North America
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Safe Harbor Privacy Policy


Copyright © 2013-2015 LPKF Laser & Electronics North America


Welcome to the LPKF Laser & Electronics (LPKF) North America website.  We truly appreciate your interest in our products and your visit to this website.  We recognize that your relationship with us is based on trust, and when it comes to maintaining your privacy, you expect us to act responsibly and in your best interest.  LPKF respects your privacy and personal sphere.

OUR COMMITMENT TO YOU

Your privacy is critically important to us and we want you to feel comfortable visiting our website and the pages you explore within. Protecting your privacy in the processing of your personal information is of paramount importance to which we pay special attention during our business processes. We make every effort to respect and protect your personal private information by holding ourselves to the highest standards in the safekeeping and use of that information.

To help better protect your privacy, the following notice explains our online information practices and the choices you can make about the way your information is collected and used.

SUMMARY

This Safe Harbor Privacy Policy (the/this “Policy”) describes the collection and use of personal information online through our website. By using our website, visitors signify their agreement with the terms and conditions of this Policy. If you’re a visitor to this website and don’t agree with this Policy, please do not use it

Your information is used to provide products or services you request, improve our services and websites, secure your data, and communicate with you about your requested products, or services. You may opt-out of receiving communication from us.

Personal information collected during visits to our website is processed by us according to the legal provisions valid for the countries in which the website is maintained. In addition, our data protection policy complies with all applicable LPKF company-wide codes of conduct. The LPKF website(s) may include however, links to other websites not covered by this Policy.

LPKF’s collection, use, and disclosure of personal information is managed in a manner consistent with the laws of the countries in which it does business; it also has a tradition of upholding the highest ethical standards in business practices. This Policy sets forth the privacy principles that LPKF follows with respect to the protection and transfer of personal information from the European Economic Area (EEA) and from Switzerland, to the United States. Please see EEA definition below.

LPKF periodically reviews its privacy policies and practices; accordingly they may be subject to change. In order to ensure familiarity with the most current version of this Policy, we encourage periodic review by our website users.

With respect to the online collection of personally identifiable information (PII) and the usage of such information, this Policy is solely authorized by LPKF Laser & Electronics.

SAFE HARBOR

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles (the “Safe Harbor Principles”) and frequently asked questions (collectively the “U.S.-EU Safe Harbor Framework”) to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the European Economic Area (EEA) to the United States (the “U.S.-EU Safe Harbor”). The EEA has also recognized the U.S.-EU Safe Harbor Framework as providing adequate data protection (OJL 45, 15.2.2001, p. 47). The United States Department of Commerce and the Federal Data Protection and Information Commissioner (FDPIC) of Switzerland have also agreed on a similar set of protection principles and frequently asked questions to enable U.S. companies to satisfy the requirement under Swiss law that adequate protection be given to personal information transferred from Switzerland to the United States (collectively the “U.S.-Swiss Safe Harbor Framework”). Consistent with its commitment to protect personal privacy, LPKF adheres to the principles set forth in the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework (collectively the “Safe Harbor Framework”).

SCOPE

This Safe Harbor Privacy Policy and its adherence to the Safe Harbor Framework, applies to all personal information received by LPKF in the United States from the EEA and from Switzerland, in any format, including electronic, paper or verbal. This Policy applies to all personal information LPKF handles (except as noted below), including on-line, off-line, and manually processed data.

DEFINITIONS

For purposes of this Policy, the following definitions shall apply

“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, LPKF or to which LPKF discloses personal information for use on behalf of LPKF.

“European Economic Area (EEA)” unites the EU Member States (which includes the twenty-eight member states of the European Union) and the three EEA EFTA States (Iceland, Liechtenstein, and Norway) into an Internal Market governed by the same basic rules. These rules aim to enable goods, services, capital, and persons to move freely about the EEA in an open and competitive environment, a concept referred to as the four freedoms.

"LPKF" means LPKF Laser & Electronics AG, its predecessors, successors, subsidiaries, divisions, and groups in the United States.

