an up-to-date list of these subprocessors where we disclose the nature of the services provided. We may add or replace subprocessors as our business needs evolve and will update our subprocessor list accordingly. If you would like a copy of the list or have questions about our subprocessors, please contact us at [email protected].

In situations where we are required to provide notice under applicable law or a specific contractual obligation, we will notify users of such changes directly. By continuing to use our Services, you acknowledge and accept any changes made to our subprocessor list.

Your General Privacy Rights and Choices
Depending on your location, you may have the following rights regarding your personal information:

Right to Access: You have the right to access your personal data. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you.
Right to Rectification: You have the right to correct inaccurate or incomplete data.
Right to Erasure: You have the right to request the deletion of your data under certain conditions.
Right to Restrict Processing: You have the right to limit the use of your data in specific scenarios.
Right to Data Portability: You have the right to receive your data in a machine-readable format to enable transfer to another service provider.
Right to Object: You have the right to object to the processing of your data for specific purposes, such as direct marketing or automated decision-making. Verification of identity may be required to process requests.
Right Not to Be Subject to Automated Decision-Making: You have the right not to be subject to decisions based solely on automated processing, including profiling, which produces legal or similarly significant effects concerning you.
Withdrawing Your Consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by emailing us at [email protected], or by referring to the contact details at the bottom of this Notice.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting Out of Marketing and Promotional Communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us by emailing us at [email protected]. You will then be removed from the marketing lists. However, we may still communicate with you, for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Request Verification
To exercise any of the above rights, please email [email protected]. We will consider and act upon any request in accordance with applicable data protection laws.

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Data Privacy Framework Compliance and International Data Transfers
ProMach complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. ProMach has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. ProMach has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, ProMach commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact ProMach at: [email protected].

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, ProMach commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.

ProMach respects your rights to limit the use and disclosure of your personal data. In accordance with the Data Privacy Framework (DPF) Principles, we offer these options.

You have the right to choose (opt out) whether your personal information is:

Disclosed to third parties for purposes other than those described in this policy; or
Used for purposes materially different from those for which it was originally collected or subsequently authorized by you.

To exercise your opt-out rights, you may contact us via the contact information listed below.

The Federal Trade Commission has investigatory and enforcement power over ProMach’s compliance with the EU-U.S. DPF, the UK Extension to the EU- U.S. DPF and the Swiss-U.S. Data Privacy Framework.

Under certain conditions, individuals may invoke binding arbitration to resolve disputes regarding ProMach’s compliance with the Data Privacy Framework (DPF) Principles. ProMach is committed to arbitrating claims in accordance with Annex I of the DPF Principles, provided that the individual has delivered notice to ProMach and followed the conditions set forth in Annex I of Principles.

ProMach is committed to protecting personal information in accordance with the Data Privacy Framework (DPF) Principles. In cases where ProMach transfers personal information to a third party, ProMach remains responsible under the DPF Principles if the third party processes such information in a manner inconsistent with the DPF Principles, unless ProMach can demonstrate that it is not responsible for the event giving rise to the damage.

Privacy Notice Updates
We may update this Privacy Notice from time to time. If we change our Privacy Notice, we will post those changes on this page and update the Privacy Notice modification date listed below. If we materially change this Privacy Notice in a way that impacts how we use or disclose your Personal Data, we will notify you directly or by prominently posting a notice of such changes before making them and by stating the effective date of the changes. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

Modification Date
The Privacy Notice was last updated on September 21, 2026.

Questions/How to Contact Us
If you have any questions or concerns with regard to this Privacy Notice, or you wish to exercise any rights described herein, please contact us via email at [email protected], via toll-free telephone at +1 866-776-6224, via standard telephone at +1 513-831-8778, or via postal mail at:

Pro Mach, Inc.
Attn: Privacy Office
50 East Rivercenter Blvd., Suite 1800
Covington, KY 41011 U.S.

Supplemental Canada Privacy Rights Statement

Last Updated: September 21, 2026

Personal Data will be collected, stored, used, and/or processed by ProMach in accordance with this Privacy Notice and our obligations under the Personal Information Protection and Electronic Documents Act of Canada (“PIPEDA”) and other applicable Canadian provincial laws (collectively, “Canadian Privacy Laws”).

Pursuant to Canadian Privacy Laws, you have a right to request access to your Personal Data and to request that inaccurate Personal Data be corrected. If you have submitted Personal Data to us and would like to have access to it, or have it corrected, please contact us in accordance with the “Questions” section listed below. When requesting access to, or correction of, your Personal Data, we will require that you verify your request via email, and we may request specific information from you to enable us to confirm the authenticity of the request and your identity, and to enable us to search our records and databases. We may charge you reasonable a fee to access your Personal Data, provided that we advise you of any such fee in advance.

Your right to access Personal Data is not absolute, and we may not be able to provide access to access certain Personal Data in certain circumstances (e.g., if the information contains Personal Data of other persons or it is subject to legal privilege). In the event that we cannot provide you with access to, or the ability to correct, your Personal Data, we will use reasonable means to inform you of the reasons why, subject to any legal or regulatory restrictions.

To delete your name from our electronic contact lists (text or email), please contact us in accordance with the “Questions” section listed below. If you have concerns with our data processing practices, you may file a complaint with the Office of the Privacy Commissioner of Canada. For more information about the Office of the Privacy Commissioner of Canada, please access its website.

In the event you reside in Quebec, ProMach will collect, store, use, and process Personal Data in accordance with this Privacy Notice and ProMach’s obligations under An Act Respecting the Protection of Personal Information in the Private Sector (CQLR, c. P-39.1), as amended by the Act to Modernize Legislative Provisions Respecting the Protection of Personal Information (commonly known as "Law 25", under which you have the following rights:

Right to Access. You can ask ProMach for a copy of the Personal Data that we retain about you.
Right to Rectification/Correction Rights. You can ask ProMach to change incorrect or incomplete Personal Data, or to make changes yourself where you have access.
Right to Withdraw Consent. Where you have provided ProMach consent for a data processing activity, you may notify ProMach of your intent to withdraw your consent, and we will advise you of any consequence of withdrawing your consent at the time of your request. The withdrawal of consent will not affect the lawfulness of processing carried out prior to such withdrawal.
Right to Deletion. You can ask us to delete or stop processing your Personal Data, for example where the data is no longer necessary for the purposes of processing. ProMach may retain certain Personal Data where required or permitted by applicable law.
Right to Data Portability. You may request your Personal Data in a structured, commonly used technological format.
Right to Be Informed of Automated Decision-Making. If ProMach engages in automated decision-making, such processing must be clearly disclosed in this Privacy Notice.
Right to De-Indexation. You may request that hyperlinks associated with your name be de-indexed under certain conditions.

ProMach is a global corporation and operates in jurisdictions across the world. The Personal Data that ProMach collects, uses, and retains will be stored in the United States and may be stored and processed in other countries outside Quebec or Canada where we, or our service providers, maintain operations or infrastructure. Please be aware that your Personal Data may be retained in a country that may not provide the same level of protections as Canadian Data Protection Laws. The measures that we use to protect Personal Data are subject to the legal requirements of the jurisdictions to which we transfer Personal Data, including lawful requirements to disclose information to law enforcement and government agencies in those countries.

To the extent we transfer your Personal Data outside Quebec or Canada, we will do so using appropriate and suitable safeguards in compliance with applicable Data Protection Laws. If you wish to obtain a copy of our policies and practices regarding service providers outside of Quebec or Canada, or if you have any questions about the collection, use, disclosure, or storage of Personal Data by service providers outside of your country of residence, please contact us in accordance with the Questions section, below.

Questions/How to Contact Us
If you have any questions or concerns with regard to this Privacy Statement, or you wish to exercise any rights described herein, please contact us via email at [email protected], via toll-free telephone at +1 866-776-6224, via standard telephone at +1 513-831-8778, or via postal mail at:

Pro Mach, Inc.
Attn: Privacy Office
50 East Rivercenter Blvd., Suite 1800
Covington, KY 41011 U.S.

