Data protection declaration

Dear users,

Nord Gear Limited is a company registered in England with company number 02970420 at registered address 7th Floor, Beaufort House, 15 St Botolph Street, London, EC3A 7NJ (“Nord”, “we”, “us).

It is important to us that you feel safe and comfortable when visiting our website www.nord.com the protection of your privacy is of great importance to us.

Nord is a data controller in respect of your personal information. This means that we are responsible for deciding how we hold and use personal information about you.

We carry out all data processing in accordance with English legal regulations. The following policy gives you an overview of what kind of data is collected, how this data is used and passed on, what security measures we take to protect your data and how you receive information about the information given to us.

§ 1 Collection and storage of personal data

Personal data are individual details about personal or factual circumstances of a specific or identifiable natural person, such as your name, your address, your telephone number, your date of birth, your bank details and your IP address. NORD-Motoriduttori s.r.l. is the responsible body for the processing of your data.

When using our websites, the following data is logged, whereby the storage serves exclusively internal system-related and statistical purposes: names of the pages accessed, the browser used, the operating system and the requesting domain, date and time of access, search engines used, names of downloaded files and your IP address. All data about usage, in particular your IP address, will be deleted after 7 days at the latest.

Further personal information is only collected if you provide it to us voluntarily, for example as part of an inquiry or registration. To use our myNord Internet portal, we require your registration. All data required for the execution and processing of orders will be requested: Your full name or your full company name together with the person authorized to represent the company, your e-mail address, your address (billing address and, if applicable, different delivery address) and, if applicable, your telephone number (e.g. if the short-term coordination of a delivery date is required). You must also choose a user name and password, both enables you to log in more easily without re-entering data. We store the data entered by you for the establishment of a customer account, via which we record, execute and process your orders. We keep your data for further orders (registration) as long as you maintain the registration. You have the right to access, correct and delete your registration data at any time. We will delete your account if the deletion is required by law, no later than two years after the execution of your last order.

Handling of applicant data

The applicant data will only be stored by us for the application process and will then be deleted after six months at the latest after the position has been filled. Upon receipt of your application documents, we will inform you about your personal data stored by us in accordance with the requirements of Article 13 GDPR.

§ 2 Use, disclosure and deletion of personal data

We use the personal data you provide to answer your inquiries, to process your order, to check the creditworthiness and for the purpose of technical administration of the websites.

Your personal data will only be passed on to third parties if the passing on is necessary for the purpose of the contract or for billing purposes or for collecting the fee or if you have expressly consented. It may also be necessary for us to pass on your address and order data to suppliers when the delivery is delivered directly ex works. Our suppliers only receive the information necessary to fulfil their respective tasks. Any other use of the information is not permitted. We are also entitled to pass on personal data for debt collection purposes. If we make advance payments in connection with an order (for example, when purchasing on account), we can only have the identity and creditworthiness of customers checked by a service provider.

Furthermore, we do not exclude the possibility that we transmit anonymised usage data for market research purposes. The identification of users is not possible.

We would like to point out that we are entitled to provide information on data in individual cases by order of the competent authority, insofar as this is necessary for the purposes of criminal prosecution, to avert danger by the police authorities of the federal states, to fulfil the legal tasks of the Federal and State Office for the Protection of the Constitution, the Federal Intelligence Service or the Military Counter-Intelligence Service or to enforce intellectual property rights.

§ 3 Safety information

We have taken a variety of security measures to adequately protect personal information.

Our databases are protected by physical, technical and procedural measures that restrict access to the information to specially authorized persons in accordance with this Privacy Policy. Our information system is located behind a software firewall to prevent access from other networks connected to the Internet. Only employees who need the information to perform a specific task will have access to personal information. Our employees are trained in security and privacy practices.

When personal information is collected via our Internet pages, transmission is encrypted using the industry standard Transport Layer Security ("SSL/TLS") technology. Sensitive information, such as credit card numbers or account information, is encrypted for further protection.

You should never give your password for access to our website to third parties and you should change it regularly. Once you have left our site, you should log out and close your browser to prevent unauthorized users from accessing your account. When communicating by e-mail, we cannot guarantee complete data security.

§ 4 Cookies and web analysis tools

"Cookies" are small files that allow us to store specific information about you on your PC when you visit our website. Cookies help us to determine the frequency of use and the number of users of our website and also allow us to make our offers as safe, convenient and as efficient as possible for you.

