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DATA PRIVACY POLICY
Kesseltronics Systems, a Division of Dover Canada Operations ULC (“Kesseltronics”) is committed to
protecting the information that our customers, business partners, and others have entrusted to us.
Kesseltronics must collect and use personal data in order to perform our business functions, produce
best-in-class products, and be a market leader. Consistent with our Kesseltronics Values, we treat any
personal data that we obtain with respect and in accordance with the various, applicable data privacy
laws around the globe.
This Data Privacy Policy (“Policy”) sets forth the principles that govern our treatment of personal data.
Any changes we make to our Policy in the future will be posted on this page, and where appropriate,
notified to the concerned persons.
By using a Kesseltronics application we associate with this Policy, or by choosing to submit personal
information to Kesseltronics, you signify your consent to all of the terms of this Policy. If you do not
agree with any terms of this Privacy Policy, please do not use our applications or submit any personal
information to Kesseltronics.
Index and Summary
This privacy policy contains the following sections:
1. INTRODUCTION
1.1 What is data privacy?
1.2 What is personal data?
1.3 What types of personal data does Kesseltronics collect or use and for what purpose?
2. OUR GUIDING PRIVACY PRINCIPLES
2.1 Data Minimization and Limited Use
2.2 Data Security
2.3 Transparency
2.4 Data Quality, Integrity, and how to Access and Correct your Personal Data
2.5 Data Retention and Disposal
3. COMPLIANCE WITH APPLICABLE LAWS, RULES, AND REGULATIONS
3.1 Disclosure to Third Parties
3.2 We Transfer Personal Information Internationally
3.3 Data Breach Notification
4. QUESTIONS
INTRODUCTION
1.1 What is data privacy?
Data privacy is the practice of only using as much personal data as is necessary to complete a business
objective, limiting access to that data to only those who need it to complete the objective, and protecting
that data from unauthorized use.
1.2 What is personal data?
Personal data is any information that, standing alone or in connection with other data, could be used to
identify the individual to whom the information relates. Personal data includes your name, contact
information and payment information Even data that uses a unique identifier instead of a name (for
example, an IP address or email address) is personal data if that unique identifier can be tied to an
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individual. In this policy, the terms “personal data” and “personal information” are used
interchangeably.
1.3 What types of personal data does Kesseltronics collect or use and for what purpose?
Kesseltronics receives and uses a wide range of personal data in order to conduct our day-to-day business
activities and to fulfill our obligations as required by law. Some examples include:
a) Contact details for key personnel at customers and potential customers for the purpose of
administering sales, service, and marketing; including online data collected through
Kesseltronics’ websites and social media sites;
b) When you use our CarWash application, we may collect your first and last name, postal
code, email address, and information regarding your use of the application, such as your
redemption of car washes and the number you have remaining, to allow you to create and
assess your account, and to provide the CarWash application in accordance with its terms
of use.
c) If you use the CarWash application to make a purchase, your payment information is
processed by the Stripe payment processing platform to pay for your purchase.
d) Contact details for personnel of vendors and suppliers for the management of the
relationship.
We do not knowingly collect or allow the collection of Personal Information from persons under the age
of 18. If you are the parent or legal guardian of a minor who has provided us with Personal Information,
you may contact us using the contact information provided below for the purpose of requesting this
information be deleted.
2. OUR GUIDING PRIVACY PRINCIPLES
2.1 Data Minimization and Limited Use
Kesseltronics limits the data that it collects and uses. Kesseltronics collects, uses, and stores personal
data in accordance with its legal obligations. This means that we aim to only collect or use personal data
that is relevant to a specific and identified purpose to which you have consented or when permitted or
required by applicable law (collectively referred to in this Privacy Policy as a “legitimate business
purpose”). In other words, Kesseltronics does not wish to collect, use, or store personal data in excess
of what is minimally required by law or for the legitimate business purpose for which that information
is being obtained or used.
Those granted access to personal information by Kesseltronics may not use that information for their
own interest.
Example: Kesseltronics’ CarWash application requires users to login with an email address that
is authorized by Google’s Firebase platform, and only the email address used for the login will
be stored on the server.
2.2 Data Security
The Principle: Kesseltronics protects personal data through physical and technical security measures
tailored to the sensitivity of personal data we hold.
Kesseltronics aims to secure the personal data we hold. We employ IT security tools, restrictions on
access to the data, and physical and organizational security measures to help prevent unauthorized or
unlawful access to personal data and accidental loss, destruction, or damage to personal data. Personal
data may be accessed by persons within our organization, or our third party service providers, who
require such access to carry out the purposes described in this Policy, or such other purposes as may be
permitted or required by the applicable law. Personal Information we collect is primarily maintained on
servers located in Ashburn, Chantilly, Manassas or Sterling, Virginia.
