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Curt G. Joa, Inc. Privacy Statement

Last Revised: June 6, 2019

Curt G. Joa, Inc. and its subsidiaries and affiliates created this Privacy Statement to disclose our information gathering and dissemination practices for this website (http://www.joa.com).

Throughout this Privacy Statement, “information” includes personal information about you.

PLEASE READ THIS PRIVACY STATEMENT AND OUR TERMS AND CONDITIONS (“TERMS”) CAREFULLY. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY STATEMENT OR OUR TERMS, DO NOT USE OR VISIT THIS WEBSITE. BY USING OR VISITING THIS WEBSITE, YOU AGREE TO THE TERMS OF THIS PRIVACY STATEMENT AND OUR TERMS.

CONTACT INFORMATION
By email: PrivacyInquiries@joa.com

By postal mail:

Curt G. Joa, Inc. - Privacy Inquiries
100 Crocker Ave.
Sheboygan Falls, Wisconsin 53085
United States of America

WHAT PERSONAL INFORMATION DO WE GATHER FROM THOSE WHO VISIT THIS WEBSITE?
When you visit or use this website, we can collect information from and about you.
Information You Voluntarily Submit. We collect and store any information you enter on this website, or provide to us in offline contacts we have with you. Information is collected from visitors to this website in the following areas:

ORDER FORMS - Some areas of this website may allow you to order products or services, whether or not for a fee. In connection with these transactions, we collect data necessary to complete the transaction and that is furnished by you. This may include contact information, including first and last name, company name, postal address and country, email address and telephone number, comments and information provided in connection with products and services.

SURVEYS - At times, you may be asked to complete survey questions that appear on this website.

EMAIL - On several screens of this website, you also have an opportunity to communicate with us by email. You may also choose to provide your email address to receive communications from us or third parties.

CONTACT/INTERACT – You also may provide information when you contact or otherwise interact with us or a third party (for example, your search queries on this website, reporting an issue with this website).

Information Collected and Stored Automatically. When you browse this website, you and your web browser may also transmit information that we automatically collect. We can automatically collect information about you, including IP address (the Internet address of your computer), domain name of your Internet service provider, your geographic location, and aggregated information that cannot be used to specifically identify you when you use or visit this website, the web pages you visit and the time of your visit, and other click-stream data. This information may be combined with other personal information you have provided. The only other type of information automatically provided to us is the type of computer, operating system and browser you are using. This information is provided by your browser, which we use to improve the performance of this website.

We also can collect information about you from publicly accessible sources, our subsidiaries and affiliates, and our third party service providers and other partners.

We can combine any of the information we collect from or about you and use it in the manner described in this Privacy Statement.

Please also see HOW WE USE YOUR PERSONAL INFORMATION, WHERE WE STORE YOUR INFORMATION, DISCLOSING YOUR INFORMATION TO OTHERS, YOUR CHOICES REGARDING YOUR INFORMATION, YOUR RIGHTS and RETENTION below.
HOW WE USE YOUR PERSONAL INFORMATION
We use your personal information to communicate with you if and when necessary in connection with your use of this website, to process and respond to your questions and comments, or to send you material and information you request. We may use your information, subject to applicable law, including:
• To personalize and enhance your website experience and to allow us to deliver the type of content and product information in which you are most interested;
• To consider your suggestions;
• Possibly to respond directly to you for clarification;
• To process your request;
• To try to and answer your questions;
• To register you for an event, contest or sweepstakes;
• To allow you to participate in surveys;
• To provide you with email messages and other information regarding upcoming events, new services and general information about our products and services. (NOTE: You may elect not to receive these communications);
• For the purposes for which you provided it (for example, engaging in a transaction);
• To provide or to facilitate providing you with products and services;
• To provide this website to you, including any notifications or updates relating to this website;
• To notify you about changes to this website, our policies, Terms or any products or services we offer or provide though it;
• To send you information about your relationship or transactions with us;
• To identify you as a user of this website;
• To contact you with information, including marketing information, that we believe will be of interest to you, either by us or a third party;
• To customize our marketing;
• For testing, research, analysis and product and service development that we or a third party can perform regarding this website (for example, user base and website usage);
• To create anonymous data or de-identified data, which we or a third party can do and which we or a third party can use for any purpose;
• To aggregate data, which we or a third party can compile, and which we or a third party can do and can use for any purpose;
• To analyze how you use this website and to analyze this website, which we or a third party can do;
• To call you via telephone and send you electronic communications (for example, emails);
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
• To investigate, and deter against fraudulent, unauthorized, or illegal activity and otherwise protect our users and our business;
• To administer and troubleshoot this website;
• In any other way we describe to you at the time you provide your information; and
• As otherwise stated in this Privacy Statement and our Terms.
We may also use your website information in order to help diagnose problems with this website. We may use all information we collect to analyze statistical use patterns and demographic data (basically, where our visitors come from and what demographic characteristics they have) and to improve this website to better serve our customers. We use your IP address to help diagnose problems with our servers, and to administer this website. Your IP address is used to help identify you and your shopping cart and to gather broad demographic information. We may also prepare and keep statistical records and other data about you and other users of this website. We may hire third parties to help us collect and analyze such data, and we may share such statistical data with third parties. We use this information to help us make this website more useful to visitors -- to learn about the number of visitors to this website, what part of this website they are interested in, how long the use this website, and the types of technology our visitors use.
Please also see WHERE WE STORE YOUR INFORMATION, DISCLOSING YOUR INFORMATION TO OTHERS, YOUR CHOICES REGARDING YOUR INFORMATION, YOUR RIGHTS and RETENTION below.