Supplemental U.S State Privacy Rights Statement

Last Updated: September 21, 2026

California Privacy Disclosures
The California Consumer Privacy Act (hereafter: ‘CCPA’) and the California Privacy Rights Act (hereafter: ‘CPRA’) provide California consumer residents who reside in California with specific rights regarding their Personal Information (which we also refer to as personal data). In addition to the above this section describes your CCPA/CPRA and other U.S privacy rights and explains how to exercise those rights.

The following does not apply to de-identified or aggregated personal data or data publicly available, which are not considered Personal Information since they do not identify any individual.

Your US Privacy Rights

“Right to Know”: You may have the right to request that we disclose to you what personal data of yours we collect, use, and/or disclose.
“Right to Delete”: You may have the right to request the deletion of your personal data collected or maintained by us. Depending on your Choices, certain offerings may be limited or unavailable. Upon verifying the validity of a deletion request, we will delete your personal data from our records and instruct any service providers or third parties to delete your information, when applicable.
“Right to Control Use”: You may have the right to control or limit the use of your personal data, including:
– Right to Opt-Out of Sales/Sharing/cross-context behavioral advertising.
– Right to Object to or Opt-Out of automated decision-making/profiling.
– Right to Opt-Out of processing/Limit Use of Sensitive personal data.
“Right of Access”: You may have the right to access your personal data, and to transmit it to another entity.
“Right of Correction”: You may have the right to request amendments to your personal data if it is inaccurate or outdated in any way. Upon verifying the validity of a verifiable correction request, we will use commercially reasonable efforts to correct your personal data as directed, considering the nature of the personal data and the purposes of maintaining your personal data.

Exercising Your Rights
We will not discriminate against you for exercising your rights.

You may make a verifiable request to exercise your privacy rights by contacting us via email at [email protected].

Please note that the above rights depend on a few factors, and we may refuse requests if there are exceptions under the applicable law.

If we cannot verify you (or your authority to act on behalf of another person) we have the right to deny the requests. While verifying your identity we generally avoid requesting additional information from you for verification purposes. If, however, we cannot verify your identity from the information already maintained by us, we may request additional information from you, which shall only be used to verify your identity while you are seeking to exercise your rights under applicable law, and for security or fraud-prevention purposes.

We delete any new Personal Information collected for verification as soon as practical after processing your request, except as required to comply with applicable legislation.

An “authorized agent” means a natural person, or a business entity registered with the Secretary of State that you have authorized to act on your behalf, conditioned you have:

Provided the authorized agent written permission to do so, and we could verify this; and
Verified your own identity directly with the business.

Subsection 1 does not apply when you have provided the authorized agent with a valid power of attorney.

We do our utmost to timely respond to a verifiable individual within the stipulated response times, and in a portable format unless it is excessive, repetitive, or materially unfounded. If we require more time, we will inform you of the reason thereof and the extension period in writing.

Pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), California residents are entitled to certain data privacy rights. For more information about the CCPA, please see https://oag.ca.gov/privacy/ccpa.

Opt-Out Rights / Do Not Sell My Personal Data. California residents have the right to opt out of the “sale” of their Personal Data. However, we do not sell your Personal Data to third parties for profit or monetary or other valuable consideration, and therefore we do not provide opt-out request processes for the sale of Personal Data (because we do not undertake such activities).

Opt-Out Rights / Do Not Share My Personal Data. California residents have the right to opt out of the “sharing” of their Personal Data. Unless otherwise set forth in a privacy or cookie policy on a specific ProMach website, we do not undertake these activities.

Children. The Application is not directed at, and should not be used by, minors under the age of sixteen (16), and therefore we do not knowingly sell or share the Personal Data of minors under sixteen (16) years of age.

Limit Use of Sensitive Personal Data. We do not use or disclose sensitive Personal Data for reasons other than those set forth in the CCPA, and therefore we do not provide individuals with the ability to limit how we use or disclose such sensitive Personal Data.

California “Shine the Light”. Under California Civil Code Section 1798.83 (“Shine the Light”), California residents have the right to request in writing from businesses with whom they have an established business relationship: (a) a list of the categories of Personal Data, as defined under Shine the Light, such as name, email address, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties; however, we do not disclose Personal Data to third parties for their direct marketing purposes.

Colorado Privacy Disclosures
Pursuant to the Colorado Privacy Act (CPA), Colorado residents are entitled to the following data privacy rights:

To confirm whether or not we are processing your Personal Data and access such Personal Data unless such confirmation or access would require us to reveal a trade secret.
To correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of your Personal Data.
To delete Personal Data provided by, or obtained about, you.
To obtain a copy of your Personal Data processed by us, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.

Submit a Privacy Request. To submit a CPA privacy request, please contact us in accordance with the “Questions” section below. If you would prefer, you may designate an authorized agent to submit a CPA privacy request on your behalf.

Privacy Request Verification Process. If you make any request related to your Personal Data, we will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, before granting you access to, erasing, or correcting, specific pieces or categories of Personal Data or otherwise responding to your request, we will, to the extent required or permitted by law, (i) require you (or your authorized agent) to verify your request via email, (ii) request certain contact information or government identifiers, and (iii) match at least two pieces of such Personal Data with data that we have previously collected from you. None of your privacy rights are absolute, and such rights are subject to exceptions and exemptions. For more information about the Colorado Privacy Act, please see https://coag.gov/resources/colorado-privacy-act/.

Privacy Requests Appeals Process: Complaints. If you would like to appeal a decision we have made with respect to your privacy request, please email us in accordance with the “Questions” section listed below, with the subject line “ATTN: Privacy Appeals,” and describe the nature of your request, and the reason for requesting an appellate review. You may file privacy complaints with the Colorado Attorney General at: https://coag.gov/file-complaint/.

Opt-Out Rights / The Sale of Personal Data. Colorado residents have the right to opt out of the “sale” of their Personal Data. However, we do not sell your Personal Data to third parties for monetary consideration or other valuable consideration, and therefore we do not provide opt-out request processes for the sale of Personal Data (because we do not undertake such activities).

Opt-Out Rights / Targeted Advertising. Colorado residents have the right to opt out of having their Personal Data used for targeted advertising purposes. Unless otherwise set forth in a privacy notice or cookie policy on a specific ProMach website, we do not undertake these activities.

Opt-Out Rights / Profiling. Colorado residents have the right to opt out of having their Personal Data used for profiling in furtherance of decisions that produce legal or similarly significant effects. However, we do not engage in such activities.

Connecticut Privacy Disclosures
Pursuant to the Connecticut Act Concerning Personal Data Privacy and Online Monitoring, also known as the Connecticut Data Privacy Act (CTDPA), Connecticut residents are entitled to the following data privacy rights:

To confirm whether or not we are processing your Personal Data and access such Personal Data unless such confirmation or access would require us to reveal a trade secret.
To correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of your Personal Data.
To delete Personal Data provided by, or obtained about, you.
To obtain a copy of your Personal Data processed by us, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means, provided we shall not be required to reveal any trade secret.

Submit a Privacy Request. To submit a CTDPA privacy request, please contact us in accordance with the “Questions” section below. If you would prefer, you may designate an authorized agent to submit a CTDPA privacy request on your behalf.

Privacy Request Verification Process. If you make any request related to your Personal Data, we will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, before granting you access to, erasing, or correcting, specific pieces or categories of Personal Data or otherwise responding to your request, we will, to the extent required or permitted by law, (i) require you (or your authorized agent) to verify your request via email, (ii) request certain contact information or government identifiers, and (iii) match at least two pieces of such Personal Data with data that we have previously collected from you. None of your privacy rights are absolute, and such rights are subject to exceptions and exemptions. For more information about the Connecticut Data Privacy Act, please see https://portal.ct.gov/AG/Sections/Privacy/The-Connecticut-Data-Privacy Act.

