1. Introduction

We are HARCO Industries, Inc. USA (“HARCO” or “HARCO Incentives” or “we” or “us”). Your privacy is important to us. We post this privacy statement (the “Privacy Statement”) so that you are aware of the personal information we collect, how it is handled and with whom it is shared.

This Privacy Statement relates to the following websites: harcoweb.com, olio-i.com, and premiumincentive.com (together, the “HARCO Websites”), and services provided through HARCO Websites or HARCO Powered Websites (collectively the “HARCO Services” or “Services”). A “HARCO-Powered Website” means a website not owned by HARCO, but which has a license from HARCO to utilize certain HARCO technologies. A “User” means any individual who has access through the use of a password to a HARCO Website or HARCO-Powered Website, including buyers of HARCO Services, participants of programs provided through a HARCO Website or HARCO-Powered Website, and employees and agents of corporate clients and Suppliers.

Your Use of the Website or Services Implies Your Consent

Your use of the HARCO Websites or Services signifies your acceptance of our collection and use of your personal information in accordance with this Privacy Statement. If you do not agree or are not comfortable with any policy described in this Privacy Statement, your remedies are to discontinue your use of the relevant website or to follow instructions described elsewhere in this Privacy Statement.

Changes in this Privacy & Use Statement

We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy or use of your personal information, we will notify you within this Privacy Statement and by means of notification on our home page, your program website, another appropriate place or by email. We may also notify you by posting the updated policy on our Websites and revising the “Effective Date” below. Please remember to check back every so often for updates.

Testimonials

We may post customer testimonials on HARCO Websites, which may contain personal information such as the customer’s name. We obtain the customer’s consent prior to posting such testimonial.

Security of Data

The security of your personal information is important to us. When you enter information (such as credit card or social security numbers) on our registration or order forms, we encrypt that information using Transport Layer Security (“TLS”). (To learn more about TLS, go to http://sites.ieee.org/ocs-cssig/?page_id=658 or https://en.wikipedia.org/wiki/Transport_Layer_Security.) When we store your information in databases or in flat files, we utilize encryption technologies designed to ensure data protection that is consistent with accepted industry standards.

We follow generally accepted industry standards to protect personal information submitted to us (both during transmission and once we receive it). No method of transmission over the Internet, or method of electronic storage, however, is 100% secure. Therefore, while we use commercially reasonable means to protect your personal information, we cannot guarantee its absolute security.

The safety and security of your personal information, however, also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites or Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Laws and Regulations

This Privacy Statement has been reviewed by legal counsel in conjunction with applicable laws and regulations, and we will use commercially reasonable efforts to monitor and update this Privacy Statement as necessary for United States legal compliance purposes.

Retention Policy

We will retain personal information only as long as necessary to fulfill the purposes set forth in this Privacy Statement, or for a period specifically required by law or regulation and thereafter will be disposed of securely or made anonymous so that it cannot be identified to any individual. HARCO’s specific retention policy for sales records is set at four years, but different retention periods may apply with respect to certain clients. Harco will dispose of data securely.

Privacy Incident and Breach Management

We have implemented an Information Security Incident Response Plan and management program whereby incidents and breaches of this Data Privacy & Use Policy are reported to a member of our IT Department and forwarded to the manager or employee responsible for information security and privacy issues. We also have a privacy breach notification policy in order to deliver notices in a 3 timely and legal fashion, including a clear escalation path and a procedure for contacting law enforcement, regulatory, or other authorities when necessary.

If you feel there has been an incident or breach please contact us at 201-894- 8941 or email us at privacy@harcoweb.com (put “Privacy Compliance” in subject line).

Changes Related to Privacy & Use

We have ongoing processes in place to monitor, assess, and address the effect on privacy requirements from various changes, including but not necessarily limited to changes related to legal and regulatory environments, industry standards, contracts with third parties, business operations and processes, people assigned responsibility for privacy and security matters, and technology.

Categories of Who Is Covered in this Privacy & Use Statement

• If you are a visitor to the portions of HARCO Websites or a HARCO-Powered Website that can be accessed without a password (our “Public Website”), please see the section “Public Website Privacy Statement” with respect to data about you. We refer to you as a “Public Website Visitor”.
• If you are a User, please see the section “User Privacy Statement” below for information on our data processing practices with respect to data about you.

What Is Not Covered in this Privacy & Use Statement

We cover only our data processing practices described in this Privacy Statement. Without limitation, this Privacy Statement does not cover data that we collect offline, on businesses or legal entities or on our employees.