"Personal information" or “Personally Identifiable Information” means any information or set of information that identifies or could be used by or on behalf of LPKF to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.

"Sensitive personal information" means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, views or activities that concern health or sex life, marital status, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, LPKF will treat as sensitive personal information, any information received from a third party where that third party treats and identifies the information as sensitive.

PRIVACY PRINCIPLES

The following privacy principles are based on the Safe Harbor Framework.

LPKF complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information received from the European Economic Area (EEA) member countries and Switzerland. LPKF has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, access, security, data integrity, and enforcement. To learn more about the Safe Harbor program, and to view LPKF’s certification, please visit export.gov/safeharbor

Notice

To the extent permitted by the Safe Harbor Framework, LPKF reserves the right to process personal information in the course of providing products and services to their clients without the knowledge of the individuals involved. Where LPKF collects personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses personal information about them, the types of non-Agent third parties to which LPKF discloses that information, the choices and means, if any, LPKF offers individuals for limiting the use and disclosure of personal information about them, and how to contact LPKF.

Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to LPKF, or as soon as practicable thereafter, and in any event before LPKF uses or discloses the information for a purpose other than that for which it was originally collected.

Where LPKF receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

When you visit our website, our webserver automatically records the name of your Internet service provider, the website from which you visit us, the websites you actually visit and the date and length of your visit. Additional personal data is only stored if volunteered by you, for example in the context of a registration, a survey, a contest, or in execution of a contract.

  • Website Links- Our website includes links (aka, hyperlinks) to other websites whose privacy practices may be similar, but may differ from those of LPKF. If you submit personal information to any of those websites, your information is no longer governed by LPKF’s privacy policies. We encourage you to read and understand the privacy policy of any website you visit.

  • Cookies- Our website(s) uses "cookies" and other similar technologies to help personalize your online experience and to remember you when you return to the site. A web browser cookie is a small piece of data sent from a website that’s anonymously placed on your hard drive. Every time the user loads the website, the browser sends the cookie back to the webserver to notify the website of the user's previous activity. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies do not personally identify you, but they allow us to monitor certain statistics, which help us improve our services, such as how many site visitors view certain pages on our website. Some cookies are deleted once you leave our website(s) (aka, session cookies), while other cookies remain after your leave our website(s) (aka, persistent cookies) so that you’re recognized when you return to our website(s).

    You also have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of our website(s) or have some of our services, such as being automatically recognized as a registered user, function properly.

  • Embedded Objects- A web bug (aka, web beacon) is an object that’s embedded in a web page or in an email and is usually invisible to the user, but it allows checking that a user has viewed the page or email. Common uses are email tracking and page-tagging for web analytics. Our website(s) and email may employ web beacons and we may associate the information gathered by this technology to a visitor or customer’s personally identifiable information.

Choice

LPKF would like to use your information to inform you about our products and services and where applicable request your opinion. Naturally your participation is completely voluntary. Should you not consent, you can inform us at any time so that we can specifically prohibit the use of your information accordingly.

For sensitive personal information, LPKF will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-Agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

LPKF will provide individuals with reasonable mechanisms to exercise their choices.

Onward Transfer

LPKF will not disclose an individual's personal information to third parties except when one or more of the following conditions is true:

  • LPKF has the individual's permission to make the disclosure.
  • The disclosure is required by law or professional standards.
  • The disclosure is reasonably related to the sale or disposition of all or part of the business.
  • The information in question is publicly available.
  • The disclosure is reasonably necessary for the establishment or defense of legal claims.
  • The disclosure is to another LPKF entity or to persons or entities providing services on behalf of LPKF or the individual (each a "transferee"), consistent with the purpose for which the information was obtained, if the transferee, with respect to the information in question
    • is subject to law providing an adequate level of privacy protection;
    • has agreed in writing to provide an adequate level of privacy protection; or
    • subscribes to the privacy principles.

