Privacy

BRENNAN INDUSTRIES PRIVACY STATEMENT

[Effective December 2022]

Personal Information Brennan May Collect

Brennan Industries, Inc. and its affiliated entities (collectively, “Brennan”) manufacture, market, distribute, sell and service hydraulic and pneumatic products in several countries. Through Brennan’s global headquarters facility in Solon, Ohio (USA), and our regional headquarters in Mississauga, Ontario (Canada) and Walsall, England (UK), we may collect, retain and process Personal Information (defined below) from:

• Prospective, present and past customers (including distributors and industrial consumers)
• Prospective, present and past employees and independent contractors
• Prospective, present and past suppliers of goods and services

In this Privacy Statement, “Personal Information” means any information provided to or collected by Brennan (a) about an identifiable individual, or an individual whose identity may be inferred or determined from such information (in isolation or collectively with other information possessed by Brennan), or (b) is otherwise designated as Personal Information expressly subject to protection by applicable law. This Privacy Statement applies regardless of how Personal Information is recorded (for example, electronically or on paper). Personal Information does not include, and this Privacy Statement does not apply to, any information (a) expressly excluded from protection by applicable law because it is available in the public domain or otherwise (“Exempted Information”), (b) about companies or other entities (“Entity Information”), or (c) respecting more than one individual where the identity of the individuals is not known and cannot be inferred from such information (“Aggregated Information”). Brennan retains the right to use Exempted Information, Entity Information and Aggregated Information in any way that is not prohibited by applicable law.

Generally, our collection, retention and processing of Personal Information is limited to the extent necessary for the efficient and effective conduct and administration of our business activities in conformity with applicable law. When Personal Information is no longer required for these purposes, Brennan uses secure procedures to destroy, delete, erase or convert such Personal Information into an anonymized form.

Information technology, privacy and security personnel based at our global headquarters in Solon, Ohio (USA) are responsible for the security and processing of Personal Information we obtain, regardless of where such information was originally collected or may be stored. Similarly, our Chief Privacy Officer based at our global headquarters in Solon, Ohio (USA) is responsible to ensure our global compliance with all applicable data privacy laws and regulations, as well as our response to your inquiries regarding your Personal Information and our policies and practices.

Our Privacy Policies

Brennan and its many employees located around the world maintain a corporate culture strongly committed to compliance with law, ethical business practices and respecting the rights of our prospective, present and past customers, employees, contractors and suppliers. Consistent with this culture, this Privacy Statement explains our policies for protecting your Personal Information. Brennan takes the protection of your Personal Information seriously. To the extent Personal Information is subject to this Privacy Statement, Brennan takes commercially reasonable steps to maintain the confidentiality of such information. In all cases, Brennan complies with its obligations under applicable law regarding the collection, use and disclosure of your Personal Information.

Because privacy laws differ among and within the countries in which we operate facilities and conduct our business, we’ve included more detailed information on how we comply with privacy laws in the applicable jurisdictions.

Our Privacy Commitments

• We are accountable for any Personal Information we obtain from you.
• We tell you why we need your Personal Information when we request it.
• We use your Personal Information only for the stated purpose, or as the law otherwise requires or permits.
• We do not sell your Personal Information for monetary consideration.
• We keep your Personal Information safe. We take information security seriously.

If we’re required to involve third parties to provide information, products or services to you (for example, manufacturers, consultants or advisors), we may need to share your Personal Information with them in the ordinary course of business. But we will tell you – and ensure they understand and respect your rights. They must also comply with applicable privacy laws – which may be different from the law in your country.

If the law requires, we may also need to share your Personal Information with the government or other regulatory entities.

If you want to know what Personal Information we have about you, please ask us – after we verify your identity, we will tell you unless the law precludes us from doing so. Simply contact us at [email protected]

If you ask us for marketing material or attend an event, we may keep your contact information in a database so that we can contact you in the future. If you don’t want this, you may contact us via our website at [hyperlink] www.brennaninc.com to update your information or preferences, or unsubscribe from any marketing lists.

We Welcome Your Questions

This Privacy Statement is a general overview of our privacy policies, practices and your rights, and we strongly encourage you to read this Privacy Statement in its entirety. You’ll find more detail in the following sections regarding specific privacy policies we follow, and rights you may enjoy, in countries where we operate facilities and conduct our business.

If you have any questions regarding our privacy policies, or require information about what Personal Information we have about you, simply contact us at [email protected]

 Privacy Policies by Country

In addition to the provisions explained elsewhere in this Privacy Statement, the following provisions describe our specific privacy policies pursuant to which Brennan collects, stores, protects, uses and discloses Personal Information (as defined herein) in Canada.

Personal Information Brennan May Collect

We may collect Personal Information from you for the purpose of (a) providing you with information regarding employment opportunities, business opportunities, or our products or services; (b) determining whether to enter into an employment or business relationship with you; (c) engaging in or administering an ongoing employment or business relationship with you; or (d) other circumstances when you provide us with Personal Information about yourself. Absent your consent to different treatment, we hold Personal Information we collect from you in confidence and do not disclose it to third parties unless expressly or implicitly authorized by you or where permitted or required by applicable law.

In the course of our relationship with you, Brennan may collect, use, and sometimes disclose as authorized different types of Personal Information for various purposes associated with our employment or business relationship, including the products and services we provide. While it’s impractical to list all of types of Personal Information we may collected, use or disclose as authorized, the types of Personal Information we most probably may collect include:

• your full name;
• contact information, such as your address, telephone number, email address, or job title;
• information to help establish your identity;
• information regarding your business or employment requirements, situation, and interests;
• whether you have subscribed to, or unsubscribed from, our mailing lists or respond to any of our marketing inquiries;
• information regarding your organization or other organizations, including information regarding directors, officers, or employees of our suppliers, distributors, customers and prospective customers;
• information regarding your personal preferences;
• your payment or other financial information; and
• any other Personal Information you voluntarily provide to us.

In some cases, we collect Personal Information from third parties such as suppliers, vendors, distributors, customers, prospective customers, regulatory and legal authorities, other organizations with whom we or you have dealings, such as government agencies, credit reporting agencies, recruitment agencies, information or service providers, and from publicly available records.

Use and Disclosure of Personal Information

Brennan uses and discloses Personal Information for the purposes set out in this Privacy Statement. Under no circumstances will Brennan sell your Personal Information for monetary consideration.

Brennan may use and disclose Personal Information for any of the following purposes:

• Establishing your identity and compliance with legal or regulatory obligations;
• Providing our products or services, or information about them;
• Administering our business relationship, which may include credit inquiries, invoicing, billing and collections;
• Research and development regarding products and services we may provide to you or other customers or prospective customers;
• Recruiting, interviewing, assessing, offering, terminating and administering your employment with Brennan;
• Analytics, including to track and manage your consent or other preferences, registrations and any unsubscribe or “do not track” requests;
• General administration, recordkeeping and analysis in connection with your employment with Brennan, or our provision of products and services to you;
• Answering your questions, and/or providing you with information or materials you asked to receive;
• Conducting market research;
• Marketing our products and services to you by email or other means if you are subscribed to our mailing lists;
• Maintaining the accuracy of your information and preferences;
• Regulatory compliance;
• Ensuring security and for crime prevention (for example: we may have CCTV cameras installed on our premises and data is captured on cameras for security purposes);
• Any purpose which is required or permitted by applicable law; and
• Any other purpose disclosed to you and to which you consent.

Marketing email and text messages sent by Brennan will give you the opportunity to update your contact details and mailing list preferences or unsubscribe from our mailing lists altogether. You may also contact us via our website at [hyperlink] www.brennaninc.com, and ask us to update your information or preferences, or unsubscribe from any marketing lists.

Brennan allows certain authorized third party providers to track and store certain information about visitors to our websites (including domain names, IP addresses and page views).

Brennan may also disclose Personal Information to organizations that perform services for us. Personal Information will only be provided to such organizations if they agree by way of contract to provide appropriate protection for such information.

Personal Information may also be subject to transfer to another organization in the event of corporate transaction such as a merger, or change of ownership. This will occur only if the transferee party(ies) maintain policies similar to those described in this Privacy Statement for the protection and use of Personal Information.

Our Websites and Cookies

In general, you can use our websites without giving us any Personal Information. If you are one of our anonymous visitors, please bear in mind that we may still record certain analytical information as disclosed in Brennan’s [hyperlink-2] Cookie Notice.

Brennan may use cookies, web beacons/pixel tags, log files and other technologies to collect certain information about visitors to our websites, and recipients of our newsletters, invitations and other communications. To find out more, review Brennan’s [hyperlink-2] Cookie Notice.

When you visit our websites, we may collect Personal Information about your visit, including your IP address, your geographic region (determined from IP address), clickstream through our website, the date and time or your visit, information about your device and network such as the browser you use and its configuration, your connection speed, the pages you view or search for on our website, what links you click, what you download, our page response times, any download or other errors, the length of your visit, and whether the emails we send are opened.

We may use this information to improve the functionality of our website, to tailor or improve the content that we may send or show you, and for analytical purposes to understand how visitors interact with our website, messages and the information we provide.

Consent

Your provision of Personal Information to Brennan means you agree and consent to our collection, use and disclosure of your Personal Information under this Privacy Statement. If you do not agree with these terms, do not provide any Personal Information to us. However, while providing Personal Information is optional, employment with Brennan, as well as certain information, products and services, can only be offered if you provide required Personal Information to us. Accordingly, we may not be able to offer employment, or provide such information, products or services, to you if you choose not provide us with required Personal Information.

You may give your consent for the collection, use and disclosure of your Personal Information in a number of different ways, such as (a) expressly by (i) signing (including a digital signature or acknowledgement) a document, (ii) agreeing through electronic means or (iii) verbally; or (b) implicitly by providing the Personal Information voluntarily.

There may be circumstances where you have provided Personal Information for one purpose, and Brennan later needs to use that Personal Information for another purpose. In such circumstances, Brennan will seek your consent to use the information for the new purpose unless applicable law requires or permits or us to use such Personal Information for that other purpose.

Please note that there are circumstances where the collection, use and/or disclosure of Personal Information may be justified or permitted without consent, or where Brennan may or must disclose Personal Information without consent, in accordance with applicable law.

You have the right to revoke your consent to the collection, use and disclosure of your Personal Information at any time. Simply contact us at [email protected] However, revocation of your consent may prevent us from providing services or products to you; in such circumstances, we will discuss with you the reason we need your Personal Information and why the revocation of your consent affects our ability to provide our services or products to you.

Storage and Security

Brennan has implemented commercially reasonable means, procedures and processes to maintain physical, procedural and technical security for Personal Information.

Brennan holds Personal Information principally in secure, virtual (or cloud) storage networks or physical storage media (which may be in electronic or printed form) located in cities where Brennan maintains facilities, or at secure, off-site storage facilities. All such Personal Information may be accessed by Brennan personnel who need to know such information for a purpose addressed in this Privacy Statement.

Personal Information you provide to Brennan may be stored outside of the jurisdiction in which you live. In such cases, Personal Information may be subject to the applicable laws of the jurisdiction(s) within which it is collected, used, stored and/or disclosed, and may be accessed by governmental and law enforcement authorities in those jurisdictions.

Accuracy and Access

Brennan is committed to ensuring any Personal Information you provide and we retain in our possession is as accurate, current and complete as necessary for the purposes for which we use that information.

You have a right to request access to your Personal Information and to request a correction to it if you believe it is inaccurate. To access and/or correct the accuracy of your Personal Information, please submit your request and/or corrections to us via the contact information provided below.

We endeavor to provide timely access to your Personal Information. However, we may require you to verify your identity to our satisfaction prior to doing so. Further, there may be circumstances where access cannot be granted. For example, we will not grant access where doing so would lead to the disclosure of Personal Information of another individual and that individual refuses to provide consent to the disclosure, or where the information is subject to legal restrictions. In such cases you will be notified of the reason why it is not possible to grant access to your Personal Information.

Changes to Our Practices and this Privacy Statement

Brennan will from time to time review and revise its privacy practices and this Privacy Statement. In the event of any amendment, an updated Privacy Statement will be posted on our website.

Your continued access to and/or use of our website or provision of Personal Information to us after any such changes constitutes your acceptance of, and agreement to this Privacy Statement, as revised. Please periodically review this Privacy Statement so that you know what Personal Information we collect, how we use it, and with whom we may share it.

Contact Us

If you ever have any questions, complaints or concerns regarding this Privacy Statement, any Personal Information you have submitted to Brennan, or if you would like to:

• access Personal Information that you have already provided so that you can correct or update it, or request that it be deleted, or
• report any violation of this Privacy Statement

you may contact Brennan’s Chief Privacy Officer by email at [email protected], or by mail at:

Brennan Industries, Inc.
Attn: Chief Privacy Officer
290 Courtneypark Drive East
Mississauga, ON L5T 2S5

In addition to the provisions explained elsewhere in this Privacy Statement, the following provisions describe our specific privacy policies pursuant to which Brennan collects, stores, protects, uses and discloses Personal Information (as defined herein) in China.

China Data Protection Laws

Your Personal Information will be treated securely and in strict confidence.

This Privacy Statement explains what Personal Information we collect, store and process, why, how it is legal and your rights. In order to do our best to be transparent, this Privacy Statement will be updated on an ongoing basis.