HARCO is not responsible for any practices employed by websites linked to or from our website or their information or content. Please remember that when you use a link to go from our Websites to another website, this Privacy Statement is no longer in effect. Your browsing and interaction on any other website is subject to that website’s own rules and policies. Please read over those rules and policies before proceeding. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Children's Privacy

The Children’s Online Privacy Protection Act was created to protect children under the age of 13 from unsuspecting acts or practices in conjunction with collecting, using, and disclosing any information about them. Our Services are not intended for anyone under the age of 13. If you are under 13, do not use or provide any information on or through our Services. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you are a parent or guardian or otherwise believe we might have any information from or about a child under 13, please contact us so that we can delete the child's information. The Services will never knowingly accept, collect, maintain or use any information from a child under the age of 13. If a child whom we know to be under the age of 13 sends personal information to us online, we will only use that information to respond directly to that child or notify parents.

“Do Not Track” Disclosures

Certain state laws require us to indicate whether we honor “Do Not Track” settings in your browser over time and across third party websites as it relates to targeted advertising. We adhere to the standards set out in this Privacy Policy and do not monitor or follow any Do Not Track browser requests we might receive from you or your browser.

How You Can Contact Us

If you have questions or concerns regarding this Privacy Statement, you should first contact us by email at privacy@harcoweb.com (put “Privacy Compliance” in subject line). You can also write to us at Attention: Webmaster, Harco Incentives, 333 S. Van Brunt Street, Englewood, NJ 07631. HARCO will respond to personal information change requests within 30 days of receiving such requests.

2. Overview of HARCO Services
2.1 Suppliers of Services to Corporate Clients

HARCO may provide access to its applications via HARCO Websites and HARCOPowered Websites to suppliers of services to corporate clients (“Suppliers”). HARCO may share certain of your information, including personal information, with such Suppliers. For instance, HARCO may share certain delivery information in order to make sure certain rewards we have offered arrive at your correct address. Any such Suppliers or other service providers are required to implement privacy and security safeguards in respect of your personal information

2.2 Buyers of Services

Individuals and companies (“Buyers”) use HARCO’s technology via HARCO Websites or HARCO-Powered Websites to design and manage incentive, recognition and reward programs.

2.3 Participants of Programs Purchased by Buyers

Participants (generally corporate client employees or stakeholders) use HARCO Services when invited or registered by a corporate client to participate in a program or Services being provided to a corporate client. They do so by viewing a HARCO-Powered Website that contains incentive, recognition and/or reward programs created by the corporate client. By accessing HARCO Services, the Participant provides information required for participation in reward activities and programs.

3. Public Website Privacy Statement

This section describes how HARCO uses and disseminates information collected about Public Website Visitors to our Public Website; it does not cover any other data processing activities.

We Won’t Collect Any Information about Public Website Visitors.

We use cookies and various traffic tracking technologies to monitor the use of our Public Websites. We collect such data related to Internet Protocol (“IP”) addresses, browser type, and cookies, but do not link it to any personally identifiable information (such as names and email addresses) that you may submit to us through other means.

Use of Cookies

A “cookie” is a small text file containing information that a web browser transfers to your computer’s hard disk for record-keeping purposes. On the Public Websites, we use cookies to analyze our site traffic patterns.

For further information, visit https://allaboutcookies.org/.

You can set your browser to not accept cookies, and the website above tells you how to remove cookies from your browser. However, in some cases, some of our website features may not function as a result.

4. User Privacy Statement
4.1 Buyers of Services for Corporate Clients

If you are a User acting as a Buyer of Services, the following terms are applicable to you:

4.1.1 General Information

• We may use your personal information for the purposes of (a) providing HARCO Services or to provide you information you request about your account or our products or services; (b) facilitating communications between you and third parties; (c) our marketing activities; (d) all credit and other financial checks in relation to any payments made by you for HARCO Services; (e) carrying out our obligations and enforcing our rights arising from any contracts entered into between you and us, including for billing and collection; and (f) fulfilling any other purpose for which you provide your personal information or any other purpose with your consent.
• HARCO does not resell or transfer your e-mail addresses or any other personal information to third parties without your explicit permission or as allowed by law. The following are some examples of when HARCO may share your personal information: (a) to our advisors, contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them; (b) to comply with any court order, law or legal process, including to respond to any government or regulatory request; (c) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of HARCO, our employees and customers or others; and (d) to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of HARCO’s assets or equity interests, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by HARCO about our users is among the assets transferred.
• The corporate clients are expected to ensure all information related to Users are collected and processed in accordance with United States legislation regarding data protection. Corporate clients have informed HARCO that Users have given their explicit consent to have their sensitive data processed. HARCO may provide analysis and reports based on aggregated User data to other third parties as a natural course of doing business. These reports and analysis of aggregated data will not include individual User information or company names.
• You have a right to access personal information about you that HARCO holds. You have the right to correct, amend, or delete that information when it is inaccurate (except when the burden or expense of providing access would be disproportionate to the risks to your privacy, or when the rights of other persons would be violated). It is your responsibility to update personal information as necessary.
• Registering to use HARCO Services requires you to give us some contact information (like your name, phone number, street and e-mail address). We will use this contact information to send you information about our systems and HARCO. Your contact information is also used to contact you when necessary (for example, following up on a request from you for technical support).
• You can update your records in the HARCO system by accessing the user information administration feature in the system or if there is a problem by sending an email to privacy@harcoweb.com (put “Update Records” in the subject line). You can also write to us at Attention: Webmaster, Harco Incentives, 333 S. Van Brunt Street, Englewood, NJ 07631.