On the one hand, we use so-called "session cookies", which are stored temporarily exclusively for the duration of your use of one of our Internet pages. On the other hand, we use "permanent cookies" to record information about computers that repeatedly access our website. This enables us to offer you optimal user guidance, to "recognize" you and to present you with a varied website and with as much new content as possible in case of the repeated use of our website. The content of a permanent cookie is limited to an identification number. A permanent cookie is valid for 60 days, after which the cookie is automatically deleted. Name, IP address or other information about your real identity is not stored, and we also do not create individual profiles about your usage behavior.

Our offers can also be used without cookies. You can deactivate the storage of cookies in your respective browser, limit them to certain Internet pages or set your browser so that it informs you as soon as a cookie is sent. You can also delete cookies from your PC's hard drive at any time. Please note, however, that in this case you must expect a limited display of our website and limited user guidance."

Google Analytics

We use Google Analytics, a web analysis service of Google Inc. (hereinafter "Google") if we obtained your consent. In that case, the legal basis for this processing is Art. 6 lit. a GDPR. Google Analytics uses cookies, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of our website is usually transferred to a Google server in the USA and is stored there. However, due to the activation of IP anonymisation on our website, Google will reduce your IP address within Member States of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases the full IP address will be transmitted to a Google server in the USA and will be shortened there. Google will use this information on our behalf to evaluate your use of our website, to compile reports on the website activity and to provide us with other services relating to the website and internet use. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data. You may refuse the use of cookies by selecting the appropriate settings in your browser, however please note that if you do this you may not be able to use the full functionality of our website. You can also prevent Google from collecting the data generated by the cookie and relating to your use of our website (including your IP address) and from processing this data by Google by clicking on the following link. An opt-out cookie is set to prevent future collection of your data when you visit the website: Disable Google Analytics .

For more information, please visit http://tools.google.com/dlpage/gaoptout or https://www.google.com/analytics/privacyoverview.html (general information on Google Analytics and data protection). Please note that the code "gat._anonymizeIp();" has been added to Google Analytics in order to ensure anonymous collection of IP addresses (so-called IP masking).

You can also prevent the collection by Google Analytics by clicking on the following link. An opt-out cookie is set to prevent future collection of your data when you visit the website: Disable Google Analytics .

Google Tag Manager

• This website uses the Google Tag Manager. This service allows website tags to be managed via an interface. Google Tool Manager simply implements tags, does not use cookies and does not collect personal data. Google Tag Manager triggers other tags that may collect personal data, if necessary. However, Google Tag Manager does not access these data.
• If tracking tacks have been disabled on domain or cookie level this applies for all tags being implemented via Google Tag Manager.

YouTube

Occasionally, we use YouTube videos on our page. These videos are incorporated in the “extended data protection mode” of YouTube. According to YouTube, no information about the visitors of the website are stored, as long as no video is played. If you do play a video, you automatically agree to your data being processed by YouTube as the responsible authority, while we have no further influence on the processing. For further information please refer to the YouTube data protection declaration, which can be found here: https://policies.google.com/privacy?hl=en-GB.

Closed myNORD user group

Via the closed myNORD area you can view details of current or previous orders and you can find information about expected delivery dates. The transmission of data from us to you is encrypted using TLS. The legal basis for the processing is Art. 6 para 1 lit. b GDPR.

We will inform you of the registration data for the myNORD area by e-mail or telephone. Of course, order data can only be viewed by you as a customer. To ensure this, we have had this area checked by an independent expert with regard to IT security.

Novalnet

For the purpose of processing credit card payments, we cooperate with the full-service payment provider Novalnet AG in the e-shop area. For this purpose, your payment details are encrypted for transmission to Novalnet. Beyond the initiation of payment processing we have no further influence on the processing of data by Novalnet. For further information we refer to the data protection declaration of Novalnet AG, which can be found here: https://www.novalnet.com/privacy