We decide what to do with your Personal Information in a different way in each country and so each of our subsidiaries that collects, stores and uses Personal Information in a particular country is a separate ‘data controller’. The data controller is responsible for the processing of your Personal Information according to applicable data protection laws (“Data Protection Laws”). Each country has different Data Protection Laws. In China, the major Data Protection Laws include:

• The Decision of the Standing Committee of the National People’s Congress on Strengthening Network Information Protection.
• The Cybersecurity Law of the PRC
• The Consumer Rights and Interests Protection Law of the PRC

We take your privacy very seriously and we ask that you read this Privacy Statement carefully in its entirety. It contains important information regarding:

• Your rights
• The Personal Information we collect about you and why we collect it;
• What we do with your Personal Information; and
• With whom we share your Personal Information.

If You Need Accessibility Assistance

If you would like this Privacy Statement in another format (for example: audio, large print, braille) please contact us.

Contact Us

If you ever have any questions, complaints or concerns regarding this Privacy Statement, any Personal Information you have submitted to Brennan, or if you would like to:

• access Personal Information that you have already provided so that you can correct or update it, or request that it be deleted, or
• report any violation of this Privacy Statement

you may contact Brennan’s Chief Privacy Officer by email at [email protected], or by mail at:

Brennan Industries, Inc.
Attn: Chief Privacy Officer
NO 2, Xinfeng Road,
Langxia Town, Jinshan District,
Shanghai P.R.C 201516

Changes to Our Practices and this Privacy Statement

We may change this Privacy Statement from time to time. You should check this Privacy Statement occasionally to ensure you are aware of the most recent version.

Useful Words and Phrases

Please familiarize yourself with the following words and phrases as they have particular meanings in the Data Protection Laws and are used throughout this Privacy Statement:

Words Meanings
Personal Information Personal Information includes any information from which a living individual can be identified, such as:
• names, addresses, telephone numbers, email addresses, photographs, and voice recordings;
• expressions of opinion about data subjects (and their own expressions of opinion/intentions); and
• information which on its own does not identify an individual but which would identify them if put together with other information we have or are likely to have in the future.
Sensitive Personal Information or Special Categories of Data Any Personal Information relating to:
• racial or ethnic origin;
• political opinions or affiliations;
• religious or philosophical beliefs or beliefs of a similar nature;
• trade union membership;
• physical or mental health or condition;
• sexual life or orientation; or
• genetic data or biometric data.
Processing Virtually anything that can be done with Personal Information, including:
• obtaining, collecting, recording, retrieving, reviewing, consulting, storing, using or holding;
• organizing, structuring, adapting or altering;
• disclosing, disseminating or otherwise making available; and
• aligning, combining, restricting, blocking, erasing or destroying.
Data Subject Individual to whom the Personal Information relates.
Supervisory Authority Authority responsible for implementing, overseeing and enforcing Data Protection Laws.
Data Controller Person who determines the purposes for which, and the manner in which, any Personal Information is processed.
Data Processor Person who processes Personal Information on behalf of Data Controller.
Data Protection Laws Laws that govern the handling of Personal Information and Sensitive Personal Information, including those identified in this Privacy Statement.

Personal Information Brennan May Collect

• Personal Information provided by you, including:

• your name
• address
• phone number
• email address
• date of birth and other identity documentation that we need to collect to comply with legal and regulatory requirements
• information you share with us to help us understand your situation, your hobbies and preferences
• information you share with us in the ordinary course of our commercial or employment relationship

• Sensitive Personal Information – If we ask you to provide Sensitive Personal Information, we will explain why we need it, how we intend to use it and your rights. If required by applicable Data Protection Laws, we will first ask you for your consent.

• Personal Information about other individuals – If you give us Personal Information on behalf of someone other than you, you confirm that the other person has appointed you to act on his/her behalf and has granted permission for you to provide his/her Personal Information to us.

• Personal Information provided by third parties – We will collect Personal Information directly from you, from authorized representatives and as otherwise permitted or required by applicable law. At times, we will also collect Personal Information from third parties such as regulatory and legal authorities, other organizations with whom you have dealings or who have a legal interest in such Personal Information, government agencies, credit reporting agencies, financial institutions, recruitment agencies and other people connected to recruitment, information or service providers, introducers and referrers and from publicly available records. We may obtain Personal Information about you from third parties in order to verify your identity, carry out anti-money laundering, anti-terrorism, sanctions screening and other background and credit checks. In performing these checks, Personal Information provided by you may be disclosed to that third party which may keep a record of that information. All Personal Information provided by you will be treated securely and strictly in accordance with the Data Protection Laws.

Why Brennan Collects and Processes Personal Information

We collect and use your Personal Information for any purpose not prohibited by applicable law, including Data Protection Laws, including:

• Provide our products and services (including information or materials you may have requested).

• Comply with legal and regulatory obligations (including establishing your identity in order to comply with anti-money laundering regulations and our other legal and regulatory obligations which may require you to provide name, address, employment/business information, and/or other legally mandated forms of identification).

• Carry out commercial and employment administrative functions (including the collection of names, addresses, government identification numbers, banking, financial details and creditworthiness for, among other lawful purposes, billing and collections, carrying out searches and checks, maintaining internal records, maintaining and developing our commercial or employment relationship with you, carrying out recruitment activities for employment and contract employee placement with us, analyzing and managing the conduct of our business activities and records).

• Carry out business development and marketing efforts (including market research, marketing our own products and services to you, keeping your information and preferences accurate, tracking and manage your consent preferences, event reservations and any unsubscribe requests, and sending you marketing materials, press releases, and other communications we think will be of interest to you and/or your business).

• Maintain personal security (including to help ensure security and for crime prevention – we may have CCTV cameras installed at the entrances to our premises and CCTV data is captured on cameras).

• To monitor our website usage to improve our services (To find out more, review Brennan’s [hyperlink-2] Cookie Notice).

If you have consented to receive marketing materials from us, you may contact us via our website at [hyperlink] www.brennaninc.com to update your information or preferences, or unsubscribe from any marketing lists.

Legal Bases for Collecting and Processing Personal Information

Under applicable Data Protection Laws, Brennan is permitted to collect and process your Personal Information for any number of lawful purposes, including:

• Consent: We may ask for consent to collect and use your Personal Information, and will always do so when required by applicable Data Protection Laws. We will collect and use your Personal Information in accordance with the terms of your consent, as well as any other manner not prohibited by law.

• Commercial or employment relationship: To effectively carryout our commercial or employment relationship, we may be required to collect and process your Personal Information for the purposes of supplying you products and services you purchase from Brennan, billing and collecting for such products and services, providing customer service, processing your pay and benefits as our employee or to satisfy our legal obligations or requirements. By engaging in commercial activity with Brennan, or accepting employment with us, you agree that we may do so.

• Legal obligations: Where we are subject to legal obligations to collect and process your Personal Information for the purposes of compliance with applicable laws; for example, we are required to identify individuals to comply with anti-money laundering regulations in many countries and are required to gather and maintain records in compliance with labor, employment, health and safety laws and regulations. We also have obligations pursuant to financial and tax legislation and reporting obligations in respect of tax administration.

• Legitimate interests: Processing your Personal Information is also legal if it is based on our ‘legitimate interests’. To process on this basis, we have considered the impact on your interests and rights, and have placed appropriate safeguards to ensure that the intrusion on your privacy is reduced as much as possible.

The following are examples of the purposes for which we will process your Personal Information on this basis:

• To carry out commercial and employment administration functions – to enable us to maintain our necessary business records.
• To ensure regulatory compliance – for example, to ensure we are not prohibited by applicable law from supplying our products or services to a particular customer or to satisfy our legal responsibilities to our employees.
• To permit us to pursue available remedies or limit any damages that we may sustain.
• To permit us to manage and respond to any complaints.
• To liaise with representatives of customers that are entities rather than individuals.
• To market, sell, distribute, deliver and bill and collect payments for the products and services we supply to customers, including providing associate customer service.
• To carry out recruitment, hiring and associated administrative activities, including those required by applicable law.

Please be aware that you have the right to object to the processing of your data for any of the legitimate interests identified. To do so, simply contact us at [email protected] or via the other contact information provided in this Privacy Statement.

Sensitive Personal Information

In certain circumstances, including the reasons and exceptions explained below, we may collect and process your Sensitive Personal Information:

• Consent: You may give us your explicit consent for us to process your Sensitive Personal Information where doing so is necessary for the effective administration of our commercial or employment relationship.

• Vital Interests: It may be necessary for Brennan to collect and process your Sensitive Personal Information to enable us to protect your vital interests. For example, we may be required to process your medical and/or health-related Personal Information in the administration of employee benefits or to protect your personal safety or life while you are present at one of our facilities or attending an event away from our facilities.

• Manifestly Public Personal Information: In circumstances where you manifestly make public your Sensitive Personal Information, and only when it is necessary for our purposes and permitted by the applicable Data Protection Laws, we may collect and process such manifestly public Personal Information. For example, we may ask you to provide your personal dietary requirements when you attend a Brennan meeting or event. We consider you to have made this Sensitive Personal Information manifestly public to Brennan to help us protect you and to ensure your health and safety. We will keep this manifestly public Sensitive Personal Information confidential and restrict it to only those persons who need to know.

• Legal claims: When we are establishing or defending legal claims.

Persons Who May Access Your Personal Information

In the course of marketing and selling our products and services, operating our business, administering our relationship with our employees and satisfying our regulatory compliance obligations, we may disclose your Personal Information to:

• Other Brennan offices, group entities and affiliates (including those located outside of China).
• Third party product and service suppliers, independent contractors and advisors, including the administrative requirements associated with our relationship with such providers.
• Providers of certain business support products and services, including logistics and freight forwarding, information technology, data security, banking, payment, insurance, credit checking, archiving and data storage.
• Providers of marketing, business development, customer relationship management and associated support products and services.
• Legal and or regulatory authorities, including disclosures we may be required to make to comply with applicable law, regulations or court orders.
• Your Personal Information may also be subject to transfer to another organization in the event of corporate transaction such as a merger, combination or acquisition, or change of ownership of our corporate organization or business. This will occur only if the transferee party(ies) maintain policies similar to those described in this Privacy Statement for the protection and use of Personal Information.
• Persons whom you instruct us to disclose, or to whom you consent to disclosure of, your Personal Information.

Transfers of Your Personal Information Outside of China

Brennan conducts its business through affiliated entities on a global basis. Accordingly, when necessary or useful to the operation or administration of our business, Brennan will transfer applicable Personal Information among our affiliated entities and between our facilities, including to facilities located outside of China.

Any transfer of your Personal Information from Brennan affiliates in China to Brennan affiliates in any country outside of China will only be performed in compliance with applicable law and subject to industry standard data protection and privacy mechanisms that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.

How Brennan Maintains the Security of Your Personal Information

Brennan has implemented commercially reasonable means, procedures and processes to maintain physical, procedural and technical security for Personal Information.

Brennan holds Personal Information principally in secure, virtual (or cloud) storage networks or physical storage media (which may be in electronic or printed form) located in cities where Brennan maintains facilities, or at secure, off-site storage facilities. All such Personal Information may be accessed by Brennan personnel who need to know such information for a purpose addressed in this Privacy Statement.

If you have any concerns about the security of your Personal Information, simply contact us at [email protected]

How Long Brennan Retains Your Personal Information

We retain Personal Information in accordance with our internal document retention policies, contractual terms and where necessary for us to meet our legal and regulatory obligations. We utilize these criteria to delete Personal Information when it is no longer necessary for us to retain it.

Complaints to the Regulator

It is important that you read this Privacy Statement in its entirety. If you believe Brennan has collected or processed your Personal Information in violation of this Privacy Statement or applicable Data Privacy Laws, you should contact us immediately at [email protected] Similarly, you may complain to the competent supervisory authority.

Contact the CAC (Cyberspace Administration of China) at this link: [hyperlink] http://www.cac.gov.cn/index.htm

In addition to the provisions explained elsewhere in this Privacy Statement, the following provisions describe our specific privacy policies pursuant to which Brennan collects, stores, protects, uses and discloses Personal Information (as defined herein) in the European Union (EU) and the broader European Economic Area (EEA).

EU Data Protection Laws

We collect and process your Personal Information in order to provide information, products and services to you, or to administer our employee-employee relationship, as the case may be. We may also process your Personal Information as a consequence of your relationship with one or more of our past, present or prospective suppliers, distributors, customers or employees, or in connection with your application for employment. We also collect Personal Information when you contact us, subscribe to one of our mailing lists or attend one of our events, including webinars and other digital events. We engage independent service providers to assist with information technology, administrative and other business support functions, including the collection, storage and processing of Personal Information.

This Privacy Statement explains what Personal Information we collect and process, why we do so, how it is legal and your rights. Brennan will from time to time review and revise its privacy practices and this Privacy Statement. In the event of any amendment, an updated Privacy Statement will be posted on our website.

We decide when, how and why to collect and process your Personal Information in the appropriate way for each country in which we operate facilities and conduct our business. The Data Controller is responsible for processing your Personal Information according to applicable Data Protection Laws (as defined herein). Our Chief Privacy Officer is responsible for ensuring we adopt the appropriate policies and procedures for collecting, storing and processing your Personal Information in accordance with applicable law, and auditing our ongoing compliance.

Each country has different Data Protection Laws. For European Union member countries, the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) applies.