4.1.2 Communication

You may choose to receive special offers and other messages from HARCO or its partners. You may, however, also choose to cease receiving such messages by updating your profile or sending an e-mail to privacy@harcoweb.com (put “Privacy Compliance” in subject line) to change information previously provided, remove your information from our database, cancel any future communications or to cancel our service. If there is a problem with the system, you can also write to us at Attention: Webmaster, Harco Incentives, 333 S. Van Brunt Street, Englewood, NJ 07631.

4.2 Participants of Programs Hosted by Corporate Clients

If you are a participant using HARCO Services to register for a program hosted by a corporate client, the following terms are applicable to you:

4.2.1 General Information

• Your personal information and other pertinent information will be collected when you register for a program on a HARCO-Powered Website. Any information that you provide will be stored on a system managed or controlled by HARCO or a partner on HARCO’s behalf.
• The information you provide is the property of the corporate clients to whom you have provided the information.

All such personal information is completely accessible to the respective corporate client and its agents. Each HARCO corporate client has its own privacy statement. By providing your personal information to HARCO for use by a corporate client or a Supplier (e.g. to order an award to be shipped to your home address) you consent to HARCO providing a copy of your personal information to that corporate client or Supplier for collection, processing and any further transfer in accordance with the privacy statement (if any) of that corporate client or Supplier. HARCO is not responsible for any actions of corporate clients or Suppliers.

4.2.2 Communications

HARCO corporate clients may use various methods for allowing you to choose to receive or cease receiving messages, depending upon the individual corporate client’s needs and the requirements for each specific program. Corporate clients may include in their registration web site a question about not receiving messages, use an unsubscribe email reply option, or use other means in which removal from the invitee or participant list is an option. HARCO does not sell or distribute data to any third party (other than to the applicable corporate clients and Suppliers) except as authorized under this policy.

5. Your California Privacy Rights

For California Residents Only. HARCO may disclose your Personal Information to its subsidiaries or other third parties who may use that information to market directly to you. As a California resident, you have the right to opt-out of having your Personal Information licensed to such third parties. We will not share your information after we have received your notification that you are opting out. If you wish to opt-out, you have the following options:

• You can send an e-mail to: privacy@harcoweb.com (put “California Privacy Opt-out” in subject line)
• You can send mail to the following postal address:
  HARCO Industries, Inc. USA
  333 South Van Brunt Street
  Englewood, NJ 07631
  ATTN: Customer Care Department
• You can call the following telephone numbers: +1-201-894-8941 Ext. 333

6. Your European Privacy Rights

For European or United Kingdom Residents Only. If you are based in the EU or the UK, in certain circumstances, you have rights under the GDPR in relation to your Personal Information.

• Request access to your Personal Information. You may have the right to request access to any Personal Information we hold about you as well as related information, including the purposes for processing the Personal Information, the recipients or categories of recipients with whom the Personal Information has been shared, where possible, the period for which the Personal Information will be stored, the source of the Personal Information, and the existence of any automated decision making.
• Request correction of your Personal Information. You may have the right to obtain without undue delay the rectification of any inaccurate Personal Information we hold about you.
• Request erasure of your Personal Information. You may have the right to request that Personal Information held about you is deleted.
• Request restriction of processing your Personal Information. You may have the right to prevent or restrict processing of your Personal Information.
• Request transfer of your Personal Information. You may have the right to request transfer of Personal Information directly to a third party where this is technically feasible.

Where you believe that we have not complied with our obligations under this Privacy Policy, or under European or UK data protection laws, you have the right to make a complaint to an EU or UK Data Protection Authority, such as the UK Information Commissioner's Office

If you wish to exercise your European or UK data subject rights, you have the following options:

• You can send an e-mail to: privacy@harcoweb.com (put “European Privacy” or “UK Privacy” in subject line)
• You can send mail to the following postal address:
  HARCO Industries, Inc. USA
  333 South Van Brunt Street
  Englewood, NJ 07631
  ATTN: Customer Care Department
• You can call the following telephone numbers: +1-201-894-8941 Ext. 333

7. Document Control and Revision History

Adopted:                            August 27, 2018
Effective Date:                   September 1, 2018
Reviewed and updated:    August 19, 2022