Aumago

We work together with the Aumago GmbH, a provider for web analysis and target group marketing. Aumago uses so-called cookies, a text file that is stored in the browser of the computer and collects/contains anonymous usage data in case you declared your consent. The legal basis for the processing in this case is Art. 6 lit. a GDPR. These data can be used to create user profiles under a pseudonym. However, no personal information is recorded. If IP addresses are collected, they are stored anonymously by deleting the last numeric keypad and are not merged with the cookies. The cookies are either Aumago cookies or cookies from service providers that Aumago uses, such as krux digital Inc., Google Inc. etc.. The user can delete the cookies directly in his browser at any time. Aumago uses the gathered data to evaluate the use of the website by visitors and for the purpose of usage-based online advertising (OBA). To revoke your consent, please visit the following website:

https://dmp.theadex.com/donttrack/1?rdr=https://www.theadex.com/opt-out and click on the "Browser Opt-out" button. Alternatively, you can activate the "Do-Not-Track function" in your browser preferences, which will be implemented by Aumago accordingly.

Google Display & Video 360 (formerly Doubleclick Bid Manager)

On this website we use the tool Display & Video 360 by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, which records data for analysis, marketing and optimisation purposes and therefore helps us to improve our marketing measures and our website. The data which is recorded is used by Display & Video 360 to link clicks on advertisements with the resulting use of our website. In this way we can determine whether Internet users who have seen our advertisements visit our website and if so, the products which they are interested in. This helps us to utilise our advertising budget more efficiently. We can also use the recorded data to provide advertising on the basis of your interests (e.g. products viewed).

Online identification number pseudonyms (e.g. cookie IDs or IP addresses) are used to record the data. For this, no identifiable user-related data such as names or addresses are saved. All of the IDs which we use are only used to identify your terminal device and your internet browser. Without your separate agreement, the recorded data will not be used to personally identify you as a user of our website.

We must point out that for users who are registered with Google, Google may have the possibility of linking the user to their visit to this website. You can find out exactly how Google processes this data by clicking on the Google privacy pages under the following link: https://safety.google/privacy/privacy-controls/

Under the following link you can find an explanation of how you can deactivate data recording by Google on your computer or your mobile terminal device: https://support.google.com/ads/answer/7395996

The legal basis for processing is your consent, if you have given this. You can change your consent here or revoke your consent here .

Campaign Manager (formerly DoubleClick by Google)

This website continues to use the Google Online Marketing Tool Campaign Manager. Campaign Manager uses cookies to place advertising which is relevant to the user, to improve reports on campaign performance or to prevent users from seeing the same advertisement several times. By means of a cookie ID Google records which advertisements are placed in the particular browser and can therefore prevent them from being displayed several times. In addition, with the aid of cookie IDs Campaign Manager can record so-called conversions, which are related to advertisement enquiries. This is the case if a user views a Campaign Manager advertisement and later calls up the website with the same browser and purchases anything there. According to Google, Campaign Manager cookies do not contain any personal information.

Due to the marketing tools which are used, your browser automatically establishes a direct connection to Google. We do not have any influence on the extent and further use of the data which are recorded by Google due to the use of this tool and therefore inform you according to our knowledge: Through the integration of Campaign Manager, Google receives information that you have called up the corresponding part of our website or have clicked on one of our advertisements. If you are registered with a Google service, Google can assign the visit to your account. Even if you have not registered with Google or are not logged in, there is the possibility that Google identifies and saves your IP address.

Furthermore, the Campaign Manager (DoubleClick Floodlight) cookies enable us to understand whether you perform certain actions on our website after you have called up one of our display/video advertisements on Google or on another platform via Campaign Manager or have clicked on these (conversion tracking). Campaign Manager uses this cookie to identify the content with which you have interacted on our websites in order to send you targeted advertising at a later date.

You can obtain further information about Campaign Manager under https://marketingplatform.google.com/intl/en_uk/about/enterprise/ as well as about data protection by Google in general: https://policies.google.com/privacy?hl=en-GB . Alternatively you can visit the website of the Network Advertising Initiative (NAI) under http://www.networkadvertising.org. Google is subject to the EU-US Privacy Shield https://www.privacyshield.gov/EU-US-Framework.

The legal basis for processing is your consent, if you have given this. You can change your consent here or revoke your consent here .

LinkedIn Insight

We use the service provider LinkedIn to evaluate the reach of our website and marketing measures. We are thus able to determine which LinkedIn user groups have visited and left our site. Thus, it is possible, for example, to send targeted advertising to you. Your visit to our website cannot be directly linked to your identity. The mentioned data merge only takes place if you agreed on it upon visiting our website. The legal basis for the processing is Paragraph 15 Section 3 Page 1 of the German Telemedia Act (TMG). You can revoke your consent at any time by clicking here.

