AKRON BRASS CAPTIUM EQUIPMENT DATA SYSTEM PRIVACY POLICY

Last modified: January 2020
Akron Brass Company, a unit of the IDEX Corporation, with its corporate office located in Wooster, OH (“Akron Brass,” “we,” “our,” “us”) is committed to being responsible custodians of the data you provide us and the data we collect in the course of operating our business.

Akron Brass takes your personal privacy seriously. This Privacy Policy describes how Akron Brass may collect, use and share your personal information and data (“Personal Data”, “personal information” or “information”). This Privacy Policy (our “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you use the CaptiumTM connected vehicle and equipment platform, portal, software, data services, gateway, and associated connected equipment, information products, services, and applications (collectively, the “Captium System”). The Captium System enables a network platform for multiple components, including chassis health and diagnostics, critical electrical controllers, multiplexing systems, water flow components, real-time notifications, run-log recording and over-the-air programming updates (collectively, “Equipment”).

This Privacy Policy applies to information we collect:

  • through your use of the Captium System, including connected Equipment, our portal, our software, and applications;
  • in email, text, and other electronic messages between you and our Captium System;
  • when you interact with our advertising and applications on third party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:
• us offline or outside of use of the Captium System or through any other means, including on any other websites and applications operated by Akron Brass or any third party;
• any third party, including through any software, website, application, or content (including advertising) that may link to or be accessible from or on the Captium System.
Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Captium System. By accessing or using our Captium System, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Captium System after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.
This Privacy Policy describes:
• THE TYPES OF INFORMATION AKRON BRASS COLLECTS
• HOW AKRON BRASS USES THE INFORMATION IT COLLECTS
• HOW AKRON BRASS MAY SHARE THE INFORMATION AKRON BRASS COLLECTS
• THIRD PARTY SERVICES AND CONTENT
• PROTECTION AND STORAGE OF THE INFORMATION AKRON BRASS COLLECTS
• YOUR CHOICES AND RIGHTS
• USE OF THE SYSTEM BY OTHERS
• CHILDREN UNDER 18
• CHANGES TO THIS PRIVACY POLICY
• CONTACT US
THE TYPES OF INFORMATION AKRON BRASS COLLECTS
Information Collected Through the Captium Portal
We collect several types of information that you provide to us and when you use our Captium portal, specifically information:
• by which users and may be personally identified, such as name, e-mail address, mobile telephone numbers and other personal information;
• that determines portal activity but does individually does not identify you, such as web traffic data, location data, logs, referring/exit pages, date and time of your visit to our portal or use of our applications, error information, clickstream data, and other communication data and the resources that you access and use on the Captium portal;
• about your internet connection, the Equipment you use to access our Captium portal and usage details; and
• information about your Equipment and the sensor data therein, such as Equipment type, network messages, error codes, diagnostics codes, date, time and location.
We collect this information:
• directly from you when you provide it to us, for instance when you contact us through our portal; and,
• automatically as you use the Captium System and Captium-connected Equipment. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, geo-location services, and other tracking technologies.