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Kesseltronics regularly evaluates the protections that we have in place for such data in order to ensure
that our security measures are tailored to the appropriate sensitivity level. However, no security
measures can provide absolute protection. We cannot ensure or warrant the security of any information
you provide to us.
2.3 Transparency
The Principle: Kesseltronics communicates with our employees, customers, suppliers, business
partners, and others about how we intend to use personal data in our day-to-day operations.
Kesseltronics provides notice in accordance with local law. Our objective is to provide information to
our customers and other key constituencies about how we intend to use personal data to conduct our
business. Notice may be provided before or at the time of collecting personal data, or as permitted by
applicable law, as soon thereafter as possible.
Consent of the data subject may be required before processing personal data. Employees handling
sensitive personal data may not do so unless the proper protections are in place. Where consent is
required, we will not process your personal data unless your consent is given.
Example: This Privacy Policy informs you of how we collect, process and use your personal data.
2.4 Data Quality, Integrity, and how to Access and Correct your Personal Data
The Principle: Kesseltronics takes reasonable steps to ensure our personal data is accurate and up-to-
date, and we also provide data subjects with the right to access and correct their personal data.
Like the individuals who share their personal data with us, Kesseltronics has an interest in ensuring that
the data we maintain is correct.
Customers, suppliers, business partners, and others are encouraged to notify Kesseltronics of changes
in their personal information so that our records remain accurate. Customers are responsible for updating
or correcting their own personal data.
Kesseltronics provides you with the ability to access and request correction of your own personal data.
Customers, suppliers, business partners, and others should submit an access or rectification request in
writing, providing proof of their identity to privacyinfo@kesseltronics.com.
Example: Customers, suppliers, business partners and others can submit requests to have their personal
data corrected or updated to privacyinfo@kesseltronics.com.
2.5 Data Retention and Disposal
The Principle: Kesseltronics will only keep personal data as long as required by the Kesseltronics
Records Management Policy, and according to the applicable laws and dispose of it securely.
Kesseltronics adheres to its Records Management Policy to determine how long we retain data,
including personal data. The retention periods are established considering Kesseltronics’ legitimate
business purposes, and according to the local regulations.
3. COMPLIANCE WITH APPLICABLE LAWS, RULES, AND REGULATIONS
3.1 Disclosure to Third Parties
At times, Kesseltronics engages third party contractors, subcontractors, service providers, and other
vendors to help us accomplish our business objectives, and to carry out the legitimate business purposes
described in this Policy. If the engagement involves the transmission of personal data, Kesseltronics
requires the service provider to treat that data consistent with this Policy.
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If you use Kesseltronics’ CarWash application, we disclose information to the car wash operator
regarding your use of the application, such as your redemption of car washes and the number you have
remaining, location of use and email address to permit the application to function in accordance with its
terms of use.
In certain circumstances, Kesseltronics may disclose personal information when required by law, when
required to protect Kesseltronics’s legal rights, or in an emergency situation where the health or security
of an individual is endangered. Kesseltronics may also disclose personal data in the context of any sale
or transaction involving all or a portion of the business.
3.2 We Transfer Personal Information Internationally
Many countries have laws and regulations restricting the international transfer of personal information
even if those transfers are between two companies of the same corporate group. Where restrictions
exist, Kesseltronics may transfer personal information outside the country where the information is
collected only if the destination country has data protection laws that provide an adequate level of
protection or a legal mechanism is used (e.g., EU standard contract clauses are in place between the two
entities or the transfer is otherwise allowed by statute).
Kesseltronics transfers personal information across borders in accordance with applicable laws. This
includes situations where Kesseltronics is dealing with service providers or third parties based in another
country and transferring personal information to them or allowing them to remotely access
Kesseltronics’s systems/data.
For residents of Canada, you expressly agree that we may transfer personal data outside of Canada. For
example, some or all of the Personal Information we collect may be stored or processed on servers
located outside of Canada, including in the United States, whose data protection laws may differ from
those of Canada. As a result, this information may be subject to access requests from governments,
courts, or law enforcement in those jurisdictions according to laws in those jurisdictions.
3.3 Data Breach Notification
Kesseltronics makes reasonable efforts to notify individuals and regulatory authorities, as required by
law, if we reasonably believe that personal information has been stolen, disclosed, altered, or infringed
by an unauthorized person.
If you become aware of or suspect a breach or an attempted breach, contact Kesseltronics immediately
at privacyinfo@kesseltronics.com
and provide the team with the information they will require to
properly investigate and respond.
4. QUESTIONS
Customers, suppliers, business partners, and others should direct their questions regarding this Policy
to:
Kesseltronics Systems
privacyinfo@kesseltonics.com, or
Assistant General Manager; 5212 Harwood Blvd., Vaudreuil-Dorion, Quebec J7V 0K2,
Canada
Dover Corporation
Legal Services Manager; 3005 Highland Parkway, Downers Grover, IL 60515, U.S.A.