Captcha

To protect our web forms from automated inquiries, we use a so-called CAPTCHA. In the context of this CAPTCHA, you will be asked to solve tasks or to click checkboxes. The user inputs and possibly the mouse movements made in this context will be used to estimate if the input comes from a human being or from an automated program. The embedding takes place based on Art. 6 para. 1 lit. f GDPR and in the interest of protection from spam and misuse. If you do not want this data processing, please refrain from using our web forms.

§ 5 E-mail and online marketing

Hubspot

We use HubSpot for our online marketing activities. With this software solution we cover, among other things, these aspects of our online marketing:

• E-mail marketing (trade fair invitations, newsletters, etc.)
• Landing Pages and Contact Forms
• Social Media Publishing & Reporting
• Reporting (e.g. traffic sources, accesses, etc.)

Our contact forms allow visitors of our website to learn more about our company, download content, receive free exhibition tickets and provide us with their contact information and other demographic information.

This information is stored on servers of our software partner HubSpot. This information can be used by us to contact visitors of our website and to determine which services of our company are of interest for them. The statistical usage data of our online marketing offers serves to optimize the website functions and to provide our website visitors with content that is tailored to your interests.

In this context, we have designed our e-mail service so that we are automatically informed, for example, if and when an e-mail was opened and at what point in time which link was clicked in the e-mail. This means that for the e-mail and online marketing activities described above, the complete IP address of the website visitors is also recorded, but it is not permanently stored.

We are able to track your visit on our website in case you declared your consent. In this case, the legal basis for this tracking is Art. 6 para 1 lit. a GDPR. You have the option of preventing tracking by HubSpot by clicking on the following link: Disable HubSpot tracking . This will set a cookie which prevents tracking by HubSpot.

This cookie is valid for two years.

All information we collect is subject to this privacy policy. We use the information collected exclusively to optimize our services.

You have the right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, you can unsubscribe by using the “unsubscribe” link at the bottom of our marketing messages. You can also update your marketing preferences by logging into your account on our website or emailing our Data Protection Officer.

Contact:

HubSpot

2nd Floor 30 North Wall Quay

Dublin 1, Ireland,

Phone: +353 1 5187500.

HubSpot is certified under the terms of the EU - U.S. Privacy Shield Framework and is subject to the TRUSTe's Privacy Seal and the U.S. - Swiss Safe Harbor Framework.

More information about the data protection regulations of HubSpot

More information from HubSpot regarding EU data protection regulations

More information about the cookies used by HubSpot can be found here and here .

Further information on data protection in connection with your contact data can be found here .

§ 6 Right to information

You have the right to be informed at any time about the data stored concerning your person, its origin and the recipients as well as the purpose of data processing. If you have any questions regarding data protection, please do not hesitate to contact our data protection officer. He can be reached as follows:

Peter Suhren

FIRST PRIVACY GmbH

Konsul-Smidt-Str. 88

28217 Bremen, Germany

Phone: +49 421 69 66 32 0

Email: [email protected]

§ 7 Right of appeal

Any data subject has the right of appeal to a supervisory authority if he or she considers that the processing of data concerning him or her contradicts data protection legislation. The right of appeal may be exercised by making a complaint to the data protection authority.

§ 8 Rights of the data subject

Data subjects have the right to obtain information from the data controller about personal data concerning them and to have inaccurate data corrected or deleted if one of the reasons stated in Art. 16 del D. Legisl. 30.6.2003 n. 196 applies, e.g. if the data is no longer required for the purposes pursued. Furthermore, there is a right to limitation of processing and the right to data portability. If data are collected on the basis of Art. 7 cap. 4 del D. lgsl 30.6.2003 n. 196 (data processing for the fulfilment of official tasks or for the protection of the public interest or data processing for the protection of legitimate interests), the data subject is entitled to object to the processing at any time for reasons arising from his particular situation. We will then no longer process the personal data unless there are demonstrably compelling reasons worthy of protection for the processing which outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims. Please address your objection to: [email protected] .

§ 9 Notice of a right to object to direct advertising

We may process your data for the purpose of direct advertising. You have your own right of objection to such processing, the objection leads to the termination of processing for the purpose of direct marketing. Please address the objection: [email protected] .