Permitted transfers of information, either to third parties or within LPKF, include the transfer of data from one jurisdiction to another, including transfers to and from the United States of America.  Because privacy laws vary from one jurisdiction to another, personal information may be transferred to a jurisdiction where the laws provide less or different protection than the jurisdiction in which the information originated.

Security

We take reasonable precautions to protect personal information in our possession from loss, misuse, unauthorized access, disclosure, alteration, destruction; and ensure the appropriate use and confidentiality of information, either for its own purposes or on behalf of our customers. Within LPKF, we restrict access to information about you to only those LPKF employees who need to know the information in order to perform their jobs; such as, providing you with information you request, notifying you of new products and services, or in servicing customer accounts. To protect your personal information, we maintain appropriate physical, electronic, and procedural safeguards in keeping with industry standards and practices, and we review and adjust these safeguards regularly in response to advances in technology.

However, due to inherent risks in transmitting information via the Internet, LPKF cannot guarantee security of information that’s not in our possession or control.

Data Integrity

LPKF processes personal information only in ways compatible with the purpose for which it was collected or subsequently authorized by the individual. To the extent necessary for such purposes, LPKF takes reasonable steps to ensure that personal information is accurate, complete, current, and otherwise relevant with regard to its intended use.

Access

If a website visitor or customer of LPKF becomes aware that information LPKF maintains about that individual is inaccurate, or if an individual would like to update or review his or her information, the individual may contact LPKF using the contact information below.  LPKF will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate.  The individual will need to provide sufficient identifying information, such as name, address, birthdate, and social security number.  LPKF may request additional identifying information as a security precaution.  In addition, LPKF may limit or deny access to personal information where providing such access would be unreasonably burdensome or expensive in the circumstances, or as otherwise permitted by the Safe Harbor Framework. In some circumstances, LPKF may charge a reasonable fee, where warranted, for access to the personal information owned by the individual requesting access.

Enforcement

LPKF will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy.  Any employee that LPKF determines is in violation of this Policy or other company privacy policies will be subject to disciplinary action up to and including termination of employment.

WHAT YOU CAN DO

If you become aware of any suspicious activity relating to your personal information, it’s your responsibility to contact us immediately.

Dispute Resolution

LPKF utilizes the self-assessment approach to assure its compliance with this Policy. LPKF periodically verifies that the Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the principles. LPKF encourages interested persons to raise any concerns with us using the contact information below. LPKF will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy.

For complaints that cannot be resolved between LPKF and the complainant, LPKF has agreed to participate in the following dispute resolution procedures in the investigation and resolution of complaints to resolve disputes pursuant to the Safe Harbor Framework:

  • For disputes involving employment-related personal information received by LPKF from the EEA, LPKF has agreed to cooperate with the data protection authorities in the EEA and to participate in the dispute resolution procedures of the panel established by the European data protection authorities.

  • For disputes involving all personal information received by LPKF from Switzerland, LPKF has agreed to cooperate with the Swiss FDPIC (Federal Data Protection and Information Commissioner).

  • For disputes involving all other personal information received by LPKF from the EEA, LPKF has agreed to TRUSTe dispute resolution.  Individuals who submit a question or concern to LPKF and who do not receive acknowledgment from LPKF of the inquiry or who think their question or concern has not been satisfactorily addressed should then contact the TRUSTe Safe Harbor Dispute Resolution Program online at https://feedback-form.truste.com/watchdog/request. Inquiries should identify LPKF Laser & Electronics (www.LPKFusa.com) as the company to which a concern or question has been submitted. NOTE: If you wish to submit a report without providing your name, you can enter NoName instead of your name.

    TRUSTe will act as a liaison between the complainant and LPKF to resolve these disputes.  The TRUSTe dispute resolution process shall be conducted in English.

    For information about TRUSTe or the operation of TRUSTe's dispute resolution program, visit TRUSTe on the Internet.

Limitation on Application of Principles

Adherence by LPKF to these Safe Harbor Principles in the Safe Harbor Framework may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.