Privacy Requests Appeals Process: Complaints. If you would like to appeal a decision we have made with respect to your privacy request, please email us in accordance with the “Questions” section listed below, with the subject line “ATTN: Privacy Appeals,” and describe the nature of your request, and the reason for requesting an appellate review. You may file privacy complaints with the Connecticut Attorney General at: https://portal.ct.gov/DCP/Complaint-Center/Consumers---Complaint-Center.

Opt-Out Rights / The Sale of Personal Data. Connecticut residents have the right to opt out of the “sale” of their Personal Data. However, we do not sell your Personal Data to third parties for monetary consideration or other valuable consideration, and therefore we do not provide opt-out request processes for the sale of Personal Data (because we do not undertake such activities).

Opt-Out Rights / Targeted Advertising. Connecticut residents have the right to opt out of having their Personal Data used for targeted advertising purposes. Unless otherwise set forth in a privacy or cookie policy on a specific ProMach website, we do not undertake these activities.

Opt-Out Rights / Profiling. Connecticut residents have the right to opt out of having their Personal Data used for profiling in furtherance of decisions that produce legal or similarly significant effects. However, we do not engage in such activities.

Nevada Privacy Disclosures
We do not currently conduct “sales” of Personal Data for purposes of Nevada law. Notwithstanding the foregoing, Nevada residents may submit a request directing us to not sell Personal Data we maintain about them to third parties who will sell or license their information to others. If you would like to exercise this right, please contact us in accordance with the “Questions” section listed below.

Virginia Privacy Disclosures
Pursuant to the Virginia Consumer Data Protection Act, Virginia residents are entitled to certain data privacy rights:

To confirm whether or not ProMach is processing your Personal Data, and to access such Personal Data.
To request ProMach correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of the Personal Data.
To request ProMach delete your Personal Data.
To obtain a copy of the Personal Data that you previously provided us in a portable and, to the extent technically feasible, readily usable format that allows it to be transmitted to another entity without hindrance, where the processing is carried out by automated means.

Submit a Privacy Request. To submit a privacy request, you may contact us using the “Questions” section below.

Privacy Request Verification Process. If you make any request related to your Personal Data, we will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, before granting you access to, erasing, or correcting, specific pieces or categories of Personal Data or otherwise responding to your request, we will, to the extent required or permitted by law, (i) require you (or your authorized agent) to verify your request via email, (ii) request certain contact information or government identifiers, and (iii) match at least two pieces of such Personal Data with data that we have previously collected from you. None of Virginia’s privacy rights are absolute, and such rights are subject to exceptions and exemptions. For more information about the Virginia Consumer Data Protection Act, please see
https://lis.virginia.gov/cgi-bin/legp604.exe?211+ful+SB1392ES1.

Privacy Requests Appeals Process; Complaints. If you would like to appeal a decision we have made with respect to your privacy request, please email us in accordance with the “Questions” section listed below, with the subject line “ATTN: Privacy Appeals,” and describe the nature of your request, and the reason for requesting an appellate review. You may file privacy complaints with the Virginia Attorney General at https://www.oag.state.va.us/contact-us/contact-info.

Opt-Out Rights / The Sale of Personal Data. Virginia residents have the right to opt out of the “sale” of their Personal Data. However, we do not sell your Personal Data to third parties for monetary consideration, and therefore we do not provide opt-out request processes for the sale of Personal Data (because we do not undertake such activities).

Opt-Out Rights / Targeted Advertising. Virginia residents have the right to opt out from having their Personal Data used for cross-contextual/targeted advertising purposes. Unless otherwise set forth in a privacy or cookie policy on a specific ProMach website, we do not undertake these activities.

Opt-Out Rights / Profiling. Virginia residents have the right to opt out of having their Personal Data used for profiling in furtherance of decisions that produce legal or similarly significant effects. However, we do not engage in such activities.

Pro Mach, Inc.
Attn: Privacy Office
50 East Rivercenter Blvd., Suite 1800
Covington, KY 41011 U.S.

Supplemental European Privacy Rights Statement

Last Updated: September 21, 2026

If you are a resident of the European Economic Area, we rely on our legitimate interest, contractual relationship, and you consent as described in this Privacy Notice to process your personal information. Additionally, subject to any exemptions as provided by law, you may have certain rights regarding the personal information we maintain about you. We offer you certain choices about what personal information we collect from you, how we use that information, and how we communicate with you. If at any time you wish to exercise your rights, please reach out to us in accordance with the “Contact Us” section below.

According to the GDPR, UK GDPR, and FADP, you have the following rights:

Right of Access. If you ask us, we will confirm whether we are processing your personal information and, if so, provide you with a copy of that personal information along with certain other details. If you require additional copies, we may charge a reasonable fee.
Right to Rectification. If your personal information is inaccurate or incomplete, you may be entitled to ask that we correct or complete it.
Right to Erasure. You may ask us to erase your personal information in some circumstances, such as where we no longer need it, or you withdraw your consent (where applicable) and where there is no other legal basis for processing.
Right to Restrict Processing. You may ask us to restrict or ‘block’ the processing of your personal information in certain circumstances, such as if you contest its accuracy or object to us processing it.
Right to Data Portability. You may have the right to obtain your personal information from us that you consented to give us or that was provided to us as necessary in connection with our contract with you, and if the processing is carried out by automated means.
Right to Object. You may ask us at any time to stop processing your personal information, and we will do so: (a) if we are relying on a legitimate interest to process your personal information, unless we demonstrate compelling legitimate grounds for the processing or your data is needed to establish, exercise, or defend legal claims; or (b) we are processing your personal information for direct marketing and, in such case, we may keep minimum information about you (for example, in a suppression list) as necessary for our and your legitimate interest to ensure your opt out choices are respected in the future and to comply with data protection laws.
Right to Withdraw Consent. If we rely on your consent to process your personal information, you may have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.
Right to lodge a Complaint. If you have a concern about our privacy practices, including the way we handled your personal information, you can report it to the data protection authority that is authorized to hear those concerns.

Please note that the above rights are not absolute, and we may be entitled to refuse requests, wholly or partly, where exceptions under applicable law apply. We will not discriminate against you for exercising such rights.

Except as described in this Notice or provided for under applicable privacy laws, there is no charge to exercise your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee taking in account the administrative costs of providing the information or taking the action requested; or refuse to act on the request and notify you of the reason for refusing the request.

Complaints. In the event you have concerns about our data processing, you have the right to file a complaint with your data protection authority.

For data protection authorities in the EU, please see here: https://edpb.europa.eu/about-edpb/about-edpb/members_en.
For the data protection authority in Switzerland, please contact the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home.html).
For the data protection authority in the UK, please contact the Information Commissioner’s Office (www.ico.org.uk).

We would, however, appreciate the opportunity to deal with your concerns before you approach a data protection authority with a complaint, and invite you to contact us in the first instance.

Contact Us
If you are a resident in the European Economic Area, we are the "data controller" of your personal information. We have appointed P.E. Labellers S.p.A. to be our representative in the EEA. You can contact them directly regarding our processing of your information via email at [email protected].

If you are a resident in the United Kingdom, we are the "data controller" of your personal information. We have appointed Evolution Bottling and Packaging Solutions Limited to be our representative in the UK. You can contact them directly regarding our processing of your information via email at [email protected].

If you have any questions or concerns with regard to this Privacy Statement, or you wish to exercise any rights described herein, please contact us via email at [email protected], via toll-free telephone at +1 866-776-6224, via standard telephone at +1 513-831-8778, or via postal mail at:

Pro Mach, Inc.
Attn: Privacy Office
50 East Rivercenter Blvd., Suite 1800
Covington, KY 41011 U.S.