Information We Collect Automatically
As you use the Captium System and Captium-connected Equipment, we may use automatic data collection technologies to collect through sensors and other means certain information about your vehicle, Equipment and hardware and how you consume information such as:
• Information about the vehicle and Equipment (e.g., information about the powertrain, engine, pump, intake pressure, temperature sensors, faults, diagnostic data, valves, user inputs, brakes, GPS location, date, time, etc.);
• details of your use of our Captium System, such as traffic data, location data, logs, referring/exit pages, date and time of your use of our portal or application, error information, clickstream data, and other communication data and the resources that you access and use on the Captium System; and
• Information about your Equipment, vehicle, computer, mobile device, and internet connection, specifically your IP address, operating system, browser type, and Captium System version information.
The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Captium System and to deliver a better and more personalized service by enabling us to:
• estimate our user size and usage patterns;
• verify your location to ensure we can provide you with our services;
• store information about your preferences, allowing us to customize our Captium System according to your individual interests;
• recognize you when you return to our Captium System.
The technologies we use for this automatic data collection on our portal may include:
• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer or mobile device. On your computer, you may refuse to accept browser cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. However, if you select this setting you may be unable to access certain parts of our Captium System. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Captium System.
• Web Beacons. Parts of our Captium System and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Akron Brass, for example, to count users who have visited those parts, used certain screens, or opened an email and for other related website and application statistics (for example, recording the popularity of certain Captium System content and verifying system and server integrity).
HOW AND THE PURPOSES FOR WHICH AKRON BRASS USES THE INFORMATION IT COLLECTS
Akron Brass will only process Personal Data where it has a legal basis to do so. We have a lawful basis for our processing of your Personal Data, including processing for our legitimate interests (when balanced against your rights and freedoms), to fulfill our obligations to you under a contract with you, and required by law, and with your consent. Akron Brass may use the information Akron Brass collects:
(a) To provide and present the Captium System to you, and to perform the associated services therewith (including portal or Equipment support services);
(b) To provide you with information, products, or services that you request from us;
(c) To process, fulfill, and administer transactions and orders for products and services ordered by you, including to verify your identity or Equipment ownership;
(d) To fulfill any purpose for which you provide it;
(e) To notify you about changes to our Captium System, or any products or services we offer or provide though them;
(f) For research and evaluation purposes, including for quality, safety, and Captium System enhancement;
(g) To enter into a contract or settlement, or to take steps at your request prior to entering into a contract or settlement (such as account registration or to perform credit checks), and to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
(h) To respond to your inquiries, to provide you with services that you request, to communicate with third parties in the handling of claims or complaints, to maintain business administration records and prevent fraud, which is our legitimate interest;
(i) To keep records and administration on how services were provided, claims and complaints were handled, including the documents underlying such services, claims and complaints, which is our legitimate interest;
(j) To understand how people use our Equipment, portal, applications, software, and services, to operate, maintain and improve our Equipment, portal, applications, software, and services, to send direct marketing communications, which is our legitimate interest;
(k) To comply with legal obligations applicable to Akron Brass, such as responding to legal process or requests for information issued by government authorities or other third parties;
(l) in any other way we may describe when you provide the information; and
(m) for any other purpose with your consent.
We may also use your information to contact you about goods and services that may be of interest to you, including through newsletters. If you wish to opt-out of receiving such communications, you may do so at any time by clicking unsubscribe at the bottom of these communications.