Internet Privacy

LPKF sees the Internet and the use of other technologies as valuable tools to communicate and interact with consumers, employees, business partners, and others.  LPKF recognizes the importance of maintaining the privacy of information collected online and has created a specific Internet Privacy Policy governing the treatment of personal information collected through websites that it operates.  With respect to personal information that’s transferred from the European Economic Area or Switzerland to the U.S., the Internet Privacy Policy is subordinate to this Safe Harbor Privacy Policy; however, the Internet Privacy Policy reflects additional legal requirements and evolving standards with respect to Internet privacy.  LPKF’s Internet Privacy Policy can be provided upon request using the contact information below.

Children’s Online Privacy Protection Act

As a business practice, LPKF does not target its product and/or service offerings toward, and does not knowingly collect any personal information from website visitors under 13 years of age who live in the United States.  LPKF will make reasonable efforts (taking into account available technology) to provide the following:

  • Direct notice to parents about our practices with regard to the collection, use, or disclosure of personal information from persons under age 13, including notice of any material change to such practices to which the parents may have previously consented.

  • Obtain verifiable parental consent, with limited exceptions, prior to any collection, use, and/or disclosure of personal information from persons under age 13.

  • Provide a reasonable means for parental review of the personal information collected from their child and to refuse to permit its further use or maintenance.

  • Establish and maintain reasonable procedures to protect the confidentiality, security, and integrity of the personal information collected from children under age 13, including by taking reasonable steps to disclose/release such personal information only to parties capable of maintaining its confidentiality and security.

  • Retain personal information collected online from a child under age 13 for only as long as is necessary to fulfill the purpose for which it was collected and delete the information using reasonable measures to protect against its unauthorized access or use.

OTHER IMPORTANT INFORMATION

You may have other privacy protections under applicable state laws. To the extent these state laws apply, we will comply with them when we share information about you.

California Residents

For LPKF website visitors and customers who are residents of California, and in accordance with California state law, we won’t share information we collect about you with companies outside of our corporate family, except as permitted by law; including for example, with your consent or to service your account. Additionally, we will limit sharing among our companies to the extent required by California state law. Please note that not all information sharing is covered under the California law, and only information on covered sharing will be included in any responses from inquiries about the information we share.

Nevada Residents

We’re providing you this notice under Nevada state law. From time-to-time, we may contact our existing customers by telephone to offer products that we believe may be of interest. Customers, who are residents of Nevada, have the right to opt out of these calls by adding their name to our internal do-not-call list. To opt out of these calls, please contact us using the information below. In addition to contacting us, Nevada residents can contact the Nevada Attorney General for more information about their rights to opt-out by calling (775) 684-1100, emailing bcpinfo@ag.state.nv.us, or by writing to: Office of the Attorney General, Nevada Department of Justice, Bureau of Consumer Protection, 100 North Carson Street, Carson City, NV 89701-4717.

Vermont Residents

For residents of Vermont, in accordance with Vermont law, we won’t share information we collect about you with companies outside of our corporate family, except as permitted by law; including for example, with your consent or to service your account. We won’t share information about your creditworthiness, but we may share information about our transactions or experiences with you within our corporate family without your consent.

CONTACT INFORMATION

Questions or comments regarding this Policy should be submitted via email to the LPKF Privacy Office at privacy@lpkfusa.com, or by mail as follows:

LPKF Laser & Electronics North America
Privacy Office
12555 SW Leveton Dr.
Tualatin, OR 97062
United States

CHANGES TO THIS SAFE HARBOR PRIVACY POLICY

This Policy may be amended from time to time, and we reserve the right to modify this Policy at any time consistent with the requirements of the Safe Harbor Framework. A notice will be posted on the LPKF website (www.lpkfusa.com) for 60 days whenever this Safe Harbor Privacy Policy is changed in a material way.


We self-certify compliance with:
Safe Harbor certification
Effective Date: 23 December 2014

This website is owned and operated by LPKF Distribution, Inc. d.b.a. LPKF Laser & Electronics North America.