We take your privacy very seriously and ask that you read this Privacy Statement carefully in its entirety as it contains important information on:

• Your rights
• The Personal Information we collect about you and why we collect and process it
• What we do with your Personal Information
• With whom your Personal Information may be shared

If You Need Help

If you would like this notice in another format (for example: audio, large print, braille) please contact our Chief Privacy Officer at [email protected]

If you have any questions about this Privacy Statement or the Personal Information we hold, you may write to us at

Brennan Industries, Inc.
Attention: Chief Privacy Officer
50 Wharf Approach
Walsall
WS9 8BX
United Kingdom.

Useful Words and Phrases

Please familiarize yourself with the following words and phrases as they have particular meanings in the Data Protection Laws and are used throughout this Privacy Statement:

Words Meanings
Personal Information Personal Information includes any information from which a living individual can be identified, such as:
• names, addresses, telephone numbers, email addresses, photographs, and voice recordings;
• expressions of opinion about data subjects (and their own expressions of opinion/intentions); and
• information which on its own does not identify an individual but which would identify them if put together with other information we have or are likely to have in the future.
Sensitive Personal Information or Special Categories of Data Any Personal Information relating to:
• racial or ethnic origin;
• political opinions or affiliations;
• religious or philosophical beliefs or beliefs of a similar nature;
• trade union membership;
• physical or mental health or condition;
• sexual life or orientation; or
• genetic data or biometric data.
Processing Virtually anything that can be done with Personal Information, including:
• obtaining, collecting, recording, retrieving, reviewing, consulting, storing, using or holding;
• organizing, structuring, adapting or altering;
• disclosing, disseminating or otherwise making available; and
• aligning, combining, restricting, blocking, erasing or destroying.
Data Subject Individual to whom the Personal Information relates.
Supervisory Authority Authority responsible for implementing, overseeing and enforcing Data Protection Laws.
Data Controller Person who determines the purposes for which, and the manner in which, any Personal Information is processed.
Data Processor Person who processes Personal Information on behalf of Data Controller.
Data Protection Laws Laws that govern the handling of Personal Information and Sensitive Personal Information, including those identified in this Privacy Statement.

Personal Information Brennan May Collect

• Personal Information provided by you, including:

• your name
• address
• phone number
• email address
• date of birth and other identity documentation that we need to collect to comply with legal and regulatory requirements
• government identification number, taxpayer identification number or other identity documentation
• information you share with us to help us understand your situation, your hobbies and preferences
• information you share with us in the ordinary course of our commercial or employment relationship

• Sensitive Personal Information – If we ask you to provide Sensitive Personal Information, we will explain why we need it, how we intend to use it and your rights. If required by applicable Data Protection Laws, we will first ask you for your consent.

• Personal Information about other individuals – If you give us Personal Information on behalf of someone other than you, you confirm that the other person has appointed you to act on his/her behalf and has granted permission for you to provide his/her Personal Information to us.

• Personal Information provided by third parties – We will collect Personal Information directly from you, from authorized representatives and as otherwise permitted or required by applicable law. At times, we will also collect Personal Information from third parties such as regulatory and legal authorities, other organizations with whom you have dealings or who have a legal interest in such Personal Information, government agencies, credit reporting agencies, financial institutions, recruitment agencies and other people connected to recruitment, information or service providers, introducers and referrers and from publicly available records. We may obtain Personal Information about you from third parties in order to verify your identity, carry out anti-money laundering, anti-terrorism, sanctions screening and other background and credit checks. In performing these checks, Personal Information provided by you may be disclosed to that third party which may keep a record of that information. All Personal Information provided by you will be treated securely and strictly in accordance with the Data Protection Laws.

Why Brennan Collects and Processes Personal Information

We collect and use your Personal Information for any purpose not prohibited by applicable law, including Data Protection Laws, including:

• Provide our products and services (including information or materials you may have requested).

• Comply with legal and regulatory obligations (including establishing your identity in order to comply with anti-money laundering regulations and our other legal and regulatory obligations which may require you to provide name, address, employment/business information, and/or other legally mandated forms of identification).

• Carry out commercial and employment administrative functions (including the collection of names, addresses, government identification numbers, banking, financial details and creditworthiness for, among other lawful purposes, billing and collections, carrying out searches and checks, maintaining internal records, maintaining and developing our commercial or employment relationship with you, carrying out recruitment activities for employment and contract employee placement with us, analyzing and managing the conduct of our business activities and records).

• Carry out business development and marketing efforts (including market research, marketing our own products and services to you, keeping your information and preferences accurate, tracking and manage your consent preferences, event reservations and any unsubscribe requests, and sending you marketing materials, press releases, and other communications we think will be of interest to you and/or your business).

• Maintain personal security (including to help ensure security and for crime prevention – we may have CCTV cameras installed at the entrances to our premises and CCTV data is captured on cameras).

• To monitor our website usage to improve our services (To find out more, review Brennan’s [hyperlink-2] Cookie Notice).

If you have consented to receive marketing materials from us, you may contact us via our website at [hyperlink] www.brennaninc.com to update your information or preferences, or unsubscribe from any marketing lists.

Legal Bases for Collecting and Processing Personal Information

Under applicable Data Protection Laws, Brennan is permitted to collect and process your Personal Information for any number of lawful purposes, including:

• Consent: We may ask for consent to collect and use your Personal Information, and will always do so when required by applicable Data Protection Laws. We will collect and use your Personal Information in accordance with the terms of your consent, as well as any other manner not prohibited by law.

• Commercial or employment relationship: To effectively carryout our commercial or employment relationship, we may be required to collect and process your Personal Information for the purposes of supplying you products and services you purchase from Brennan, billing and collecting for such products and services, providing customer service, processing your pay and benefits as our employee or to satisfy our legal obligations or requirements. By engaging in commercial activity with Brennan, or accepting employment with us, you agree that we may do so.

• Legal obligations: Where we are subject to legal obligations to collect and process your Personal Information for the purposes of compliance with applicable laws; for example, we are required to identify individuals to comply with anti-money laundering regulations in many countries and are required to gather and maintain records in compliance with labor, employment, health and safety laws and regulations. We also have obligations pursuant to financial and tax legislation and reporting obligations in respect of tax administration.

• Legitimate interests: Processing your Personal Information is also legal if it is based on our ‘legitimate interests’. To process on this basis, we have considered the impact on your interests and rights, and have placed appropriate safeguards to ensure that the intrusion on your privacy is reduced as much as possible.

The following are examples of the purposes for which we will process your Personal Information on this basis:

• To carry out commercial and employment administration functions – to enable us to maintain our necessary business records.
• To ensure regulatory compliance – for example, to ensure we are not prohibited by applicable law from supplying our products or services to a particular customer or to satisfy our legal responsibilities to our employees.
• To permit us to pursue available remedies or limit any damages that we may sustain.
• To permit us to manage and respond to any complaints.
• To liaise with representatives of customers that are entities rather than individuals.
• To market, sell, distribute, deliver and bill and collect payments for the products and services we supply to customers, including providing associate customer service.
• To carry out recruitment, hiring and associated administrative activities, including those required by applicable law.

Please be aware that you have the right to object to the processing of your data for any of the legitimate interests identified. To do so, simply contact us at [email protected] or via the other contact information provided in this Privacy Statement.

Sensitive Personal Information

In certain circumstances, including the reasons and exceptions explained below, we may collect and process your Sensitive Personal Information:

• Consent: You may give us your explicit consent for us to process your Sensitive Personal Information where doing so is necessary for the effective administration of our commercial or employment relationship.

• Vital Interests: It may be necessary for Brennan to collect and process your Sensitive Personal Information to enable us to protect your vital interests. For example, we may be required to process your medical and/or health-related Personal Information in the administration of employee benefits or to protect your personal safety or life while you are present at one of our facilities or attending an event away from our facilities.

• Manifestly Public Personal Information: In circumstances where you manifestly make public your Sensitive Personal Information, and only when it is necessary for our purposes and permitted by the applicable Data Protection Laws, we may collect and process such manifestly public Personal Information. For example, we may ask you to provide your personal dietary requirements when you attend a Brennan meeting or event. We consider you to have made this Sensitive Personal Information manifestly public to Brennan to help us protect you and to ensure your health and safety. We will keep this manifestly public Sensitive Personal Information confidential and restrict it to only those persons who need to know.

• Legal claims: When we are establishing or defending legal claims.

Persons Who May Access Your Personal Information

In the course of marketing and selling our products and services, operating our business, administering our relationship with our employees and satisfying our regulatory compliance obligations, we may disclose your Personal Information to:

• Other Brennan offices, group entities and affiliates (including those located outside of the EU/EEA).
• Third party product and service suppliers, independent contractors and advisors, including the administrative requirements associated with our relationship with such providers.
• Providers of certain business support products and services, including logistics and freight forwarding, information technology, data security, banking, payment, insurance, credit checking, archiving and data storage.
• Providers of marketing, business development, customer relationship management and associated support products and services.
• Legal and or regulatory authorities, including disclosures we may be required to make to comply with applicable law, regulations or court orders.
• Your Personal Information may also be subject to transfer to another organization in the event of corporate transaction such as a merger, combination or acquisition, or change of ownership of our corporate organization or business. This will occur only if the transferee party(ies) maintain policies similar to those described in this Privacy Statement for the protection and use of Personal Information.
• Persons whom you instruct us to disclose, or to whom you consent to disclosure of, your Personal Information.

Transfers of Your Personal Information Outside of the EU/EEA

Brennan conducts its business through affiliated entities on a global basis. Accordingly, when necessary or useful to the operation or administration of our business, Brennan will transfer applicable Personal Information among our affiliated entities and between our facilities, including to facilities located outside of the EU/EEA.

Any transfer of your Personal Information from Brennan affiliates in the EU/EEA to Brennan affiliates in any country outside of the EU/EEA will only be performed in compliance with applicable law and subject to industry standard data protection and privacy mechanisms that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.

How Brennan Maintains the Security of Your Personal Information

Brennan has implemented commercially reasonable means, procedures and processes to maintain physical, procedural and technical security for Personal Information.

Brennan holds Personal Information principally in secure, virtual (or cloud) storage networks or physical storage media (which may be in electronic or printed form) located in cities where Brennan maintains facilities, or at secure, off-site storage facilities. All such Personal Information may be accessed by Brennan personnel who need to know such information for a purpose addressed in this Privacy Statement.

If you have any particular concerns about the security of your Personal Information, simply contact us at [email protected]

How Long Brennan Retains Your Personal Information

We retain Personal Information in accordance with our internal document retention policies, contractual terms and where necessary for us to meet our legal and regulatory obligations. We utilize these criteria to delete Personal Information when it is no longer necessary for us to retain it.

In addition to the provisions explained elsewhere in this Privacy Statement, the following provisions describe our specific privacy policies pursuant to which Brennan collects, stores, protects, uses and discloses Personal Information (as defined herein) in the United Kingdom.

UK Data Protection Laws

We collect and process your Personal Information in order to provide information, products and services to you, or to administer our employee-employee relationship, as the case may be. We may also process your Personal Information as a consequence of your relationship with one or more of our past, present or prospective suppliers, distributors, customers or employees, or in connection with your application for employment. We also collect Personal Information when you contact us, subscribe to one of our mailing lists or attend one of our events, including webinars and other digital events. We engage independent service providers to assist with information technology, administrative and other business support functions, including the collection, storage and processing of Personal Information.

This Privacy Statement explains what Personal Information we collect and process, why we do so, how it is legal and your rights. Brennan will from time to time review and revise its privacy practices and this Privacy Statement. In the event of any amendment, an updated Privacy Statement will be posted on our website.

We decide when, how and why to collect and process your Personal Information in the appropriate way for each country in which we operate facilities and conduct our business. The Data Controller is responsible for processing your Personal Information according to applicable Data Protection Laws (as defined herein). Our Chief Privacy Officer is responsible for ensuring we adopt the appropriate policies and procedures for collecting, storing and processing your Personal Information in accordance with applicable law, and auditing our ongoing compliance.

Each country has different Data Protection Laws. In the UK, the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679, and the Data Protection Act 2018 apply.

If You Need Help

If you would like this notice in another format (for example: audio, large print, braille) please contact our Chief Privacy Officer at [email protected]

How to Contact Us

If you have any questions about this Privacy Statement or the Personal Information we hold, or to exercise any rights under applicable Data Protection Laws, you may write to us at:

Brennan Industries, Inc.
Attention: Chief Privacy Officer
50 Wharf Approach
Walsall
WS9 8BX
United Kingdom.

Or contact us via email at: [email protected]

Useful Words and Phrases

Please familiarize yourself with the following words and phrases as they have particular meanings in the Data Protection Laws and are used throughout this Privacy Statement:

Words Meanings
Personal Information Personal Information includes any information from which a living individual can be identified, such as:
• names, addresses, telephone numbers, email addresses, photographs, and voice recordings;
• expressions of opinion about data subjects (and their own expressions of opinion/intentions); and
• information which on its own does not identify an individual but which would identify them if put together with other information we have or are likely to have in the future.
Sensitive Personal Information or Special Categories of Data Any Personal Information relating to:
• racial or ethnic origin;
• political opinions or affiliations;
• religious or philosophical beliefs or beliefs of a similar nature;
• trade union membership;
• physical or mental health or condition;
• sexual life or orientation; or
• genetic data or biometric data.
Processing Virtually anything that can be done with Personal Information, including:
• obtaining, collecting, recording, retrieving, reviewing, consulting, storing, using or holding;
• organizing, structuring, adapting or altering;
• disclosing, disseminating or otherwise making available; and
• aligning, combining, restricting, blocking, erasing or destroying.
Data Subject Individual to whom the Personal Information relates.
Supervisory Authority Authority responsible for implementing, overseeing and enforcing Data Protection Laws.
Data Controller Person who determines the purposes for which, and the manner in which, any Personal Information is processed.
Data Processor Person who processes Personal Information on behalf of Data Controller.
Data Protection Laws Laws that govern the handling of Personal Information and Sensitive Personal Information, including those identified in this Privacy Statement.