COOKIE POLICY

Cookie Policy — English

Pro Mach, Inc. Cookie Policy

Last Updated: February 24, 2026

This Cookie Policy explains how Pro Mach, Inc. and its affiliates and subsidiaries (“ProMach”, “we”, “us”) use cookies and similar technologies on the ProMach Website (https://www.promachbuilt.com/) and related sites. The ProMach Website (www.ProMachBuilt.com), as well as its affiliate and subsidiary websites, uses cookies, web beacons, and other techniques for legitimate business purposes, including for storing your preferences and navigation to, from, and on our Website. These techniques may also be used to help us count users that visit specific pages on our Website and other related web statistics. Most browsers allow users to activate settings to refuse some or all of these techniques. You should consult your browser provider’s instructions on privacy settings to determine the settings most appropriate for your preferences. If you disable or refuse cookies, please note that some parts of our Website may then be inaccessible or not function properly. Unless you have adjusted your browser settings to refuse cookies, our system may issue cookies when you direct your browser to our Website. Our use of strictly necessary cookies is based on our legitimate interests in providing a secure, functioning Website. For other categories of cookies, we rely on your consent where required by applicable law. In jurisdictions that require consent for non-essential cookies (for example, the EU/EEA, UK, and Quebec), we will only use non-essential cookies after you have provided consent through our cookie banner or other consent tools.

What is a Cookie and a Web Beacon?
Cookies are text files containing small amounts of information which are downloaded to your hard disk or to your browser’s memory when you visit our Website. Cookies are useful because they help arrange the content and layout of our Website and allow us to recognize those computers or other devices that have previously accessed our Website. Cookies do many different jobs, such as allowing our Website to remember your preference settings and helping us to enhance the usability and performance of our Website. Our Website also may contain electronic images known as web beacons – sometimes called single-pixel gifs – that allow us

to count the number of users who have visited specific pages. We may also include web beacons in promotional e-mail messages or newsletters in order to determine whether messages have been opened and acted upon. Cookies may be set by us (first-party cookies) or by third parties (third-party cookies) and may be stored only for the duration of your visit (session cookies) or for a longer period (persistent cookies) in accordance with our retention policy or until they are no longer needed, whichever is shorter. The type of cookie or similar technology that may be used on our Website or other materials can be identified in the following categories:

Strictly Necessary Cookies
These cookies are essential for basic functionalities of our Website, and they enable you to move around our Website and use their features, particularly in connection with information searches and order placement. Without these cookies, services you have asked for cannot be provided. These cookies do not gather information about you that could be used for marketing or other similar activities. Some examples of strictly necessary cookies include the following: a “shopping basket” cookie, which is used to remember the products that you wish to purchase when you add products to your shopping basket or proceed to checkout; a “login/authentication” cookie which allows and manages your login to our Website and identifies you after logging in for a single session; a “session” cookie which is required to carry out the data transmission and provide our Website to you; and, a “security” cookie that detects repeat failed login attempts or similar abuses of the Website. These types of cookies are regularly stored only as long as required for their purpose.
Performance Cookies
These cookies collect information about how you use our Website. For example, a performance cookie may identify which pages you access most often and if any error messages are transmitted from our Website. These cookies collect information that is used to improve how our Website work. Without these cookies, we cannot learn how our Website is performing and make relevant improvements that could better your browsing experience. See Google Analytics (below) for more information.
Functionality & Profile Cookies
These cookies allow our Website to store information that you provide, such as preferences, and to store technical information useful for your interactions with our Website. For instance, they remember your user ID and elements of your user profile. They also ensure that your experience using the Website is relevant to you. They may also be used to provide services you have asked for, such as watching a video or commenting on a blog (without being a cookie that is strictly necessary for our Website to function). These cookies will not be used to track your browsing activity on other websites (cross-site tracking). Without these cookies, a website cannot remember choices you have previously made or personalize your browsing experience. For example, we use a cookie to store your language preferences, which allows us to present you with product search results in the correct language, and we use a cookie to store your choice about the appearance of the cookie information banner that we display on our Website. This cookie will help us remember your choice about the appearance of the cookie information banner when you subsequently visit the same site where you made your choice about the banner and any other website with the same domain or the same top-level domain.
Advertising Cookies and Similar Technologies
These cookies or similar technologies may be used to deliver advertisements that are more relevant to you and your interests. They may also be used to limit the times you see an advertisement, as well as help to measure the effectiveness of the advertising campaign. These cookies may track your visits to other websites. Without these cookies or other technologies, online advertisements you encounter will be less relevant to you and your interests. Where enabled, we may permit third-party advertising partners to use cookies and other technologies to collect information about your browsing activities over time and across different websites when you use our Website, in accordance with your consent and applicable law. You may withdraw or change your consent for advertising cookies at any time via our cookie banner or preference center, where available, or by adjusting your browser settings.

How to Set Your Cookie Preferences?
You can usually modify your browser settings to decline cookies and you can withdraw your consent at any time to our use of cookies by modifying the settings of your browser to reject or disable cookies or by opting out of specific cookies through other opt-out options. If you choose to decline cookies altogether, you may not be able to fully experience the features of the Website that you visit.

You can manage your cookie preferences in several ways: (1) through our cookie banner or preference center, where available, you can choose which categories of

cookies you accept or reject, and you can change your choices at any time; use your browser settings to decline or delete cookies. Please refer to your browser’s help pages for more information on “Do Not Track” settings; using third-party consent management for third-party websites; however, if you choose to disable non-essential cookies, commonly referred to as labeled as functional or performance cookies, you may not be able to fully experience the features of the Website.

Where required by law (for example, in the EU/EEA, UK, and certain Canadian provinces), we will only use advertising cookies and similar technologies after you have provided your consent.

Our Use of Web Analytics
We use a tool called “Google Analytics” to collect information about your use of this Website. In particular, Google Analytics collects user information, such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics only to improve this Website. Google Analytics collects only the Internet Protocol (IP) address assigned to you on the date you visit this Website, rather than your name or other personally identifying information. We do not combine the information collected through the use of Google Analytics with any personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this Website, the cookie cannot be used by anyone but Google. In addition, Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this Website by disabling cookies on your browser. Google Analytics also uses electronic images known as web beacons (sometimes called single pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our Website is used. You can find additional information about add-ons here: tools.google.com/dlpage/gaoptout. Where personal data collected by Google Analytics is transferred to countries outside your jurisdiction (for example, to the United States), such transfers are carried out in accordance with applicable data-protection law, for example, by relying on standard contractual clauses or other lawful transfer mechanisms. To receive the most recent information on how

Google uses your Personal Data and other data, please visit google.com/policies/privacy/partners.

Our Privacy Policy
For more information about our data practices and your privacy rights, please visit our privacy policy at https://www.promachbuilt.com/privacy/.

DATA PROCESSING NOTICE

Data Processing Notice — English

Pro Mach, Inc. Data Processing Notice for Employees and New Hires

Last Updated: March 18, 2026

This Data Processing Notice applies to employees, workers, contractors, and job applicants of Pro Mach, Inc., related subsidiaries and affiliates (“ProMach”, “we”, “us”) and describes how we act as a controller of Personal Information in the employment and recruitment context.

Pro Mach is committed to protecting the privacy and security of your Personal Information. As part of the employee enrollment process and in connection with your employment with ProMach, you may be asked to provide, and ProMach will need to retain and process, certain Personal Information about you and other third-parties. We want you to know that we respect your privacy, and place great importance on maintaining the security of Personal Information that you provide to us. This Data Processing Notice (“Notice”) describes how ProMach collects, discloses, and uses your Personal Information, your responsibilities and obligations to ProMach and others, and the data privacy rights afforded to you under certain data protection laws, statutes, and regulations (“Data Protection Laws”). This Notice covers all employees, workers, contractors, and job applicants of ProMach and its affiliates. ProMach acts as the data controller responsible for the Personal Information described in this Notice.

Please read this Notice carefully.

This Notice does not form part of any contract of employment or other agreement to provide services, and nothing in this Notice shall be construed to (in any way) terminate, supersede, undermine, or otherwise modify the status of the employment or professional relationship between you and ProMach, pursuant to which ProMach may terminate the employment or professional relationship at any time, with or without cause, and with or without notice. This Notice imposes no independent obligation on ProMach to proceed with any business transaction or agreement, and does not create any employment or professional relationship between you and ProMach. ProMach may amend or update this Notice from time to time and we will, when necessary and appropriate, notify you of such amendments and updates.