HOW AKRON BRASS MAY SHARE THE INFORMATION AKRON BRASS COLLECTS
We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
Akron Brass and its affiliated entities share information with each other or with third party service providers for general business purposes pursued by Akron Brass, such as internal administration, wireless services providers, billing, claim handling and services, , and providing you or your organization with services.
Through the Captium System, we may share Personal Data, Equipment data, and other information with the Equipment manufacturer or owner and other relevant third parties (e.g., authorized dealers and service providers, and component suppliers and distributors).
Akron Brass and its affiliated entities may share information with third party data controllers (including law enforcement agencies and potential transaction partners) where Akron Brass and its affiliated entities have a legal basis to do so.
Akron Brass does not sell, rent, or otherwise share Personal Data with information that reasonably identifies you for their independent use except as expressly described in this Privacy Policy or when Akron Brass has a legal basis to do so, for instance with your prior consent.
We may also disclose your Personal Data:
• to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• to enforce or apply our Portal Terms of Use https://www.captiumconnect.com/terms-of-use and other agreements, including for billing and collection purposes;
• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Akron Brass, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction and sharing with maintenance or emergency service providers;
• 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 our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Akron Brass about our Captium System users are among the assets transferred;
• to fulfill the purpose for which you provide it. For example, we may disclose your personal information to a Provider; and,
• for any other purpose disclosed by us when you provide the information.
If Akron Brass transfers EU Personal Data to a recipient outside the European Union, it will only do so in compliance with the European General Data Protection Regulation. If you have questions about the international transfers of your Personal Data or the appropriate safeguards Akron Brass has in place, or wishes to obtain a copy of such safeguards, please contact us as set forth below.
THIRD PARTY SERVICES AND CONTENT
Our Captium System may include integrated content or links to content provided by third parties (such as Equipment manufacturers, vehicle OEMs, social media platforms, GPS and geolocation providers, telecommunication providers, etc.). This Privacy Policy does not address the privacy, security, or other practices of the third parties that provide such content and services, and we are not responsible for nor do we control the information practices of these third party services providers. You must exercise your own judgment as to the adequacy and appropriateness of the sharing of this information with us. We recommend considering the privacy policies applicable to third-party website prior to visiting those websites.
PROTECTION AND STORAGE OF THE INFORMATION WE COLLECT
Akron Brass deploys administrative, technical, and physical safeguards designed to safeguard the information that Akron Brass collects. However, no information system can be 100% secure. This means that Akron Brass cannot guarantee the absolute security of your Personal Data. Moreover, Akron Brass is not responsible for the security of information you transmit to us over networks that Akron Brass does not control, including the Internet and wireless networks. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Captium System, in your operating system, or on third party applications and websites.
RETENTION AND DESTRUCTION OF PERSONAL DATA
Akron Brass retains the information Akron Brass collects in an identifiable form as reasonably necessary and only for as long as required to fulfill the purposes for which Akron Brass collects the information and to comply with our legal obligations.
YOUR CHOICES AND RIGHTS
Access and Update. You can review and change certain aspects of your Personal Data by logging into our Captium Portal. You may also contact and notify us through the Contact Information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
Restrictions. You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing but we have retained it as permitted by law.
Portability. To the extent the Personal Data you provide Akron Brass is processed based on your consent, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.
Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by closing your Captium account and ceasing all use of the Captium System. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.
Right to be Forgotten. You have the right to request that we delete all of your Personal Data. We cannot delete your Personal Data except by also deleting your user account, and we will only delete your account when we no longer have a lawful basis for processing your Personal Data or after a final determination that your Personal Data was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies.
Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.
How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any of the methods listed under Contact Information. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Data, you may be charged a fee subject to a maximum set by applicable law.
If you do not wish to have your email address used by Akron Brass to promote our own products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from us. This opt out does not apply to information provided to Akron Brass as a result of a product purchase, or your use of the Captium System or our services.
CONSENT TO PROCESSING OF PERSONAL DATA IN THE UNITED STATES
If you are a resident of the European Economic Area (“EEA”), in order to provide our Captium System, products, and services to you, we may send and store your Personal Data outside of the EEA, including to the United States. Accordingly, your Personal Data may be transferred outside the country where you reside or are located, including to countries that may not or do not provide an adequate level of protection for your Personal Data.
Your Personal Data is transferred by Akron Brass to another country only if it is required or permitted under applicable data protection law and provided that there are appropriate safeguards in place to protect your Personal Data. By using the Captium System, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data that you provide directly to us on the Captium System. To ensure your Personal Data (other than Personal Data you provide directly to us on our Captium System) is treated in accordance with this Privacy Policy, Akron Brass uses Data Protection Agreements between Akron Brass and all other recipients of your data that include, where applicable, the Standard Contractual Clauses adopted by the European Commission (the “Standard Contractual Clauses”) or other lawful mechanisms for the transfer of EU Personal Data outside of the EEA. The European Commission has determined that the transfer of Personal Data pursuant to the Standard Contractual Clauses provides for an adequate level of protection of your Personal Data. Under these Standard Contractual Clauses, you have the same rights as if your data was not transferred to such third party.
USE OF THE CAPTIUM SYSTEM BY OTHERS
This Privacy Policy applies to anyone who uses or accesses the Captium System. Accordingly, you must provide this Privacy Policy to anyone who uses or operates a vehicle or Equipment that you rent, lease, own, or otherwise control or are responsible for. If you sell, rent, lease, or otherwise transfer your Equipment, it is your responsibility to delete all Equipment related information (such as Personal Data, GPS information, passwords, etc.) from the Captium System and contact us to transfer or cancel your account. If you do not delete this information, it may remain on the vehicle’s Captium System and may be accessible to future users of the vehicle.
CHILDREN UNDER 18
Our Captium System is not intended for children under 18 years of age. No one under age 18 may provide any information to or through the Captium System. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on our Captium System or on or through any of their features, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 18, please contact us.
CHANGES TO THIS PRIVACY POLICY
Akron Brass may update this Privacy Policy from time to time. The effective date of the current Privacy Policy is noted at the top of this page. Akron Brass encourages you to periodically review this page. You will be informed separately if needed, for instance should we process your Personal Data for other purposes than set out in this Privacy Policy. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically accessing the Captium System and reviewing this Privacy Policy to check for any changes.
CONTACT US
If you have any questions, concerns, complaints, or suggestions regarding our Privacy Policy or otherwise need to contact us, you may contact us at the contact information below or through the “Contact” page on our portal or our application, or by using the information below.
How to Contact Us:
Akron Brass Company
343 Venture Blvd
Wooster, OH 44961
Telephone: 1.800.228.1161
Email: akroncares@idexcorp.com