WHERE WE STORE YOUR INFORMATION
We store the information that we collect on our systems. By using this website, you understand that your information can be transferred to countries outside of your country of residence, which may have data protection rules that are different from those of your country.

DISCLOSING YOUR INFORMATION TO OTHERS
Information may be disclosed to third parties in accordance with this Privacy Statement, subject to applicable law. Please note that a user can choose not to share certain information.
We may disclose your information with third parties with whom we have partnered to provide specific services to us or services on our behalf in connection with this website (for example, providing products or services, marketing, data analysis, enhancing the information collected from or about you, etc.). We can use third parties to perform any of the actions or activities allowed under this Privacy Statement. We can share information about you that they need to perform their functions and in accordance with our agreements with them.
In addition, we may be required to disclose your information to third parties to comply with law or in response to subpoenas, warrants, or court orders or in connection any legal process or cooperate with government or law enforcement agencies or officials or private parties, (including laws outside of your country of residence), fraud prevention, regulation, and other legal action or if we reasonably believe it is necessary to do so to protect us, our customers, or the public.
We also may be required to disclose your information to third parties to:
• Enforce or apply our Terms and other agreements;
• Protect our rights, reputation, safety and property or in an emergency, or that of our users or others;
• Resolve disputes;
• Protect against legal liability;
• Establish or exercise our rights to defend against legal claims; or
• Investigate, prevent or take action regarding suspected illegal activities, the rights, reputation, safety or property of us, users or others, violation of our Terms, policies or agreements or as otherwise required by law.
If we become involved in a merger, acquisition, sale of assets, joint venture, securities offering, financing, bankruptcy, reorganization, liquidation, dissolution, or other transaction or if the ownership of all or substantially all of our business otherwise changes, we may share or transfer your information to a third party or parties in connection therewith and it can be used subsequently by such third party or parties.
We may disclose your information to any subsidiary or affiliate of ours for purposes consistent with this Privacy Statement. Any subsidiary or affiliate of ours will be required to maintain that information in accordance with this Privacy Statement.
We or a third party can analyze how you use this website and can analyze this website.
We can share aggregated or de-identified information relating to visitors to and users of this website with any third party for any purpose.
We or a third party can analyze how you use this website and can analyze this website.

We can share your information other than as described in this Privacy Statement if we notify you and you consent to the sharing thereof.
We can share your information with any other individual or third party or service provider at your request.
We can disclose your information for any other purpose we describe to you at the time you provide your information.

Please also see WHAT PERSONAL INFORMATION DO WE GATHER FROM THOSE WHO VISIT THIS WEBSITE? above and DO NOT TRACK, ONLINE TRACKING AND OTHER TECHNOLOGIES below.

