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Festo Ltd Data Privacy Notice

Festo Limited (“Festo”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

For your ease of reference, this privacy notice is divided into the following sections:

1. Important information and who we are

2. The data we collect about you

3. How your personal data is collected

4. How we use your personal data

5. Disclosures of your personal data

6. International transfers

7. Data security

8. Data retention

9. Your legal rights

10. Glossary

1. Important Information and who we are

Purpose of this privacy notice
This privacy notice aims to give you information on how Festo collects and processes your personal data.

Controller
Festo is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy notice).

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your rights in relation to your personal information, please contact the DPO using the details set out below.

Contact details
Full name of legal entity: Festo Limited (Company Number: 00926749)
Name or title of DPO: Sarah Smith
Email address: dataprivacy.gb@festo.com
Postal address: Festo Limited, Applied Automation House, Caswell Road, Brackmills Industrial Estate, Northampton, NN4 7PY

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

We may change this privacy notice from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. We advise you to check this privacy notice for changes whenever you visit our website – www.festo.com

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

· Identity Data includes first name, last name, title, gender and CCTV imagery for security purposes.
· Contact Data includes billing address, delivery address, email address, social media details, and telephone numbers.

·Financial Data includes bank account and payment card details.

·Transaction Data includes details about payments to and from you, any meeting records where you have met with us and other details of products and services you have purchased from us.· Technical Data includes internet protocol (IP) address, your login data to our website, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
· Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses through the use of our website.
· Usage Data includes information about how you use our website, products and services.· Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We may hold details of any dietary requirements you may have. This is a Special Category of Personal Data and we will therefore explicitly require your consent first before obtaining the same.

This list of personal data is not exhaustive and further information may be requested from you when Festo considers it fair and necessary to do so.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

· Direct interactions.

You may give us personal data such as Identity, Contact, Financial, Transaction, Profile, Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email, through our website and social media, meeting face to face at our offices or otherwise. This includes personal data you provide when you:

· Meet employees face to face;
· enquire about our products;
· provide your business card;
· complete lead capture forms at events we also attend;
· visit our offices and/or sign the electronic visitor system;
· create an account on our website;
· request marketing to be sent to you; or
· give us some feedback.

· Automated technologies or interactions.
As you interact with our websites and with emails received from us, we may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

As a customer of Act-On, we also use the Act-On Beacon Tracker, a service provided by Act-On Software, Inc, 121 SW Morrison St., Suite 1600, Portland, OR 97204. This enables Act-On to place a cookie in your browser. These cookies become invalid after one year and are not used for the purpose of personal identification. The cookie is used to track the activity of anonymous and known visitors which are interacting with the website including, web landing pages, forms and other web resources.

· Internal databases. We may collect personal data from other entities forming part of the Festo Group and from our own internal databases. This includes, but is not limited to, personal data obtained through the Festo Official Partner Network, Festo Didactic online testing and personal data already stored within our email and electronic storage systems/databases.

· Third parties or publicly available sources. We may receive and share personal data about you with various third parties and public sources as set out below:

· Identity, Contact and Marketing and Communications Data from the following sources:

(a) publicly available sources such as CoCredo and Companies House;

(b) industry information resources such as GlobalSpec and Industry Direct;

(d) our other customers and prospective customers of Festo.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

· Where we need to perform the contract we are about to enter into or have entered into with you.

· Where it is necessary for our legitimate interests (or those of a third party) and your interests and
fundamental rights do not override those interests.

· Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you if you are an individual or consumer via email or text message. You have the right to withdraw consent to marketing at any time by emailing dataprivacy.gb@festo.com.

Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us by emailing dataprivacy.gb@festo.com should you require details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer whether online or otherwise and manage our relationships with prospective customers

(a) Identity
(b) Contact

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (maintaining and nurturing relationships with customers and prospects).

To process and deliver your order including:

(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(c) Liaising with our suppliers in respect of your order

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing &
Communications

(a) Performance of a contract with you.

To manage our relationship with you which will include:
(a) General communication relating to your order/future orders

(b) Granting Access Management

(b) Notifying you about changes to our terms or privacy policy

(c) Asking you to leave a review or take a survey

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Profile
(f) Marketing &
Communications

(a) Performance of a contract with you (b) Necessary for our legitimate interests (maintaining and nurturing relationships with customers and prospects).

To enable you to provide feedback on our services, enable us to deal with any complaints and improve our service offering

(a) Identity
(b) Contact
(c) Transaction
(d) Profile
(e) Usage
(f) Marketing & Communications

(a) Performance of a contract with you (b) Necessary for our legitimate interests (maintaining and nurturing relationships with customers and prospects).

To ensure we meet with our certification and health and safety requirements

(a) Identity
(b) Contact
(c) Technical
(d) Transaction
(e) Profile

(a) Necessary to comply with a legal obligation.