Personal Information Brennan May Collect

• Personal Information provided by you, including:

• your name
• address
• phone number
• email address
• date of birth and other identity documentation that we need to collect to comply with legal and regulatory requirements
• government identification number, taxpayer identification number or other identity documentation
• information you share with us to help us understand your situation, your hobbies and preferences
• information you share with us in the ordinary course of our commercial or employment relationship

• Sensitive Personal Information – If we ask you to provide Sensitive Personal Information, we will explain why we need it, how we intend to use it and your rights. If required by applicable Data Protection Laws, we will first ask you for your consent.

• Personal Information about other individuals – If you give us Personal Information on behalf of someone other than you, you confirm that the other person has appointed you to act on his/her behalf and has granted permission for you to provide his/her Personal Information to us.

• Personal Information provided by third parties – We will collect Personal Information directly from you, from authorized representatives and as otherwise permitted or required by applicable law. At times, we will also collect Personal Information from third parties such as regulatory and legal authorities, other organizations with whom you have dealings or who have a legal interest in such Personal Information, government agencies, credit reporting agencies, financial institutions, recruitment agencies and other people connected to recruitment, information or service providers, introducers and referrers and from publicly available records. We may obtain Personal Information about you from third parties in order to verify your identity, carry out anti-money laundering, anti-terrorism, sanctions screening and other background and credit checks. In performing these checks, Personal Information provided by you may be disclosed to that third party which may keep a record of that information. All Personal Information provided by you will be treated securely and strictly in accordance with the Data Protection Laws.

Why Brennan Collects and Processes Personal Information

We collect and use your Personal Information for any purpose not prohibited by applicable law, including Data Protection Laws, including:

• Provide our products and services (including information or materials you may have requested).

• Comply with legal and regulatory obligations (including establishing your identity in order to comply with anti-money laundering regulations and our other legal and regulatory obligations which may require you to provide name, address, employment/business information, and/or other legally mandated forms of identification).

• Carry out commercial and employment administrative functions (including the collection of names, addresses, government identification numbers, banking, financial details and creditworthiness for, among other lawful purposes, billing and collections, carrying out searches and checks, maintaining internal records, maintaining and developing our commercial or employment relationship with you, carrying out recruitment activities for employment and contract employee placement with us, analyzing and managing the conduct of our business activities and records).

• Carry out business development and marketing efforts (including market research, marketing our own products and services to you, keeping your information and preferences accurate, tracking and manage your consent preferences, event reservations and any unsubscribe requests, and sending you marketing materials, press releases, and other communications we think will be of interest to you and/or your business).

• Maintain personal security (including to help ensure security and for crime prevention – we may have CCTV cameras installed at the entrances to our premises and CCTV data is captured on cameras).

• To monitor our website usage to improve our services (To find out more, review Brennan’s [hyperlink-2] Cookie Notice).

If you have consented to receive marketing materials from us, you may contact us via our website at [hyperlink] www.brennaninc.com to update your information or preferences, or unsubscribe from any marketing lists.

Legal Bases for Collecting and Processing Personal Information

Under applicable Data Protection Laws, Brennan is permitted to collect and process your Personal Information for any number of lawful purposes, including:

• Consent: We may ask for consent to collect and use your Personal Information, and will always do so when required by applicable Data Protection Laws. We will collect and use your Personal Information in accordance with the terms of your consent, as well as any other manner not prohibited by law.

• Commercial or employment relationship: To effectively carryout our commercial or employment relationship, we may be required to collect and process your Personal Information for the purposes of supplying you products and services you purchase from Brennan, billing and collecting for such products and services, providing customer service, processing your pay and benefits as our employee or to satisfy our legal obligations or requirements. By engaging in commercial activity with Brennan, or accepting employment with us, you agree that we may do so.

• Legal obligations: Where we are subject to legal obligations to collect and process your Personal Information for the purposes of compliance with applicable laws; for example, we are required to identify individuals to comply with anti-money laundering regulations in many countries and are required to gather and maintain records in compliance with labor, employment, health and safety laws and regulations. We also have obligations pursuant to financial and tax legislation and reporting obligations in respect of tax administration.

• Legitimate interests: Processing your Personal Information is also legal if it is based on our ‘legitimate interests’. To process on this basis, we have considered the impact on your interests and rights, and have placed appropriate safeguards to ensure that the intrusion on your privacy is reduced as much as possible.

The following are examples of the purposes for which we will process your Personal Information on this basis:

• To carry out commercial and employment administration functions – to enable us to maintain our necessary business records.
• To ensure regulatory compliance – for example, to ensure we are not prohibited by applicable law from supplying our products or services to a particular customer or to satisfy our legal responsibilities to our employees.
• To permit us to pursue available remedies or limit any damages that we may sustain.
• To permit us to manage and respond to any complaints.
• To liaise with representatives of customers that are entities rather than individuals.
• To market, sell, distribute, deliver and bill and collect payments for the products and services we supply to customers, including providing associate customer service.
• To carry out recruitment, hiring and associated administrative activities, including those required by applicable law.

Please be aware that you have the right to object to the processing of your data for any of the legitimate interests identified. To do so, simply contact us at [email protected] or via the other contact information in “How to Contact Us” provided in this Privacy Statement.

Sensitive Personal Information

In certain circumstances, including the reasons and exceptions explained below, we may collect and process your Sensitive Personal Information:

• Consent: You may give us your explicit consent for us to process your Sensitive Personal Information where doing so is necessary for the effective administration of our commercial or employment relationship.

• Vital Interests: It may be necessary for Brennan to collect and process your Sensitive Personal Information to enable us to protect your vital interests. For example, we may be required to process your medical and/or health-related Personal Information in the administration of employee benefits or to protect your personal safety or life while you are present at one of our facilities or attending an event away from our facilities.

• Manifestly Public Personal Information: In circumstances where you manifestly make public your Sensitive Personal Information, and only when it is necessary for our purposes and permitted by the applicable Data Protection Laws, we may collect and process such manifestly public Personal Information. For example, we may ask you to provide your personal dietary requirements when you attend a Brennan meeting or event. We consider you to have made this Sensitive Personal Information manifestly public to Brennan to help us protect you and to ensure your health and safety. We will keep this manifestly public Sensitive Personal Information confidential and restrict it to only those persons who need to know.

• Legal claims: When we are establishing or defending legal claims.

Persons Who May Access Your Personal Information

In the course of marketing and selling our products and services, operating our business, administering our relationship with our employees and satisfying our regulatory compliance obligations, we may disclose your Personal Information to:

• Other Brennan offices, group entities and affiliates (including those located outside of the UK).
• Third party product and service suppliers, independent contractors and advisors, including the administrative requirements associated with our relationship with such providers.
• Providers of certain business support products and services, including logistics and freight forwarding, information technology, data security, banking, payment, insurance, credit checking, archiving and data storage.
• Providers of marketing, business development, customer relationship management and associated support products and services.
• Legal and or regulatory authorities, including disclosures we may be required to make to comply with applicable law, regulations or court orders.
• Your Personal Information may also be subject to transfer to another organization in the event of corporate transaction such as a merger, combination or acquisition, or change of ownership of our corporate organization or business. This will occur only if the transferee party(ies) maintain policies similar to those described in this Privacy Statement for the protection and use of Personal Information.
• Persons whom you instruct us to disclose, or to whom you consent to disclosure of, your Personal Information.

Transfers of Your Personal Information Outside of the UK

Brennan conducts its business through affiliated entities on a global basis. Accordingly, when necessary or useful to the operation or administration of our business, Brennan will transfer applicable Personal Information among our affiliated entities and between our facilities, including to facilities located outside of the UK.

Any transfer of your Personal Information from Brennan affiliates in the UK to Brennan affiliates in any country outside of the UK will only be performed in compliance with applicable law and subject to industry standard data protection and privacy mechanisms that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.

How Brennan Maintains the Security of Your Personal Information

Brennan has implemented commercially reasonable means, procedures and processes to maintain physical, procedural and technical security for Personal Information.

Brennan holds Personal Information principally in secure, virtual (or cloud) storage networks or physical storage media (which may be in electronic or printed form) located in cities where Brennan maintains facilities, or at secure, off-site storage facilities. All such Personal Information may be accessed by Brennan personnel who need to know such information for a purpose addressed in this Privacy Statement.

If you have any particular concerns about the security of your Personal Information, simply contact us at [email protected] or via the other contact information in “How to Contact Us” provided in this Privacy Statement.

How Long Brennan Retains Your Personal Information

We retain Personal Information in accordance with our internal document retention policies, contractual terms and where necessary for us to meet our legal and regulatory obligations. We utilize these criteria to delete Personal Information when it is no longer necessary for us to retain it.

Your Rights Under UK Data Protection Laws

As a Data Subject, you have the following rights regarding your Personal Information under the Data Protection Laws:

• Right of Access: You have the right to access the Personal Information collected and held by Brennan that relates to you. You may ask to see what Personal Information we hold about you and be provided with:
• a copy;
• details of the purpose for which it is being or is to be processed;
• details of the recipients or classes of recipients to whom it is or may be disclosed, including if they are located outside the UK and what protections are used for outbound (oversea) transfers;
• the period for which it is held (or the criteria we use to determine how long it is held);
• any information available about the source of that Personal Information; and
• whether we carry out an automated decision-making, or profiling, and where we do so, information about the logic involved and the envisaged outcome or consequences of that decision or profiling.
To help us find the Personal Information easily, please provide us as much information as possible about the type of Personal Information you would like to access.

• Right to Correct: You have the right to require us, free of charge, to correct any errors in your Personal Information collected and held by Brennan. If you would like to do this, please:
• contact us via email at [email protected] or via the other contact information in “How to Contact Us” provided in this Privacy Statement;
• let us have sufficient information to verify your identity; and
• let us know the Personal Information that is incorrect and exactly how it should be corrected.
• Right to Opt-Out: You have the right to ask us to stop contacting you with direct marketing information. If you have consented to receive marketing materials from us, you may contact us via our website at [hyperlink] www.brennaninc.com to update your information or preferences, or unsubscribe from any marketing lists.

• Automated Decision Making: You have certain rights in relation to automated decision making. If you have questions about whether and to what extent Brennan may collect or process Personal Information for purposes of automated decision making, please contact us via email at [email protected] or via the other contact information in “How to Contact Us” provided in this Privacy Statement.

• Right to Prevent Processing: You have the right to restrict or prevent your Personal Information being processed. You may request that we stop processing your Personal Information temporarily if:
• you do not believe your Personal Information is accurate (we will recommence processing after confirming the accuracy of your Personal Information, including any necessary corrections);
• the processing is unlawful but you do not want us to erase your Personal Information;
• we no longer need the Personal Information for our processing; or
• you have objected to processing because you believe that your interests should override our legitimate interests.

• Right to Data Portability: You have the right to have your Personal Information ported to another Data Controller (e.g. if you decide to create a commercial relationship with another supplier or seek or accept employment with another employer). You may ask for an electronic copy of your Personal Information which we hold electronically. You can also ask us to provide this directly to another party.

• Right to Erasure: You have the right to ask us to erase your Personal Information where:
• you do not believe we need your Personal Information in order to process it for the purposes set out in this Privacy Statement;
• if you had given us consent to process your Personal Information, you withdraw that consent and we cannot otherwise legally process your Personal Information;
• you object to our processing and we do not have any legitimate interests that permit us to continue to process your Personal Information; or
• your Personal Information has been processed unlawfully or has not been erased when it should have been.

There are exceptions and exemptions that apply to some of these rights which we will apply in accordance with the Data Protection Laws. We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex, in which case we will respond within three months.

If you have any comments, concerns or complaints about Brennan’s use of your Personal Information, please contact us immediately via email at [email protected] or via the other contact information in “How to Contact Us” provided in this Privacy Statement.

Complaints to the Regulator

It is important that you ensure you have read this Privacy Statement in its entirety. If you believe Brennan has failed to collect or process your Personal Information in compliance with this Privacy Statement or otherwise violated applicable Data Privacy Laws, you should contact us immediately via email at [email protected] or via the other contact information in “How to Contact Us” provided in this Privacy Statement. Similarly, you may complain to the competent supervisory authority. You may contact the Information Commissioner’s Office via [hyperlink] www.ico.org.uk.

In addition to the provisions explained elsewhere in this Privacy Statement, the following provisions describe our specific privacy policies pursuant to which Brennan collects, stores, protects, uses and discloses Personal Information (as defined herein) in the United States.

This Privacy Statement applies to all Brennan activities involving the collection, storage, processing and use of Personal Information, including online or digital activities such as [hyperlink] www.brennaninc.com and our other websites in which it is posted or linked, software, applications, systems and other information technology resources (collectively, “Brennan Resources”) that Brennan makes available or otherwise provides access to our prospective, present and past customers (including distributors and industrial consumers), employees and independent contractors, suppliers of goods and services and other persons who access Brennan Resources.