DO NOT TRACK, ONLINE TRACKING AND OTHER TECHNOLOGIES
At this time, we do not respond to “Do Not Track” signals sent from web browsers or other mechanisms that provide users the ability to exercise choice regarding the collection of personally identifiable information about a user’s online activities over time and across third party Internet services.
Third parties may collect personally identifiable information about an individual user's online activities over time and across different websites when a user uses this website.
We may place small data files, called "cookies," in the browser file of your computer's hard drive. Persistent cookies remain on the visitor’s or user’s computer after the browser has been closed. Session cookies exist only during a visitor’s or user’s online session and disappear from the visitor’s or user’s computer when they close the browser software. These cookies automatically identify your browser to our server whenever you interact with this website. We use the cookies to record website statistics. Most browsers automatically accept the cookies, but you usually can change your browser setting to prevent the acceptance of cookies. Certain web pages may not function properly if you choose not to accept cookies.
Below is a link to a resource regarding online tracking:
For Google Analytics, please see https://policies.google.com/privacy, https://policies.google.com/technologies/partner-sites, https://www.google.com/analytics/terms/ and https://tools.google.com/dlpage/gaoptout.

LINKS TO OTHER WEBSITES
We may create links to other websites that we think may be of interest to you. We do not endorse any other websites, and this Privacy Statement applies only to your use of this website. We have not reviewed the privacy policies of any websites we link to this website, and you should read the privacy policies of each website you visit to determine what information that website may collect about you.

SECURITY
Although we use physical, electronic, and administrative safeguards to help protect the information you submit via this website from accidental or unlawful destruction, loss or alteration and from unauthorized access, use, or disclosure, we cannot guarantee its absolute security. No Internet or electronic communication transmission is ever fully secure or error free. Internet or electronic communications, including those sent through this website, may not be secure. You should use caution whenever submitting information through this website and take special care in deciding which information you provide us with.

YOUR CHOICES REGARDING YOUR INFORMATION
You have choices regarding your information on this website.
1. Changing Your Information. You can make changes to your information, including accessing your information, correcting or updating your information or deleting your information by telephone at 920-467-6136 or by emailing us at PrivacyInquiries@joa.com.

2. Email Communications. You can make changes regarding receiving email communications from us by contacting by telephone at 920-467-6136 or by emailing us at PrivacyInquiries@joa.com.
3. Withdrawing Consent. You can withdraw your consent to our processing of your personal information at any time by emailing us at PrivacyInquiries@joa.com.
Please also see DO NOT TRACK, ONLINE TRACKING AND OTHER TECHNOLOGIES above and YOUR RIGHTS and RETENTION below.

YOUR RIGHTS
1. European Union Rights. The following rights apply in certain circumstances only to individuals in the European Union.

• To request confirmation of whether or not we process your personal information, details of the information that we hold about you and how we use it and to access your
personal information and to be provided with a copy, please email us at PrivacyInquiries@joa.com.

• To request rectification of your personal information: if you believe that the personal information we hold about you is inaccurate, you can request that we correct it and can also request us to complete personal information about you which is incomplete by emailing us at PrivacyInquiries@joa.com.

• To request deletion of your personal information on one of the following grounds, please email us at PrivacyInquiries@joa.com:

- you believe that it is no longer necessary for us to hold your personal information;

- we are processing your personal information on the basis of legitimate interests and you object to such processing and we cannot demonstrate an overriding legitimate ground for the processing;

- where our processing of your personal information is for direct marketing purposes and you object to such processing;

- you have provided your personal information to us with your consent and you wish to withdraw your consent and there is no other ground under which we can process your personal information; or

- you believe the personal information we hold about you is being unlawfully processed by us.

• To request that we restrict processing of your personal information on one of the following grounds, please email us at PrivacyInquiries@joa.com.

- where you believe the personal information we hold about you is inaccurate and while we verify accuracy;

- we want to delete your personal information as the processing is unlawful but you want us to continue to store it;

- we no longer need your personal information for the purposes of our processing but you require us to retain the information for the establishment, exercise or defense of legal claims; or

- where you have objected to us processing your personal information based on our legitimate interests and we are considering your objection.

• To request to object to our processing of your personal information where it is based on our legitimate interests or where such processing is for direct marketing purposes, please email us at PrivacyInquiries@joa.com.