Definitions
For purposes of this Notice, the following terms are defined as followed:

The term “Personal Information” means any information that can be used to distinguish or trace an individual’s identity, either alone or when combined with other personal or identifying information, that is linked or linkable to a specific individual, and that is subject to, or otherwise afforded protection under, any Data Protection Laws.

The term “Sensitive Personal Information” means any Personal Information that (i) poses a risk of financial, reputational, or other harm to an individual if compromised, or (ii) reveals race or ethnicity, political opinions, religious or philosophical beliefs, membership in a trade union, (iii) relates to the processing of genetic data, (iv) biometric data for the purpose of uniquely identifying a natural person, (v) data concerning an individual’s physical, metal, or emotional health, (vi) data concerning an individual’s sex life, gender identity, and sexual orientation, and (vii) an individual’s criminal records. For illustrative purposes only, the term Sensitive Personal Information may include, but is not limited to, the following: a national identification number (e.g., Social Security/Insurance Number), driver’s license number, bank account number, credit or debit card number, passport number and date of birth (when in combination with other data that can subject an individual to risk of identity theft), and user names and passwords for online accounts. Where we process Sensitive Personal Information (special category data under GDPR Article 9), we do so on the basis of applicable employment and social security law, your explicit consent where required, or as necessary for the establishment, exercise, or defense of legal claims.

Categories/Types of Personal Information
ProMach collects Personal Information to satisfy its legitimate business purposes and interests, or as may otherwise be required or permitted by law. The types and categories of Personal Information that ProMach collects and retains in the employment context is set forth in Annex A. This Personal Information may relate to a ProMach employee, or an employee’s family, partners, dependents, or other individuals that have a familial or other relationship with the employee. ProMach may collect and process Personal Information concerning third parties related to, or otherwise affiliated with, its employees (e.g., emergency contact information, beneficiary information, and employment references). We collect only the Personal Information that is reasonably necessary for the purposes described in this Notice, and we will clearly indicate where any collection is mandatory and where it is voluntary. For purposes of California law, the categories of Personal Information described in Annex A include “identifiers,” “professional or employment information,” “education information,” “financial information,” “sensory information,” “internet or network information,” “medical information,” “geolocation data,” and “inferences,” as those terms are defined under the California Consumer Privacy Act.

Online Monitoring
Please be aware that ProMach uses cookies and other tracking technologies within our internal “intranet” and external websites (each a “Site”) to monitor and log activities and communications on our systems and Sites where necessary for security, compliance, and business operations, in accordance with applicable law, to safeguard, improve, and analyze usage of the Site, and for the other purposes listed in this Notice. Such monitoring is carried out based on our legitimate interests in securing our systems, complying with legal obligations, and protecting our business and workforce. Where required by applicable law, monitoring is subject to your prior notification and, where legally required, your explicit acknowledgment. In the event you access a ProMach external-facing website, your Personal Information will also be collected and processed in accordance with the privacy policy posted or otherwise linked to such a website. Monitoring is conducted in a proportionate manner and limited to what is reasonably necessary for these purposes.

Sources of Personal Information Collection
Most often, ProMach collects Personal Information directly from the applicable employee (electronically, in writing, or verbally). For example, ProMach requires employees to complete background information when they begin employment or enter into a contractual relationship with ProMach. ProMach may receive Personal Information about an employee (indirectly) from third parties within ProMach, such as a supervisor or colleague. ProMach may also receive Personal Information about an employee from third parties who provide services to ProMach, such as companies that provide benefits, payroll, corporate training or other services. For example, if an employee has been hired through a third-party staffing or recruiting firm, ProMach will receive Personal Information on his or her experience and qualifications. In addition, Personal Information on an employee’s use of the Internet, email, or other ProMach systems and applications is automatically generated. Where permitted or otherwise authorized by law, we will collect and retain Personal Information about employees as part of the background check process.

Purposes of Data Processing
ProMach collects and uses Personal Information about, or related to, its employees and relevant third parties for a broad range of routine legal, business, and human resource (“HR”) management purposes. See Annex B for examples of our use of your Personal Information. ProMach may have multiple reasons to process Personal Information, and the identification of one such reason does not preclude the applicability of any other. ProMach may, from time to time, provide additional information with respect to the means and purposes for collecting and using Personal Information. We process Personal Information as necessary for the performance of your employment or services contract (Article 6(1)(b) GDPR), to comply with our legal obligations such as employment, social security, tax, and health and safety laws (Article 6(1)(c) GDPR), and for our legitimate interests in managing our business and workforce, except where such interests are overridden by your rights (Article 6(1)(f) GDPR). Where we rely on your consent for specific processing activities (such as optional diversity surveys or certain benefits programs), we will clearly explain this, and you may withdraw consent at any time without affecting the lawfulness of prior processing.

In the event that our data processing will occur for reasons outside of those detailed in this Notice, additional notification of that processing will, if required by Data Protection Law, be provided. ProMach does not undertake any decision-making concerning its employment activities solely by automated means and without any human involvement.

Disclosure of Personal Information
When appropriate to support ProMach’s management and administration, or to comply with legal or regulatory obligations, ProMach may disclose, transfer, or otherwise share Personal Information with authorized third parties, such as any ProMach affiliate or subsidiary, or third-party vendors and service providers. For example, as part of our data sharing practices, we may provide Personal Information to regulatory and law enforcement authorities, or ProMach’s outside legal counsel, auditors, and other professional advisors when required by law or to further our business interests. We may also disclose your Personal Information to third-party service providers, such as the payroll company we use to facilitate payment obligations, the administrator of our group pension plan, brokers who we use to obtain insurance for your benefit, our private medical care provider, our private dental care provider, providers of online training services, external training providers, employment screening and verification support services, and other types of service providers (e.g., our cloud storage providers). ProMach may also share your Personal Information with potential acquirers or investors of ProMach, or the business area in which you work. We may share your Personal Information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of ProMach’s practice or assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by ProMach, in any form or format, is among the assets transferred.

Data Retention
The Personal Information you provide to ProMach may be stored electronically, and/or in hard copy. ProMach implements appropriate technical and organizational measures, commensurate with the nature, scope, context, purposes, and risks of processing, associated costs, and business resources, during its data processing activities, including protections to mitigate the risk of unauthorized or unlawful processing and accidental loss, destruction, or damage. These measures include password protections for online information systems, anonymization of data in certain circumstances, and restricted access to Personal Information, such as when Personal Information is processed by ProMach’s Human Resources Department. ProMach employees and authorized third-parties that have access to your Personal Information are bound by confidentiality obligations, and are required to treat your Personal Information in accordance with applicable legal requirements. ProMach will only retain your Personal Information so long as it is necessary to perform a function for which it was originally collected, which may include the management and administration of pre-, current, and post-employment relationships. We maintain internal retention schedules that define how long different categories of records are kept based on legal, regulatory, and business requirements. Retention periods vary by jurisdiction and data category. After the applicable retention period expires, Personal Information is securely deleted or anonymized.

If you are offered, and accept, an employment position with ProMach, we will retain the information you provided during the employment application and recruitment process in accordance with our employee records schedule, to which you will have access upon your start of employment. If you are not provided, or accept, an employment offer, ProMach will retain your Personal Information in accordance with our internal retention management process, which is designed to ensure that records no longer necessary for legal, regulatory, administrative or business purposes may be disposed of in a timely manner.

International Data Transfers
ProMach is a global corporation and located in jurisdictions across the world. The Personal Information that ProMach collects, uses, and retains will be stored in United States and may be stored in other countries in which we, or our service providers, have locations. Please be aware that your Personal Information may be retained in a country that does not provide the same level of protections as the laws in your country of residence or location. The measures that we use to protect Personal Information are subject to the legal requirements of the jurisdictions to which we transfer Personal Information, including lawful requirements to disclose information to law enforcement and government agencies in those countries. In addition, ProMach does not participate in the United States-European Union Data Protection Framework (DPF). To the extent we transfer your Personal Information outside the jurisdiction in which you reside, we will do so using appropriate safeguards in compliance with applicable Data Protection Laws, such as Standard Contractual Clauses (SCCs) supplemented by Transfer Impact Assessments (TIAs) where required, adequacy decisions, or other lawful transfer mechanisms. These safeguards include contractual protections and appropriate technical and organizational measures designed to protect your Personal Information during and after transfer. If you wish to access written information about our policies and practices regarding service providers outside of your country of residence, or if you have any questions about the collection, use, disclosure, or storage of Personal Information by service providers outside of your country of residence, please contact us in accordance with the Contact Information section below.