For management and auditing of our business operations including accounting

(a) Identity
(b) Contact
(c) Transaction
(d) Technical

(a) Necessary to comply with a legal obligation.

To share information, as needed, with business partners, service providers or as part of providing and administering our products or operating our business

(a) Identity
(b) Contact
(c) Transaction
(d) Marketing & Communications

(a) Performance of a contract with you (b) Necessary for our legitimate interests (maintaining and nurturing relationships with customers and prospects).

To share your information, as needed, with our Official Partners and contractors for direct marketing purposes.

(a) Identity
(b) Contact
(c) Transaction
(d) Profile
(e) Usage
(f) Marketing & Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (maintaining and nurturing relationships with customers and prospects).
(c) With your consent where the direct marketing involves e-marketing to individuals

To carry out checks at Credit Reference and Fraud To carry out checks at Credit Reference and Fraud Prevention Agencies pre-application, at application, and periodically after that

(a) Identity
(b) Contact
(c) Transaction

(a) Necessary to comply with a legal obligation.

To use data analytics to improve our website, products, marketing, customer relationships and experiences

(a) Technical
(b) Usage

(a) Necessary for our legitimate interests (maintaining and nurturing relationships with customers and prospects).

To make suggestions and recommendations to you via direct email marketing about goods or services that we offer and which may be of interest to you

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing & Communications

(a) Necessary for our legitimate interests (maintaining and nurturing relationships with customers and prospects).
(b) With your consent where the personal data being processed relates to that of an individual.

To make automated decisions on whether to inform you of products which may be of interest to you

(a) Technical
(b) Usage
(c) Contact

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (maintaining and nurturing relationships with customers and prospects).

To discover prospective customers and build our business through lead and event management

(a) Identity
(b) Contact
(c) Marketing & Communications

(a) Necessary for our legitimate interests (maintaining and nurturing relationships with customers and prospects).

To store CCTV imagery obtained at our offices for security purposes.

(a) Identity

(a) Necessary for our legitimate interests
(keeping employees and customers safe and secure by preventing crime).

Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing.

Promotional offers from us
We may use your Identity, Contact, Technical, Usage, Profile and Marketing and Communications Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). In certain situations, we may also use automated decision making to offer the most relevant products to you.

You will receive marketing communications from us if you have requested information from us or purchased goods from us and, in each case, you have not exercised your right to object to receive that marketing.

Third-party marketing
We will get your express opt-in consent before we share an individual’s personal data with any company outside the Festo group of companies for electronic marketing purposes.

Object to marketing
You can ask us or third parties to stop sending you marketing messages at any time by clicking on and following the unsubscribe link in the email.

Where you exercise your right to object to your personal data being used to receive these marketing messages, this will not apply to personal data provided to us as a result of an order you have made.

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please email us at dataprivacy.gb@festo.com.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

-Internal Third Parties such as other companies within the Festo Group.
- External Third Parties such as the following:

Service providers providing IT, telephone, system administration and support services.

Professional advisers including lawyers, bankers, auditors and insurers based providing consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities who may require reporting of processing activities in certain circumstances.

Other third parties such as
credit card companies;
our official partners;
marketing suppliers for our own marketing purposes;
travel companies when making travel arrangements for our contacts;
educational establishments when we are obtaining accreditation for contacts; and
sub-contractors such as Marketing Results Limited which sends out our marketing materials to our contacts, and marketing suppliers that provide our telephone services to maintain and enhance data quality.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We share your personal data within the Festo Group. This will involve transferring your data outside the European Economic Area (EEA).
We ensure your personal data is protected through binding corporate rules which require all our group companies to follow the same rules when processing your personal data.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring a safeguard is implemented. For example, where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please email dataprivacy.gb@festo.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please email dataprivacy.gb@festo.com.

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by emailing us at dataprivacy.gb@festo.com.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Version: 5 August 2018

Cookies

For this website to function correctly, we sometimes store small files – called cookies – on your machine. Most large websites do this.

What are cookies?
A cookie is a small text file that a website leaves on your computer, tablet or smartphone when you visit the website. This allows the portal to "remember" certain entries and settings (e.g. logon, language, font size and other display preferences) for a certain length of time. As a result, you do not have to set these again each time you visit the website and navigate on it.

How do we use cookies?
Festo uses cookies in various ways, such as for the following purposes:

Authenticating and identifying you when you use our websites and applications so that we can provide you with the services you are requesting
Tracking information that you have provided us with, e.g. storing articles in your shopping basket when you are in the Online Shop.
Providing the websites and applications from Festo that you are using
Storing your settings or the position you were at when you finished using a website or an application from Festo
Measuring your use of websites and applications from Festo so that we can improve them and adapt our websites and online services to what you are likely to be interested in
Understanding your probable interests so that we can provide you with more relevant content on the Festo site.

The functions and properties of individual cookies are described below:

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