Please carefully read this Privacy Statement in its entirety to learn more about how we collect, use, disclose and store Personal Information and the steps we take to help protect it from unauthorized use or disclosure. When you access the Brennan Resources and submit Personal Information to Brennan, you consent to the collection, processing and retention of your Personal Information as described in this Privacy Statement.

This Privacy Statement is incorporated into and made a part of our [hyperlink-11] Terms of Use. If you have not done so already, please also review Brennan’s [hyperlink-11] Terms of Use, which contain provisions that limit Brennan’s liability to you.

IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY STATEMENT, THEN PLEASE DO NOT ACCESS OR USE ANY BRENNAN RESOURCES OR OTHERWISE PROVIDE ANY PERSONAL INFORMATION TO BRENNAN.

Brennan holds Personal Information principally in secure, virtual (or cloud) storage networks or physical storage media (which may be in electronic or printed form) located in cities where Brennan maintains facilities, or at secure, off-site storage facilities. All such Personal Information may be accessed by Brennan personnel who need to know such information for a purpose addressed in this Privacy Statement.

Any transfer of your Personal Information from Brennan affiliates in the US to Brennan affiliates in any country outside of the US will only be performed in compliance with applicable law and subject to industry standard data protection and privacy mechanisms that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.

Personal Information Brennan Collects

Please familiarize yourself with the following words and phrases as they have particular meanings in the Data Protection Laws and are used throughout this Privacy Statement:

Words Meanings
Personal Information Personal Information includes any information from which a living individual can be identified, such as:
• names, addresses, telephone numbers, email addresses, photographs, and voice recordings;
• expressions of opinion about data subjects (and their own expressions of opinion/intentions); and
• information which on its own does not identify an individual but which would identify them if put together with other information we have or are likely to have in the future.
Sensitive Personal Information or Special Categories of Data Any Personal Information relating to:
• racial or ethnic origin;
• political opinions or affiliations;
• religious or philosophical beliefs or beliefs of a similar nature;
• trade union membership;
• physical or mental health or condition;
• sexual life or orientation; or
• genetic data or biometric data.
Processing Virtually anything that can be done with Personal Information, including:
• obtaining, collecting, recording, retrieving, reviewing, consulting, storing, using or holding;
• organizing, structuring, adapting or altering;
• disclosing, disseminating or otherwise making available; and
• aligning, combining, restricting, blocking, erasing or destroying.
Data Subject Individual to whom the Personal Information relates.
Supervisory Authority Authority responsible for implementing, overseeing and enforcing Data Protection Laws.
Data Controller Person who determines the purposes for which, and the manner in which, any Personal Information is processed.
Data Processor Person who processes Personal Information on behalf of Data Controller.
Data Protection Laws Laws that govern the handling of Personal Information and Sensitive Personal Information, including those identified in this Privacy Statement.
Location Data Information about the location of the device used to access Brennan Resources.
Usage Data Information about an individual’s activity on or through Brennan Resources that, by itself, does not identify the individual, such as browser type, operating system and webpages visited.

When you use Brennan Resources, we may collect Personal Information, Sensitive Personal Information, Location Data and Usage Data. Certain subsets of Personal Information, such as information about health or medical status, and Location Data (defined below) may constitute Sensitive Personal Information subject to stricter regulation and consent requirements under applicable Data Protection Laws. Before providing it to us, you should carefully consider whether to disclose your Sensitive Personal Information. If you do provide Sensitive Personal Information to us, you consent to its use and disclosure for the purposes and in the manner described in this Privacy Statement.

We do not consider Usage Data to be Personal Information because Usage Data by itself typically does not identify a particular individual. However, where Usage Data and Personal Information are linked together in a manner that identifies an individual person, the Usage Data (in such limited scenarios) may be considered Personal Information.

How Personal Information is Collected and Used

Brennan may collect, store, process and otherwise use Personal Information (including Sensitive Personal Information) to provide, operate and administer our business, employment relationships and Brennan Resources, including:

• Pursuant to our Commercial or Employment Relationship: We may collect Personal Information from you for the purpose of (a) providing you with information regarding employment opportunities, business opportunities, or our products or services; (b) determining whether to enter into an employment or business relationship with you; (c) engaging in or administering an ongoing employment or business relationship with you; or (d) other circumstances when you provide us with Personal Information about yourself. Absent your consent to different treatment, we hold Personal Information we collect from you in confidence and do not disclose it to third parties unless expressly or implicitly authorized by you or where permitted or required by applicable law. In the course of our relationship with you, Brennan may collect, use, and sometimes disclose as authorized different types of Personal Information for various purposes associated with our employment or business relationship, including the products and services we provide. While it’s impractical to list all of types of Personal Information we may collected, use or disclose as authorized, the types of Personal Information we most probably may collect include:

• your full name;
• contact information, such as your address, telephone number, email address, or job title;
• information to help establish your identity;
• information regarding your business or employment requirements, situation, and interests;
• whether you have subscribed to, or unsubscribed from, our mailing lists or respond to any of our marketing inquiries;
• information regarding your organization or other organizations, including information regarding directors, officers, or employees of our suppliers, distributors, customers and prospective customers;
• information regarding your personal preferences;
• your payment or other financial information; and
• any other Personal Information you voluntarily provide to us.

• Personal Information Collected From Third Parties: In some cases, we collect Personal Information from third parties such as suppliers, vendors, distributors, customers, prospective customers, regulatory and legal authorities, other organizations with whom we or you have dealings, such as government agencies, credit reporting agencies, recruitment agencies, information or service providers, and from publicly available records.

• Personal Information You Voluntarily Provide: We collect and use the Personal Information you voluntarily provide to us. You may access certain Brennan Resources without registering or identifying yourself but, if you do not register, you may not have access to certain Brennan Resources. If you choose to register, we may use the Personal Information you provide to confirm your registration and to respond to requests from you. Upon your request, we may also Personal Information to send you special promotions or newsletters with information that may interest you.

• When you Correspond with Brennan about Brennan Products or Services or Employment. If you contact Brennan or use Brennan Resources to ask questions or report problems regarding your experience with our products or services or as a Brennan employee, we may use Personal Information to effectively respond or otherwise address these commercial or employment matters.

• Through Data Collection Tools. Brennan may automatically collect Personal Information about use of Brennan Resources through data collection tools, such as web beacons and cookies. To find out more, review Brennan’s [hyperlink-2] Cookie Notice.

• Your Location Data. Brennan may collect Location Data concerning the device you use to access Brennan Resources. Such Location Data may include: (i) the location of the device derived from GPS or WiFi use; (ii) the IP address of the device or internet service used to access Brennan Resources; and (iii) other information made available by a user or others that indicates the current or prior location of the user, such as geotag information in photographs. If do not want us to collect Location Data from your device, please disable the location settings on your device. Note, however, that disabling the location setting may affect your ability to access and use certain Brennan Resources.

• When You Connect with Brennan Resources via Social Media: Certain Brennan Resources may link or otherwise associate with social media platforms and social media plug-ins (e.g., the Facebook “Like” button, “Share to Twitter” button) (collectively, “Social Media”). When accessing Brennan Resources through Social Media, Brennan may (depending on the applicable user privacy settings) automatically have access to Personal Information provided to or through the Social Media platform. Brennan may collect and use this Personal Information for the purposes described in this Privacy Statement or otherwise as permitted by applicable Data Protection Laws.

How Your Personal Information is Shared and Disclosed

We may collect, store, process, use, share and disclose Personal Information as described at the time it is collected and as follows:

• To Perform Services. We may use third parties to perform services requested or functions initiated by users. In addition, we may disclose Personal Information to identify a user in connection with communications sent through Brennan Resources. We also may offer users the opportunity to share information with friends and other users through Brennan Resources.

• With Brennan’s Third Party Contractors. We share information, including Personal Information, with our service providers to perform the functions for which we engage them, such as employee administration, finance and accounting, customer relationship management, other business and technology administration, data analysis, system design and maintenance, customer services and for marketing and promotions.

• Social Media Plugins. When you use Brennan Resources, Social Media platform operators can place a cookie on your computer to recognize individuals who have previously visited Brennan Resources. If you are logged into a Social Media account while using Brennan Resources, the social plugins allow that Social Media to receive information that you have accessed and used Brennan Resources. The social plugins also allow the Social Media operator to share information about your activities in or through Brennan Resources with other Social Media users. Brennan does not control any of the content from the Social Media plugins. For more information about Social Media plugins, please refer to the privacy statements and other legal notices of the Social Media platform.

• Legal Requirements. In certain circumstances, Brennan may release your Personal Information in response to a law, regulation, court order, subpoena, search warrant, binding order of a data protection agency, governmental request or other legal or regulatory process. Brennan may disclose information if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Brennan and our customers, employes or others.

• Corporate Changes. We may transfer information, including your Personal Information, in connection with a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control by Brennan or any affiliated company (in each case, whether in whole or in part). When one of these events occurs, Brennan will use reasonable efforts to notify users before information is transferred or becomes subject to different privacy practices.

[Digital Advertising

We use third-party advertising companies to serve ads on other websites and digital services. These companies may use information obtained from data collection tools in order to measure advertising effectiveness and to provide advertisements of interest to you.

[hyperlink-12] You can opt out here so as not to receive targeted ads from use of the tools, but this will not affect any general advertisements you may receive.

[landing-12] Brennan: Your Advertising Choices

Why am I receiving interest-based ads from Brennan?

To provide you with a more relevant online experience, Brennan works with ad networks to customize some of the ads that you see based on your past online activity. You do not receive more online ads than you normally would, but the ads you receive will tend to be more relevant.

Your interests are associated with advertising cookies that are stored in your browser. You can access our [hyperlink-2] Cookie Notice and customize settings [hyperlink-2] here.

How do I opt-out?

You can prevent the ad networks listed below [include opt-out menu with applicable ad networks] from showing you interest-based ads by opting-out. Opting-out will only suppress interest-based ads, and you may continue to see other online ads (not interest-based) from Brennan and other companies.

Please note that these opt-outs rely on cookies in your web browser. If you delete your web browser cookies, or use a different browser or computer, these ad networks will no longer know that you have opted out.]

Links to Other Websites and Services

A link to a third-party website or digital service does not mean Brennan endorses it or the quality or accuracy of information presented on it. If you decide to visit a third-party website or service, you are subject to its privacy practices and not this Privacy Statement. We encourage you to carefully read the privacy policy or statement and other legal notices of each website or service that you visit.

Our Children’s Policy

Brennan Resources are not intended for use by individuals under 18 years of age. If you are under 18 years of age, you should not access or use any Brennan Resource.

Your Privacy Choices

Brennan aims to provide you with choices regarding the Personal Information you provide to us. This section describes mechanisms we offer you to control certain uses and disclosures of your Personal Information.

• Your Choice: When you access any Brennan Resources, you may be asked to affirmatively choose (“opt in”) to provide requested Personal Information. You may always choose not to provide the requested Personal Information, which may diminish your experience or ability to access and use certain Brennan Resources. For example, it may not be possible for you to subscribe to our mailing lists or apply for employment if you do not provide us with requisite Personal Information.

• Correct/Update Your Personal Information: You may request disclosure of the Personal Information you previously provided to Brennan, and correct or update such Personal Information, by contacting us at [email protected] or other contact information provided in this Privacy Statement. Please not our response to your request will require you to assist us in verifying your identity.

• Receive Marketing Communications: When you register for Brennan Resources, you may request to receive email containing information about Brennan that we think you might find useful, including promotions, announcements of new services and products, and newsletters on particular topics. You may contact us via our website at [hyperlink] www.brennaninc.com to update your information or preferences, or unsubscribe from any marketing lists.

• Accept and Reject Cookies: Your browser software can be set to reject all cookies, but if you reject our cookies, certain of the functions and conveniences of Brennan Resources may not work properly. To learn more about cookies, please check your browser’s help or similar feature or visit [hyperlink] www.allaboutcookies.org.

• How We Respond to Browser “Do Not Track” Signals: Some web browsers incorporate a “do-not-track” or similar feature that signals to websites with which the browser communicates that a visitor does not want to have his/her online activity tracked. If a digital service that responds to a particular DNT signal receives the DNT signal, the browser can block that digital service from collecting certain Personal Information about the browser’s user. As of the effective date of this Privacy Statement, not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, Brennan (as well as many other digital service operators) does not currently respond to DNT signals. For more information about DNT signals, visit [hyperlink] www.allaboutdnt.com.

How Personal Information is Retained and Secured

We retain Personal Information in accordance with our internal document retention policies, contractual terms and where necessary for us to meet our legal and regulatory obligations. We utilize these criteria to delete Personal Information when it is no longer necessary for us to retain it.

In accordance with applicable laws, we employ reasonable security measures intended to help protect the security of all Personal Information submitted through Brennan Resources. The security of Personal Information transmitted through the internet cannot, however, be guaranteed. We are not responsible for any interception or interruption of any communications or for changes to or losses of data through the internet. Users of Brennan Resources are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of Brennan Resources. Any access to Brennan Resources through your user ID and password will be treated as authorized by you. To help protect your Personal Information, we may suspend your use of all or part of Brennan Resources, without notice, if Brennan suspects or detects any breach of security. Unauthorized access to such areas is prohibited and may lead to criminal prosecution.

