Xamax Privacy Statement
Effective as of May 25, 2018

Purpose
Xamax Industries, Inc., including its subsidiaries and affiliates (collectively, “Xamax”, “we” or “us”) respects the privacy of its customers, and website visitors (collectively “you”). The Xamax Privacy Statement (the “Privacy Statement”) describes the information that we collect, how we obtain the information, and how we may use or disclose that information. This Privacy Statement also describes the measures we take to protect the security of the information and how individuals can contact us about our privacy practices.

Xamax complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and please visit https://www.privacyshield.gov/.

Scope
This Privacy Statement covers our privacy practices with respect to the collection, use, and disclosure of personal information obtained through:

1. Interaction with all Xamax web-based properties referred to as the Xamax Website (the “Xamax Website”).

You should review this Privacy Statement carefully, because if you do not agree with our practices, you should not use the Xamax Website. By using the Xamax Website, you accept and agree to our privacy practices.

Definitions
For the purposes of this Privacy Statement, where not otherwise defined, the following terms have the meanings set forth:

Customer” means any entity that purchases Xamax products and services.
Providers” means third parties that link to or from Xamax Website or provide services, features or information in connection with Xamax Website.

How We Collect Information
As further described below, we collect information from visitors to the Xamax Website and users of services from several sources:
• fill out forms on a Xamax Website;
• submit data and content via a Xamax Website, engage in a chat, post a comment, participate in forums or other interactive features of a Xamax Website or request further information or services from us;
• enter a contest or promotion we sponsor;
• report a problem with a Xamax Website;
• contact us;
• complete our surveys; or
• subscribe to our email newsletters.

Information We Collect
We collect information including, without limitation, company name and address, mailing address, email address, IP address and telephone number.
We collect details about your website visits, including, but not limited to, your IP address, usage patterns, traffic data, location data, logs and other communication data and the resources that you access, as well as information about your computer and internet connection, including your operating system and browser type.
In addition to the foregoing, Xamax may collect information on behalf of Customers who have provided forms, namely
• Company name and address.
• User’s contact information including, first name, last name, phone number and email address.
• Informational requests and requests for pricing or quotes.
• Transactional information about the user’s movements throughout the site.
• Demographic information about the user base as a whole.

How We Use Information Collected
We use information that we collect about visitors to the Xamax Website for the following purposes:
• To present Xamax Website and its content in a suitable and effective manner for you and for your computer or mobile device.
• To improve the Xamax Website
• To provide you with information, products or services that you request from us
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and Xamax, including without limitation, Xamax Website Terms and Conditions.
• To notify you about changes to a Xamax Website or obtain any required consent.
• To allow you to participate in interactive features of a Xamax Website when you choose to do so.
• To track your browsing behavior, such as the pages you visited over time.
• To improve your Xamax Website and content experience.
For example, Xamax uses a third party for reporting and analytics to measure the effectiveness of our Xamax Website, marketing efforts for the Xamax Website (for example, the effectiveness of email promotions) and to identify areas for improvement.

Sharing of Information We Collect
As set forth more fully above, we collect certain data. Except as expressly set forth herein, or with your explicit consent, we do not share, sell, rent or trade information collected with third parties for their promotional purposes.
To the extent we are legally permitted to do so, we will take reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of legal process.
Users may withdraw consent at any time by clicking on the “unsubscribe” link located in the emails sent by Xamax or via your user preference settings. For more information, see the section; Communication Preferences and Choices below.

Public Forums and Comments
Your contributions in public forums, including comment threads, are posted on and transmitted to other visitors of the Xamax Website at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other visitors of the Xamax Website with whom you may choose to share your contributions. Therefore, we cannot and do not guarantee that your contributions will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures contained on the Xamax Website. You understand and acknowledge that, even after removal, copies of your contributions may remain viewable in cached and archived pages, or might have been copied or stored by other websites. Proper access and use of information provided on the Xamax Website, including your contributions, is governed by the Xamax Website Terms and Conditions and known or suspected violations should be reported to our Privacy Officer via email at info@xamax.com. We recommend that you do not share personal information in your contributions.

International Transfer of Data
Xamax may store and process any information collected in connection with the Xamax Website in any country where we have facilities or in which we engage service providers. The Xamax office is provided below. By using Xamax Website, you consent to the collection, storage, transfer and processing of information outside of your country of residence, including in the United States.

Xamax Industries, Inc.
63 Silvermine Rd
Seymour, CT 06483

General
If you ask us to contact you about goods and services that may be of interest to you, we may use your personal information or permit selected third parties to use your personal information to provide you with such services. Users may withdraw consent at any time by clicking on the “unsubscribe” link located in the emails sent by Xamax or via your user preference settings. For more information, see the section; Communication Preferences and Choices below.

Transfers of Personal Data
Xamax complies with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information transferred from the European Economic Area and Switzerland to the United States.

Data Integrity and Purpose Limitation
Xamax limits collection of personal information to the information that is relevant for the purposes of processing and we will not process such personal information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you. To the extent necessary for those purposes, we will also take reasonable steps to ensure that personal information is reliable for its intended use, accurate, complete and current.

Security Statement
Xamax maintains reasonable and appropriate measures to protect the personal information obtained through the Xamax Website from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Accessing and Correcting Your Personal Information
You may send us an email at info@xamax.com to request access to, correct or delete any personal information that you have provided to us in connection with the Website. We will make reasonable efforts to respond to such requests, but reserve the right to enforce reasonable limits in cases where the legitimate rights of persons other than the individual would be violated or where the burden or cost of providing access would be disproportionate to the risks to the individual’s privacy.

Customer End-User Data
Since each Customer is in control of what information, including any personal information, it collects from its users, how that information is used and disclosed, and how that information can be changed, users of the Xamax Website must contact the applicable Customer administrator identified within the Customers privacy policy with any inquiries about how the Customer uses and discloses personal information and how to access or correct personal information contained in Customer data.

Communication Preferences and Choices
We provide certain choices regarding the information website visitors provide to us. We have created mechanisms to provide you with the following control over your information when using the Xamax Website. If you do not wish to have your email address used for promotional purposes by Xamax, you may withdraw consent at any time by clicking on the “unsubscribe” link located in the emails sent by Xamax or by contacting: info@xamax.com.

Third Party Websites and Applications
This Website may link to websites that are not owned or controlled by Xamax. As such, this Privacy Statement does not apply to information collected on any third-party site or by any third-party application that may link to or be accessible from the Website. In addition, Customers and other third parties, including our business partners, may develop applications or provide services to you or other third parties using the Xamax Website. This Privacy Statement does not apply to information collected by Customers, our business partners and other third parties or third-party applications or services, even if this information is collected using our Website.

Changes to Our Privacy Statement
Xamax reserves the right to update or change this Privacy Statement from time to time. If we make material changes to this Privacy Statement, we will notify you through an appropriate online notice (and obtain your consent where required by applicable law). Your continued use of the Xamax Website is deemed to be acceptance of any updates or changes we make to this Privacy Statement and as such, we ask that you review the Privacy Statement periodically for any updates or changes that we may have made.

Contact Information
To ask questions or comment about this Privacy Statement and our privacy practices or if you need to update, change or remove your information, contact us at: info@xamax.com, or Xamax Industries, Inc., 63 Silvermine Rd, Seymour, CT 06483

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