Your Data Rights and Responsibilities
Depending on the jurisdiction in which you reside, or where ProMach conducts its data processing activities, you may be afforded additional rights or privileges under applicable Data Protection Laws. Schedule 1 sets forth those additional data protection rights or privileges.

To the extent your provide ProMach with Personal Information, including the Personal Information on a third-party, you must (i) ensure, on a continuing basis, the accuracy, reliability, and relevancy of such Personal Information, (ii) only collect and provide to ProMach such Personal Information in accordance with all applicable Data Protection Laws, including when applicable, in accordance with all data processing notice and consent requirements, and (iii) inform the third-parties whose Personal Information you provide to ProMach, or who the third-party directly provides ProMach to facilitate or engage in a personal, non-business, related function with you, that the ProMach will collect and retain such Personal Information in accordance with our website privacy policy, which may be amended from time to time. Without limiting the foregoing, you must, promptly and without delay, notify ProMach (preferably in writing) of any amendments that need to be made to your Personal Information to ensure its accuracy, reliability, and relevancy. If you choose not to provide us with the Personal Information identified herein, then ProMach may not be able to satisfy our own contractual or legal obligations, and, in such circumstances, continued employment with ProMach may not be permissible. You acknowledge and agree that ProMach shall not be held liable for any consequence directly resulting from these circumstances. For general information about ProMach’s consumer privacy practices, please visit https://www.promachbuilt.com/privacy/. ProMach also takes reasonable steps to ensure that the Personal Information in our systems is accurate, complete, and up to date, for example by periodically asking you to review and confirm your details. Depending on the jurisdiction in which you reside, you may have additional rights under applicable Data Protection Laws. For Canadian employees and job applicants, you may have the right to file a complaint with the Office of the Privacy Commissioner of Canada or the applicable provincial commissioner, as described in Schedule 1. For California employees and job applicants, the specific rights that apply to Personal Information we collect in the employment and recruitment context are set forth in the California section of Schedule 1.

Data Safeguards
ProMach has implemented appropriate physical, technical, and organizational security measures designed to secure your Personal Information against accidental loss and unauthorized access, use, alteration, or disclosure. All employees who have access to Personal Information shall collect and use such data in accordance with all applicable Data Protection Laws and ProMach policies and procedures, including this Notice. Any employee who has access to Sensitive Personal Information shall, at any and all times, (i) protect its confidentiality, integrity, and availability, (ii) protect it from any unlawful or unauthorized access, use, or disclosure, and (iii) limit its access and use to the minimum extent necessary and required to perform an authorized business or legal function. Without limiting the foregoing, all ProMach employees who collect, use, or access Sensitive Personal Information are hereby prohibited from the following: publicly displaying or posting the Sensitive Personal Information; requiring an individual to transmit the Sensitive Personal Information over the Internet without a secure connection or encryption; and selling or using the Sensitive Personal Information for any purpose unrelated to ProMach’s business operations. Any employee who reasonably suspects a breach of the foregoing must immediately notify his/her supervisor. In the event of a data breach affecting your Personal Information that is likely to result in a risk to your rights, ProMach will notify the relevant supervisory authority within 72 hours where required by law, and will notify affected individuals without undue delay where the breach is likely to result in a high risk to their rights and freedoms.

Website Privacy Statement
For information regarding ProMach’s privacy practices concerning customers, consumers, and business-to-business contacts, please see https://www.promachbuilt.com/disclaimer-privacy-policy/.

Contact Information
When you submit a privacy request, we may ask for information to verify your identity (and, where applicable, the identity and authority of any authorized agent) before responding, as permitted by law. We aim to respond to all requests within the timeframes required by applicable Data Protection Laws.

If you have questions, concerns, or comments related to how ProMach processes your Personal Information, including whether you would like to exercise the rights and privileges described herein, please email our Data Privacy Champion at [email protected].

In the alternative, you can write to us at the following:
Pro Mach, Inc.
ATTN: Privacy Request
50 East Rivercenter Blvd., Suite 1800
Covington, KY 41011 U.S.

ANNEX A

The Personal Information ProMach Collects and Retains

General Categories of Personal Information	Description
Personal Identifiers and Contact Data	Basic data that is used to identify or contact an individual (e.g., name, title, email address, telephone number, physical address, and date of birth).
Sensitive Government Identifiers	Information used to validate your identify, such as a social security number, driver’s license number, state identification card, and passport number.
Personnel File Data	Data describing an individual’s current employment-related functions, responsibilities and job-related details (e.g., current position, title, salary plan, pay grade or level, unit/department location, supervisor and subordinates, identification number assigned by HR, employment contract or another contractual arrangement in place, work history with ProMach, start and termination dates, length of service, promotions, compliance-related behavior, criminal records, violations of ProMach policies and procedures, disciplinary matters, hotline submissions, internal complaints, or claims, investigations, results and remediation steps and actions).
Payroll and Benefits Data	Information ProMach requires to process payroll, health, wellness, and other benefits (e.g., salary and wage, banking details, bonus, benefits including for dependents, stock incentives, overtime, salary reviews, working time records, tax and social security details, including pension administration).
Administrative Data	Data related to the administration of ProMach’s HR and administrative functions (e.g., email and user accounts, user rights, IT and collaboration tools, helpdesk information, organizational details, including attendance, document repositories and portals, charging codes, email, telephone, Internet and resource usage information, log files, IP addresses, traffic data and content of communications, photographs and visual images, business travel and expenses).
Immigration and Work Eligibility Data	Data and documentation required under immigration laws (e.g., citizenship, passport data, visa data, details of residency or work permit, I-9 data).
Health Data	Information about your health, including any medical condition, health and sickness-related data (e.g., sick leave requests), and ability to perform work-related functions and activities.
Professional Experience	Data included in a personal resume (e.g., curriculum vitae, former employment and employer, awards and recognitions, language proficiency, memberships and associations, references, publications, volunteer work, career goals, and professional skills).
Education Data	Information pertaining to an individual’s education (e.g., level of education completed, schools and universities attended, degrees and certifications obtained, dates of graduation or completion, grades and grade point average, transcripts, attendance records, courses taken, sanctions or other disciplinary record, awards and honors).
Video Communications, Audio, and Images	Video conferencing events information (e.g., voice and/or video recordings, in the course of training events, meetings, conferences and other events that ProMach may organize), telephone and similar voice recordings, and employee photos for identification badges, system profiles, and similar purposes.
Career Development and Performance Data	Data related to an individual’s performance and goals with ProMach (e.g., performance appraisals, career goals and development, action planning, career plans, degree of performance, appraisal and assessment records, training data).
Feedback	Your feedback about ProMach’s work environment, products, goods and/or services, which include data gathered from questionnaires which you voluntarily complete.
Correspondence Data	Records and copies of an individual’s correspondence with ProMach.
Technical Data and Communications Content	Electronic communications information, such as email, computer, internet, telephone, and mobile device usage; IP address; log-in information; and other data describing an individual’s use of ProMach resources and content associated with such usage (e.g., usage and content retained in or transmitted on a ProMach’s laptop, desktop, cellphone, email account, or telecommunications systems).
Geolocation; Badge Swipes	Data about your location recorded by computing, information technology, and electronic card access systems, networks, and devices. We also record and retain information related to where and when you “swipe” your employee badge in connection with a ProMach entrance or exit point, or to access ProMach equipment, assets, or resources.
Stock Ownership	When relevant, we collect details of any shares, directorships, awards or any other equity or share rights you may have in ProMach (whether awarded, cancelled, purchased, exercised, vested, unvested or outstanding).
Characteristics of Protected Classifications Under State or Federal Law	ProMach collects information that is considered protected under state or federal law such as age, national origin, citizenship, marital status, information related to medical conditions (including physical or mental disability information) when relevant, gender, pregnancy or childbirth and related medical conditions, veteran or military status, etc.
Equality and Diversity Information.	Information about your race, ethnicity, sexual orientation, and veteran and disability status.
Inferences	ProMach may, in limited circumstances, draw inferences from the (non-sensitive) Personal Information identified in this Annex A (e.g., the level of performance of a specific employee during a specific period of time) to better assess employee performance and for similar business purposes.