Updates to This Privacy Statement

Brennan reserves the right to change the terms of this Privacy Statement. If we make any material changes to this Privacy Statement, we will notify you in advance through Brennan Resources. If we decide to use Personal Information in a manner that is materially different from the uses described in this Privacy Statement or otherwise disclosed to you, you will have the choice to allow or disallow any additional uses or disclosures of your Personal Information. We will not make retroactive changes that reduce your privacy rights unless we are legally required to do so. Your continued use of Brennan Resources after the Effective Date constitutes your acceptance of the amended Privacy Statement. The most current version of this Privacy Statement posted on www.brennaninc.com supersedes all previous versions.

Privacy Rights for California Residents

California Civil Code Section 1798.83 permits individual California residents to request certain information regarding Brennan’s disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please write or send an email to the address below.

California Consumer Privacy Act – Notice for California Residents

The California Consumer Privacy Act of 2018 (CCPA) gives California consumers the right to know what Personal Information is collected about them, how it will be used and to whom it is disclosed. The CCPA gives California consumers the right to request access to and deletion of their Personal Information, and the right to request that their Personal Information not be sold to the extent applicable under the CCPA.

The purpose of this notice is to describe our practices regarding the collection, use, disclosure, and sale of Personal Information and instructions for submitting CCPA data privacy requests. Some of the Personal Information that we collect, use, and disclose may be exempt from the CCPA because it is regulated by other federal and state laws that apply to us.

We collect Personal Information from you when you interact with Brennan Resources online or offline. The Personal Information we may collect from you will depend on the nature of our interaction with you, but can include the following categories that we have collected in the preceding twelve (12) months:

Categories of Personal Information Collected Sources of Collection Purpose of Collecting/Sharing Categories of Third Parties to Whom We Disclose Personal Information
Identifiers – such as full name, postal address, phone number, unique personal identifier, online identifier, internet protocol (IP) address, email address, account name, social security number (partial and full), driver’s license number, passport number, or other similar identifiers • You (directly)
• Government records
• Public sources
• Healthcare providers
• Health insurance companies (health plans) and other payors
• Authorized/legal representatives
• Third parties who provide validation, verification, administrative functions and fulfillment or logistics services in connection with our products and services
• Consumer reporting agencies and other third parties who verify information you provide
• Third parties who help us maintain the accuracy of our data and data aggregators that help us complete and enhance our records
• Third parties who provide digital marketing and analytics services for us using cookies and similar technologies that contain a unique identifier, such as an advertising ID
• Determine program, benefits, product, and service eligibility
• Enroll you in and administer our employment benefits, services and programs
• Provide our products and services to you
• Administer, manage, analyze, and improve our commercial, business and employment relationships, programs, products, and services
• Communicate with you regarding our business, benefits, programs, products, and services
• Procure vendor/supplier products and services, including to manage and satisfy related vendor/supplier contractual obligations
• Analyze and better understand your needs, preferences, and interests, as well as those of other consumers
• Conduct internal business analysis and market research
• Advertising and product promotion, including to contact you regarding programs, products, services, and topics that may be of interest or useful
• Engage in joint marketing initiatives
• Administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices
• Provide access to, monitor, and secure our facilities, equipment, and other property
• Monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
• Comply with legal and regulatory obligations
• To identify you and your device(s) for any/all purposes identified above, including to monitor your use of and interactions with programs, products, services, and advertisements for such purposes or to help ensure the integrity of our programs and the preservation of your privacy
• Third parties that manufacture or otherwise supply the products and services we market and sell to you
• Health insurance companies (health plans) and other payors
• Authorized/legal representatives
• Third-parties that help administer, manage and analyze our commercial, business and employment relationships, programs, products and services
• Third parties with whom we have joint marketing and similar arrangements
• Third parties who provide benefit verification, program enrollment, and product fulfillment services in connection with our products and services
• Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention
• Third parties who deliver our communications, such as the postal service and couriers
• Other third parties as necessary to complete transactions and provide our products/services, including freight fowarders, delivery companies, agents, and manufacturers
• Third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors
• Third party network advertising partners.
• Third parties who assist with our information technology and security programs
• Third parties who assist with fraud prevention, detection, and mitigation
• Consumer reporting agencies
• Our lawyers, auditors, and consultants
• Legal and regulatory bodies and other third parties as required by law

Health Insurance and Other Employee Benefit Information – including an individual’s insurance policy number or subscriber identification number, any unique identifier used by a health insurer to identify the individual, or any information in the individual’s application and claims history • You (directly)
• Health insurance companies (health plans) and other payors
• Authorized/legal representatives
• Third parties who provide benefit verification, program enrollment, and product fulfillment services in connection with our employee benefit plan and programs
• Determine benefit and program eligibility and enrollment status
• Administer, manage, analyze, and improve our employee benefit plans and programs
• Procure vendor/supplier products and services, including to manage and satisfy related vendor/supplier contractual obligations
• Monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
• Comply with legal and regulatory obligations
• Health insurance companies (health plans) and other payors
• Authorized/legal representatives
• Third parties who provide benefit verification, program enrollment, and product fulfillment services in connection with our employee benefit plans and programs
• Other third parties as necessary to complete transactions and administer, manage, analyze, and improve our employee benefit plans and programs
• Our lawyers, auditors, and consultants
• Legal and regulatory bodies and other third parties as required by law

Financial Information – including bank account number, credit or debit card number, or other financial information • You (directly)
• Authorized/legal representatives
• Third parties that provide business, finance, accounting, administrative and similar services required for the efficient operation of our business
• Payment processors and other financial institutions
• Third parties that assist with fraud prevention, detection, and mitigation
• Administer the sale, delivery and payment for products and services we sell, as well as warranty and customer service functions
• Administer our business operations, including all payroll and accounting functions
• Determine program, product, and service eligibility and coverage.
• Enroll you in and administer our employment benefits, services and programs
• Provide our products and services to you
• Administer, manage, analyze, and improve our commercial, business and employment relationships, programs, products, and services
• Procure vendor/supplier products and services, including to manage and satisfy related vendor/supplier contractual obligations
• Monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
• Comply with legal and regulatory obligations
• Health insurance companies (health plans) and other payors
• Authorized/legal representatives
• Third parties that provide business, finance, accounting, administrative and similar services required for the efficient operation of our business
• Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention
• Other third parties as necessary to complete transactions and provide our products/services
• Consumer reporting agencies
• Our lawyers, auditors, and consultants
• Legal and regulatory bodies and other third parties as required by law

Medical Information – including any information in possession of or derived from a healthcare provider, health insurance plans or contractors regarding employee medical history, mental or physical condition, or treatment • You (directly)
• Healthcare providers
• Health insurance companies (health plans) and other payors.
• Authorized/legal representatives
• Administer employment relationship, including workers’ compensation claims, return to work, disability matters (including accommodations) and other matters impacting employees
• Monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
• Comply with legal and regulatory obligations
• Health insurance companies (health plans) and other payors
• Authorized/legal representatives
• Other third parties as necessary to complete transactions and administer, manage, analyze, and improve our employee benefit plans and programs
• Our lawyers, auditors, and consultants.
• Legal and regulatory bodies and other third parties as required by law

Protected Characteristics – such as race, gender, physical or mental disability, and religion • You (directly)
• Authorized/legal representatives
• Third parties that provide access to information you make publicly available, such as social media platforms
• Third parties who provide us with supplemental consumer data or data analytics and market research services, such as data aggregators
• Administer employment relationship
• Analyze and better understand your needs, preferences, and interests, as well as those of other consumers
• Conduct internal business analysis and market research
• Monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
• Comply with legal and regulatory obligations.
• Authorized/legal representatives
• Third parties with whom we have joint marketing and similar arrangements.
• Other third parties as necessary to complete transactions and provide our products/services
• Our lawyers, auditors, and consultants.
• Legal and regulatory bodies and other third parties as required by law.

Commercial Information – including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies • You (directly)
• Consumer reporting agencies
• Third parties that provide business, finance, accounting, administrative and similar services required for the efficient operation of our business
• Other third parties that facilitate, process, and complete transactions and provide customer service
• Administer, manage, analyze, and improve our products and services.
• Communicate with you regarding our products and services.
• Procure vendor/supplier products and services, including to manage and satisfy related vendor/supplier contractual obligations
• Analyze and better understand your needs, preferences, and interests, as well as those of other consumers
• Conduct internal business analysis and market research.
• Engage in joint marketing initiatives
• Monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
• Comply with legal and regulatory obligations
• Third parties that provide business, finance, accounting, administrative and similar services required for the efficient operation of our business
• Authorized/legal representatives
• Third parties with whom we have joint marketing and similar arrangements
• Third parties that manufacture or otherwise supply the products and services we market and sell to you
• Other third parties as necessary to complete transactions and provide our products/services
• Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention
• Third party network advertising partners
• Consumer reporting agencies
• Our lawyers, auditors, and consultants
• Legal and regulatory bodies and other third parties as required by law

Network Activity Data – Internet or other electronic network activity information, such as browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement • Your computer and mobile devices (automatically) when you visit or interact with our websites, applications, and online platforms
• Cookies, web beacons, and similar technologies (automatically) when you visit our websites or third-party websites
• Third party advertising partners and other third parties who provide digital marketing services
• Third parties who provide website and online security services
• Administer, manage, analyze, and improve our products and services
• Analyze and better understand your needs, preferences, and interests, as well as those of other consumers
• Conduct internal business analysis and market research
• Advertising and product promotion, including to contact you regarding our products and services, and topics that may be of interest or useful
• Engage in joint marketing initiatives
• Administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices.
• Monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
• Comply with legal and regulatory obligations
• To identify you and your device(s) for any/all purposes identified above, including to monitor your use of and interactions with programs, products, services, and advertisements for such purposes
• Third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors
• Third party network advertising partners
• Third parties who assist with our information technology and security programs
• Third parties who assist with fraud prevention, detection, and mitigation
• Our lawyers, auditors, and consultants
• Legal and regulatory bodies and other third parties as required by law

Geolocation Data – an individual’s precise geolocation data • Your mobile devices with your permission upon downloading and when you visit or interact with our websites, applications, and online platforms
• Administer, manage, analyze, and improve our products and services
• Conduct internal business analysis and market research
• Administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices
• Monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
• Comply with legal and regulatory obligations
• Third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors
• Third parties who assist with our information technology and security programs
• Third parties who assist with fraud prevention, detection, and mitigation
• Our lawyers, auditors, and consultants
• Legal and regulatory bodies and other third parties as required by law

Electronic and Sensory Data – audio, electronic, visual, thermal, olfactory, or similar information (e.g., a recording of a customer service call) • You (directly)
• When you contact or visit us (automatically), such as when we record calls to our call centers or use CCTV cameras in our facilities
• Your mobile devices and other internet-connected devices with your permission when you use these devices and relevant applications
• Third parties that provide access to information you make publicly available, such as social media platforms

• Administer, manage, analyze, and improve our commercial, business and employment relationships, programs, products, and services
• Analyze and better understand your needs, preferences, and interests, as well as those of other consumers
• Administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices
• Monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
• Provide access to, monitor, and secure our facilities, equipment, and other property
• Comply with legal and regulatory obligations
• To identify you and your device(s) for any/all purposes identified above, including to monitor your use of and interactions with programs, products, services, and advertisements for such purposes
• Third parties that provide business, finance, accounting, administrative and similar services required for the efficient operation of our business
• Authorized/legal representatives
• Third parties that manufacture or otherwise supply the products and services we market and sell to you
• Other third parties as necessary to complete transactions and provide our products/services
• Third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors
• Third party network advertising partners
• Third parties who assist with our information technology and security programs
• Third parties who assist with fraud prevention, detection, and mitigation
• Our lawyers, auditors, and consultants
• Legal and regulatory bodies and other third parties as required by law

Written Signature – an individual’s written signature • You (directly from participant).
• Authorized/legal representatives, family members, and caregivers.
• Third parties who provide benefit verification, program enrollment, and product fulfillment services in connection with our products and services
• Provide our products and services to you
• Administer, manage, analyze, and improve our commercial, business and employment relationships, programs, products, and services
• Procure vendor/supplier products and services, including to manage and satisfy related vendor/supplier contractual obligations
• Engage in joint marketing initiatives
• Monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
• Comply with legal and regulatory obligations
• Third parties that provide business, finance, accounting, administrative and similar services required for the efficient operation of our business
• Third parties that manufacture or otherwise supply the products and services we market and sell to you
• Authorized/legal representatives
• Third parties with whom we have joint marketing and similar arrangements
• Third parties who provide benefit verification, program enrollment, and product fulfillment services in connection with our products and services
• Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention
• Other third parties as necessary to complete transactions and provide our products/services
• Our lawyers, auditors, and consultants
• Legal and regulatory bodies and other third parties as required by law

Inferences – drawn from any of the information listed above to create a profile about an individual reflecting the individual’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. (e.g., predictions about an individual’s preferences or tendencies) • We draw inferences from the information we collect from and about you, such as your preferences, characteristics, attributes, and abilities.
• Analyze and better understand your needs, preferences, and interests, as well as those of other consumers
• Advertising and product promotion, including to contact you regarding programs, products, services, and topics that may be of interest or useful
• Engage in joint marketing initiatives
• Administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and device
• Comply with legal and regulatory obligations.
• Third parties that provide business, finance, accounting, administrative and similar services required for the efficient operation of our business
• Third parties with whom we have joint marketing and similar arrangements
• Our lawyers, auditors, and consultants
• Legal and regulatory bodies and other third parties as required by law

[landing-5] Exercise Your Rights as a California Resident

The CCPA provides California resident consumers with specific rights (subject to certain exceptions):

• Right to Know: You have the right under the CCPA to request that we disclose what Personal Information we collect, use, disclose, and sell. The process for exercising this right is describe below under How to Submit a Data Privacy Request (California Residents).