• Data portability: to request to receive the personal information that you have provided to us in a structured, commonly used and machine-readable format and to transmit this to another data controller (where technically feasible) where the processing is based either on consent or on the performance of a contract, and the processing is carried out by automated means, please email us at PrivacyInquiries@joa.com.

• To lodge a complaint with a supervisory authority in an applicable European Union country if your request or inquiry is not satisfactorily resolved by us after emailing us at PrivacyInquiries@joa.com.

2. Processing. We process the information of individuals in the European Union based on one or more of the following legal bases:

• Performance of a contract: we or a third party process your website information to perform the contract that you have with us (for example, providing this website to you).

• Legitimate interests: we or a third party can use your information where we or such third party have legitimate interests to do so (for example, analyzing users’ behavior on this website for assessing website usability and processing information for business or legal purposes).

• Consent: we can ask for your consent to use your information for specific purposes. You can withdraw your consent to our processing of your personal information at any time by emailing us at PrivacyInquiries@joa.com.

• Legal obligation: we may be required to use your information to comply with a legal obligation (for example, complying with law, in response to legal process or cooperating with government or law enforcement agencies or officials or private parties).

• The processing is necessary to protect the vital interests of our users or of others (for example, processing personal information, including disclosing data with law enforcement agencies in case of threats to the safety of users or of others).

2. Cross-Border Transfers. For transfer of your personal information from the European Economic Area to countries that are not considered adequate by the European Commission, we have put in place adequate measures. We also participate in the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks regarding the collection, use and retention of personal information from European Union member countries and Switzerland, respectively. We have certified with the U.S. Department of Commerce that we adhere to the Privacy Shield Principles. To learn more about the Privacy Shield Principles, visit https://www.privacyshield.gov/welcome. If you have any inquiries or complaints about our handling of your personal information under Privacy Shield, or about our privacy practices generally, please contact us by email at PrivacyInquiries@joa.com. We have further committed to cooperate and comply with the panel of European Data Protection Authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) in the resolution of any Privacy Shield complaints we do not otherwise satisfactorily address with you directly. Under certain conditions, as more fully described at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you can pursue binding arbitration when other dispute resolution procedures have been exhausted.
Please see this Privacy Statement regarding:
o the types of personal information we collect,
o the purposes for collection and use of such personal information,
o the types of third parties to which we can provide personal information and the purposes for which we can do so; and
o the right of individuals to access their personal information and the choices and means we offer individuals for limiting the use and disclosure of their personal data.
If we transfer personal information received under the Privacy Shield to a third party, the third party's access, use and disclosure of the personal data must also be in compliance with our Privacy Shield obligations, and we will remain liable under the Privacy Shield for any failure to do so by the third party unless we prove we are not responsible for the event giving rise to the damage.
Please see our Privacy Shield registration at https://www.privacyshield.gov/list. We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC). We may be required to disclose personal information that we handle under the Privacy Shield in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Please also see WHAT PERSONAL INFORMATION DO WE GATHER FROM THOSE WHO VISIT THIS WEBSITE?, HOW WE USE YOUR PERSONAL INFORMATION, WHERE WE STORE YOUR INFORMATION, DISCLOSING YOUR INFORMATION TO OTHERS and YOUR CHOICES REGARDING YOUR INFORMATION above and RETENTION below.
RETENTION

We will retain your personal information for as long as reasonably necessary for the purposes described in this Privacy Statement, while we have a legitimate business need to do so in
connection with your use of this website, or as required by law (for example, for legal, tax, accounting or other purposes), whichever is the longer.

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

Please also see YOUR CHOICES REGARDING YOUR INFORMATION and YOUR RIGHTS above.

CHILDREN
We do not knowingly collect personal information from children under age 18. If you are under the age of 18, please do not access, use or submit any personal information through this website. If you have reason to believe that we may have accidentally received personal information from a child under age 18, please contact us immediately by email at PrivacyInquiries@joa.com or by telephone at 920-467-6136.
CHANGES TO THIS PRIVACY STATEMENT
We reserve the right to update or modify this Privacy Statement at any time and from time to time without prior notice. Please review this Privacy Statement periodically, and especially before you provide any information. This Privacy Statement was made effective on the date indicated above.