ANNEX B

Examples of Our Use of Your Personal Information

Making a decision about your recruitment or appointment and checking that you are legally entitled to work in the applicable jurisdiction.

Determining the terms on which you work for us, and administering the employment agreement or contract we have entered into with you, which includes paying you and, if you are an employee, deducting tax and social security contributions, providing benefits to you such as private medical coverage, dental coverage, childcare vouchers, and liaising with benefits and pension providers, where applicable.

Addressing legal disputes and work accidents that involve you, and gathering evidence for possible grievance or disciplinary hearings.

Making decisions about your continued employment or engagement with ProMach, and facilitating termination arrangements.
Managing employee career development, performance (e.g., performance reviews, managing performance, and determining performance requirements), assessing qualifications for a particular job or task, including compensation and benefits; benchmarking, administering payroll and benefit arrangements (including long-term incentive awards and bonus administration); obtaining management and employee satisfaction feedback; managing absences (e.g. sickness, parental leave and other family-related and flexible-work policies); overseeing health and safety as well as travel and expenses; reporting on general headcount; planning for emergency response and disaster recovery; ensuring compliance with ProMach’s Code of Conduct.

Executing ProMach’s day-to-day activities, allowing employees to work together and collaborate, providing services to customers, and ensuring business continuity.

Complying with health and safety obligations, including taking the following actions: helping to maintain the health and safety of ProMach’s employees and others in the workforce; implementing and maintaining emergency and/or exposure management programs concerning hazardous substances; assessing the working capacity of an individual; reintegrating individuals into the workforce (including checking and monitoring fit-for-work status); providing support and care for individuals entitled to benefits in connection with illness or (partial or full) work incapacity; detecting and responding to an incident; managing the employee health file; providing employees with social benefits that depend on the state of an individual’s health (e.g., parental leave, sick leave); maintaining proper documentation of accidents and first-aid health care in case of incidents; and responding to pandemics, epidemics, and other health emergencies.

Ensuring compliance with legal or fiscal obligations and ProMach policies (e.g., anti-money laundering, bribery, fraud and corruption), which includes undertaking auditing, investigations, and background checks on employees.

Security purposes (such as detecting security incidents, protecting against unauthorized, malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity) and ensuring network and information security, including preventing unauthorized access to our communication systems and preventing malicious software distribution. ProMach monitors our information security environment, including email communications transmitted or stored thereon, and employees should have no expectation of privacy with respect to any communications transmitted or stored on ProMach’s information technology, networks, or assets.

To display employees’ business contact details (e.g., names or photographs) on ProMach’s website or on other social media websites and in other means of communication, such as press releases, newsletters or marketing materials.

To conduct data analytics studies to review and better understand employee retention and attrition rates, identification of key skills, review of performance indicators, identify employee patent or advances filed, understand impact and use of project charging codes, and build generic, employee-related profiles to be used for ProMach’s analytical and business development purposes, including but not limited to, reviewing trends, identification of skills for certain positions/roles, and establishing and understanding performance review criteria.

To carry out diversity and equal-opportunity monitoring and reporting, thereby enabling ProMach to support employees in expressing their individual diversity, ensuring that our workforce is positioned to meet the diverse needs of our consumers, ensuring that talent systems and practices support the full development and advancement of all employees, and generating aggregated level reports and analytics for ProMach so that we have a better understanding of our diversity in support of inclusive cultures.

SCHEDULE 1

JURISDICTION SPECIFIC DATA PROTECTION LAWS

If your Personal Information is subject to, or afforded protection under, any of the following Data Protection Laws, then you are entitled to receive notice of the following:

CANADA (INCLUDING QUEBEC)
ProMach will collect, store, use, and process Personal Information in accordance with this Notice and ProMach’s obligations under applicable data protection laws in Canada, including the Act to Modernize Legislative Provisions respecting the Protection of Personal Information (collectively, “Canadian Data Protection Law”). Pursuant to Canadian Data Protection Law, you have the following rights and privileges:

Access Rights. You can ask ProMach for a copy of the Personal Information that we retain about you.
Rectification/Correction Rights. You can ask ProMach to change incorrect or incomplete data, or to make changes yourself where you have access.
Withdraw Consent. Where you have furnished to ProMach your consent for a data processing activity, you may notify ProMach of your intent to withdrawal you consent, and we will advise you of any consequence of withdrawing your consent at the time of your request.
Deletion Rights. You can ask us to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing.

ProMach is a global corporation and located in jurisdictions across the world. The Personal Information that ProMach collects, uses, and retains will be stored in United States and may be stored in other countries outside Quebec or Canada where we, or our service providers, have locations. Please be aware that your Personal Information may be retained in a country that does not provide the same level of protections as Canadian Data Protection Laws. The measures that we use to protect Personal Information are subject to the legal requirements of the jurisdictions to which we transfer Personal Information, including lawful requirements to disclose information to law enforcement and government agencies in those countries. To the extent we transfer your Personal Information outside Quebec or Canada, we will do so using appropriate and suitable safeguards, including contractual protections and technical/organizational measures, in compliance with applicable Data Protection Laws. If you wish to access written information about our policies and practices regarding service providers outside of Quebec or Canada, or if you have any questions about the collection, use, disclosure, or storage of Personal Information by service providers outside of your country of residence, please contact us in accordance with the Contact Information section, above.

Surveillance. ProMach engages in “electronic monitoring” of employee devices and use of ProMach systems, networks, and other devices, and this Notice, and other applicable ProMach policies, serves as notice of the same. The term “electronic monitoring” means the “collection of information on an employer’s premises concerning employees’ activities or communications by any means other than direct observation, including the use of a computer, telephone, wire, radio, camera, electromagnetic, photoelectronic or photo-optical systems.

EUROPEAN UNION (EU), SWITZERLAND, AND UNITED KINGDOM (UK)
If you are located in the EU, Switzerland, or the UK, you have the following data protection rights:

Right to Know. The right to know about what Personal Information ProMach collects and processes about you, including the types and categories of Personal Information we collect and process, the sources of such Personal Information, our retention criteria, with whom we share your Personal Information, cross-border data transfers, and how to file complaints and inquiries. Such information is set forth in this Privacy Policy.
Automated Decision Making. ProMach does not engage in any activity that subjects our customers, Site users, survey participants, or others to a decision based solely on automated processing, including profiling, which produces legal effects, or similarly significant results, impacting them.
Access Rights. You may ask us whether we process any of your Personal Information and, if so, receive access to such Personal Information . When complying with an access request, we will also provide you with additional information, such as the purposes of the processing, the categories of Personal Information concerned as well as any other information necessary for you to exercise the essence of this right.
Rectification. You have the right to have your Personal Information corrected/rectified in case of inaccuracy or incompleteness. Upon request, we will correct inaccurate Personal Information about you and, taking into account the purposes of the processing, update any incomplete Personal Information, which may include the provision of a supplementary statement.
Erasure. You have the right to have your Personal Information erased, which means the deletion of your Personal Information by us and, where possible, any other controller to whom your data has previously been disclosed. However, your right to erasure is subject to statutory limits and prerequisites (e.g., where your Personal Information is no longer necessary in relation to the initial purposes for which it was processed, your Personal Information was processed unlawfully).
Restriction of Processing. You have the right to obtain the restriction of the processing of your Personal Information, which means that we suspend the processing of your Personal Information for a certain period of time. Circumstances which may give rise to this right include situations where the accuracy of your Personal Information is contested, but we need time to verify the inaccuracy (if any) of your Personal Information.
Data Portability. You have the right to request us to provide you with your Personal Information in a structured, commonly used and machine-readable format and to have such data transmitted directly to another controller, where technically feasible.
Right to Object. You have the right to object to the processing of your Personal Information, which means you may request us to no longer process your Personal Information. This only applies in case the “legitimate interests” ground (including profiling) constitutes the legal basis for processing (see below “Legal Basis for Processing”). However, at any time (and free of charge) you can object to having your Personal Information processed for direct marketing purposes.
Withdrawing Consent. You also may withdraw your consent at any time if we are solely relying on your consent for the processing of your Personal Information. However, this will not impact our legal basis to process such Personal Information prior to the withdrawal of your consent.