• Right to Deletion: You have the right under the CCPA to request deletion of any Personal Information about you that we have collected from you. The process for exercising this right is describe below under How to Submit a Data Privacy Request (California Residents).

• Right to Opt-Out: You have the right under the CCPA to opt-out of the sale of your Personal Information. To exercise this right click the following link [hyperlink-4] Do Not Sell My Personal Information.

• Right to Non-Discrimination: You have the right under the CCPA not to be discriminated against for exercising your rights. Brennan will never discriminate against you for exercising your rights under the CCPA or other applicable laws.

How to Submit a Data Privacy Request (California Residents)

To exercise your Right to Know and/or Right to Deletion, simply notify Brennan with your request to exercise such right(s) using the contact information described below under Contact Us. To process your request for access or deletion, we must be able to verify your identity to a reasonable degree of certainty. When you contact us, we will require information to verify your identity and to locate your Personal Information (if any) held by Brennan.

To verify your identity, you must provide the required information requested by Brennan, which may include the last 4 digits of your social security number. We will ask you to provide your contact information and additional identifiers based on your relationship with us. Before we process your request, we will match these data points with data points we currently maintain to verify your identity, verify your relationship (if any) with us and locate your Personal Information (if any) held by Brennan.

You may designate an authorized agent to make a request to access, delete, or opt-out of the sale of your information on your behalf. When you use an authorized agent to submit a request for access or deletion, you must provide the authorized agent with written permission to do so, and, in certain circumstances, we may ask you to verify your own identity directly with us. We may deny a request from an authorized agent that does not submit satisfactory proof they have been authorized by you to act on your behalf.

Right to Know

Please note that we may not be required to provide you access to the specific pieces of Personal Information we have collected about you or delete information if we are unable to verify your identity.

Right to Delete

We may not be required to delete Personal Information under certain circumstances. Specifically, the CCPA includes exemptions that provide we do not have to delete data that, for example, is necessary to comply with legal obligations including those pertaining to employment relationships, legal compliance and certain other lawful purposes.

Sale or Disclosure of Personal Information

The CCPA defines “sale” broadly to include sharing, transferring, disclosing or otherwise communicating Personal Information with a third party for monetary or other valuable consideration. We share Personal Information with service providers who work on our behalf and agree not to use or sell your Personal Information for other purposes or if you have intentionally directed us to share information with a third party. In addition, with your approval, we share certain internet tracking data, including cookies and the IP address used to access our websites.
Notice of Financial Incentive

Brennan does not offer financial incentives in exchange for the collection or sale of Personal Information. However, we may provide discounts, rebates and similar financial incentives to individuals who use our products and services and enroll in incentive programs we offer from time to time. Enrolling in these programs requires you to provide certain of your Personal Information so that we may administer the programs and, in some cases, provide marketing and advertising to you. Under the CCPA, this could be considered an offer of a “financial incentive,” and so we provide this notice to you to describe our practice and to provide a good faith estimate of the value of your Personal Information that we may collect related to these programs. In the normal course of our business, we do not assign monetary or other value to Personal Information, but in accordance with CCPA, we make a good faith estimate that the value of the Personal Information collected and used is equivalent to the value of the discount, rebate or similar financial incentives we provide in these programs. To make this good faith estimate, we may consider among other factors, the (i) categories of Personal Information collected, (ii) the discount, rebate or incentive offered, (iii) the sales or use of our products and services by those who enroll versus those who do not, and (iv) the cost and expenses we incur in offering the programs.

The incentive programs require you to opt-in to participate as set forth in the enrollment materials. My completing the enrollment process (which may require you to provide Personal Information), you opt-in to the program and consent to our collection, storage, processing and use of the Personal Information provided in accordance with this Privacy Statement. You can opt-out either by contacting us at the information set forth below, or by following the terms and conditions provided when you are enrolling in the program. While we will not discriminate against you for exercising your rights under CCPA, if you request deletion of your Personal Information, we may not be able to delete such information if it is necessary to administer the incentive, rebate or discount you requested and still provide you such incentive, rebate or discount.

Personal Information Collected from Employees, Contractors and Job Applicants

• Employees – If you are a Brennan employee and would like more information about the categories of Personal Information we collect from you and the purposes for which the Personal Information will be used, please contact us at [email protected]

• Contractors – If you are a contractor performing services for Brennan and would like information about the categories of Personal Information we collect from you as a contractor and the purpose for which the Personal Information will be used, please contact us at [email protected]

• Job Applicants – If you are applying for a position with Brennan and would like information about the categories of Personal Information Brennan collects from you as a job applicant and the purposes for which the Personal Information, please visit our [hyperlink-3] Privacy Statement.

Contact Us

Persons who are unable to review or access this Privacy Statement due to a disability may contact us to request access this Privacy Statement in an alternative format. Please contact us:

By phone: (440) 248-1880

By email: [email protected]

By U.S. Mail or overnight courier: Brennan Industries, Inc.
Attn: Chief Privacy Officer
6701 Cochran Road
Solon, Ohio 44139

Please include your name, address, and email address if you want to receive a response by email. Otherwise, we will respond by postal mail within the time required by applicable law.

BRENNAN INDUSTRIES COOKIE NOTICE

Cookies Explained

When you visit any website, it may store or retrieve information on your browser, mostly in the form of cookies or other similar tracking technology (collectively, “Cookies”). This information might be about you, your preferences or your device, and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience. When you visit [hyperlink] www.brennaninc.com, our web server will query your browser to detect whether Cookies were set during a previous visit. Because we respect your right to privacy, you can choose not to allow some types of cookies. See “Manage Your Cookies” below to find out more and change our default Cookies settings. Please note that blocking some types of Cookies may impact your experience on our website and the services we are able to offer to you.

Cookies help to analyze web traffic and allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. Certain Cookies may contain personal data. Cookies may collect information, including a unique identifier, user preferences, profile information, membership information and general usage and volume statistical information. Cookies may also be used to collect individualized website use data, provide electronic personalization or conduct and measure the effectiveness of advertising.

Cookies may be set by the website owner (i.e., Brennan) or third parties (“Third-Party Cookies”). Third-Party Cookies enable third-party features or functionality to be provided on or through the website. The third parties that set Third-Party Cookies can recognize your computer when it visits the website in question and also when it visits certain other websites.

Your browser software can be set to reject all cookies, but if you reject our cookies, certain of the functions and conveniences of our website may not work properly. To learn more about cookies, please check your browser’s help or similar feature or visit [hyperlink] www.allaboutcookies.org.

How Brennan Uses Cookies

We use Cookies for several reasons. Some Cookies are required for technical reasons in order for our website to operate, and we refer to these as “essential” or “strictly necessary” Cookies. Other Cookies enable us to track and target the interests of our users to enhance the experience on our websites. Third parties set Cookies through our website for advertising, analytics and other purposes.

We may place Cookies or similar files on your device for security purposes, to tell us whether you have visited our website before, to remember your language preferences, to determine if you are new visitor or to otherwise facilitate site navigation, and to personalize your experience. Cookies allow us to collect technical and navigational information, such as browser type, time spent on our website and pages visited. Cookies also allow us to select which of our advertisements or offers are most likely to appeal to you and display them to you. Cookies may enhance your online experience by saving your preferences while you are visiting websites (including [hyperlink] www.brennaninc.com).

The specific types of first- and third-party Cookies utilized through our website and the purposes they perform are described below.

Cookies are not the only way to recognize or track visitors to a website. We may use other technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphic files that contain a unique identifier that enable us to recognize when someone has visited our websites or opened an email we have sent them. This allows us, for example, to monitor the traffic patterns of users from one page within our websites to another, to deliver or communicate with Cookies, to understand whether you have come to our website from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of email marketing campaigns. In many instances, these technologies are reliant on Cookies to function properly, and so declining Cookies will impair their function.

Manage Your Cookies

You can choose 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 would prefer not to accept Cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a Cookie, which lets you choose whether or not to accept it; (ii) to disable existing Cookies; or (iii) to set your browser to automatically reject any Cookies. However, please be aware that if you disable or reject Cookies, some features and services may not work properly.

REQUEST: DO NOT SELL MY PERSONAL INFORMATION

Rights under the California Consumer Privacy Act for California Residents

The California Consumer Privacy Act (CCPA) provides you with rights regarding how your Personal Information (as defined in our [hyperlink-3] Privacy Statement) is treated. Under the CCPA, California residents can choose to opt out of the “sale” of their Personal Information to third parties. Although Brennan will never sell your Personal Information for monetary consideration, the CCPA broadly defines “sale” to include data collection for the purpose of creating advertising and other communications. [hyperlink-13] Learn more about CCPA and your privacy rights.

How to Opt-Out

By clicking this [hyperlink-14] link, we will no longer collect or sell your Personal Information except as may be required or permitted by applicable law. This applies to both third-parties and the data we collect to help personalize your experience on our website or through other communications.

For more information, view our [hyperlink-3] Privacy Statement.

To be eligible to opt-out, you must be browsing from California.

[landing-13] https://oag.ca.gov/privacy/ccpa

[landing-14] [Internal Brennan opt-out notification]

[landing-12] BRENNAN INDUSTRIES TERMS OF USE

Terms of Use

These Terms of Use cover the use of websites, online services, applications, telephone support services, email, text and messaging, blogs, software and networks (including internet of things (IoT) devices, web and social media sites and pages, games and contests) (collectively, “Brennan Resources”) of Brennan Industries, Inc. and/or its subsidiaries and affiliates (collectively, “Brennan”). For information regarding how your Personal Information (as defined in our [hyperlink-3] Privacy Statement) may be collected, stored, processed and used with respect to Brennan Resources, please read our [hyperlink-3] Privacy Statement which is incorporated in its entirety in these Terms of Use.

By accessing Brennan Resources, you confirm you (a) have read these Terms of Use, our [hyperlink-3] Privacy Statement, and our [hyperlink-2] Cookie Notice, and (b) consent to their respective terms, conditions, restrictions and limitations. Brennan may at any time, in its sole discretion, (a) revoke the access of any person to Brennan Resources; and (b) modify, change, withdraw, delete, or disable any Brennan Resources in whole or in part.

Contact Us

If you have questions or require additional information regarding these Terms of Use, please see the contact information provided in our [hyperlink-3] Privacy Statement.

Updates and Revisions

These Terms of Use may change from time to time. Updates to these Terms of Use will be published via the landing page at [hyperlink] www.brennaninc.com.

Your IP Address

An Internet Protocol (IP) address is a number automatically assigned to your computer or other device by your Internet Service Provider (ISP). Brennan Resources may automatically collect and use your IP address (which, if required by applicable law, may be shortened to ensure the numbers do not identify you). Your IP address is used for identification purposes to ensure data requested by you can be sent to your computer or other device in a manner tailored to your location when accessing Brennan Resources.

Unless required by applicable law, Brennan does not treat IP addresses, server log files or associated data as Personal Information because it does not reveal your specific identity. Brennan uses IP addresses for, among other things, administering our websites and systems, calculating website usage levels, and diagnosing issues adversely impacting Brennan Resources. We also use IP addresses in conjunction with cookies to “remember” your computer or other device, to save you from resetting your localized preferences each time the same computer or other device accesses Brennan Resources. For more information, see our [hyperlink-2] Cookie Notice.

Registered (or Recognized) User

Brennan Resources may permit you to become a registered (or recognized) user. When you become such a user, we may ask for your name, email address, job title, telephone number, employer company, mailing address, your country and other identifying information. We may use cookies to remember your details and content preferences. For more information, see our [hyperlink-2] Cookie Notice. You may be asked whether you would like to receive email messages regarding our products, services or other topics which may be of interest to you. The Brennan organizations will not send you such messages without your consent. You may contact us via our website at [hyperlink] www.brennaninc.com to update your information or preferences, or unsubscribe from any marketing lists.

Live Chat Messaging

Brennan Resources may offer “Live Chat” messaging, which allows direct, real-time messaging between you and Brennan representatives. If you use “Live Chat,” we may ask for your name, email address, job title, telephone number, employer company, mailing address, your country and other identifying information. “Live Chat” is operated through third party vendor and your Personal Information collected through “Live Chat” may be stored or otherwise processed outside your own country (including outside the European Economic Area). Transcripts of “Live Chat” sessions may be retained to answer additional questions you may have about Brennan products and services or for Brennan to improve its products and services. Please do not use “Live Chat” unless you consent to your Personal Information being transferred to a third party vendor and/or outside your own country (including outside the European Economic Area).

Warning: As with all free text fields and online chat applications, “Live Chat” via Brennan Resources enables you to manage the content of the communications you send. Brennan Resources, and particularly “Live Chat”, are only intended for business use. Brennan does not wish to collect Personal Information through any Brennan Resources other than you business contact details, and only as strictly necessary to effectively process queries about the products, services and business of Brennan. You should take care when using Brennan Resources, and particularly any “Live Chat” facility, not to provide Personal Information that relates to you in your personal or private capacity; or any Sensitive Personal Information (as defined in our [hyperlink-3] Privacy Statement).