To exercise any of these data privacy rights, please complete our privacy webform or contact us, or have your designated agent contact us, in accordance with the “Contact Us” section listed below. To the extent permitted by law, we will need to verify your identity (or the identity of your agent) and ensure the authenticity of your request.

Legal Basis for Processing
We process your Personal Information in accordance with the legal bases set forth in law. For example, our processing of Personal Information (as described herein) is justified based on the following legal grounds:

Legitimate Interests. Processing is necessary for our legitimate interests as set out herein (e.g., monitoring your use of ProMach technology and your compliance with the terms and conditions governing the same, compliance with foreign laws).
Contract Undertaking. Processing is necessary for the performance of a contract to which you are a party (e.g., your employment contract).
Legal Compliance. Processing is required to comply with a legal or statutory obligation (e.g., tax disclosures).

Complaints
In the event you have concerns about our data processing, you have the right to file a complaint with your data protection authority.

For data protection authorities in the EU, please see here: https://edpb.europa.eu/about-edpb/about-edpb/members_en.
For the data protection authority in Switzerland, please contact the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home.html).

For the data protection authority in the UK, please contact the Information Commissioner’s Office (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach a data protection authority with a complaint, and invite you to contact us in the first instance.

THE UNITED STATES
Without limiting any provisions in this Employee Data Privacy Notice, including this Annex C, this Employee Data Privacy Notice, either alone or in conjunction with other ProMach policies and procedures, satisfies ProMach’s legal obligation to draft and/or provide notice with regard to how ProMach collects, uses, safeguards, disposes, or otherwise processes social security numbers or similar data afforded protection under U.S. state law, including Conn. Gen. Stat. Ann. § 42-471; 201 Mass. Code Regs. §§ 17.01 – 17.04; Mich. CL § 445.84; New Mex. SA 1978, §§ 57-12b-1 – 57-12b-4; N.Y. Gen. Bus. Law § 399-ddd; and Tex. Bus. & Com. Code Ann. § 501.0.52.

California
Pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), California residents are entitled to certain data privacy rights:

Right to Know (Specific Pieces of Personal Information). You have the right to know the specific pieces of your Personal Information that we have collected about you.
Right to Know (Categories of Personal Information). You have the right to know (i) the categories of Personal Information we have collected from you; (ii) the categories of sources from which the Personal Information is collected; (iii) the categories of your Personal Information we have sold or disclosed for a business purpose; (iv) the categories of third parties to whom your Personal Information was sold or disclosed for a business purpose; and (v) the business or commercial purpose for collecting or selling your Personal Information.
Right to Delete. You have the right to request that we delete your Personal Information that we have collected and retain.
Right to Correct. You have the right to request that we correct inaccurate Personal Information that we have collected and retain.
Nondiscrimination: The right not to be subject to discrimination for asserting your rights under the CCPA.

Opt Out Rights: Do Not Sell/Share Personal Information
California residents have the right to request that organizations cease “selling” or “sharing” their Personal Information to third parties for profit, monetary or valuable consideration, and under similar circumstances. However, except as otherwise set forth in privacy notices on our external websites available to the general public, ProMach does not “sell” or “share” Personal Information regarding our employees to third parties or regarding any person under sixteen (16) years of age, and therefore we do not provide individuals with the ability to opt out of such activities.

Opt-Out of Profiling/Automated Decision-Making
California residents may request to opt out of automated processing or profiling performed on Personal Information to evaluate, analyze, or predict personal aspects related to an individual’s economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. ProMach does not currently engage in profiling that produces legal or similarly significant effects on employees, but you may contact us to inquire about any automated processing of your Personal Information.

Limit Use of Sensitive Personal Information
California residents have the right to request that organizations limit the use of their sensitive Personal Information in certain circumstances. However, ProMach does not use or disclose sensitive Personal Information regarding our employees for reasons other than those set forth in the CCPA, and therefore we do not provide individuals with the ability to limit how we use or disclose such sensitive Personal Information.

Submit a Privacy Request
To submit a CCPA privacy request, please (i) contact your supervisor or (ii) you may write to us in accordance with the “Contact Information” section listed above in the Notice. If you would prefer, you may designate an authorized agent to submit a CCPA privacy request on your behalf. An authorized agent must be registered with the California Secretary of State to conduct business in California.

Privacy Request Verification Process
If you (or your authorized agent) make any request related to your Personal Information under the CCPA, ProMach will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, ProMach will, to the extent required or permitted by law, require you (or your authorized agent) to verify your request via email, request certain contact information or government identifiers, and we will match at least two pieces of such Personal Information with data that we have previously collected from you before granting you access to, erasing, or correcting, specific pieces or categories of Personal Information, or otherwise responding to your request. We may require written documentation that demonstrates a third party is authorized to serve as your agent for the purposes of submitting the requests set forth herein, unless you have provided the authorized agent with power of attorney pursuant to California Probate Code §§ 4121 to 4130. None of the CCPA’s rights are absolute, and such rights are subject to legal and regulatory exceptions and exemptions. For more information about the CCPA, please see https://oag.ca.gov/privacy/ccpa.

Connecticut
For purposes of CT ST § 31-48d, ProMach engages in “electronic monitoring,” and this Employee Data Privacy Notice, and other applicable ProMach policies, serves as notice of the same. The term “electronic monitoring” means the “collection of information on an employer’s premises concerning employees’ activities or communications by any means other than direct observation, including the use of a computer, telephone, wire, radio, camera, electromagnetic, photoelectronic or photo-optical systems, but not including the collection of information for security purposes in common areas of the employer's premises which are held out for use by the public, or which is prohibited under state or federal law.”

Delaware
For purposes of DE ST TI 19 § 705, ProMach monitors or otherwise intercepts the telephone conversations or transmissions, electronic mail or transmissions, or Internet access or usage of its employees and of any party accessing ProMach’s information technology assets, networks, systems, environment, and resources, and the use of the same constitutes consent to the foregoing.

New York
For purposes of NY CIV RTS § 52–c, ProMach employees are hereby notified that any and all telephone conversations or transmissions, electronic mail or transmissions, or Internet access or usage by an employee, by any electronic device or system, including but not limited to the use of a computer, telephone, wire, radio or electromagnetic, photoelectronic or photo-optical systems, that are owned, leased, or operated by ProMach may be subject to interception and monitoring at any and all times and by any lawful means.

BENEFITS MACHINE READABLE FILES

Benefits Machine Readable Files — English

Benefits Machine Readable Files

Federal regulations known as the Transparency in Coverage Rule require the Pro Mach, Inc. Employee Benefits Plan to make certain machine-readable data files (“MRFs”) available to the public beginning July 1, 2022. These MRFs are maintained by Anthem, AmeriBen and Surgery Plus are hosted by them on their respective websites at:

AmeriBen (https://github.com/Ameriben/MRF)
Anthem (https://www.anthem.com/machine-readable-file/search)
SurgeryPlus (https://www.edhc.com/ProviderPricingTransparency/)

You may search for the Pro Mach plan MRFs using Pro Mach’s EIN, 58-2402604.