Your Consent to Targeted Marketing

When you access Brennan Resources you may be asked whether you would like to receive email messages regarding Brennan products and services or other topics which may be of interest to you. One or more cookies may be used to record your preferences, tailor your experience or better target marketing information to your particular needs or preferences. For more information, see our [hyperlink-2] Cookie Notice. You may contact us via our website at [hyperlink] www.brennaninc.com to update your information or preferences, or unsubscribe from any targeted marketing email lists.

Brennan intends to send targeting marketing emails to your business email address only. We do not wish to send marketing emails to your personal email address. Please do not provide us your personal email address.

Under applicable law, you may have rights to object to use of your email address for marketing purposes at any time and free of charge, and you may be entitled to “opt-out” via any communication type or media (e.g., not solely by means of an “unsubscribe” request sent to us by email). Your objection (or “opt-out” request) must be received by us in order to be effective. If you wish to subject such an objection or request to us, please see the contact information provided in our [hyperlink-3] Privacy Statement.

Persons Under 18 Years of Age

Use of Brennan Resources is restricted to persons 18 years of age or older. If you are under 18 years of age, you must not access any Brennan Resources,

Software

Any software, application, program, or files (collectively “Software”) that may be made available for download, access, or other use from any Brennan Resources may be the copyrighted work of Brennan and/or its suppliers. Use of the Software is governed by the terms of this notice and the applicable end user license agreement (“EULA”). The Software is made available for use solely in accordance with the EULA. Any reproduction or redistribution of the Software not in accordance with the EULA is expressly prohibited by law. WITHOUT LIMITING THE FOREGOING, COPYING OR REPRODUCING ANY PORTION OF THE SOFTWARE, INCLUDING TO ANY OTHER SERVER OR LOCATION OR MEDIA FOR FURTHER REPRODUCTION OR REDISTRIBUTION, IS EXPRESSLY PROHIBITED. THE SOFTWARE IS WARRANTED, IF AT ALL, ONLY ACCORDING TO THE TERMS OF THE EULA. EXCEPT AS OTHERWISE LIMITED BY APPLICABLE LAW, PARKER HEREBY DISCLAIMS ALL WARRANTIES AND CONDITIONS WITH REGARD TO THE SOFTWARE, INCLUDING ALL IMPLIED WARRANTIES AND CONDITIONS OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE AND NONINFRINGEMENT.

Content and Social Media

The Brennan Resources may include bulletin boards, chat rooms, newsgroups, messaging, games, contests, and other media (collectively, “Social Media”) which allow feedback and/or real-time interaction between users. Except for items posted with Brennan’s prior authorization, Brennan does not monitor, control or regulate any messages, images, information or files made available via Social Media. It is a condition of your use of Brennan Resources (including Social Media) that you do not:

• Restrict or impede any other user from using Brennan Resources (including Social Media).

• Post or transmit any unlawful, anti-competitive, threatening, abusive, libelous, defamatory, inflammatory, offensive, obscene, vulgar, pornographic, profane or indecent information.

• Post or transmit any information, software or other material that violates or infringes upon the rights of others.

• Post or transmit any information, software or other material that contains a virus, malicious code or other harmful component.

• Post, transmit or in any way exploit any information, software or other material for commercial purposes, or which contains advertising, other than for the business purposes of Brennan.

Brennan reserves the right, in its sole and absolute discretion, to delete any content that violates these Terms of Use, and to pursue legal action against any person who violates these Terms of Use

By posting messages or images, uploading files, data or other information, or by engaging in or providing feedback, suggestions, requests, corrections, comments, or any other form of communication through or concerning any Brennan Resources (including Social Media), you grant Brennan an irrevocable, perpetual, royalty-free, non-exclusive, unrestricted, worldwide right and license to:

• Use, copy, sublicense, adapt, transmit, retransmit, distribute and/or publicly perform or display any such message, image, file, data or other information, or other communication.

• Sublicense to third parties the unrestricted right to exercise any of the foregoing rights granted with respect to any such message, image, file, data or other information, or other communication. The foregoing grants shall include the right to exploit any intellectual property or proprietary rights in such message, image, file, data or other information, or other communication, including but not limited to rights under copyright, trademark, patent, publicity, or privacy laws in any relevant jurisdiction, and Brennan accepts no obligation for maintaining the confidentiality of any such file, message, image, file, data or other information, or other communication.

Use Restrictions

By accessing Brennan Resources, except to the extent permitted by applicable law, you acknowledge and agree you will not:

• Make any Brennan Resources or Software available to, or use any Brennan Resources or Software for the benefit of, anyone other than you or Brennan.

• Sell, resell, license, sublicense, distribute, rent or lease any Brennan Resources or Software.

• Use any Brennan Resources or Software to store or transmit infringing, libelous, or otherwise unlawful or tortious material, or to store or transmit material in violation of any person’s privacy or other rights.

• Use any Brennan Resources or Software to store or transmit malicious code, or to interfere with or disrupt the integrity or performance of any Brennan Resources or data contained therein.

• Attempt to gain unauthorized access to any Brennan Resources or Software.

• Permit direct or indirect access to or use of any Brennan Resources or Software in a way that violates these Terms of Use or EULA.

• Copy any Brennan Resources or Software, or any part, feature, function or user interface thereof.

• Frame or mirror any part of any Brennan Resources or Software.

• Reverse engineer any Brennan Resources.

File Transfer Protocol (FTP) Sites

Although Brennan will endeavor to use reasonable efforts to ensure files uploaded to a FTP or other file sharing server associated with any Brennan Resources will be accessible only to the individual(s) for whom the file is intended, Brennan is not responsible for any unauthorized access to any uploaded file, and accepts no obligation for maintaining the confidentiality of any such file. Brennan reserves the right to review, remove and/or delete any uploaded file, for any reason, and in its sole discretion. Uploading the copyrighted or confidential material of a third party is strictly prohibited. Brennan makes no representation with respect to the integrity or functionality of any file uploaded or downloaded in connection with the use of Brennan Resources, including, but not limited to, any representation that the file is virus-free or contains no defects. By uploading or downloading any file associated with any Brennan Resources, you expressly agree to these Terms of Use.

User Data

As used herein, “User Data” means data, information or other content submitted by or for you, or collected or processed by or for you, with respect to your access or use of any Brennan Resources. You warrant that you have the right to license use of the User Data to Brennan, and you grant to Brennan and its distributors, agents and business partners, each acting in its capacity as such, an irrevocable, perpetual, non-exclusive license to copy, backup, store, transfer, maintain, modify and otherwise use the User Data.

Copyright Matters

Brennan respects the rights of all copyright holders and has adopted and implemented a policy that provides for the removal from its web site of materials that infringe the rights of copyright holders. If you believe your copyright work has been copied in a way that constitutes copyright infringement, please provide to Brennan the following information pursuant to the Online Copyright Infringement Liability Limitation Act, Title II of the Digital Millennium Copyright Act, 17 U.S.C. §§ 512 et seq.:

• Physical or electronic signature of person authorized to act on behalf of owner of exclusive right allegedly infringed.

• Identification of copyright work claimed to have been infringed, or, if multiple copyright works are covered by a single notification, a representative list of such works.

• Identification of material claimed to be infringing or to be the subject of infringing activity that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit us to locate such material.

• Information reasonably sufficient to permit us to contact the complaining party.

• Statement that the complaining party has a good-faith belief use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law.

• Statement that the information in the notification is accurate, and under penalty of perjury, that the complaining party is authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.

Brennan’s Copyright Agent for notice of claims of copyright infringement on or regarding Brennan Resources can be contacted at: Copyright Agent, Attn: Legal Department, Brennan Industries, Inc., 6701 Cochran Road, Solon, Ohio 44139 or via email at [email protected]

LIMITATION OF WARRANTY

DATA AND INFORMATION CONTAINED IN BRENNAN RESOURCES ARE BELIEVED TO BE ACCURATE, BUT ARE PROVIDED “AS IS” WITHOUT WARRANTY OR CONDITION OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO THE IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE. IN NO EVENT SHALL BRENNAN BE LIABLE FOR ANY DAMAGES OF ANY KIND WHATSOEVER, INCLUDING ANY SPECIAL, INDIRECT, OR CONSEQUENTIAL DAMAGES, RELATING TO THE USE OF BRENNAN RESOURCES EXCEPT AS OTHERWISE LIMITED BY APPLICABLE LAW.

BRENNAN DOES NOT WARRANT (A) ANY BRENNAN RESOURCES WILL BE UNINTERRUPTED OR ERROR-FREE, (B) DEFECTS WILL BE CORRECTED, OR (C) ANY BRENNAN RESOURCES, OR THE DEVICES THAT MAKES IT AVAILABLE, ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS. THIS DISCLAIMER OF LIABILITY APPLIES TO ANY DAMAGES OR INJURY CAUSED BY ANY FAILURE OF PERFORMANCE, ERROR, OMISSION, INTERRUPTION, DELETION, DEFECT, DELAY IN OPERATION OR TRANSMISSION, COMPUTER VIRUS, COMMUNICATION LINE FAILURE, THEFT OR DESTRUCTION OR UNAUTHORIZED ACCESS TO, ALTERATION OF, OR USE OF RECORD, WHETHER FOR BREACH OF CONTRACT, TORTIOUS BEHAVIOR, NEGLIGENCE, OR UNDER ANY OTHER CAUSE OF ACTION. YOU ACKNOWLEDGE AND AGREE BRENNAN IS NOT LIABLE FOR THE DEFAMATORY, OFFENSIVE OR ILLEGAL CONDUCT OF UNRELATED USERS OR THIRD PARTIES, AND THE RISK OF INJURY FROM THE FOREGOING RESTS ENTIRELY WITH YOU. EXCEPT AS OTHERWISE LIMITED BY APPLICABLE LAW, IN NO EVENT WILL BRENNAN, OR ANY PERSON OR ENTITY INVOLVED IN CREATING, PRODUCING OR DISTRIBUTING ANY BRENNAN RESOURCES, BE LIABLE FOR ANY DAMAGES, INCLUDING, WITHOUT LIMITATION, DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR PUNITIVE DAMAGES ARISING OUT OF THE USE OF OR INABILITY TO USE ANY BRENNAN RESOURCES.

LIMITATION OF LIABILITY

UNDER NO CIRCUMSTANCES SHALL BRENNAN BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL OR CONSEQUENTIAL DAMAGES RESULTING FROM OR OTHERWISE ATTRIBUTABLE TO THE USE OF, OR THE INABILITY TO USE, ANY BRENNAN RESOURCES. BY ACCESSING ANY BRENNAN RESOURCES, YOU ACKNOWLEDGE AND AGREE THAT BRENNAN IS NOT LIABLE FOR ANY DEFAMATORY, ANTI-COMPETITIVE, OFFENSIVE, OR ILLEGAL CONDUCT OF ANY USER. IF YOU ARE DISSATISFIED WITH ANY BRENNAN RESOURCES, OR WITH ANY OF THESE TERMS OF USE, YOUR SOLE AND EXCLUSIVE REMEDY IS TO DISCONTINUE USING THE APPLICABLE BRENNAN RESOURCES.

INDEMNIFICATION

YOU ARE SOLELY RESPONSIBLE FOR, AND AGREE TO DEFEND, INDEMNIFY AND HOLD HARMLESS BRENNAN AND ITS OWNERS, DIRECTORS, OFFICERS, EMPLOYEES AND REPRESENATIVES FROM AND AGAINST, ALL LIABILITIES, CLAIMS, DAMAGES, AND EXPENSES, INCLUDING ATTORNEYS’ FEES, ARISING OUT OF YOUR USE OR MISUSE OF BRENNAN RESOIRCES, OR FROM OR RELATED TO ILLEGAL, INFRINGING, OBSCENE, DEFAMATORY OR OTHERWISE UNLAWFUL USER DATA, OR YOUR VIOLATION OR ALLEGED VIOLATION OF THESE TERMS OF USE.

Governing Law and Precedence

These Terms of Use are governed by, and are to be construed in accordance with, the laws of the State of Ohio, USA, without giving effect to any principles of conflicts of law. If any provision of these Terms of Use shall be unlawful, void or unenforceable, then such provision (a) shall be deemed modified as necessary to be lawful, in effect and enforceable to the fullest extent permitted by applicable law, or (b) if such modification is not permitted under applicable law, then such provision shall be deemed severable from the Terms of Use and shall not affect the validity and enforceability of any remaining provisions.

NOTWITHSTANDING ANY CONTRACT BETWEEN YOU AND BRENNAN, OR ANY OTHER TERMS AND CONDITIONS THAT MAY GOVERN ANY OTHER ASPECT OF YOUR RELATIONSHIP WITH BRENNAN, BY ACCESSING ANY BRENNAN RESOURCES YOU UNDERSTAND AND AGREE THESE TERMS OF USE ARE THE ONLY TERMS AND CONDITIONS APPLICABLE YOUR ACCESS AND USE OF BRENNAN RESOURCES, AND SUPERSEDE ANY CONTRACT OR OTHER TERMS AND CONDITIONS IN EFFECT BETWEEN YOU AND BRENNAN REGARDING ANY OTHER MATTERS. ANY STATEMENT TO THE CONTRARY IS VOID AB INITIO AND OF NO FORCE OR EFFECT.

Copyright

Copyright © Brennan Industries, Inc. Year of copyright is the current year. All rights reserved. The content of Brennan Resources may not be copied, reproduced, replaced, distributed, published, displayed, modified, or transferred in any form or by any means except with the prior permission of Brennan Industries, Inc. Copyright infringement is a violation of federal law subject to criminal and civil penalties.

Last updated: December 2022